Privacy Policy

This is the online privacy policy (the “Policy”) for UnitedSettlement.com (the “Site”) owned and operated by United Debt Settlement, LLC (“us”, “we”, or “our”). This Policy is designed to tell you about our practices regarding collection, use, and disclosure of information that you may provide via this Site and certain related services we provide you (the “Services”).

Please read this Policy carefully to understand how we collect and use your Personal Information, the choices you have for controlling your Personal Information and the circumstances under which we may share such information with others. This Policy forms part of the Terms that govern your use of the Site and Services. Notwithstanding, nothing in this Policy, the Terms, or any other agreement with us limits or waives any rights you may have under applicable privacy or data protection laws.

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1. Agreement to this Policy

By using the Site or Services, you consent to this Policy, including your consent to our use and disclosure of your Personal Information as detailed in this Policy. We may update this Policy periodically; the “Last Updated” date will reflect changes. Continued use after changes constitutes acceptance of the revised Policy.

2. What information is subject to this Policy?

A. Personal Information

“Personal Information” refers to any information, in any form, about an identified or identifiable individual or household, including an individual or household whose identity may be inferred or determined from such information.

We may collect the following Personal Information about you: name, address, email, phone number, birthdate, gender, communication preferences, location data, employment data, IP address, browsing history, transaction history, account information, and information from communications with us.

B. Sensitive Personal Information

“Sensitive Personal Information” is a more sensitive subset of Personal Information.

We may collect the following categories of Sensitive Personal Information: Identification numbers (SSN, driver’s license, passport), financial account credentials, precise geolocation, racial/ethnic origin, citizenship/immigration status, gender (where considered sensitive), credit profile information, and exact contents of certain communications.

Unless expressly stated otherwise in this Policy, we refer to Personal Information and Sensitive Personal Information together as “Personal Information.”

C. What is not Personal Information?

Personal Information does not include the following: publicly available information; de-identified or aggregated consumer information; or information exempted from applicable state privacy laws, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Reporting Act (“FCRA”), or health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), etc.

D. Non-Public Personal Information (“NPI”)

NPI is non-public information collected by financial institutions under the Gramm-Leach-Bliley Act and certain state laws, including information consumers provide to obtain financial products/services, transaction results, or information obtained in connection with providing financial products/services.

3. Do we collect NPI?

Yes. As a company that conducts activities that are financial in nature, we are a “financial institution”, as that term is defined by the GLBA, and certain of the information we collect from, or about, you qualifies as NPI. If you utilize our financial products and services, we will use and share any information that we collect from, or about, you in accordance with our Gramm-Leach-Bliley Act Privacy Policy, which offers you certain choices with respect to the use and sharing of your personal information.

4. How do we collect Personal Information?

We collect only the Personal Information that is reasonably necessary and proportionate to our legitimate business purposes.

We collect Personal Information:

• Directly from you when you use the Site or Services
• Automatically via cookies and similar technologies (see Cookie Policy)
• From third parties including affiliates, service providers, social media platforms, online databases, and marketing data providers. We may also purchase marketing data about our customers from third parties and combine it with the Personal Information or Sensitive Personal Information our customers provide us, to offer advertising and products from our company.

5. Why do we collect your Personal Information?

We collect Personal Information to operate and provide the products and Services you purchase, to provide you with a customized Site experience, and to notify you of other products or services that you may be interested in.

We may collect and use your Personal Information for any of the following purposes:

• Manage your account and preferences
• Communications with you
• Customer support with the Site or the Services
• Process transactions or perform the Services
• Ensure safety, security, and fraud prevention
• Personalize your experience
• Conduct marketing and send advertisements
• Manage and Improve the Site and our Services
• Meet legal and compliance obligations
• Conduct research on user demographics and behaviors

Personal Information collected for one purpose may also be used for any of the other purposes listed above.

6. Who do we share your Personal Information with?

We will share your personal information with third parties only in the ways that are described in this Policy or the Gramm-Leach-Bliley Privacy Policy.

We may share your Personal Information with third parties for the purpose of allowing them to provide information about products and services that we think will be of interest to you. By providing your Personal Information on or through the Site, or in connection Services, you agree that we may buy, sell, rent, lease, share, or provide your Personal Information to other trusted third-parties.

You have the right to opt out of such sharing at any time as described in the How Do You Opt Out of Data Sharing? section, below.

We may share your Personal Information with the following third parties:

• Service Providers who operate the Site (including webhosting and Site maintenance), provide customer relationship management services, provide the Services, assist with data storage or management, or assist with marketing/research. We provide our Service Providers with only the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure.
• Ad Networks who provide advertisements about goods and services that may be of interest to you. Advertisements may be shown via the Site, the Services, or third-party sites. These companies may place or recognize a unique cookie on your computer or use other technologies such as web beacons (see Cookie Policy). This Policy does not cover any use of information that an Ad Network may collect from you. It also does not cover any Personal Information that you may choose to provide to an Ad Network or to an advertiser whose goods or services are advertised through the Site.
• Business Affiliates and Partners who control, are controlled by, or are under common control with us. If our company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information in connection with such transaction.
• Financial Institutions including credit card issuers, lenders, banks, or other parties as necessary to provide the Services.
• Legal Personnel, including our attorneys, law enforcement, courts, and regulatory bodies when legally required or to protect rights.

7. How do we use and share your Personal Information?

In the past twelve (12) months, we have collected and shared Personal Information for the following purposes and with the following third parties:

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to the third parties listed above for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category C: Protected classification characteristics under California or federal law.
• Category D: Commercial Information
• Category F: Internet or other similar network activity
• Category G: Geolocation Data
• Category L: Sensitive Personal Information

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to the third parties listed above for marketing or cross-context behavioral advertising purposes.

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category D: Commercial Information.
• Category F: Internet or other similar network activity
• Category G: Geolocation Data

8. What are your rights and choices?

If you live in California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the rights and/or choices described in this section:

• Right to access: The right for a consumer to access from a business/data controller the information or categories of information collected about a consumer, the information or categories of information shared with third parties, or the specific third parties or categories of third parties to which the information was shared; or, some combination of similar information. Some states, like California, allow you to make two requests per year, free of charge.
• Right to correct: The right for a consumer to request that incorrect or outdated Personal Information be corrected but not deleted.
• Right to Delete: The right for a consumer to request deletion of Personal Information about the consumer under certain conditions.
• Right to opt out of certain processing: The right for a consumer to restrict a business’s ability to process certain types of Personal Information about the consumer, such as the right to opt out of sharing of Sensitive Personal Information or profiling, where applicable.
• Right to portability: The right for a consumer to request Personal Information about the consumer be disclosed in a common file format.
• Right to opt-out of sales or sharing: The right for a consumer to opt out of the sale of Personal Information about the consumer to third parties.
• Right to limit the use of Sensitive Personal Information: You may have a right to limit our use of Sensitive Personal Information for any purposes other than to provide the Services or goods you request or as otherwise permitted by law.
• Right against automated decision making: A prohibition against a business making decisions about a consumer based solely on an automated process without human input. We do not engage in automated decision making, including profiling, that produces legal or similarly significant effects concerning consumers as defined under applicable state privacy laws.
• Right to appeal: Where a controller declines to take action regarding a consumer’s request to exercise any privacy right, the controller must allow the consumer to appeal the decision and provide instructions on how they may request an appeal.
• Private right of action: Some states give you the right to seek civil damages from us for violations of data privacy laws.
• Right to withdraw consent: You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on your consent before its withdrawal.
• Right of Non-Discrimination: You have a right to exercise your rights under this section free of discrimination. We will not discriminate against you in any way if you choose to exercise your rights under this section.

Please Note: These rights do not extend to Personal Information that is exempted from your state’s applicable privacy laws. For NPI and other information exempted from state privacy laws under the GLBA, please see our Gramm-Leach-Bliley Act Privacy Policy for more information about how we use and process your information and your rights.

9. How do you opt out of data sharing?

A. Opt Out Request Form

Submit opt out requests through our Data Request Form.

B. Universal Opt Out Mechanism

Where required by applicable law, we honor Global Privacy Control (GPC) and other legally recognized universal opt-out signals as valid requests to:

• Opt out of the sale of Personal Information
• Opt out of sharing Personal Information for cross-context behavioral advertising
• Limit the use of Sensitive Personal Information

Such signals apply to the browser or device transmitting the signal and may need to be renewed if you change devices, browsers, or clear cookies.

C. Personal Information Shared with Third Parties

Opt-out requests apply prospectively only and do not affect Personal Information you provided before opting out that was already shared with applicable third parties in accordance with this Policy. If we have already shared your Personal Information with third parties, their use of that information is governed by their own privacy policies and opt-out procedures, for which we are not responsible. To opt out or exercise your rights with respect to information already shared with third parties, please follow the instructions in those third parties’ applicable privacy policies.

10. How do you make a request to exercise your rights or choices?

A. How to make a Request

To exercise your rights or to make an inquiry, please visit our Data Request Form or you can contact us using any of the methods listed in the Contact Us section.

We may verify your identity before processing requests. Verification information is used only for verification, security, or fraud-prevention and deleted after processing.

B. Our Response to Requests

We will confirm receipt of your request within 10 business days. In general, we will respond within 45 days of our receipt of your request. If we need more time to respond, we will let you know the reason for the additional time and may take up to another 45 days to respond.

C. Authorized Agents

You may designate an authorized agent to exercise your rights on your behalf. We require verification of the agent’s authority and may require attestation under penalty of perjury. Without power of attorney, we also require you to verify your identity.

D. What to do if you disagree with our decision

If we deny your request, you may appeal by contacting us (see Contact Us section) with your name, email, request type, appeal reason, and original request reference.

11. What is Our Cookie Policy?

A. Cookies Explained

We use tracking technologies (“Cookies”) including cookies, pixels, and tracking scripts to collect, store, and track information about you and your use of the Site or Services.

We may use the following tracking technologies on our Site or in providing the Services:

• Cookies: Small text files stored on your device for months; deletable through browser settings. Cookies can be stored on your device for months, but you can choose to delete cookies stored on your device at any time through your browser settings.
• Pixels/Web Beacons: Tags on web pages/emails recording activities; stop tracking when you navigate away. We may also allow some third parties to place web beacons on our Site or in our communications. Pixels are not stored on your device and will stop tracking you once you navigate away from the Site.
• Tracking Scripts: Small piece of code, typically in JavaScript, monitoring user behavior, such as page visits, time spent on pages, clicks, and device information. Tracking scripts usually work with cookies to identify and re-identify website users across sessions.

B. Cookie Classifications

Cookies are classified by their purpose (their primary function on the website) and generally fall into one or more of the following categories:

• Essential: Required for the Site to function. You cannot disable these.
• Targeted Advertising: Deliver targeted ads and measure effectiveness.
• Personalization: Remember preferences (such as your username, language, or the region you are in) and provide enhanced features.
• Analytics: Understand Site performance and visitor interactions.

We use cookies for all of the above purposes.

C. How We Use Third Party Cookies

We may also use third party cookies or analytics tools for the following purposes:

• Third Party Analytics Tools: We use third party analytics tools to collect information about how consumers use our Site. This information is collected in aggregated form only. Some third party analytics tools, such as Google, allow you to control your privacy preferences across all websites by allowing you to download an extension for your browser.
• Third Party Ad Servers: We may use other third-party tracking technologies (“Ad Servers”) to either re-target relevant advertising about our products or services, or enable third parties to serve their ads and monitor users’ responses to their advertisements. Ad Servers may re-direct you to other websites not associated with us. The use of Ad Servers may be considered a “sale” or “sharing” for cross-context behavioral advertising under applicable state privacy laws. You may opt out of such sharing at any time through our Data Request Form, by using a recognized universal opt-out mechanism, such as the Global Privacy Control (GPC), or using any of the other opt out mechanisms described below.
  • Note: Ad Servers have their own privacy practices, we do not control these third parties’ use of cookies, or how they manage the information they gather through them. You should review the privacy policies of other websites you visit or link to from our Site to understand how these other websites use cookies and how they use the information they collect through the use of cookies on their own websites.

D. Blocking, Disabling, or Opting Out of Cookies

You may have choices about the collection of information by cookies we use on the Site.

• Manage your cookie preferences: Clicking on the “Manage Preferences” tool in the bottom right hand corner of the Site and selecting the cookies you wish to disable. You cannot disable essential cookies. Disabling cookies may impact your ability to use all of the features and functionality of the Site.
• Browser Settings: Most browsers allow you to reject cookies by default. You may also be able to delete our cookies as soon as you leave the Site. Disabling cookies may impact your ability to use all of the features and functionality of the Site.
• Google Ad On: For Google Analytics, you may download an Opt-out Browser Add-on. Please note that the Add-on does not prevent information from being sent to us. To learn more about the Add-on tool for Google Analytics, click here.
• Subscribe to Opt-Out Lists: Some advertisers and service providers that perform advertising-related services for us and for third parties may participate in the self-regulatory programs. See the below links to learn more:
  • Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices.
  • Network Advertising Initiative (“NAI”), see http://www.networkadvertising.org/choices/.
• Request to “Opt-Out Of The Sale Or Sharing Of Personal Information”: Submit the Data Request Form.
• Do Not Track Signals: Some browsers allow you to turn on Do Not Track signals (DNTs), which sends a signal to the websites you visit telling those sites that you do not wish to allow third-party cookies. There is no standard technology at this time for companies to receive these signals. Our Site does not currently consistently respond to DNTs received from web browsers.

12. What is de-identified or aggregate data and how do we use such data?

“De-identified data” cannot reasonably be linked to a particular person. “Aggregate data” shows high-level trends without linking to individuals.

We may de-identify and aggregate data for business purposes (improving products, security, analytics). We maintain such data in de-identified/aggregate form and do not attempt re-identification except as legally permitted. Third parties receiving such data commit to maintaining it in de-identified form.

13. Safeguarding Your Personal Information

We endeavor to safeguard and protect our users’ Personal Information. We utilize electronic and physical security to reduce the risk of improper access to or manipulation of the Personal Information you submit during transmission and storage, but cannot and do not guarantee the security or integrity of the information. We shall have no liability for breaches of security or integrity or third-party interception in transit. Please be advised that any transmission of data at or through the Site is at your own risk.

14. How do we protect your financial information?

Any financial information provided to us (including credit card and payment information) is stored/shared/transmitted in encrypted format complying with PCI standards using SSL (secure socket layer) encryption.

15. What other steps can you take to protect your account?

If you create an account with us, your account is password protected so that you and only you have access to this personal information. You may edit your account information by using your user ID and password. Do not divulge your password. We will never ask for your password in unsolicited calls/emails. Sign out and close your browser after use, especially on shared/public computers.

16. Protecting Children’s Privacy Online

The Site is not intended for users under the age of 18, nor do we knowingly collect, retain or share information in connection with the Site from children under the age of 18.

With respect to children under the age of thirteen (13), we do not knowingly collect information from children under 13. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).

If you believe that we have received information from a child or other person who is not of a majority age in their relevant jurisdiction, please contact us at our email or physical mailing address listed in the “Contact Us” section below and we will take all reasonable efforts to remove the information.

17. Do we use or process Personal Information outside the country where the data was originally collected?

This Policy is intended to cover collection of information on our Site from residents of the United States. If you are visiting our Site from outside the United States, please be aware that your Personal Information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and laws of the United States and other countries might not be as comprehensive as those in your country. By using our Site and Services, you understand that your information may be transferred to our facilities and those third-parties with whom we share it as described in this Policy.

18. How long do we retain Personal Information?

Unless you request deletion, we retain Personal Information for the duration of our relationship or as long as necessary to fulfill collection purposes, whichever is longer. We consider amount, nature, sensitivity, risk of harm, processing purposes, and legal requirements when determining retention periods.

19. External Links

The Site may contain links to other websites or allow others to send you such links. A link to a third party’s site does not necessarily mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party sites. You access such third-party sites or content at your own risk. You should always read the privacy policy of a third-party site before providing any information to the site.

20. How will we inform you of changes to this Policy?

We may modify this Policy at any time. Changes supersede previous policies. Updates will be posted with a revised “Last Updated” date. Check frequently for updates. For material changes, we will notify you by email and/or account notice as required by applicable privacy laws. For changes to how we collect, use, process, or share Personal Information, we’ll provide opportunity to consent or opt out as required by applicable law, and such changes will not apply retroactively without your consent.

21. State Specific Disclosures

California – Shine the Light Law

California residents have the right to request certain details about how their Personal Information is shared with third parties and, in some cases, affiliates for direct marketing purposes. We may from time to time elect to share certain Personal Information about you with third parties for those third parties’ direct marketing purposes. If you are a California resident, you may obtain the categories of Personal Information shared and the names and addresses of third parties that received Personal Information for their direct marketing purposes during the preceding calendar year. You may make this request by contacting us using the information provided in the Contact Us section. Such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. To help us determine if this right applies to you, we may ask that you attest to the fact that you are a California resident and provide a current California address. Please note that we are only required to respond to one request per customer each year.

California and Vermont

We automatically treat accounts with Vermont and California billing addresses as if you requested we not share information with nonaffiliated third parties and limit information shared with affiliates. If we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you.

Nevada

We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing by using the contact information provided in Section 21. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: [email protected].

22. Contact Us

If you have any questions or concerns about us, the Site, the Services, this Policy, the Gramm-Leach-Bliley Privacy Policy, or to exercise your rights or choices, please contact us:

DATA REQUEST FORM

Mail:
United Debt Settlement, LLC
519 8th Ave
6th Floor
New York, NY 10018

Email: [email protected]