This Privacy Notice for California Residents supplements the information contained in the Privacy Policy of Lamont, Hanley & Associates, Inc. (“LHA,” “we,” “us,” or “our”) GENERAL PRIVACY POLICY and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). Lamont, Hanley & Associates, Inc. is a debt collector.  We do not buy or sell your personal information. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice. For questions concerning this Notice or to obtain a copy of this Notice in an alternative format, please call us at 1-800-639-2204. 

A. Consumer Rights
The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights.

1. ACCESS RIGHTS:
You have the right to request that LHA disclose certain information to you about our collection of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources from which your personal information was collected.
• The categories of your personal information that we disclosed for a business purpose.
• The categories of third parties to whom your personal information was disclosed for a business purpose.
• Our business or commercial purpose for collecting your personal information.
• The specific pieces of personal information we collected about you.

 

2. RIGHT TO NON-DISCRIMINATION:
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

3. DELETION RIGHTS:
You have the right to request that LHA delete any personal information about you that we have collected from you. However, this right does not apply where we need to retain the personal information in order to do any of the following:

• Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between LHA and you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 of Title 12 of Part 2 of the Penal Code;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
• To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with LHA;
• Comply with a legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Additionally, requests to delete may be denied if deletion could restrict our ability to comply with federal, state or local laws, as well as our ability to exercise or defend legal claims.If there are no applicable exclusions, once we receive your verifiable consumer request, we will delete any of your personal information which we have collected from you.

B. Exercising Your Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by:

• Calling us at 1-800-639-2204 or emailing: compliancehelp@lhainc.com

Only you, or a person that you registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To verify your request, we will compare information you provided with the information LHA already has. We will match 2-3 identifying, personal information data points to verify that the request came from the consumer. We cannot provide you with personal information if we cannot verify your identity or your authority to make the request. If we cannot verify the request, we will notify you.

C. Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information
• Information excluded from the CCPA’s scope, like:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Specifically, we collect the following categories of personal information:

Category	Examples of Information We May Collect	Collected
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
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
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
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	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
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

 

D. Sources of Personal Information Collected
We collect personal information from the following categories of sources:

• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the debt collection 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 debt collection services to them.
• Directly or indirectly from activity on our website or our external payment portal. For example, we collect payment information from our external payment portal.
• From third-parties that interact with us in connection with the debt collection services we perform. For example, from government and/or publicly available data bases.
• Directly from you, the consumer.

 

E. Purposes for Collection of Personal Information
We use or disclose the personal information we collect for the following business purpose:

• Debt collection.
• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to process a payment, we will use that information to process said payment.
• To provide you with information or services that you request from us.
• To provide you with email or text alerts and other notices concerning our services.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for collections.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and our clients, including for collections.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

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

 

F. Categories of Personal Information Sold
The CCPA provides for the right to opt out of the sale of personal information. LHA, however, does not and will not sell, share, rent or trade your personal information to any third parties for their commercial purposes.

 

G. Categories of Personal Information Disclosed
We engage certain trusted third parties to perform functions and provide services to us for a business purpose. We may share your personal information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Personal identifying information
• Characteristic information
• Retail information
• Professional or employment related information

 

H. Categories of Third Parties
We may disclose personal information for business purposes to the following categories of third parties:

• The client that placed the account for collections.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
• Others as allowed by the CCPA and any other applicable law.

 

I. Changes to this Privacy Notice
This Notice was last updated on June 29, 2020. We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will notify you by email or through a notice on our website homepage.

Effective Date: 6/29/2020
Last Reviewed on: 6/29/2020

This communication is from a debt collector.