Privacy Policy

1. Information We Collect

1.1 Personal Information

When you use our services or contact us, we may collect the following types of personal information:

• Identity Information: Full name, date of birth, Social Security number, driver’s license number, and government-issued identification
• Contact Information: Email address, phone number, mailing address, and billing address
• Financial Information: Bank account information, credit card details, income information, employment details, debt information, credit reports, and financial statements
• Business Information: Business name, EIN/Tax ID, business structure, revenue information, and business debt details
• Communication Records: Records of your communications with us, including emails, phone calls, and chat messages
• Legal Information: Information related to legal proceedings, creditor information, and settlement negotiations

1.2 Information Collected Automatically

When you visit our website, we automatically collect certain information about your device and browsing behavior:

• IP address and location data
• Browser type and version
• Operating system
• Device identifiers
• Pages visited and time spent on pages
• Referring website addresses
• Click patterns and navigation paths
• Cookies and similar tracking technologies

1.3 Information from Third Parties

We may receive information about you from third parties, including:

• Credit bureaus and credit reporting agencies
• Your creditors and collection agencies
• Background check services
• Public records
• Fraud prevention services
• Analytics providers

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Service Delivery

• Evaluate your eligibility for our debt relief and settlement programs
• Negotiate with your creditors on your behalf
• Provide financial consulting and debt management services
• Create and manage your account
• Process payments and settlements
• Provide legal assistance and representation when necessary
• Monitor and track your debt relief progress

2.2 Communication

• Respond to your inquiries and support requests
• Send you important updates about your account and services
• Provide notifications about settlement opportunities
• Send administrative information, such as policy updates
• Communicate with creditors and their representatives

2.3 Business Operations

• Verify your identity and prevent fraud
• Comply with legal obligations and regulatory requirements
• Improve our website and services
• Conduct data analysis and research
• Protect our legal rights and interests
• Enforce our terms of service

2.4 Marketing (With Your Consent)

• Send promotional materials about our services
• Provide information about new programs or offerings
• Conduct surveys and gather feedback

3. How We Share Your Information

We may share your information with the following parties:

3.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Payment processors and financial institutions
• Cloud storage providers
• Email and communication service providers
• Credit reporting agencies
• Data analytics providers
• IT security and maintenance providers
• Background check services

3.2 Creditors and Collection Agencies

To negotiate settlements and resolve your debts, we share necessary information with:

• Your creditors and their representatives
• Collection agencies
• Debt buyers
• Legal representatives of creditors

3.3 Legal and Regulatory Authorities

We may disclose your information when required by law or to:

• Comply with legal processes, court orders, or government requests
• Respond to subpoenas or regulatory inquiries
• Protect our rights, property, or safety
• Enforce our agreements and policies
• Prevent fraud or illegal activities
• Cooperate with law enforcement

3.4 Business Transfers

If Delancey Street is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred to the successor entity.

3.5 With Your Consent

We may share your information with other parties when you have given us explicit consent to do so.

4. Data Security

We implement robust security measures to protect your personal and financial information:

• Encryption: We use industry-standard SSL/TLS encryption to protect data transmitted over the internet
• Secure Storage: Your information is stored on secure servers with restricted access
• Access Controls: Only authorized personnel with a legitimate need can access your information
• Regular Audits: We conduct regular security audits and assessments
• Employee Training: Our staff receives regular training on data privacy and security
• Multi-Factor Authentication: We use multi-factor authentication for sensitive systems
• Firewalls: Advanced firewall systems protect our networks
• Monitoring: We continuously monitor for security threats and unauthorized access

While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we take all reasonable precautions to protect your data.

5. Cookies and Tracking Technologies

5.1 Types of Cookies We Use

• Essential Cookies: Required for website functionality and security
• Performance Cookies: Help us understand how visitors use our website
• Functionality Cookies: Remember your preferences and settings
• Marketing Cookies: Track your online activity to deliver relevant advertisements

5.2 Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may limit your ability to use some features of our website.

5.3 Third-Party Analytics

We use third-party analytics services (such as Google Analytics) to analyze website usage. These services may use cookies and similar technologies to collect information about your use of our website.

6. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

6.1 Access and Portability

• Request access to the personal information we hold about you
• Request a copy of your information in a portable format

6.2 Correction and Updates

• Request correction of inaccurate or incomplete information
• Update your contact information and preferences

6.3 Deletion

• Request deletion of your personal information (subject to legal retention requirements)
• Note: We may need to retain certain information for legal, regulatory, or legitimate business purposes

6.4 Restriction and Objection

• Request restriction of processing in certain circumstances
• Object to processing based on legitimate interests

6.5 Marketing Communications

• Opt out of receiving marketing communications at any time
• Unsubscribe from promotional emails using the link in each message
• Contact us to be removed from our marketing lists

6.6 Do Not Sell My Personal Information

We do not sell your personal information to third parties. If our practices change, we will update this policy and provide you with the ability to opt out.

7. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services and fulfill the purposes described in this policy
• Comply with legal, regulatory, and tax obligations
• Resolve disputes and enforce our agreements
• Maintain business records for legitimate business purposes

The specific retention period depends on the type of information and the purposes for which it is used. Financial and legal records are typically retained for 7 years or longer as required by law.

8. Children’s Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected information from a child under 18, we will take steps to delete that information promptly.

9. State-Specific Privacy Rights

9.1 California Residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• Right to know what personal information is collected, used, and shared
• Right to delete personal information
• Right to opt-out of the sale or sharing of personal information
• Right to correct inaccurate personal information
• Right to limit the use of sensitive personal information
• Right to non-discrimination for exercising your rights

9.2 Virginia, Colorado, Connecticut, and Other States

Residents of states with comprehensive privacy laws have similar rights to access, correct, delete, and opt-out of certain data processing activities.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. When we transfer your information internationally, we use appropriate safeguards to protect your data in accordance with applicable laws.

11. Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the “Last Updated” date at the top of this policy
• Notify you via email or through a notice on our website
• Obtain your consent if required by applicable law

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Legal Compliance

Our privacy practices comply with applicable federal and state laws, including but not limited to:

• Gramm-Leach-Bliley Act (GLBA)
• Fair Debt Collection Practices Act (FDCPA)
• California Consumer Privacy Act (CCPA/CPRA)
• Virginia Consumer Data Protection Act (VCDPA)
• Colorado Privacy Act (CPA)
• Connecticut Data Privacy Act (CTDPA)
• Other applicable state privacy laws

15. Consent

By using our website and services, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with this policy, please do not use our website or services.

For our services that require explicit consent, we will obtain your separate written consent at the appropriate time.