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.