Last modified February 15, 2013

INTRODUCTION

This privacy policy (“Privacy Policy”) applies to the web site www.bcc-chicago.com and such other websites owned and/or operated by Bonded Collection Corporation, BCC Collection Services and/or BCC Financial Services (“Company”, “we”, “us”, “our”) (collectively, the “Sites”) however accessed and/or used, whether via personal computers, mobile devices or otherwise. This Privacy Policy only covers the Sites and does not cover any information otherwise collected by us (such as, without limitation) in the “real world” [offline] or at any other web site whether or not owned by us.

The purpose of this Privacy Policy is to clearly and concisely inform users of and visitors to (“you” or “your”) the Sites of: (1) the information that we collect through the Sites; (2) how we use that information; (3) how we protect that information; (4) what, if any, information we may share and with whom; (5) and how you can review your Personally Identifiable Information (“PII”) collected through the Sites and request modifications and corrections. Please take a moment to read this Privacy Policy to learn how we handle your personal information.

This Privacy Policy also applies to interactive features and/or downloads that we own and/or operate and that are available through the Sites. This Privacy Policy also applies to interactive features or materials that interact with the Sites and post this Privacy Policy.

This Privacy Policy is further subject to the Terms of Use.

INFORMATION WE COLLECT:

We collect personal information when you sign-up as a client, request services (such as through electronic mail), and when you otherwise provide us with your information. We collect only personal information which you provide to us or authorize to be provided to us and only that which is reasonably necessary to provide you with requested services, maintain your account, provide you excellent customer service and communicate with you regarding services ordered.  Additionally, we may use your personal information to communicate with you about special services, offers, and updates. During your visits to the Sites, we may use cookies, a passive tracking technology used solely during your visit(s).  Company cookies are non-persistent cookies, only record statistical data during your visit to allow for full site functionality and no information gathered by such cookies is retained after your session ends.

Important Information for Debtors: We understand that falling behind on financial obligations can be extraordinarily stressful and difficult to navigate. Any interaction with us is an attempt to collect a debt and information provided by you to us may be used for such purposes.  That said, we strive to provide Debtors the opportunity to facilitate payment of debts owed through the Sites.  In addition to information that you may provide directly to us, we may collect personal information about you from your creditors and/or from third parties/publicly available information.

Additional Services – Underwriting Program: Company may from time to time act as a third-party facilitator between medical professional providers/users  and Connexus Credit Union as further discussed in the Terms of Use.  For those using these services, Company provides a mechanism through the Sites for medical professionals to directly transmit through the Sites information that you may share with such provider (we do not provide such information) for purposes of medial credit underwriting.  Company does not capture or store such information except as necessary for the functioning of the service(s). YOU ARE SOLELY RESPONSIBLE FOR ANY PERSONAL INFORMATION THAT YOU MAY SHARE WITH YOUR MEDICAL PROVIDER OR OTHERS FOR PURPOSES OF USING THIS SERVICE(S) OR ANY PERSONAL INFORMATION THAT YOU MAY SHARE WITH ANY THIRD PARTY.

When you use the Underwriting Program, you will be giving information about your credit to your healthcare provider.  YOU SHOULD ENSURE THAT YOU HAVE READ AND RECEIVED A COPY OF YOUR RIGHTS UNDER THE HEALTH INFORMATION PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA”) and your provider’s privacy and other policies. The information entered into the Sites by your provider is maintained only to allow the provider to communicate with Connexus and is not maintained for any other purpose.  Your rights with respect to your medical information are governed by HIPAA and the policies and procedures of your individual provider.  Your use of the Underwriting Program will be governed by a separate agreement between you and your provider.

HOW WE MAY USE AND SHARE YOUR INFORMATION:

To insure our clients and users of our company’s commitment to legal compliance, Company has enacted written policies and internal controls within our collection procedures to comply with various United States Codes and Acts governing the privacy, handling and dissemination of consumer information, including, without limitation the Gramm-Leach Bliley Act (“GLB”), Regulation P, and the Fair Debt Collection Practices Act (“FDCPA”).  We will not use your PII in violation of applicable law.

We may use the information that we collect about you: (1) to provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Sites’ features; (3) to process service requests, which may include email verification; (4) to improve the Sites or our services, to customize your experience on the Sites, or to serve you specific content that is most relevant to you; (5) to contact you with regard to your use of the Sites and, in our discretion, changes to the Sites and/or Sites’ policies; (6) to comply with court orders, valid subpoenas, and/or other applicable laws and regulations; (7) for our business purposes, including in the event of a business transfer; and (8) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy

HOW WE PROTECT YOUR INFORMATION:

Company uses industry standard Secure Sockets Layer encryption on all web pages where personal information is required or where stored. Additionally, we urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. We do everything reasonably possible to protect your information transmitted via the Internet. However, since no transmissions over the Internet or through other content/information sharing devices (such as a smart phone or a tablet) can be absolutely secured, WE DO NOT WARRANT OR REPRESENT THAT WE CAN GUARANTY THE SECURITY OF ANY INFORMATION THAT YOU TRANSMIT TO US AND YOU USE THE SITES AND PROVIDE SUCH INFORMATION SOLELY AT YOUR OWN RISK. In the event of a data or security breach in which your PII may be compromised, we make commercially reasonable efforts to notify you and/or the requisite governmental or other regulatory agency promptly and as required by law.

COMMUNICATING WITH YOU AND ADDITIONAL SECURITY INFORMATION

Bonded Collection Corporation utilizes the latest technology available to increase the service level and effectiveness in debt recovery.

Client Communication:

Most communication with our clients is performed via phone conversations. However, lately many of our clients appreciate the benefits of communicating over the internet:

Bonded Collection Corporation uses electronic mail on a regular basis to communicate with the clients we serve. All client service representatives and managers have e-mail accounts that are checked on a regular basis.

Request for all of our standard reports can be submitted through our website, via a password protected screen. Most requests can be filled via an e-mail response, with attachment if needed.

Clients have the ability to view all the active accounts placed with Bonded by dialing into our system at any time. The security we have in place will give our clients access to their accounts only. Clients can review the notes and activities on an individual file since being placed at our agency – clients can even leave a comment on the file for the actual collector to see!

Remote access can only occur after the proper security is set-up, but overall it is safe and simple – all you need is a PC and modem.

Debtor Communication:

Email communication with consumer debtors is only performed with their EXPRESSED PERMISSION (verbal, written, or e-mail.)

In some cases, especially in our commercial collection area, the use of e-mail for communication has proven very efficient to bring an account to resolution.

File Exchanges/Business Placement:

Bonded receives placement of accounts from our clients in many different formats and mediums. Manual placements (copies of over-due invoices) are still favored by many of our existing clients. Other options available include:

Data transfer of information on diskette

E-mail of information

Place of files directly on Bonded’s FTP server

EDI transmission of industry standard formats through our VAN (i.e. Motor Carrier Standard 210 invoice.)

Bonded has a static IP address which can be positively identified in the event a client wants us to retrieve/place files on their FTP server

Some clients choose to employ PGP Encryption prior to transferring files. Bonded Collection Corporation is equipped to comply with this procedure if the need arises.

Bonded prides itself on working closely with our clients to derive the best solution (for both parties) for data exchange.

Bonded employs data programmers to convert data in your standard format to the record layout needed by our collection management software. Start-up cost of this nature are the responsibility of Bonded Collection Corporation.

Security:

Bonded treats information technology security as an extremely serious topic. Security precautions include the following:

Firewall protection limiting access to our network by “hackers”

The network containing confidential debtor account information is segregated from our internal PC network and

Manager and Client Services representatives are educated on the use of PGP encryption for exchanges of sensitive data over e-mail.

Verisign is utilized as our web security provider for our BCC Webpay feature which allows your customers to make payments over our website.

CHILDREN

Company does not knowingly solicit personal information from children or send children requests for personal information.  The Sites are intended for a general audience over the age of 18 only. We do not knowingly collect information from children under the age of eighteen [18] and we will delete any PII collected that we determine to be of a child less than eighteen [18] years of age. If you are not at least age 18, you are prohibited from using the Sites!

REVIEW AND CORRECTIONS TO YOUR PII

You are solely responsible for the accuracy and content of any personal information which you submit to the Sites (or which may be collected by the Sites pursuant to this Privacy Policy).  If you wish to review your PII stored by Company and make any legitimate corrections, please contact Company: (1) By electronic mail to – customerservice@bccfs.com; or (2) by postal mail to – ATTN: Privacy Policy, Bonded Collection Corporation, 2400 E. Devon Avenue, Suite #257, Des Plaines, IL 60018

YOUR ACCEPTANCE OF THIS POLICY

By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Sites. Your continued use of the Sites following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy as we deem reasonable and appropriate without notice to you. Any changes to the Privacy Policy will apply as soon as they are posted; however, we will not use your PII in a manner that is materially different from what was stated in the Privacy Policy at the time you shared the information. The  “last revised” date at the beginning of this Privacy Policy reflects the date of the most recent changes to the policy. We encourage you to check the “last revised” date whenever you visit the Sites (or as often as you feel appropriate) to see whether or not changes have been made to this Privacy Policy.