Last Updated: January 1, 2020
Use of our Site is strictly limited to persons who are of legal age in the jurisdictions in which they reside. You must be at least eighteen (18) years of age to use our Site. If you are not at least 18 years of age, please do not use or provide any information through this Site.
II. Personal Information We Collect, From Where, And Why
The following is a description of: (i) the categories of non-public Personal Information we may have collected in the preceding 12 months; (ii) the sources from which we may have collected it; and (iii) the business purposes for which we may have collected it.
A. Information that you provide to us directly.
If you contact or correspond with us, we may keep a record of your contact information and correspondence, and we reserve the right to use your contact information, and any other information that you provide to us in your message, to respond thereto. We may use this Personal Information to further correspond with you, to accept payments on your account, or to otherwise manage your account with us.
If you wish to change or correct any information voluntarily submitted to us, please do so by contacting us in the manner described, below.
Please note that all communications between us are with a debt collector, in an attempt to collect a debt. Any information obtained will be used for that purpose.
B. Information provided to us by others acting on your behalf.
We may also receive and maintain Personal Information (e.g., name, address, telephone number, email address, social security number, account numbers, financial information, etc.) contained in communications with parties other than a consumer, such as a consumer’s spouse, power of attorney, authorized representative, or the consumer’s attorney in connection with the collection of any debt.
C. Information we receive from creditors that we service and represent.
We receive and maintain Personal Information regarding consumer accounts receivable within the accounts that we service for our clients. This information is either provided directly by our clients or an agent acting on their behalf. This information usually includes the consumer’s name, consumer’s social security number, information contained on credit applications, the original creditor’s account number, the balance of the account, and the last date a payment was received on the account. We use this information to seek the collection and recovery of those accounts receivable and to fulfill our responsibilities as a debt collection law firm to our clients.
D. Information we receive from our Service Providers.
We use Service Providers to assist us with our business activities. Such Service Providers may include location service providers, process servers, and other vendors that assist us in conducting business. We may receive and maintain Personal Information from Service Providers and Collection Service Providers that we contract with to assist us in recovering accounts. This information includes letter correspondence, email communications, and call recordings with consumers.
E. Information we receive from Credit Reporting Bureaus.
We receive and maintain Personal Information provided by one or more of the major Credit Reporting Bureaus. We use this information to seek the collection and recovery of those accounts receivable and fulfill our responsibilities as master servicer to our clients.
F. Information collected by your use of this Site
However, like most other websites, our Site automatically collects certain other information and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of RLG’s website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
(i) Your IP Address
Like most websites, each time you visit our Site, we may automatically collect your internet protocol (IP) address and the web page from which you came. In order to administer and optimize the Sites for you and to diagnose and resolve potential issues with or security threats to our Site or the company, we may use your IP address to help identify users and to gather broad demographic information about them.
(ii) Cookies, Pixel Tags, and Web Beacons
Our web pages may also incorporate “pixel tags,” “web beacons,” or similar tracking technologies (collectively, “pixel tags”) that allow us or our agents to track the actions of users of the Site. Pixel tags are used to collect information, such as the name of your Internet service provider, the IP address of the computer you are using, the type of browser software and operating system that you use, the date and time you access the Site, the website address, if any, from which you linked directly to the Site, the website address, if any, to which you travel from the Site and other similar traffic-related information.
We may also aggregate your information with similar data collected from other users to help us improve the Site and the services that we provide through the Site.
(iii) Do Not Track
Our Site tracks when visitors to our website enter through a marketing landing page. The Site also keeps a record of third party websites accessed when a user is on the RLG website and clicks on a hyperlink. But we do not track users to subsequent sites and do not serve targeted advertising to them.
(iv) Analytics Information
The web servers that serve the Site may gather certain navigational information about where visitors go on our Site and information about the technical efficiencies of our Site and services. In the process of gathering navigational information, anonymous information may be collected which will provide information regarding a visitor’s use of our Site. Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, a particular individual. Examples of anonymous information may include information about your Internet browser, domain type, service provider and IP address information collected through tracking technologies and aggregated or de-identified data. We use this information to operate, maintain, and provide to you the features and functionality of the Site.
III. Personal Information That We Share With Others
A. No Sales of Information to Third Parties for their Own Use.
B. Sharing Information with Affiliates and Service Providers That Help Us Perform Our Business Activities.
We may share your non-public Personal Information and other information that we have collected with our affiliates and Service Providers.
Service Providers are persons and entities that we contract with to provide us a material service in connection with debt buying and collection activities and to assist us with recovering accounts for our portfolio clients. Our Service Providers include law firms, collection agencies, accounts receivable management companies, data service providers, and technology.
In connection with providing these business services to RLG, one or more of our Service Providers may have access to your non-public Personal Information. This Personal Information will not be used for any purpose other than as reasonably necessary to perform a business purpose that we authorize, and it will not be further used by the Service Provider or disclosed to any Third Party.
C. Sharing Information with Third-Parties at Your Direction.
We may share your non-public Personal Information with Third Parties to whom you or your agents authorize us in advance to intentionally disclose to or allow to use your Personal Information in connection with services that we provide.
D. Sale of our Company or Company Assets
In the event of a sale, assignment or transfer of our assets or of any portion of our business, we reserve the right to transfer any and all information that we collect from individuals, or that we otherwise collect in connection with the Site, to unaffiliated third-party purchasers.
E. Monitoring, Enforcement and Legal Requests
RLG has no obligation to monitor the Site or the use of the Site or to retain the content of any user session. However, we reserve the right, at all times, to monitor, review, retain and/or disclose any information, including non-public Personal Information, as may be necessary to satisfy any applicable law, regulation, legal process or governmental request or to cooperate with law enforcement and other authorities.
We may also use IP addresses to identify a Site user when we feel it is necessary to protect the Site, our service, clients, potential clients or others.
F. Our Internal Use and Research
RLG reserves the full and unrestricted right to use and disclose de-identified information; anonymized information; aggregated information or publicly available information that has not been combined with nonpublic Personal Information for purposes including, but not limited to, RLG’s own internal use, data mining, and research. We may also use non-personal information about portfolio accounts to assist our clients with the acquisition of and disposition of certain portfolio accounts at the end of their lifecycle.
IV. Other Sites/Third Party Links
V. Protection Of Your Personal Information
RLG is committed to protecting your privacy. We will take reasonable security procedures and practices appropriate to protect Personal Information provided to us through the Site or that we otherwise collect from loss, misuse, unauthorized access, disclosure, alteration and destruction. Our data security and privacy policies and practices are periodically reviewed and modified as necessary.
VII. Contact Us With Questions
VIII. CALIFORNIA RESIDENTS: Summary Of Consumer Rights Under The California Consumer Privacy Act (“CCPA”)
The California Consumer Privacy Act (CCPA) took effect on January 1, 2020. The CCPA grants new privacy rights to California consumers, including:
- The right to know what personal information is collected, used, shared or sold, both as to the categories and specific pieces of personal information;
- The right to delete personal information held by businesses and by extension, a business’s service provider;
- The right to opt-out of the sale of personal information. Consumers are able to direct a business that sells personal information to stop selling that information. Children under the age of 16 must provide opt in consent, with a parent or guardian consenting for children under 13; and
- The right to non-discrimination in terms of price or service when a consumer exercises a privacy right under CCPA.
A business subject to the CCPA that collects a California consumer’s personal information must, at or before the point of collection, inform the consumer as to the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
A covered business must disclose and deliver the personal information the business collected about the consumer in response to a verifiable consumer request.
For purposes of the CCPA, “Personal information” does not include:
- Publicly available information from government records;
- De-identified or aggregated consumer information; or
- Information excluded from the CCPA’s scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
A further summary of consumer rights provided by the CCPA follows.
B. Right to Know.
A business that collects personal information must also disclose, in response to a verifiable consumer request, the following:
- The categories of personal information the business has collected about the consumer;
- The categories of sources from which that personal information is collected;
- The business or commercial purpose for collecting or selling personal information collected from consumers;
- The categories of third parties with which the business shares personal information;
- The specific pieces of personal information the business has collected about the consumer making the request;
A business that sells a consumer’s personal information or discloses a consumer’s personal information for a business purpose must disclose the following in response to a verifiable consumer request:
- The categories of personal information the business has collected about the individual consumer
- The categories of personal information the business has sold about the consumer and categories of third parties to which the personal information was sold by category or categories of personal information for each third party to which the personal information was sold. Or, if the business has not sold any consumer personal information, it must state that fact)
- The categories of personal information the business has disclosed about the consumer for a business purpose. Or, if the business has not disclosed any consumer personal information for a business purpose, it must state that fact.
C. Right to Deletion.
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. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an 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 contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
D. Right to Non-Discrimination.
A business must not discriminate against a consumer who exercises any of the consumer’s rights under the CCPA. However, a business may charge different prices or provide a different quality of goods or services if the difference is reasonably related to the value provided to the consumer by the consumer’s data and may offer financial incentives to a consumer for the collection, sale, or deletion of personal information on a prior opt-in consent basis.
E. Right to Opt-Out.
A business that sells consumers’ personal information to third parties needs to provide notice to consumers thereof and that consumers have the right to opt out of the sale of their personal information. A business must provide a “Do Not Sell My Personal Information” link on its Internet homepage that links to an Internet webpage that enables a consumer to opt out of the sale of the consumer’s personal information.
A business must not sell the personal information of consumers if the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers between 13 and 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s personal information.
- Consumers’ rights under the CCPA, including the consumer right to opt out of the sale of the consumer’s personal information and a separate link to the “Do Not Sell My Personal Information” Internet Web page;
- The methods for submitting consumer requests; and
- A list of the categories of personal information that the business has collected about consumers, sold about consumers, and disclosed about consumers for a business purpose in the preceding 12 months
IX. CALIFORNIA RESIDENTS: How To Make A CCPA Consumer Rights Request.
A. Instructions for Submitting a CCPA Consumer Rights Request to Us
If you wish to exercise any of the CCPA consumer rights summarized above, such as a Request to Know or a Request to Delete Personal Information, you can do so in one of the following ways:
- Click on this link to complete and submit the referenced form;
- Call us toll-free at 1-877-440-0860; or
- Reach us by email or U.S. mail at:
Resurgence Legal Group, P.C.
ATTN: Chief Compliance Officer
3000 Lakeside Dr.
Bannockburn, IL 60015
Upon receiving a verifiable request to know or a request to delete, we will confirm receipt of the request within ten (10) days and provide some information about how we will verify and handle the request, and by when you should expect to receive a response.
Please note that you may only make a verifiable consumer Request to Know or Request to Access your data under the CCPA two times within any 12-month period.
B. Verification Of The Person Making A Consumer Rights Request.
Of course, we need to be reasonably sure that the person making the request is actually you! So, we may need some information from you to verify that you are the person whose Personal Information you are asking to know about or to delete. Accordingly, a verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We 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. Making a verifiable consumer request does not require you to create an account with us. We will only use any personal information provided in a verifiable consumer request to verify your identity or authority to make the request.
C. Designating An Authorized Agent to Make A Consumer Rights Request for You.
Only you or a person registered with the California Secretary of State that you designate and authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. For your protection, we will need to first see some proof that someone seeking to act on your behalf is actually authorized by you to do so. You may also make a verifiable consumer request on behalf of your minor child.
D. Response Timing and Format.
We will try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we need more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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.
If you are making a Request to Delete your Personal Information, we will re-confirm with you that you really want your information deleted after verifying your request.
If we cannot respond to or comply with your Request to Know or Request to Delete, say because we cannot verify your identity or because an exception applies, we will explain the reasons we cannot comply with your request. 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.