Last Updated: September 1, 2024
Notice to California Residents
This section applies solely to California residents and supplements, without limiting, the Privacy Policy outlined above. This notice is provided by Debtbusters.com (collectively referred to as “we”, “our”, or “us”).
These provisions are designed to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA carry the same meaning when used in these Provisions. This notice details how we collect, use, and share personal information, and outlines the rights and choices California residents have regarding the handling of their personal data.
This notice does not cover personal information related to:
- Publicly available information from government records.
- De-identified or aggregated user information.
- Health or medical information governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the California Confidentiality of Medical Information Act (CMIA), or clinical trial data.
- Personal information protected under specific sectoral privacy laws, such as the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Notice of Collection of Personal Information
The personal information we collect depends on the nature of California residents’ interactions with us. The following are examples of interactions and the associated personal information we may collect:
Types of Interaction:
- Website and Mobile App Use and Registration
- Applying for Products or Services
- Participation in Surveys and Contests
- Communication with Us
| Category of Personal Information | Collected | Sold | Disclosed for a Business Purpose |
|---|---|---|---|
| Identifiers: Full Name, Social Security Number, Email address, etc. | Yes | No | Service providers, marketing partners, banking partners, government entities, law enforcement, auditors, examiners, lawyers and other parties as required by law |
| Financial data: Bank account, credit or debit card number, transactions. | Yes | No | Service providers, marketing partners, banking partners, government entities, law enforcement, auditors, examiners, lawyers and other parties as required by law |
| Protected Classification Characteristics: age, race, sex, religion, national origin, marital status. | Yes | No | Service providers, marketing partners, banking partners, government entities, law enforcement, auditors, examiners, lawyers and other parties as required by law |
| Commercial Information: records of personal property, products or services obtained. | Yes | No | Service providers, marketing partners, banking partners, government entities, law enforcement, auditors, examiners, lawyers and other parties as required by law |
| Biometric Information: preferences, trends, abilities, predispositions, characteristics, behaviors. | Yes | No | Service providers, marketing partners, banking partners, government entities, law enforcement, auditors, examiners, lawyers and other parties as required by law |
| Network activity information: Browsing history, search history, interaction with a website. | Yes | No | Service providers, marketing partners, banking partners, government entities, law enforcement, auditors, examiners, lawyers and other parties as required by law |
| Geolocation data: physical location of device. | Yes | No | Service providers, marketing partners, banking partners, government entities, law enforcement, auditors, examiners, lawyers and other parties as required by law |
| Professional or employment-related information: Current or past job history. | Yes | No | Service providers, marketing partners, banking partners, government entities, law enforcement, auditors, examiners, lawyers and other parties as required by law |
Use of Personal Information
Information collected is used to personalize your experience on our Site, improve your experience with our Site, products and services, to advertise to you, recognize you on subsequent visits, verify your identity, evaluate you for certain products/services, build a better member experience, improve member relationship protocols, fulfill contract obligations with you, to respond to inquired from you, testing, research, analysis, product development, respond to law enforcement, court orders or governmental examiners and to train and educate employees for compliance purposes.
We may also supplement the information you provide or that we gather from your interaction with our Site by using third party sources such as credit bureau information and address/phone information to verify your identity and to protect you against fraud or identity theft.
California Residents Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. Following are those rights and how to exercise them:
Right to Know Access:
You can request free of charge the following information covering the prior 12-months of your request:
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected about you
- Our business purpose for collecting or selling that personal information
- The categories of third parties with whom we have shared that personal information
- The specific pieces of personal information we collected about you (also called a data portability request)
- The categories of information that we sold in the prior 12 months, and for each category, the categories of third parties to which we sold that particular category of personal information
- The categories of information that we disclosed for a business purpose in the prior 12 months and for each category, the categories of third parties to which we disclosed that particular category of personal information
Right to Opt-Out of the Sale of Your Personal Information
The CCPA provides it’s residents the right to opt-out of our sale of your personal information to third parties.
Right to Request Deletion
You have the right to request that we delete your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request to delete your personal information from our (their) records, unless a CCPA exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
Please be advised that deleting your personal information may terminate your access to certain of the Site Offerings. If you wish to continue using the full complement of Site Offerings, we may not be able to delete all of the personal information that we have on file for you.
Further after we delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
How to Exercise your Rights
If you wish to exercise any of your CCPA rights noted above or have any questions or comments about this privacy policy, the ways in which we collect and use your personal information, or your choices and rights regarding such use, please contact us by either:
- Calling us at: 866-223-4395
- Emailing us at: [email protected]
We will respond to your request within the provisions allowed by CCPA; in no event later than 45 days of the receipt of your request, unless we notify you of any delay otherwise.
Submitting Requests for Someone Else
California residents can utilize an “Authorized Agent” to make requests on their behalf. We will require that the Authorized Agent provide us with a valid written authorization confirming said authority that is executed by you and the Authorized Agent.
Identity Verification
When you make any CCPA request, we are required to verify your identity before providing a response to the request. We will ask you to verify your identity when you submit a request, including any Authorized Agent’s identity.
Right to Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights, including but not limited to:
- Deny you goods or services
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
- Provide you a different level or quality of goods or services
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Privacy Information for California Employees, Contractors, and Applicants
We collect Personal Information from current and past employees (‘Employees’), Contractors, and Applicants and comply with the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”), collectively referred to as “California Privacy Law.” This California HR Privacy Notice applies to California Employees, Contractors, and Applicants (“you” or “your”).
For the purposes of this California HR Privacy Notice, “Personal Information” means information that is linked or reasonably linkable to a particular individual or household.
However, the following categories of information are not considered Personal Information:
- Publicly available information;
- De-identified or aggregated data; or
- Information otherwise excluded from the scope of California Privacy Law.
- This Privacy Notice provides the following information to California Employees, Contractors, and Applicants:
- Categories of Personal Information we collect;
- Purposes for which we use Personal Information;
- Categories of Personal Information we disclose to third parties;
- Categories of third parties to which we disclose Personal Information; and
- How Employees, Contractors, and Applicants can exercise their rights under California Privacy Law:
- The rights to access, correct, or delete Personal Information;
- The right to obtain a portable copy of Personal Information;
- The right to limit the use of sensitive Personal Information in certain circumstances; and
- The right to opt-out of the sharing of Personal Information for behavioral advertising, sales of Personal Information, use of automated decision-making, or certain profiling. This includes information in our response to access requests about the rationale involved in those decision-making processes, as well as a description of the likely outcome of the process with respect to the consumer.
- The right to non-discrimination for exercising CPRA rights;
- The right to be notified, before, or at the time personal information is collected, about the type of personal information collected and what we may do with that information.
Categories of Non-Sensitive Personal Information
The table below outlines the non-sensitive categories of Personal Information we collect about Employees, Contractors, and Applicants, and whether and how they are disclosed to third parties.
We collect Non-Sensitive Personal Information from the following sources:
Directly from our Employees, Contractors, and Applicants.
| Category of Personal Information: Identifiers |
|---|
| Examples |
| Names, home addresses, personal email addresses, personal phone numbers, next of kin |
| Purpose(s) |
| Complying with statutory obligations and to improve services |
| Targeted Advertising |
| We do not engage in targeted advertising or share Personal Information for targeted advertising purposes |
| Sale |
| We do not sell Personal Information to anyone |
| Sharing |
| This information may be shared with Processors and Affiliates |
| Retention Period |
| We retain this information for 3 years, or as dictated by applicable regulations |
| Other Disclosures |
| This information may be disclosed to Processors and Affiliates. We disclose Identifiers to comply with statutory obligations, improve services, and to enable our processors to provide customer service on our behalf. |
| Category of Personal Information: Personal Characteristics |
|---|
| Examples |
| Personal Characteristics may contain the following: Age, gender, race, ethnicity, disability, and national origin data when provided by employee. |
| Purpose(s) |
| Complying with statutory obligations and to improve services |
| Targeted Advertising |
| We do not engage in targeted advertising or share Personal Information for targeted advertising purposes |
| Sale |
| We do not sell Personal Information to anyone |
| Sharing |
| This information may be shared with Processors and Affiliates |
| Retention Period |
| We retain this information for 3 years, or as dictated by applicable regulations |
| Other Disclosures |
| This information may be disclosed to Processors and Affiliates. We disclose Personal Characteristics to comply with statutory obligations and to improve services. |
| Category of Personal Information: Professional Information |
|---|
| Examples |
| Professional Information may contain the following: employment history or other materials provided upon application for employment |
| Purpose(s) |
| Complying with statutory obligations and to improve services |
| Targeted Advertising |
| We do not engage in targeted advertising or share Personal Information for targeted advertising purposes |
| Sale |
| We do not sell Personal Information to anyone |
| Sharing |
| This information may be shared with Processors and Affiliates |
| Retention Period |
| We retain this information for 3 years, or as dictated by applicable regulations |
| Other Disclosures |
| This information may be disclosed to Processors and Affiliates. We disclose Professional Information to comply with statutory obligations and to improve services. |
| Category of Personal Information: Educational Information |
|---|
| Examples |
| Educational Information may contain the following: any and all educational information provided during the application and interview process |
| Purpose(s) |
| Complying with statutory obligations and to improve services |
| Targeted Advertising |
| We do not engage in targeted advertising or share Personal Information for targeted advertising purposes |
| Sale |
| We do not sell Personal Information to anyone |
| Sharing |
| This information may be shared with Processors and Affiliates |
| Retention Period |
| We retain this information for 3 years, or as dictated by applicable regulations |
| Other Disclosures |
| This information may be disclosed to Processors and Affiliates. We disclose Educational Information to comply with statutory obligations and to improve services. |
Categories of Sensitive Personal Information
The table below outlines the categories of Sensitive Personal Information Achieve collects about Employees, Contractors, and Applicants and whether they are shared with third parties.
We collect Sensitive Personal Information from the following sources:
From our affiliates (“affiliates” are businesses that share common ownership with Achieve)
Directly from our Employees, Contractors, and Applicants
| Category of Sensitive Personal Information: Sensitive Category Data |
|---|
| Examples |
| Sensitive Category Data may contain the following: employee provided information regarding racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, sex life, or citizenship or immigration status. |
| Purpose(s) |
| Complying with statutory obligations and to report on and track diversity and inclusion efforts. |
| Targeted Advertising |
| We do not engage in targeted advertising or share Personal Information for targeted advertising purposes |
| Sale |
| We do not sell Personal Information to anyone |
| Sharing |
| This information may be shared with Processors and Affiliates |
| Retention Period |
| We retain this information for 3 years, or as dictated by applicable regulations |
| Other Disclosures |
|
This information may be disclosed to Processors and Affiliates. We disclose Sensitive Category Data to comply with statutory obligations, report on and track diversity and inclusion, and to publish employees’ work contact information in an intra-company directory for other employees to view. We may disclose applicants’ submitted Sensitive Personal Information with our HR department and other employees to process applications. We respond to subpoenas, wage garnishments, and court orders in accordance with applicable state and federal laws. Sensitive Personal Information may also be used or disclosed as otherwise permitted or required by applicable law to provide physical security by complying with police requests and working with our third-party security team. |
| Category of Sensitive Personal Information: Financial Data |
|---|
| Examples |
| Financial Data may contain the following: banking information related to payroll processing and direct deposit information. |
| Purpose(s) |
| Complying with statutory obligations; improving payroll services and offering direct deposit options to employees. |
| Targeted Advertising |
| We do not engage in targeted advertising or share Personal Information for targeted advertising purposes |
| Sale |
| We do not sell Personal Information to anyone |
| Sharing |
| This information is not shared with third parties |
| Retention Period |
| We retain this information for the duration of employment or as dictated by applicable law. |
| Other Disclosures |
| This information is not otherwise disclosed to third parties. |
Use of Personal Information
We use Personal Information for the purposes described above. Other examples of how we may use your Personal Information within Achieve include:
Publishing Employees’ work contact information in an intra-company directory for other Employees to view.
Disclosing applicants’ submitted Personal Information to our HR department and other employees as needed to process applications.
Sharing applicants’ submitted Personal Information with our HR department and other employees to process applications.
Creating profiles of contractors’ performance based on work product.
Personal Information may also be used or disclosed as otherwise permitted or required by applicable law.
Disclosing Personal Information
We disclose Personal Information with the following categories of third parties:
Processors (also referred to as “Service Providers” or “Contractors” in California law): We use processors to securely handle Personal Information on our behalf for our business purposes and only on our instructions. California privacy laws and our contracts with these companies prevent them from using your Personal Information for their own purposes.
Affiliates: We may disclose your information with our affiliates, subsidiaries, and representatives as part of our relationship with you.
Other Employees, Contractors, and Applicants: Content you post on our systems may be displayed to other Employees, Contractors, and Applicants as appropriate.
Our Business Partners: We may disclose relevant Personal Information with our business partners, for example to provide you with offers and discounts for products and services that may interest you.
See the tables above for more details about how different categories of Personal Information are disclosed.
We do not sell Personal Information to anyone. We do not share Personal Information for advertising purposes.
Exercising Your Personal Information Rights
California Employees, Contractors, and Applicants have the following rights under California Privacy Law:
The right to know the Personal Information we have collected about them, including the categories of sources from which we collected the Personal Information, the purpose(s) for collecting, selling, or sharing your Personal Information, and the categories of third parties to whom we have disclosed your Personal Information;
The rights to access, correct, or delete Personal Information;
The right to obtain a portable copy of Personal Information;
The right to limit the use of Sensitive Personal Information and opt-out through “limiting the use of my personal information” in certain circumstances;
The rights to opt-out of the sharing of Personal Information for behavioral advertising, targeted advertising, sales of Personal Information, use of automated decision-making, or certain profiling. This includes response to access requests to include meaningful information about the logic involved in those decision-making processes, as well as a description of the likely outcome of the process with respect to the consumer;
The right not to receive discriminatory treatment for exercising privacy rights; and
The right to be notified, before, or at the time personal information is collected, the type of personal information collected, and what we may do with that information.
If you are a California Employee, Contractor, or Applicant, you can submit a request to exercise your Personal Information rights under California Privacy Law by sending an email to your HRBP, sending an email to [email protected], or calling our toll-free number at 866-223-4395. To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will use commercially reasonable efforts to verify your identity for this purpose. Any information you provide to authenticate your identity will only be used to process your rights request. Please be aware that we do not accept or process rights requests through other means (e.g., via fax or social media).
After submitting your request, we will verify your identity by requesting your full name, email address, and sending an email to the email address provided with a link to click. Requests to opt-out of marketing do not require verification. If you do not complete the verification process, we may be unable to process your request. It is important that you provide a valid email address in order for us to be able to process your request. Any information you provide to authenticate your identity will only be used to process your rights request and not for any other purpose. Please be aware that we do not accept or process rights requests submitted through other means.
We will confirm receipt within 10 business days and respond to your rights request within 45 days (or 15 days for requests to opt-out of the sale of Personal Information, requests to opt-out of targeted advertising, and requests to limit the use of Sensitive Personal Information), though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions.
You can make a request up to twice a year, free of charge. We reserve the right to decline to process, or charge a reasonable fee for, requests from an Employee, Contractor, or Applicant that are manifestly unfounded, excessive, or repetitive.
Notice of Right to Limit the Use of Sensitive Personal Information
You have the right to limit some uses of Sensitive Personal Information. You may direct Achieve not to use Sensitive Personal Information except as necessary to provide goods or services you have requested or other exempt purposes.
However, we only use Sensitive Personal Information for purposes that are exempt from this right, such as to provide you with goods or services you have requested, to detect and prevent security incidents, or verifying the quality of our goods and services. The full list of these exempt purposes are specified in California Code of Regulations, Title 11, Section 7027(m).
Children’s Data
We do not knowingly sell or share for targeted advertising the Personal Information of California residents under 16 years of age.
We comply with the Children’s Online Privacy Protection Act (“COPPA”), in addition to California privacy law, with respect to any Personal Information we collect or use from children under the age of 13.
Limiting the Use of Sensitive Personal Information
California Privacy Law provides a right to limit some uses of Sensitive Personal Information. In particular, you may direct Achieve not to use Sensitive Personal Information and to opt-out through limiting the use of your personal information except as necessary to provide goods or services you have requested.
You may submit a request to limit the use of your sensitive Personal Information by submitting a rights request as described above.
Authorized Agent Requests
California Privacy Law allows you to designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above. We may require verification of your authorized agent in addition to the information for verification above for Employees, Contractors, and Applicants and households.
Contact Us
If you have any questions or concerns regarding this California HR Privacy Notice, contact us at [email protected].
