Privacy Policy

We are a debt collection agency attempting to collect a debt and any and all information obtained will be used for that purpose.

FTA Financial LLC (also referenced below as we, our, and us) is delivering this Privacy Notice to you to generally describe the nonpublic personal and financial information we gather about you, and our privacy practices relating to such information and how those practices relate to the protection, use and disclosure of your nonpublic personal information (your “Customer Information”). Please carefully read this Privacy Notice.

What Information Do We Collect?

We collect Customer Information about you from the following sources:
• Information we receive from you on applications or other forms. This information may include:
o Your name
o Address
o Social Security Number
o Telephone number
o Other relevant information that you provide
• Information we receive about your account transactions with us, our affiliates, or others including
the original creditors. This may include information such as :
o Account balance
o Payment history
o Account activity
• Information we receive from the consumer reporting agencies (such as credit scores and history) and other information relating to your creditworthiness.

How Do We Use Your Information?

We do not use Customer Information we have obtained about you for any purpose other than to service or manage your account(s) in the ordinary course of our business.

We do not share Customer Information we have obtained about you with affiliates or non-affiliated third parties except to the extent necessary to aid us in servicing or managing your account(s) in the ordinary course of our business, such as:
o to companies to whom we may assign your account for servicing;
o to companies that provide mailing services to us; and
o to service providers that help us administer our database containing your account.

INFORMATION SECURITY

We restrict access to Customer Information about you to those employees or service providers who need to know that information to service your account(s). We maintain physical, electronic and procedural safeguards that comply with applicable laws and regulations to guard your Customer Information. Whenever we hire third parties to provide support services in order to help us service or manage your account(s), we will require them to conform to our privacy standards and to allow us to audit them for compliance. Such third parties and their employees receiving Customer Information we have obtained about you are required to limit their use of your Customer Information to the particular purpose for which it is shared and they are not allowed to share it with others except to fulfill that limited purpose.

COLLECTION OF DATA

Personal information (such as name, address, phone number, email address etc) may be collected from you on www.payfta.com only when you voluntarily provide such information. Web site visitors who do not want their practice-identifiable information collected online are asked to call FTA Financial LLC toll free at 1-877-978-7389.

Information collected is securely stored and may not be available to you for modification once submitted. FTA Financial LLC will never sell this information or provide it to any third party without consent from you.

Personal information about customers and/or patients may be collected during the account placement process. This information will NOT be made available to any other third parties.

ACCURACY

A commitment to use reasonable procedures to ensure that information collected, used and exchanged will be accurate and complete.

COOKIES

Like many other commercial sites, our site may utilize a standard technology called a “cookie” to collect information about how our site is used. Cookies were designed to help a Web site recognize a user’s browser as a previous visitor and thus save and remember any preferences that may have been set while the user was browsing the site. A cookie cannot retrieve any other data from your hard drive, pass on a computer virus, or capture your e-mail address. Our Web site may use cookies to securely store our clients’ username and password or to make it easier for you to access the site in the future.

SECURITY

Information that you provide FTA Financial LLC is securely stored. Once logged in, all of your communications are transmitted via SSL (Secure Sockets Layer) encrypted forms which ensure that the information cannot be intercepted while in transit. Credit card payments made on www.payfta.com are transmitted via SSL as well and the numbers are NOT stored in our database.

USE OF INFORMATION

During your visits to our site, your usage may be logged by our web server. We collect user-specific information on what pages you access or visit, as well as information volunteered by you. This information may be used to generate reports on web traffic and usage patterns that allow us to modify the site to best fit our needs.

COMPLIANCE

FTA Financial LLC has made a strong commitment to collect, use and disclose information in accordance with applicable state and federal laws, including the Fair Credit Reporting Act and the Fair Debt Collection Practices Act.

EMPLOYEE EDUCATION

FTA Financial LLC has made a strong commitment to educate all employees regarding information practices and the proper handling and use of information obtained.

SAFEGUARDS TO PROTECT PERSONAL INFORMATION

We maintain physical, electronic, and organizational safeguards to protect consumer information. We continually review our policies and practices, monitor our computer networks, and test our security to ensure the safety of consumer information.
FTA Financial LLC maintains the following policies and procedures:
• System Lockdown of servers during initial installation and configuration.
• Background Screening of all personnel and ongoing systems security training.
• Use of confidentiality agreements for all employees and independent contractors.
• Restricted access to authorized personnel, who have a bona-fide business reason.
• Intrusion detection policy to prevent unauthorized access.
• Password policy

DISCLOSURE TO THIRD PARTIES

FTA Financial LLC does not disclose nonpublic information supplied by customers to anyone, except as permitted by law or authorized by the customer. We are committed to protecting our customer’s information, including information covered under the Health Insurance Portability and Accountability Act (HIPAA) and the Gramm Leach Bliley Act (GLBA). Under HIPAA we protect our customers’ Protected Health Information (PHI) and under GLBA we protect our customers’ Non-Public Personal Information. From time to time FTA Financial LLC may disclose personal information to authorized third parties, such as law firms or payment processing companies, for the sole purpose of collecting a debt or processing a payment. FTA Financial LLC has no direct control over the privacy policies or procedures of third parties, and is not responsible for such policies and procedures.

REMEDIAL ACTION

In the event any misuse of information is discovered or reported by any 3rd party for which FTA Financial LLC provided information we will take the necessary steps to correct the incident. We will immediately notify all parties involved as well as provide details on the action taken to correct the incident.

DISPOSAL OF ELECTRONIC RECORDS

Electronic records are stored on a secure server for an indefinite period of time. However, the following process is in place should it become necessary to dispose of any electronic records; the manager of the user of the electronic records must determine what the level of maximum sensitivity of data stored on the device is. Below is listed the action based on data sensitivity according to the data assessment process.
• Unclassified – No requirement to erase data but in the interest of prudence normally erase the
data using any means such as reformatting or degaussing.
• Sensitive – Erase the data using any means such as reformatting or degaussing.
• Confidential – The data must be erased using an approved technology to make sure it is not
readable using special hi technology techniques. The currently approved method of erasing the
data is to use the program D-BaN to erase the data using the DoD option. This option erases the
data using 7 complete passes on the hardrive.

VERMONT & CALIFORNIA RESIDENTS

We will not disclose your consumer information to affiliates or non-affiliated third parties except as provided above, in compliance with the requirements of Vermont and California law.