Privacy Notice
Our Privacy Policy
As you may well know, Congress has passed the Gramm-Leach-Bliley Act. The GLB deals with how financial institutions treat nonpublic personal financial information. Joseph, Mann & Creed hereafter known as “JMC” understands how important your privacy is to you. This is why we, JMC strongly believe in protecting the confidentiality and security of information we obtain about you. JMC privacy policies and procedures apply only to our company, not to third parties who may handle your personal information.
Miranda Requirement
The Fair Debt Collection Practices Act provides that a debt collector may not use any false, deceptive, or misleading representation or means in connection with the collection of debt. Section 807 of the Fair Debt Collection Practices Act provides that "false, deceptive, or misleading representation" includes the failure to disclose in the initial oral or written communication with the consumer that "the debt collector is attempting to collect a debt and that any information obtained will be used for that purpose", and the failure to disclose in subsequent communications that "the communication is from a debt collector". This is referred to as the "Mini-Miranda" Requirement Our internal policy on the Mini-Miranda Requirement exceeds the minimum standards required by law; our policy is that a collector must give the Mini-Miranda to a consumer on each contact made. Collectors are trained to give the Mini-Miranda once they have identified that the person they are speaking with is the correct debtor and prior to discussing the debt or any demand for payment.
Choice and Consent
JMC collects only personal information essential to securing payment of our clients’ receivables. Failure to provide the minimum personal information required to complete a payment may result in further collection efforts from JMC or our clients. By providing JMC with personal information, you are giving JMC implicit consent to use this information for further collections efforts. JMC employees may request your explicit consent prior to collecting sensitive personal information from you. If personal information is to be used for purposes not previously identified in this privacy notice you will be notified. All payment information is protected in accordance with PCI DSS Security Standards and explicit consent is required prior to processing any credit card payments.
Security
Confidential information entrusted to JMC will be secured from unauthorized viewing, accidental distribution, and accidental loss. Confidential information is received in both paper and electronic form. Account information is not purged from our database. Your personal information is kept electronically and any paper containing personal information is disposed of securely. JMC maintains compliance with SSAE 16 security principles such as:
Employees are authorized to access personal information based on job responsibilities.
Authentication is used to prevent unauthorized access to personal information stored electronically.
JMC provides secure processing areas for mail collection, mail opening, payment posting, reconciliation and remittances.
Physical security is maintained over personal information stored in hard copy form, and encryption is used to prevent unauthorized access to personal information sent over the internet.
Additional security safeguards are applied to sensitive information.
Parties to Whom We Disclose information
Joseph, Mann & Creed does not sell, release, or distribute any nonpublic information obtained except as required or permitted by law. Personal information is disclosed to third parties only for the purposes identified in this notice and for which you have provided implicit or explicit consent unless a law or regulation specifically allows or requires otherwise. Third parties may include our clients, vendors, and credit card processors with whom we have agreements to protect your personal information in a manner consistent with the relevant aspects of our privacy policy. All information is transmitted in accordance with our security policy and may be transmitted in paper or electronic form.
Access to your information
JMC collects information fairly and lawfully from others, such as credit bureaus, affiliates, or other companies. JMC may collect information regarding your whereabouts or financial information from third- party sources. You have the right to obtain certain items of information that we have collected about you. You also have the right to request correction of information if you feel it is not accurate. These requests must be made in writing. If we agree, we will correct our records and may notify our client. If we do not agree, we will be sure to communicate this to you.
Telecommunications Disclosure
You authorize your wireless carrier to use or disclose information about your account and 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.
Inquiry, Complaint and dispute process
Any inquiries, complaints or disputes should be directed to our corporate compliance officer in writing to the address listed at the end of this policy.
Communications
To change how Joseph, Mann, and Creed communicate with you, please contact your collection representative, write to our mailing address at 8948 Canyon Falls Blvd. Suite 200, Twinsburg, Ohio 44087, or email our compliance department at compliance@jmcbiz.com
Jmc online privacy policy
As is true of most web sites, our servers automatically collect and store certain technical information when you visit our web sites, including information such as the internet protocol (IP) address of the device you use to connect to the Internet, browser type, internet service provider (ISP), the web site you came from and exited to, operating system, date/time stamp, and pages visited. In addition, we or our third-party service providers may place and read session and/or persistent "cookies" on the computer you are using, and use other technologies such as Web beacons, clear GIFs, tracking pixels and tags, when you visit our websites or open our email. JMC and our service providers may use information from our server logs, cookies and other technologies, in combination with information you provide, transaction information, and information that we or they collect from others, to process your transactions, to fulfill legal and regulatory requirements, and as otherwise permitted by applicable law. We do not intend to collect personal information from children under 13 years of age. If we learn that we have collected this information from a child under the age of 13, we will promptly take all reasonable steps to delete the data from our system. Unless prohibited by law, you have the right, upon reasonable notice, to view any personally identifiable information collected from you through your visits to or use of our websites, to make corrections to such information if necessary, or to request that such information be removed from our systems. You may do so by contacting us at the address indicated at the end of this policy. Our website also permits you to access non-JMC sites directly from our website. It is important to remember that if you link to a non-JMC site from any of our websites that party's privacy policy and its terms and conditions of use apply to you. We encourage you to learn about each third party's privacy policy before giving your information to them.
Anti-Human-Trafficking Policy
Purpose
Joseph, Mann & Creed and the United States Government prohibit trafficking in persons. The U.S. Government’s policy prohibiting trafficking in persons is available at 48 CFR Section 52.222-50 and is summarized below under the heading: “Summary of U.S. Government Policy of Prohibiting Trafficking in Persons.”
Joseph, Mann & Creed is committed to a work environment that is free from human trafficking and slavery, which for purposes of this policy includes forced labor and unlawful child labor. Joseph, Mann & Creed will not tolerate or condone human trafficking or slavery in any part of our organization.
Joseph, Mann & Creed employees, subsidiaries, contractors, subcontractors, vendors, suppliers, partners and others through whom Joseph, Mann & Creed conducts business must avoid complicity in any practice that constitutes trafficking in persons or slavery.
Scope
This policy applies to all employees, and every employee is responsible for reading, understanding and complying with this policy. Joseph, Mann & Creed managers are responsible for ensuring that employees who report to them comply with this policy. If you have any questions or concerns relating to this policy, consult Bill Mann, Perry Creed or human resources.
Procedures
Report any conduct that you believe to be a violation of this policy to Bill Mann, Perry Creed, or human resources.
Employees who fail to report actual or suspected misconduct may be deemed in violation of this policy.
Disciplinary Actions
Joseph, Mann & Creed will not tolerate retaliation against an employee for reporting a concern in good faith or cooperating with a compliance investigation, even when no evidence is found to substantiate the report.
Any violation of this policy may be grounds for disciplinary action, up to and including termination.
Violation of the U.S. Government’s policy again human trafficking may also result in criminal prosecution of responsible individuals.
Summary of U.S. Government Policy of Prohibiting Trafficking in Persons
U.S. Government policy prohibits trafficking in persons and slavery. Government contractors and their employees, subcontractors, subcontractor employees, and agents must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but not limited to, the following activities:
· Engaging in any form of trafficking in persons.
· Procuring commercial sex acts.
· Using forced labor in the performance of any work.
· Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority.
· Using misleading or fraudulent practices during the recruitment of employees or offering of employment/contract positions, such as failing to disclose, in a format and language understood by the employee or applicant, basic information; or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing, and associated costs (if provided by the employer or agent), any significant cost to be charged to the employee or applicant, and, if applicable, the hazardous nature of the work.
· Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place.
· Charging applicants recruitment fees.
· If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment.
· If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards.
· If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing with legally required information and in a language the employee understands.
