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PRIVACY LAWS

CMRE Financial Services, Inc. is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy applies to the CMRE Financial Services, Inc. site and governs data collection and usage. By using the CMRE Financial Services, Inc. site, you consent to the data practices described in this statement. This Statement does not apply to information collected by or through websites, applications, or content operated by any third party.

Collection of your Personal Information

CMRE Financial Services, Inc. ("CMRE, "we," "our," or "us") collects personally identifiable information, such as your email address, name, home or work address, telephone number, or other personally identifiable information you provide to us through submitting online forms or communicating with us. We also collect anonymous demographic information about you but does not identify you, such as your ZIP code and age.

CMRE also automatically collects certain information about your equipment and browsing patterns that does not identify you when you visit our family of websites. This information can include, for example: your IP address, browser type, operating system, domain names, access times, and referring website addresses. This information is used by CMRE for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the CMRE site. There may be features that are developed in the future that may result in the collection of additional new information. We do not allow third parties to collect personally identifiable information about a user's online activities over time and across different sites, services, and applications, when that user uses our site or service. We do not respond to Do Not Track signals because we do not track personal information about a user's online activities over time and across third party websites or services.

CMRE keeps track of the websites and pages our users visit within the CMRE family of websites in order to determine what CMRE services are the most popular.

CMRE encourages you to review the privacy statements of websites you choose to visit from our site so that you can understand how those websites collect, use, and share your information. CMRE is not responsible for the privacy statements or other content on websites outside of the CMRE family of websites.

Use and Disclosure of your Personal Information

CMRE collects and uses personal information we collect about your or that you provide to us:

  • To present our website and its contents to you.
  • To provide you with information or services that you request from us.
  • To offer and fulfill our core business purposes.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us or an owner of an applicable account, including for billing and collection.
  • To notify you about changes to our website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

CMRE does not sell, rent, or lease its customer lists or your personal information to third parties. CMRE may disclose aggregated or deidentified information about our website users that does not identify any individual without restriction. We may disclose personal information that we collect as described in this Statement:

  • To contractors, service providers, and other third parties we use to support our business, such as creditor clients, insurers, payment processor vendors, mailing vendors, consumer reporting agencies, and information technology providers, who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • Pursuant to a merger, acquisition, or sale of all or a portion of CMRE's assets.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CMRE or others.

CMRE does not disclose information to any in party in violation of the Fair Debt Collection Practices Act.

Security of your Personal Information

CMRE utilizes appropriate physical, electronic, and procedural safeguards to secure your personal information (including any social security numbers if applicable) from unauthorized access, use, or disclosure. When personal information is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. To further safeguard this information, access to sensitive information such as any social security numbers is limited, and our employees must abide by standards of conduct and confidentiality agreements.

Requesting Access or Changes to Your Information

You can make changes to personally identifiable information we collect from you by one of the following methods;
Calling us at (877) 650-6130
Emailing us at myinfo@cmrefsi.com

Changes to this Statement

CMRE Financial Services, Inc will occasionally update this Statement of Privacy to reflect company and customer feedback. CMRE Financial Services, Inc encourages you to periodically review this Statement to be informed of how CMRE Financial Services, Inc is protecting your information.

Changes of Ownership or Control of CMRE Financial Services, Inc.

We may transfer, combine, merge, or sell all or part of our business to another entity or entities. If such an event occurs, personal information CMRE has collected or maintained may be transferred to a new controlling party or parties, who will be permitted to use your personal information under the terms of this Statement of Privacy for the purposes for which you supplied it.

Contact Information

CMRE welcomes your comments regarding this Statement of Privacy. If you believe that CMRE has not adhered to this Statement, please contact CMRE at myinfo@cmrefsi.com. We will use commercially reasonable efforts to promptly determine and remedy the problem.

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 Statement of Privacy. Any terms defined in the CCPA and applicable California Attorney General regulations have the same meaning as used in this Privacy Policy Notice.

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, including: name, DOB, address, gender, account number, religious affiliation, previous payment and other financial information, email address, insurance information, SSN, employment information, telephone number, IP address, military or veteran status, medical information, audio information, username, and information collected or shared pursuant to HIPAA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws. We also may collect additional categories of personal information users provide directly to us or our service providers.

2. How Your Personal Information is Collected

We collect most of this personal information from our clients or from you or your authorized representative by telephone or written communications. However, we may also collect information:

  • From publicly accessible sources (e.g., property records or court records);
  • From our service providers (e.g., call analytics, skip-tracing, payment processing, 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, SSN, employment information, telephone number, IP address, military or veteran status, audio information, username, and information collected or shared pursuant to HIPAA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws.

We have not sold 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 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

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.

For applicable personal information access and 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.

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;
  • Provide the requested information disclosure to you more than twice in a 12-month period.
  • Provide the requested information disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person's behalf; or
  • Provide the requested information disclosure 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 we delete personal information about you that we collected from you and retained, subject to certain exceptions.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and the relevant 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.
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • 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 submit verifiable requests for information or deletion described herein by calling us at (877) 650-6130 or by email at myinfo@cmrefsi.com.

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.

We are not obligated to make an information disclosure or carry out a deletion request pursuant to the CCPA if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person's behalf.

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: February 5th, 2020

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