PRIVACY
NOTICE This
Privacy Notice is being given on behalf of each of the following related
companies (the “Sherman Companies”). It
describes the general policy of the Sherman Companies regarding the personal
information of customers and former customers.
Information
We May Collect. The Sherman Companies may collect the
following personal information: (1) information that we receive from your
account file at the time we purchase or begin to service your account, such as
your name, address, social security number, and assets; (2) information that
you may give us through discussion with you, or that we may obtain through your
transactions with us, such as your income and payment history; (3) information that we receive from consumer
reporting agencies, such as your creditworthiness and credit history, and (4)
information that we obtain from other third party information providers, such
as public records and databases that contain publicly available data about you,
such as bankruptcy and mortgage filings.
All of the personal information that we collect is referred to in this
notice as “collected information”. Confidentiality
and Security of Collected Information. At the Sherman Companies, we restrict
access to collected information about you to individuals who need to know such
collected information in order to perform services in connection with your
account. We maintain physical safeguards
(like restricted access), electronic safeguards (like encryption and password
protection), and procedural safeguards (such as authentication procedures) to
protect collected information about you. Sharing
Collected Information with Affiliates From time to time, the Sherman
Companies may share collected information about customers and former customers
with each other in connection with administering and collecting accounts to the
extent permitted under the Fair Debt Collection Practices Act. Sharing
Collected Information with Third Parties The Sherman Companies do not share
collected information about customers or former customers with third parties,
except as permitted in connection with administering and collecting accounts
under the Fair Debt Collection Practices Act.
PRIVACY NOTICE Your privacy is important to Arrow. The following Privacy Notice applies to current and former individual customers. We collect and use nonpublic personal information (“information”) about you to conduct and manage our business. Sources of this information include the following: -Information we receive from your original creditor and from applications submitted by you to the original creditor; -Information we receive from you through correspondence or communication with us, whether by mail, telephone, or the Internet, and which may include your name, address, Social Security Number, assets, income, or other information you provide; -Information about your transactions with us, our affiliates, or others, such as your account balance and payment history; -Information we receive from third parties, such as consumer reporting agencies. We only disclose information to affiliated and non-affiliated third parties as permitted or required by the federal Fair Debt Collection Practices Act (“FDCPA”). We may share information we collect with third parties that provide mailing and/or other collection-related services to us. When we share your information with these companies, they are required to limit their use of your information to the particular purpose for which it was shared and they are not allowed to share it with others except to fulfill that limited purpose. In addition, if permitted by FDCPA, we may also share your information with our affiliates and non-affiliated third parties if also permitted by applicable law. We restrict access to nonpublic personal information about you to those employees who need to know that information to service your account or manage our business. We maintain physical, electronic, and procedural security measures to protect your information. You may have other privacy protections under state laws. The effective date of this notice is February 1, 2005. It replaces all prior privacy policies issued by Arrow Financial Services LLC or any other Arrow company. We reserve the right to amend this privacy notice at any time and we will inform you of any changes to this notice as required by law. This notice is made on behalf of Arrow Financial Services LLC and all companies, trusts or other special purpose entities established by any Arrow company.
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