Client Privacy and Security Policy

Consumer Debt Counselors, including its various divisions, affiliates, partners, sponsors, employees, officers, directors, and agents (collectively, "Consumer Debt Counselors," "we" or "our"), has drafted this Client Privacy and Security Policy to ensure that you can clearly understand our data and security practices and policies as you work with Consumer Debt Counselors and use the Consumer Debt Counselors websites and software applications (the "Sites"). This Client Privacy and Security Policy describes the types of Personal Information we collect, how we use the information, with whom we share it, and the choices you can make about our collection, use, and disclosure of your Personal Information.

The phrase "Personal Information" refers to information that personally identifies you, such as your name, address, telephone number, email address, credit card number or other billing information, personal financial information, account numbers, and more. We also describe the measures we take to protect the security of your Personal Information and how you can contact us about our privacy practices. This Client Privacy and Security Policy incorporates by reference the Terms and Conditions for the Sites, which apply to this Client Privacy and Security Policy. When you visit the Sites or provide us with information, you consent to our use and disclosure of the information we collect or receive as described in this Client Privacy and Security Policy.

Please review this Client Privacy and Security Policy periodically, as we may update it from time to time without prior notice to reflect changes in our data practices. We will post a prominent message on our Sites to notify you of any significant changes to our Client Privacy and Security Policy and indicate when we most recently updated it at the bottom of the notice. If we make material changes to the policy that will affect previously collected Personal Information, we will notify you if we have your updated contact information.

The Information We Collect

We may obtain information about you from various sources, including our Sites, when you call or email us or communicate with us through social media, or when you participate in seminars or other events. We also may obtain information about you from affiliate companies, business partners, and other third parties and publicly available information.

The types of information we may obtain include (i) your Personal Information, such as your name, email address, phone number, postal address, income data, household size, and marital status; (ii) your payment information, including your payment card number, security code, and expiration date or your bank account information; (iii) your creditor account information, including the names of your creditors, your account numbers with them, and the total amount owed; (iv) your personal financial status, including your total debt information, income, and living expenses; (v) your demographic information, including your zip code, occupation, and education; and (vi) other data that you may submit to us or that may be included with information provided to us by third parties such as credit reporting agencies.

In addition, when you visit our Sites, we may collect certain information by automated means, such as cookies and web beacons (see "About Cookies Tracking Choices and Third Party Advertisers" for more information). The information we may collect by automated means includes (i) information about the devices our visitors use to access the internet (such as the IP address and the device, browser, and operating system type); (ii) pages and URLs that refer visitors to our Sites, also pages and URLs that visitors exit to once they leave our Sites; (iii) dates and times of visits to our Sites; (iv) information on actions taken on our Sites (such as page views, site navigation patterns and job view or application activity); (v) a general geographic location (such as country and city) from which a visitor accesses our Sites; and (vi) search terms that visitors use to reach our Sites.

How We Use the Information We Collect

We may use the information we obtain about you to (i) register, manage, and maintain your account on the Sites (should you choose to enroll in a program with us); (ii) provide products or services you request; (iii) process, validate, and deliver your services (including by processing payment card transactions and contacting you about your orders, including by telephone); (iv) obtain concessions from your creditors and resolve accounts (applicable to debt management program clients); (v) provide administrative notices or communications applicable to services that you have contracted via Consumer Debt Counselors; (vi) respond to your questions and comments and provide customer support; (vii) manage your participation in our events, where you have signed up for such events; (viii) operate, evaluate, and improve our business and the products and services we offer; (ix) analyze and enhance our marketing communications and strategies (including by identifying when emails we have sent to you have been received and read); (x) analyze trends and statistics regarding visitors' use of our Sites, mobile applications, and social media assets, and the jobs viewed or applied to on our Sites; (xi) protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users; (xii) enforce our Sites' Terms of Use; and (xiii) comply with applicable legal requirements and industry standards and our policies.

We also use non-personally identifiable information and certain technical information about your computer and your access to the Sites, including your internet protocol (IP) address, to operate, maintain, and manage the Sites. We collect this information by automated means, such as cookies and web beacons (see "About Cookies Tracking Choices and Third Party Advertisers" for more details).

If we seek to use the information we obtain about you in other ways, we will provide specific notice and request your consent at the time of collection.

Information We Share

We do not sell our clients' Personal Information to anyone for any reason.

Where you have provided Personal Information on a Site that is "hosted" or "co-branded" by another company, then that information will be made available to both Consumer Debt Counselors and the hosting/co-branding company. Consumer Debt Counselors is not responsible for what the hosting/co-branding company, or any third party with whom you may share your Personal Information, subsequently does with your information. You should review the privacy policy of the hosting/co-branding company to ensure that you are comfortable with how it intends to use and disclose your information.

We also may share Personal Information with our service providers who help us deliver our products and services to you. These service providers may only use or disclose the information as necessary to perform services on our behalf or as otherwise required by law.

Consumer Debt Counselors also may disclose specific user information when such disclosure is required to comply with the law (as determined by a valid subpoena), to seek assistance from law enforcement, to prevent a crime, or protect national security (as determined by a valid subpoena), or to protect the interests or safety of Consumer Debt Counselors or other users of the Sites.

About Cookies, Tracking Choices, and Third-Party Advertisers

A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected devices to identify the visitor's browser uniquely or to store information or settings in the browser. A "web beacon" is also called a web bug, pixel tag, or clear GIF. Used in combination with cookies, a web beacon is an often-transparent graphic image, usually no larger than 1-pixel x 1-pixel, placed on a website or in an email used to monitor the user's behavior visiting the website or sending the email.

Consumer Debt Counselors uses cookies and other similar technologies for the convenience of our users. Cookies enable us to serve secure pages to our users without asking them to sign in repeatedly. Most internet browsers allow you to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. However, please be aware that some Consumer Debt Counselors features or services may not function properly without cookies.

Links to Other Websites

Our Sites may contain links to other sites for your convenience and information. Other companies not owned by Consumer Debt Counselors may operate these sites. These other sites or linked third-party sites may have their own privacy notices, which you should review if you visit those sites. We are not responsible for the content of any sites not owned by Consumer Debt Counselors, any use of those sites, or those sites' privacy practices.

How We Protect Personal Information

Consumer Debt Counselors maintains administrative, technical, and physical safeguards designed to assist us in protecting the Personal Information we collect against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard Personal Information will never be defeated or fail or that those measures will always be sufficient or effective. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your Personal Information will always remain private. As a Sites user, you understand and agree that you assume all responsibility and risk for your use of the Sites, the internet generally, and the documents you post or access and for your conduct on and off the Sites.

You should safeguard any account username and password and not share that information with anyone to further protect yourself. You should also sign off your account and close your browser window when you have finished your visit to our Sites. Please note that we will never ask for your Consumer Debt Counselors account username or password via email.

How to Contact Us

You can direct questions regarding this Client Privacy and Security Policy to Consumer Debt Counselors by emailing us at hello [at] consumerdebtcounselors [at] com, Re: Client Privacy and Security Policy, or by sending us a letter to Consumer Debt Counselors at 831 W. Morse Blvd., Winter Park, FL 32789, Attention: Compliance Officer. Please include your full name, postal address, and email address in all correspondence with us.

Updated: September 13, 2021