Privacy Policy

1. Introduction

CREDFLOW LLC ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our debt collection services or visit our website.

We operate in full compliance with the Fair Debt Collection Practices Act (FDCPA), the Fair Credit Reporting Act (FCRA), and all applicable federal and state privacy laws.

2. Information We Collect

2.1 Information from Clients

When businesses engage our collection services, we may collect:

• Business information (name, address, contact details)
• Account information for debts to be collected
• Documentation supporting the validity of debts
• Payment and billing information

2.2 Information about Debtors

In the course of our collection activities, we may receive or collect:

• Personal identifiers (name, address, phone number, email)
• Social Security Number (when legally permitted)
• Employment information
• Financial information related to the debt
• Communication records
• Payment history and arrangements

2.3 Website Information

When you visit our website, we automatically collect:

• IP address and browser information
• Pages visited and time spent on site
• Referring website information
• Device and operating system information

3. How We Use Your Information

3.1 Primary Uses

We use collected information to:

• Perform debt collection services
• Verify the validity and amount of debts
• Locate and communicate with debtors
• Process payments and maintain records
• Comply with legal and regulatory requirements
• Prevent fraud and unauthorized activities

3.2 Communications

We may use your information to:

• Send notices required by law
• Communicate about debt obligations
• Respond to inquiries and requests
• Provide account updates to clients

3.3 Legal Compliance

We use information as necessary to:

• Comply with court orders and legal processes
• Respond to requests from law enforcement
• Exercise or defend legal claims
• Comply with audit requirements

4. Information Sharing and Disclosure

We do not sell, rent, or trade personal information. We may share information in the following circumstances:

4.1 With Clients

We share collection status, payment information, and debtor communications with our clients who placed accounts for collection.

4.2 With Service Providers

We may share information with trusted third-party service providers who assist us in:

• Skip tracing and debtor location
• Payment processing
• Legal services
• Technology and infrastructure support

4.3 Credit Reporting

When legally permitted, we may report debt information to credit reporting agencies in accordance with the Fair Credit Reporting Act.

4.4 Legal Requirements

We may disclose information when required by law, including:

• In response to subpoenas or court orders
• To comply with regulatory investigations
• To protect our rights or property
• In emergency situations to protect safety

5. Data Security

We implement comprehensive security measures to protect your information:

• 256-bit SSL encryption for data transmission
• Encrypted storage of sensitive information
• Access controls and authentication protocols
• Regular security assessments and updates
• Employee training on data protection
• Incident response procedures

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security but are committed to using industry-standard protections.

6. Your Rights

6.1 Rights Under FDCPA

If you are a debtor, you have the right to:

• Request validation of the debt
• Dispute the debt within 30 days
• Request that we cease communication
• Specify how and when we may contact you

6.2 Privacy Rights

Depending on your location, you may have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion of information (subject to legal requirements)
• Opt-out of certain uses of your information
• File complaints with regulatory authorities

6.3 California Privacy Rights

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

• Right to know what information we collect
• Right to delete personal information
• Right to opt-out of sale (we do not sell personal information)
• Right to non-discrimination

7. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to:

• Maintain session information
• Analyze website traffic and usage
• Improve user experience
• Provide security features

7.1 Types of Cookies

• Essential Cookies: Required for website functionality
• Analytics Cookies: Help us understand website usage
• Security Cookies: Detect authentication and prevent fraud

7.2 Managing Cookies

You can control cookies through your browser settings. However, disabling cookies may limit website functionality.

8. Contact Information

For privacy-related questions, to exercise your rights, or to file a complaint:

8.1 Regulatory Contacts

You may also contact:

• Consumer Financial Protection Bureau (CFPB)
  855-411-CFPB (2372)
  www.consumerfinance.gov
• Federal Trade Commission (FTC)
  1-877-FTC-HELP (1-877-382-4357)
  www.ftc.gov

9. Additional Information

9.1 Children's Privacy

Our services are not directed to individuals under 18. We do not knowingly collect information from children.

9.2 Data Retention

We retain information for as long as necessary to:

• Provide our services
• Comply with legal obligations
• Resolve disputes
• Enforce our agreements

9.3 International Transfers

We operate in the United States. Information may be transferred to and processed in the United States.

9.4 Changes to Privacy Policy

We may update this Privacy Policy periodically. The "Last Updated" date reflects the most recent changes. Continued use of our services constitutes acceptance of the updated policy.