PRIVACY POLICY STATEMENT
Thank you for visiting Joseph, Mann & Creed (JMC). We are committed to the privacy of our visitors. We collect no personal information about you when you visit our Web site unless you choose to provide that information to us.
Here is how we handle information about your visit to our Web site.
In compliance with the EU-U.S. DPF, Joseph, Mann & Creed commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF.
Joseph, Mann & Creed complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) set forth by the U.S. Department of Commerce. Joseph, Mann & Creed has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/
In compliance with the EU-U.S. DPF Joseph, Mann & Creed to resolve DPF Principles-related complaints about our collection and use of your personal information. EU individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF should first contact Joseph, Mann & Creed at:
For Inquiries Contact: compliance@jmcbiz.com or call 1-877-369-5092
Joseph, Mann & Creed will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Joseph, Mann & Creed is subject to the investigitory and enforcement powers of the Federal Trade Commission (FTC).
An individual may, under certain conditions, invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms. Please visit the following link for additional information: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2
Joseph, Mann & Creed does not transfer personal information to third parties. If in the future JMC does transfer personal information to a third party acting as an agent on JMC’s behalf, JMC shall remain liable under the DPF principles if its agent processes such personal information in a manner inconsistent with DPS principles, unless JMC proves it is not responsible for the event giving rise to the damage.
Under the Principles, the right of access is fundamental to privacy protection. In particular, it allows individuals to verify the accuracy of information held about them. The Access Principle means that individuals have the right to:
1. obtain from an organization confirmation of whether or not the organization is processing personal data relating to them;[14]
2. have communicated to them such data so that they could verify its accuracy and the lawfulness of the processing; and
3. have the data corrected, amended or deleted where it is inaccurate or processed in violation of the Principles.
ii. Individuals do not have to justify requests for access to their personal data. In responding to individuals’ access requests, JMC will first be guided by the concern(s) that led to the requests in the first place. For example, if an access request is vague or broad in scope, an organization may engage the individual in a dialogue so as to better understand the motivation for the request and to locate responsive information. JMC might inquire about which part(s) of the organization the individual interacted with or about the nature of the information or its use that is the subject of the access request.
iii. Consistent with the fundamental nature of access, JMC will always make good faith efforts to provide access. For example, where certain information needs to be protected and can be readily separated from other personal information subject to an access request, JMC will redact the protected information and make available the other information. If JMC determines that access should be restricted in any particular instance, it will provide the individual requesting access with an explanation of why it has made that determination and a contact point for any further inquiries.
Burden or Expense of Providing Access
i. The right of access to personal data may be restricted in exceptional circumstances where the legitimate rights of persons other than the individual would be violated or where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question. Expense and burden are important factors and should be taken into account but they are not controlling factors in determining whether providing access is reasonable.
ii. For example, if the personal information is used for decisions that will significantly affect the individual (e.g., the denial or grant of important benefits, such as insurance, a mortgage, or a job), then consistent with the other provisions of these Supplemental Principles, JMC would have to disclose that information even if it is relatively difficult or expensive to provide. If the personal information requested is not sensitive or not used for decisions that will significantly affect the individual, but is readily available and inexpensive to provide, an organization would have to provide access to such information.
c. Confidential Commercial Information
i. Confidential commercial information is information that JMC has taken steps to protect from disclosure, where disclosure would help a competitor in the market. Organizations may deny or limit access to the extent that granting full access would reveal its own confidential commercial information, such as marketing inferences or classifications generated by the organization, or the confidential commercial information of another that is subject to a contractual obligation of confidentiality.
ii. Where confidential commercial information can be readily separated from other personal information subject to an access request, the organization should redact the confidential commercial information and make available the non-confidential information.
d. Organization of Data Bases
i. Access can be provided in the form of disclosure of the relevant personal information by an organization to the individual and does not require access by the individual to an organization’s data base.
ii. Access needs to be provided only to the extent that an organization stores the personal information. The Access Principle does not itself create any obligation to retain, maintain, reorganize, or restructure personal information files.
e. When Access May be Restricted
i. As organizations must always make good faith efforts to provide individuals with access to their personal data, the circumstances in which organizations may restrict such access are limited, and any reasons for restricting access must be specific. As under the GDPR, an organization can restrict access to information to the extent that disclosure is likely to interfere with the safeguarding of important countervailing public interests, such as national security; defense; or public security. In addition, where personal information is processed solely for research or statistical purposes, access may be denied. Other reasons for denying or limiting access are:
1. interference with the execution or enforcement of the law or with private causes of action, including the prevention, investigation or detection of offenses or the right to a fair trial;
2. disclosure where the legitimate rights or important interests of others would be violated;
3. breaching a legal or other professional privilege or obligation;
4. prejudicing employee security investigations or grievance proceedings or in connection with employee succession planning and corporate re-organizations; or
5. prejudicing the confidentiality necessary in monitoring, inspection or regulatory functions connected with sound management, or in future or ongoing negotiations involving the organization.
ii. An organization which claims an exception has the burden of demonstrating its necessity, and the reasons for restricting access and a contact point for further inquiries should be given to individuals.
f. Right to Obtain Confirmation and Charging a Fee to Cover the Costs for Providing Access
i. An individual has the right to obtain confirmation of whether or not this organization has personal data relating to him or her. An individual also has the right to have communicated to him or her personal data relating to him or her. An organization may charge a fee that is not excessive.
ii. Charging a fee may be justified, for example, where requests for access are manifestly excessive, in particular because of their repetitive character.
iii. Access may not be refused on cost grounds if the individual offers to pay the costs.
g. Repetitious or Vexatious Requests for Access
i. JMC may set reasonable limits on the number of times within a given period that access requests from a particular individual will be met. In setting such limitations, an organization should consider such factors as the frequency with which information is updated, the purpose for which the data are used, and the nature of the information.
h. Fraudulent Requests for Access
i. JMC is not required to provide access unless it is supplied with sufficient information to allow it to confirm the identity of the person making the request.
i. Timeframe for Responses
i. JMC will respond to access requests within a reasonable time period, in a reasonable manner, and in a form that is readily intelligible to the individual. An organization that provides information to data subjects at regular intervals may satisfy an individual access request with its regular disclosure if it would not constitute an excessive delay.
ADDITIONAL NOTICES
Types of personal data collected
Contact information
Communication data
Contract data
Payment information
JMC offer individuals the opportunity to choose (i.e., opt out) whether their personal information is to be disclosed to a third party or (to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. To Opt-out, simply contact: compliance@jmcbiz.com or call 1-877-369-5092.
Recipients The personal data transferred may be disclosed only to the following recipients or categories of recipients:
Management of the company and the employees handling the debt collection procedures
- Credit agencies - third-party debtors
- registration offices
- courts
- service providers
- bailiffs
- lawyers
Sensitive data (if appropriate)
The personal data transferred concern the following categories of sensitive data:
Name, address, date of birth, personal ID number, telephone (landline and mobile) number, e-mail address, information related to the claim itself.
To the best of our knowledge, no sensitive data is being transferred.
Telecommunications Disclosure
You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud.
California Residents Only
A consumer has the right to request that the business disclose the following:
· Categories of personal information we collect;
· The categories of sources from which the personal information is collected;
· The purpose for collecting the personal information and how long such information will be retained;
· The categories of third-parties with whom we share personal information; and
· The specific pieces of information we have collected, disclosed, or sold.
Such a request can be made to Joseph, Mann & Creed at 1-877-369-5092 or email us at Compliance@jmcbiz.com. Once we receive your request, we will compare information you provided with the information we already have. If we can verify that the request came from you, we will provide the required information. We will match 2 – 3 identifying, personal information data points to verify that the request came from you.
Cookies
To better serve our visitors, we use technology to track new and returning visitors actions while on the website. These small files are commonly referred to as "cookies." Our cookies do not contain any personally-identifiable information. Our web measurement applications compare the behavior of new and returning visitors in the aggregate to help us identify work flows and trends and also resolve common problems on our site.
Cookies are small files that Web servers place on a user's hard drive. They can serve several functions:
they allow the Web site to identify you as a previous visitor each time you access a site;
they track what information you view at a site (important to JMC to ensure visitors find what they are looking for);
in the more advanced cases they track your movements through many Web sites but not the whole Web;
businesses use them for customer convenience to allow them to produce a list of items to buy and pay for them all at one time and to garner information about what individuals are buying at their sites;
advertisers use them to determine the effectiveness of their marketing and offer insights into consumer preferences and tastes by collecting data from many Web sites; and
they can be used to help a Web site tailor screens for each customer's preference.
We will retain data the technology makes available only as long as required by law, or specific program need as specified by the National Archives and Records Administration’s General Records Schedule 20, which pertains to Electronic Records or other approved records schedule as applicable.
If you are concerned about the potential use of the information gathered from your computer by cookies, you can set your browser to prompt you before it accepts a cookie. You can remove or block the use of web measurement and customization technologies by changing the setting of your browser to block cookies as described at USA.Gov.
Security Notice
Information collected and stored automatically: If you do nothing during your visit but browse through the Web site, read pages, or download information, we will gather and store certain information about your visit automatically. This information does not identify you personally. We automatically collect and store information like the following concerning your visit:
The Internet domain (for example, "xcompany.com" if you use a private Internet access account or "yourschool.edu" if you connect from a university's domain);
Your IP address (an IP address is a number that is automatically assigned to your computer whenever you are surfing the Web) from which you access our Web site;
The type of browser and operating system used to access our site;
The date and time you access our site;
The pages you visit; and
If you linked to our Web site from another Web site, the address of that Web site.
We use this information to help us make our site more useful to visitors, to learn about the number of visitors to our site, and the types of technology our visitors use. We do not track or record information about individuals and their visits.
Information protection: For site security purposes and to ensure that this service remains available to all users, JMC’s computer system employs software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. If such monitoring reveals evidence of possible abuse or criminal activity, such evidence may be provided to appropriate law enforcement officials. Unauthorized attempts to upload or change information on this server are strictly prohibited and may be punishable under the Computer Fraud and Abuse Act of 1986 and the National Information Infrastructure Protection Act or other law.
Information that you voluntarily provide: We do not collect personally identifiable information unless you choose to provide it to us. If you provide us with personally identifiable information, for example, by sending an e-mail or by filling out a form and submitting it through our Web site, we use that information to respond to your message and to help us provide you with the information and services that you request. All uses of that information are described on the Web page containing the form.
Submitting voluntary information constitutes your consent to the use of the information for the stated purpose. When you click the "Submit" button on any of the Web forms found on our sites, you are indicating your voluntary consent to use of the information you submit for the purpose stated.
How information is used: The information we collect is used for a variety of purposes (e.g., to retrieve your account, to respond to requests for information, and to resolve issues with outstanding balances due). We make every effort to disclose clearly how information is used at the point where it is collected so you can determine whether you wish to provide the information.
Retention of Information: We destroy the information we collect when the purpose for which it was provided has been fulfilled unless we are required to keep it longer by statute or official policy. Electronically submitted information is maintained and destroyed according to the principles of the Federal Records Act and the regulations and records schedules approved by the National Archives and Records Administration, and in some cases information submitted to us may become an agency record and therefore might be subject to a Freedom of Information Act request.
Also, JMC is not responsible for the privacy practices employed by non-JMC sites that may link to the JMC web site or non-JMC sites hosted on JMC computers (e.g. web sites of professional organizations.)
Links to other sites: Our Web site contains links to various other federal agencies and private organizations. Once you link to another site, you are then subject to the privacy policies of the new site. It is always a good idea to read the Privacy Policy of any site you visit.
Your rights under the Privacy Act: Information on the Privacy Act can be found on the following web site: DoC Privacy Office.
JMC Endorsement Disclaimer Policy
Links to websites outside the U.S. Federal Government or the use of trade, firm, or corporation names within JMC websites are for the convenience of the user. Such use does not constitute an official endorsement or approval by the International Trade Administration or U.S. Commerce Department of any private sector website, product, or service.
Third Party Websites and Applications
JMC has a presence on several social media/Web 2.0 platforms (Facebook, YouTube, Twitter, LinkedIn, and other third-party services)) and clearly contain JMC’s official logo. Each of these web sites provides JMC unique ways of sharing information. It also allows visitors with a way to communicate with the agency. Some may allow visitors to log in, create profiles and save information in those profiles. We do not collect any personally identifiable information about you through your use of these social media/Web 2.0 platforms. We may collect public information, such as user/screen name, city, state, and zip code of visitors to these web sites, and comments posted about JMC for statistical, research, and promotional purposes only. Further, JMC has no control over the third-party’s use of this information and is not liable regarding the third-party’s safeguarding your information. These web sites have their own privacy, security and accessibility policies.
