Firstsource Advantage

California Consumer Privacy Act Disclosure

CALIFORNIA CONSUMER PRIVACY ACT DISCLOSURE

Effective:   January 1, 2020

Last Updated: January 20, 2020

Firstsource Advantage, LLC (also referred to as “we”, “us”, or “our”) respects your privacy and is committed to providing a transparent notice of our Privacy Notice and Disclosure for California Residents. This California Consumer Privacy Act Disclosure (“CCPA Disclosure”) explains how Firstsource Advantage, LLC collects, uses, and discloses personal information subject to the California Consumer Privacy Act (“CCPA”).  It also describes the privacy rights of California residents under the CCPA and how they can exercise those rights.

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

This CCPA Disclosure supplements the information contained in our privacy policy and applies solely to California residents.

What Personal Information is Covered by the CCPA?

Under the CCPA, personal information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The following table includes categories of personal information that we have collected over the past 12 months, as defined in the CCPA, that we collect, use or disclose about a California resident.

Category Examples Collected Used in the Past 12 months
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, , address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Yes Yes
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status. No No
D. Commercial information. Records of personal property or considered. No No
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No No
F. Internet or other similar network activity. Cookies, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes Yes
G. Geolocation data. Physical location or movements. No No
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No No
I. Professional or employment-related information. Current or past job history. Yes Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No No
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No No

 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • Performing services, including maintaining or servicing accounts, providing collection services, verifying customer information, processing payments, or performing data analysis
  • Fraud detection and prevention
  • Protecting against security risks
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • Conduct internal research and development or otherwise improve our operations
  • Analyzing your engagement with our company (including our website)
  • To perform various internal business functions, such as auditing
  • If you are applying for a job, then in connection with your employment application

Please note that Personal Information does not include:

  • Publicly available information from government records
  • De-identified or aggregated consumer information
  • Information excluded from the CCPA’s scope, including
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (CalFIPA)

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without your consent.

How We Obtain Information

We obtain the categories of information listed above from the following categories of sources:

  • Directly from the individual, our clients, or their agents. For example, from electronic data file transfer that our clients provide to us related to the services for which they engage us
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them
  • Directly and indirectly from activity on our websites. For example, from submissions through our website portal or website usage details collected automatically.  If you fill out a contact us form or other information you provide to us on our website or mobile applications
  • From third-parties that interact with us in connection with the services we perform
  • From affiliated service providers who provide functionality and analytics regarding website usage

Personal Information Disclosed for Business Purposes

We may disclose personal information to third-parties to perform the following activities:

  • Auditing for legal and regulatory compliance
  • Security for detecting security breaches
    • Protecting against fraud and malicious activity
    • Taking action against wrongdoers (e.g. fraudsters and hackers)
  • Debugging
    • Identifying and fixing technical errors
  • Performing services
    • Account maintenance
    • Customer or collection services
    • Processing transactions
  • Service providers who provide functionality and analytics regarding website usage

Sale of Personal Information

We do not sell personal information and have not sold personal information in the past 12 months.  For purposes of this Disclosure, “sold” means the disclosure of personal information to a third party for monetary or other valuable consideration.

Rights under the CCPA

1. If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:

  • The categories of personal information we have collected about you
  • The categories of sources from which we collected such personal information
  • The business purpose for collecting such information about you
  • The categories of personal information about you that we have disclosed to third parties (if applicable) and the categories of third parties to whom we have disclosed such personal information
  • The specific pieces of information we have collected about you

2. You have the right to request deletion of personal information we collected about you, unless the CCPA recognizes an exception.

3. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

How to Exercise Your Rights

If you are a California resident and would like to exercise your rights described above, please submit your request by:

Changes to This California Consumer Privacy Act Disclosure

We may change or update this CCPA Disclosure from time to time.  When we do, we will post the revised CCPA Disclosure with the “Last Updated” date.

Contact for More Information

If you have any questions or concerns about this CCPA Disclosure or our privacy practices, you may contact us by:

Website: https://www.firstsourceadvantage.com/contact/

Email: firstsourceccpa@na.firstsource.com

Postal Address:

Firstsource Advantage, LLC
Attn: Compliance Officer
205 Bryant Woods South
Amherst, NY 14228