NCI E-mail Usage and Consent Policy

NCI recognize the importance of maintaining the privacy and accuracy of our customer's information. Below is the NCI E-mail Usage and Consent Policy, which we have also made available in PDF format by clicking here

This Policy explains the guidelines for any and all e-mail communications between you and NCI and confirms your consent to the use by NCI of e-mail to communicate with you:

1. Scope: This Policy covers the use of e-mail by NCI to communicate with our customers or third parties. If your matter is urgent or requires immediate attention, please contact us via telephone.
2. Consent to Use of E-mail: You may indicate your consent e-mail communications in any of the following ways, including but not exclusive to:
   1. Previous Communication: If you have received a communication from NCI regarding previous consent provided by you to your creditor for communication via the e-mail address you provided to your creditor, due to that prior consent to your creditor, NCI shall consider that you have also consented to communication by NCI via the same e-mail address, unless NCI receives notice from you, as outlined herein, that you do not wish to communicate via e-mail ("Opt Out Notice") or that you wish for NCI to use an alternate e-mail address.
   2. Incoming E-Mail or E-mail Request Form: If you have communicated to us by e-mail or filled out the e-mail request form on the NCI website, you consent to NCI's use of the e-mail address used or provided by you to communicate with you. This shall not include e-mail communications to us with a request to opt-out (in paragraph 6 below), change your e-mail address (in paragraph 7 below) or end the e-mail relationship (in paragraph 8 below).
   3. Verbal Request: If you have communicated verbally, for example by telephone, to NCI that you wish to communicate by e-mail, you consent to NCI's use of the e-mail address provided by you to communicate with you.
3. Your E-Mail Address: You confirm that the e-mail address you provided to your creditor or to NCI is a personal and private e-mail address. If you have provided an e-mail address that may be monitored or viewed by a third party, such as a work e-mail address or a shared e-mail address, you should be aware that such e-mail can be viewed by unintended persons. We recommend that you provide us with an e-mail address that is for your personal and private use, and that cannot be viewed, used or accessed by anyone other than you, for us to communicate with you. If this is a concern or if you would like us to use another e-mail address than the one you provided, please contact us to provide an updated e-mail address
4. Content of E-Mails:
   1. Creating the E-Mail: When communicating with NCI via e-mail, you should include the following information:
   2. Subject Line: Your NCI ID number, which can be found on the upper right hand corner of any letter correspondence received from NCI. You do not need to include any other information in the Subject Line.
   3. Body of the E-Mail: In order for Altisource or NCI to respond to you in a timely manner, please include the following:
      1. Name: Your full name
      2. Account ID Number: NCI ID Number which can be found on the upper right hand corner of any letter correspondence from NCI. This is not the account number assigned to you by your creditor.
      3. Purpose: The reason and substance your communication (for example, if you are responding to us, if you are making a request, if you are proposing a payment plan, etc.); and
      4. Response Time: Let us know the expected time in which you would like a response. For general matters, we try to respond within 3 business days from the date of your e-mail. If the expected time is exceeded, please contact us by telephone. If the matter is urgent or you require a response immediately, please contact us by telephone.
5. Unsubscribe: In compliance with the Can-Spam Act of 2003, on any e-mail from Altisource or NCI, there will be instructions for opting out of receiving future e-mails. Such instructions may include, without limitation: (a) clicking a link on the e-mail to unsubscribe, (b) an e-mail address where you can send a request to unsubscribe or c) instructions for mailing a written request to unsubscribe from future e-mails.
6. Opt Out: If you have received a communication from Altisource or NCI regarding your prior consent to your creditor to communicate with you via e-mail and you do not want Altisource or NCI to communicate with you via e-mail, please provide NCI with a written Opt Out Notice. You may make this request via e-mail to communications@ncirm.com or letter sent to Nationwide Credit, Inc. Attn: E-mail Opt-Out, NATIONWIDE CREDIT, INC., PO BOX 14581,DES MOINES, IA 50306-3581. In the event you choose to send your Opt Out Notice via e-mail, this will not be considered consent to use your e-mail as provided in paragraph 2(b) above.
7. Changing Your E-mail Address: If you have received a communication from NCI regarding your prior consent to your creditor to communicate with you via e-mail and you do not want NCI to communicate with you via that particular e-mail address or if at any time you want us to use a different e-mail address than the one we have on file, please contact us to provide an updated e-mail address.
8. Ending the E-Mail Relationship: Ending the E-Mail Relationship: Either you or NCI may request to discontinue using e-mail as a means of communication. You may make this request via e-mail to communications@ncirm.com or letter sent to Nationwide Credit, Inc. Attn: E-mail Opt-Out, 1150 E. University Dr, 1st Floor, Tempe, AZ 85281. In the event you choose to send your request toend the e-mail relationship via e-mail, this will not be considered consent to use your e-mail as provided in paragraph 2(b) above.
9. All requests to unsubscribe, opt out or end the e-mail relationship will be respected.
10. NCI are not responsible for e-mail messages that are lost due to technical failure during composition, transmission and/or storage.

CALIFORNIA RESIDENTS: PRIVACY POLICY NOTICE

This Privacy Policy Notice is intended for California residents pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), and supplements the information contained in the above Privacy Policy. Any terms defined in the CCPA and applicable California Attorney General regulations have the same meaning as used in this Privacy Policy Notice.

If you have a disability call us at toll-free number 1-800-456-4729 or write to us at Nationwide Credit, Inc. PO Box 15130 Wilmington, DE 19850 and we can provide an alternative format for this information.

1. Information We Collect About You

   We may collect and use personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be directly or indirectly linked, with a consumer, device, or household (“personal information”).

Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as (but not limited to) information governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the California Confidentiality of Medical Information Act (“CMIA”), the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

We regularly collect (and have collected in the past 12 months) several types of personal information about individuals offline regarding accounts we service for other entities, including: name, DOB, address, gender, account number, payment and other financial information, email address, insurance information, Social Security Number, employment information, telephone number, IP address, military or veteran status, audio information, username, commercial information (such as records of property, products, or services purchased, or other purchasing or consuming histories or tendencies), internet activity such as interaction with our website(s) or application(s), inferences drawn from any personal information categories to create a profile about a consumer reflecting the consumer’s preferences, characteristics, aptitudes, or behavior, publicly available information, and information collected or shared pursuant to HIPAA, CMIA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws. We also may collect additional categories of personal information users provide directly to us, our clients, or our vendors.

2. How Your Personal Information is Collected

   We collect most of this personal information from our creditor clients or from you or your authorized representative if you provide it to us. However, we may also collect information:

   • From publicly accessible sources (e.g., property or other government records);
   • From our vendors (e.g., call analytics, information source, skip-tracing, payment processing, mailing, and other vendors)
3. Why We Use or Disclose Your Personal Information

   We regularly use or disclose personal information for one or more of the following business purposes:

   • Fulfill the reason you provided the information. For example, if you share your personal information to make a payment, we will use that information to process your payment.
   • Perform services on behalf of a business or service provider, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing analytic services, or providing similar services on behalf of the business or service provider
   • Provide you with information or services that you request from us
   • Auditing related to consumer interactions
   • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
   • Debugging to identify and repair errors that impair existing intended functionality
   • Short-term, transient use, where the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction
   • Undertaking activities to verify or maintain the quality of a service or device that is owned, made by or for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, made by or for, or controlled by us
   • Respond to law enforcement requests and as required by applicable law or court order
   • As appropriate to protect the rights, property, or safety of us, our clients, or others
   • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different purposes without providing you notice.

We regularly disclose (and have disclosed in the past 12 months) several types of personal information about individuals for one or more business purposes, including: name, DOB, address, gender, account number, previous payment and other financial information, email address, insurance information, Social Security Number, employment information, telephone number, IP address, military or veteran status, audio information, username, commercial information (such as records of property, products, or services purchased, or other purchasing or consuming histories or tendencies), internet activity such as interaction with our website(s) or application(s), inferences drawn from any personal information categories to create a profile about a consumer reflecting the consumer’s preferences, characteristics, aptitudes, or behavior, publicly available information, and information collected or shared pursuant to HIPAA, CMIA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws.

We have not sold your personal information over the last 12 months and will not sell your personal information under the CCPA.

4. Verifiable Consumer Requests for Information

   Upon verification of identity, California residents may in some cases request that a business:

   • Disclose the categories of personal information the business collected about the consumer;
   • Disclose the categories of sources from which the personal information is collected
   • Disclose the categories of personal information that the business sold about the consumer;
   • Disclose the categories of personal information that the business disclosed about the consumer for a business purpose;
   • Disclose the categories of third parties with whom the business shares personal information
   • Disclose specific pieces of personal information the business has collected about the consumer
   • Disclose any financial incentives offered by the business for collection, sale, or deletion of personal information

   Businesses that provide information requested pursuant to the CCPA must provide such information in a readily useable format and allow consumers to transmit the information from one entity to another without hindrance.

   A business may charge a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to you by your personal information.

   Please note that we are not required to:

   • Carry out information access requests we receive from you if acting as a service provider to another entity regarding such information
   • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
   • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
   • Provide requested information if a CCPA or applicable exception applies.
5. Right to Request Deletion of Personal Information

   Upon verification of identity, California residents may in some cases request that a business delete personal information collected from them, subject to certain exceptions.

   We may deny your deletion request if we are acting in the role of a service provider to another business regarding the applicable personal information. If we deny your request on that basis, we will generally refer you to the relevant business. In addition, we may deny your deletion request if retaining the information is necessary for us or our client to:

   • Complete the transaction for which the personal information was collected, provide a good or service requested by you, as reasonably anticipated within the context of your relationship with the relevant business, or otherwise perform a contract between you and the business.
   • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
   • Debug to identify and repair errors that impair existing intended functionality.
   • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
   • Comply with the California Electronic Communications Privacy Act.
   • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent.
   • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the relevant business.
   • Comply with a legal obligation.
   • Otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information; or
   • If another CCPA or applicable exception applies.

   California residents may obtain more information about verifiable requests pursuant to the CCPA by contacting us by completing a web form at Link, or calling us at toll-free number 1-800-456-4729, or by mail at Nationwide Credit, Inc. PO Box 15130 Wilmington, DE 19850

6. Verifying Your Identity If You Submit CCPA Requests

   If you choose to contact us directly via the designated methods described above to exercise your CCPA rights, you will need to:

   • Provide enough information to reasonably identify you [(e.g., your full name, account number if applicable, and potentially other identifying information]; and
   • Describe your request with sufficient detail to allow us to properly process and respond to your request.

   In addition to the exceptions described in this Notice, we are not obligated to make an information disclosure or carry out a deletion request pursuant to the CCPA if we cannot sufficiently verify the identity of the requestor.

   If seeking to make a verifiable request under the CCPA on behalf of someone else, we require enough information to reasonably identify the subject of the request (including name and other identifying information) and the subject’s written consent to make the CCPA request on his or her behalf, as consistent with applicable law.

   Any personal information we collect from you in order to verify your identity in connection with your CCPA request will be used solely for the purposes of verification.

   Last modified: 07/01/2020