“Consumer” shall mean an individual, or the legal representative of such an individual, who has been given access to CIN products and/or services solely for the Consumer’s own personal, family or household purposes.
“Customer” shall mean a Consumer who has a continuing relationship with CIN by virtue of activating an account at a CIN Site and ordering or using a product or service through the CIN Sites.
- WHO WE ARE
CIN is the leading provider of information services, due diligence products, and practice management solutions to the consumer law industry. CIN is also a reseller of consumer credit data maintained by the national credit bureaus. CIN offers Consumers and Customers a comprehensive portfolio of innovative products, services and tools that assist in the accurate, efficient, and cost-effective preparation of consumer law cases.
CIN is by definition a consumer reporting agency (CRA) operating in accordance with the requirements of the federal Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq. The FCRA establishes the following principles for all CRAs:
- Privacy: A CRA may furnish information from your personal credit profile to a Third Party only if 1) that Third Party has a permissible purpose to receive such information, and 2) you have given the CRA “written instructions” authorizing the CRA under Section 604(a)(2) of the Fair Credit Reporting Act (15 U.S.C. §1681 et. seq.) to obtain your personal credit profile from one or more of the national credit bureaus and provide it to the Third Party.
- Access: Consumers may receive a copy of information a CRA maintains about them. Such reports can be obtained free of charge once per year or for a reasonable fee for additional disclosures. Please visit the following website to obtain more information: www.annualcreditreport.com
- Accuracy: CRAs must follow reasonable procedures to assure accuracy of the information they maintain and furnish. When you obtain a copy of your information, you have a right to dispute and have the information reinvestigated and corrected in the CRA’s database.
- Fairness: CRAs obtain their information from various sources including public records and direct reports from creditors. The FCRA establishes time frames for how long a CRA can report certain types of negative credit data and activity.
- Accountability: The Federal Trade Commission is charged with overseeing the operations of CRAs and enforcing FCRA requirements.
- TYPES OF INFORMATION WE COLLECT AND DISCLOSE
Web Site Analytics: Our Web servers automatically collect the domain names, not the e-mail addresses, of visitors to the Sites. CIN uses this information to measure to measure the use of our Sites, the number of visits, the average time spent on the Sites, the pages viewed per visit, and similar information, with the goal of developing ideas to improve the content and flow of our Sites.
Nonpublic Personal Information (“NPI”): When a Consumer or Customer orders, retrieves, or uses CIN products or services, the types of NPI that we may collect include:
- Information we receive from Consumers and Customers on applications, forms, electronic templates, and in other communications to us, whether in writing, in person, by telephone, by Internet connection, or any other means;
- Information we obtain from Consumers’ and Customers’ activities on our Sites through the use of electronic technologies such as cookies;
- Information Consumers and Customers give to us when they make purchases;
- Information about Consumers’ and Customers’ transactions with us, our affiliated companies, or others;
- Information we receive from a consumer reporting agency and other data and information providers.
- Data provided by Consumers and Customers such as their names, addresses, telephone numbers, SSNs, and dates of birth;
- Consumers’ and Customers’ account data such as account numbers, balances, and payment history;
- Consumers’ and Customers’ credit data including credit history as provided by CRAs;
- Verifying data necessary to authenticate Consumers’ and Customers’ identities;
- Data on purchases made through CIN and its affiliates; and
- Anonymous and aggregated data about Consumers’ and Customers’ use of the Sites and products, including but not limited to Site navigation and types of Site functionality used.
- ENTITIES WITH WHOM WE SHARE INFORMATION
In order to conduct its core businesses, including but not limited to the development, enhancement, positioning, and marketing of core products and services, CIN shares NPI with the following as permitted by law:
- Affiliates, meaning those companies that are members of our corporate family; and
- Non-affiliated third-party companies, meaning companies that perform services on our behalf, such as vendors; or on your behalf, such as a licensed attorney whom you have hired to represent you; but only to the extent required to process transactions that you have authorized, respond to your inquiries, or create the products or services that you have ordered. These non-affiliated third-party companies may be either financial service providers such as the national credit bureaus, or non-financial companies such as bankruptcy forms preparation software vendors and non-profit organizations approved by the U.S. Dept. of Justice to administer the consumer credit counseling courses required under current bankruptcy law. CIN does not share the NPI of any Consumer, Customer or former Customer with any non-affiliated third-party companies that fall outside of these parameters unless required by law, such as in response to a subpoena or in order to comply with a government regulation.
- HOW WE SAFEGUARD NPI
We currently maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard Consumer and Customer NPI. In addition, CIN employs the following security measures to protect privacy of data stored within its network:
- 128 bit SSL Encryption
- Secure User Names & Passwords to authenticate users accessing the system
- CIN’s network and systems are protected by a TrueSecure Certified Firewall
- Consumer and Customer IP addresses are tracked to diagnose problems and potential system abuse. IP addresses are not used to identify Consumers or Customers and are not linked to Consumer or Customer account or access information
- CIN does not authorize the scanning of its network systems or attempted penetration testing of any degree without the written consent of management.
CIN may, from time to time, contact Consumers and Customers via e-mail addresses they have provided to us to inform them of changes or updates to our Sites or products. However, we will never send any Consumers or Customers a request via e-mail for any personally identifiable information (e.g., social security number, account number, date of birth, etc.). If you receive an e-mail appearing to come from CIN asking for personally identifiable information, please contact our Customer Support Department at 1-866-218-1003 or email@example.com so that we can take the proper action to protect you.
- FORMER CUSTOMERS
We share the NPI collected from Former Customers in accordance with the terms stated in this Policy.
- CONTACTS FOR CHANGES AND CORRECTIONS
If you want to update or correct information you have provided us, you can do so by sending us a letter to Credit Infonet, Inc., 4540 Honeywell Court, Dayton, OH, 45424; emailing us at firstname.lastname@example.org; or calling us at 1-866-218-1003. If you want to correct information in a consumer report we provide on you that you believe is incorrect, you can do so through the dispute resolution process provided under the Fair Credit Reporting Act or other applicable laws.
- ADDITIONAL INFORMATION
For additional information about privacy or consumer reporting, visit the following Web sites:
Federal Trade Commission: www.ftc.gov
Consumer Data Industry Association: www.cdiaonline.org