Credico (USA) LLC Privacy Notice

 

Last Modified: December 17, 2019

 

Credico (USA) LLC (“we” or “Credico”) is committed to protecting the privacy rights of Consumers. For purposes of this policy, “you” or “your” means any visitor to our website or any Consumer or household whose Personal Information [1] is received by Credico in any way. Protecting your privacy is fundamental to the way Credico (USA) LLC conducts business. This Privacy Notice explains what Personal Information is, how we receive and may use Personal Information, and, most importantly, Credico’s commitment to honor your rights under certain privacy laws. By using the Credico Website or Services, you consent to the privacy practices described in this Policy.

 

Personal Information

In the course of providing services to our business partners, we may receive sensitive information about their clients (“you” or “Consumer ”) that potentially identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household (”Personal Information”). Personal Information does not include publicly available information, deidentified information, or aggregated Consumer information.

 

Collection of Personal Information

We may receive Personal Information for the purpose of performing services on behalf of our business partners:

We may also receive Personal Information:

We will not retain or use any Personal Information for any purpose other than: (i) providing services to our business partners; and (ii) using the Personal Information internally to verify sales completed by our subcontractors, maintain the quality of our services, comply with legal requirements, and improve the services for our business partners.

We may disclose Personal Information we receive: (i) to our subsidiaries, affiliates, contractors, service providers, and other third parties we use to support our business; (ii) to fulfill the purpose for which you provide it; (iii) to comply with any court order, law, regulation, or legal process, including responding to any government or regulatory request; (iv) to carry out our obligations and enforce our rights arising from any contracts entered into between you and our business partners; (v) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our business partners or others; or (vi) with your consent.

We do not engage in any of the following: (i) selling Personal Information; (ii) retaining, using, or disclosing Personal Information for any purpose other than providing services to our business partners; or (iii) retaining, using, or disclosing Personal Information outside of the direct business relationship with our business partners.

 

Data Security

Credico has implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access and disclosure. The use of, and access to, your Personal Information by us is restricted to employees and subcontractors who need to know that information to provide services to our business partners. We maintain physical, electronic and procedural safeguards to limit access to your Personal Information.

 

Consumer Requests

Data Privacy laws, such as the California Consumer Privacy Act (“CCPA”), provide certain Consumers with specific rights regarding their Personal Information. When a verified request is submitted through our designated Request Form, Consumers have the right to know the categories and specific pieces of Personal Information that we receive pertaining to the requesting Consumer. We will honor the legal rights provided in applicable Data Privacy laws to all verified Consumer requests. This section describes how to exercise your right to: (i) know what Personal Information Credico has collected about you; and (ii) request that your Personal Information is deleted, provided that no exception exists.

 

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the 12 months preceding the date of your verified request. We will make all reasonable efforts to retain Personal Information no longer than necessary, which typically will be less than 12 months.

Once we receive your request and confirm you’re a verifiable Consumer, our Data Manager, within the timelines required under the Data Privacy laws, will disclose to you:

 

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.

An exception would apply if any of the following occur: (i) the request would violate evidentiary privilege; (ii) your information is necessary to comply with any court order, law, or legal process, including responding to any government or regulatory request; (iii) your information is necessary to complete the transaction for which the Personal Information was collected; (iv) you previously made two (2) requests within a twelve (12) month window.

Once we receive and confirm your verifiable Consumer request and an exception does not apply, we will delete (and direct our service providers to delete) your Personal Information from our records.

 

Exercising Access, Data Portability, and Deletion Rights

To exercise the rights described above, please submit a verifiable Consumer request to Credico’s Data Manager, through any of the following methods:

Only you, or a person that you authorize to act on your behalf, may make a verifiable Consumer request related to your Personal Information. If an agent submits a request on your behalf, Credico will require that you: (1) provide the authorized agent written permission to do so; and (2) verify your own identity directly with Credico. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf. If the agent demonstrates authorization through power of attorney, Credico will not require written permission to make a request on your behalf.

A verifiable Consumer request for access, data portability, or deletion, may only be made twice within a 12-month period. The verifiable Consumer request must:

Credico cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

You are not required to create an account with Credico to make a verifiable Consumer request. Credico will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

Credico will acknowledge receipt of your request within ten (10) days of its receipt. Credico endeavors to respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Sharing Personal Information

Credico may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

 

Non-Discrimination

We will not discriminate against you for exercising any of your data privacy rights and we will not cause our business partners or subcontractors to:

 

Changes to Our Privacy Notice

Credico reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your use of our Website following the posting of changes constitutes your acceptance of such changes.

 

Contact Information

If you have any questions or comments about this notice, the ways in which Credico collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights please do not hesitate to contact us at:

Phone: 1-888-457-0688

Email: privacy@credicousa.com

Request Form

 

[1] “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, or that is otherwise deemed personal information under Applicable Privacy Laws.

[2] “Consumer” means an individual or household about whom we have received personal information.

 


 

Credico Marketing Limited (Credico UK) Privacy Notice

 

Last Modified: July 2, 2020

 

Credico Holdings Ltd. and our subsidiaries and affiliates (”COMPANY” or “We”) respect your privacy and commit to protecting it through our compliance with the practices described in this notice.

This notice describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our website or other digital properties, communications, or forms that link or refer to this notice (our “Website”). This notice applies to the personal data collected through our Website, regardless of the country where you are located.

Please read this notice carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website, you accept and consent to the practices described in this notice. This notice may change from time to time (see Changes to Our Privacy Notice). Your continued engagement with our Website after any such revisions indicates that you accept and consent to them, so please check the notice periodically for updates.

 

Data We May Collect About You 

We collect and use different types of data from and about you including:

If we combine or connect non-personal, technical, or demographic data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

 

How We Collect Data About You   

We use different methods to collect data from and about you including through:

 

Cookies and Automatic Data Collection Technologies  

Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Website. It also allows us to improve our Website by enabling us to:

 

How We Use Your Personal Data 

We use your personal data to provide you with services, communicate with you, or to conduct other business operations. Examples of how we may use the personal data we collect include to:

 

Disclosure of Your Personal Data  

We may share your personal data with:

We may also disclose your personal data to third parties:

We may share non-personal data without restriction.

 

Consent to Personal Data Transfer   

We are based in the United Kingdom and may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own.

By submitting your personal data or engaging with the Website, you consent to this transfer, storing, or processing.

 

Your Personal Data Use Choices 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  If you do not want us to use your contact information to promote our services or third parties’ products or services, you can opt-out by emailing enquiries@credico.uk.com or mailing a written request to the following address:

Credico UK
Suite D2, First Floor,
The Quadrant, Mercury Court,
Chester, CH1 4QR

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.

 

Accessing and Correcting Your Personal Data

You can access, review, and change your personal data by sending us an email at enquiries@credico.uk.com to request access to, correct, or delete personal data that you have provided to us. We may not be able to accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively affect the information’s accuracy.

 

Data Security  

The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

 

Children’s Online Privacy  

We do not direct our Website to minors and we do not knowingly collect personal data from children under 18 years of age or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at enquiries@credico.uk.com.

 

Changes to Our Privacy Notice

We will post any changes we may make to our privacy notice on this page. If the changes materially alter how we use or treat your personal data we will notify you through a notice on the Website home page. Please check back frequently to see any updates or changes to our privacy notice.

 

Contact Information  

Please address questions, comments, and requests regarding this privacy notice and our privacy practices to  enquiries@credico.uk.com or alternatively:

Credico UK
Suite D2, First Floor,
The Quadrant, Mercury Court,
Chester, CH1 4QR