Joseph, Mann & Creed Privacy Policy
As you may well know, Congress has passed the Gramm-Leach-Bliley Act. The GLB
deals with how financial institutions treat nonpublic personal financial information.
Joseph, Mann & Creed hereafter known as “JMC” understands how important your
privacy is to you. This is why we, JMC strongly believe in protecting the confidentiality
and security of information we obtain about you. JMC privacy policies and procedures
apply only to our company, not to third parties who may handle your personal
information.
Mini-Miranda Requirement
The Fair Debt Collection Practices Act provides that a debt collector may not use any
false, deceptive, or misleading representation or means in connection with the collection
of debt. Section 807 of the Fair Debt Collection Practices Act provides that "false,
deceptive, or misleading representation" includes the failure to disclose in the initial oral
or written communication with the consumer that "the debt collector is attempting to
collect a debt and that any information obtained will be used for that purpose", and the
failure to disclose in subsequent communications that "the communication is from a debt
collector". This is referred to as the "Mini-Miranda" Requirement
Our internal policy on the Mini-Miranda Requirement exceeds the minimum standards
required by law; our policy is that a collector must give the Mini-Miranda to a consumer
on each contact made. Collectors are trained to give the Mini-Miranda once they have
identified that the person they are speaking with is the correct debtor and prior to
discussing the debt or any demand for payment.
Choice and Consent
JMC collects only personal information essential to securing payment of our clients’
receivables. Failure to provide the minimum personal information required to complete a
payment may result in further collection efforts from JMC or our clients. By providing
JMC with personal information, you are giving JMC implicit consent to use this
information for further collections efforts. JMC employees may request your explicit
consent prior to collecting sensitive personal information from you. If personal
information is to be used for purposes not previously identified in this privacy notice you
will be notified. All payment information is protected in accordance with PCI DSS
Security Standards and explicit consent is required prior to processing any credit card
payments.
Security
Confidential information entrusted to JMC will be secured from unauthorized viewing,
accidental distribution, and accidental loss. Confidential information is received in both
paper and electronic form. Account information is not purged from our database. Your
personal information is kept electronically and any paper containing personal information
is disposed of securely. JMC maintains compliance with SSAE 16 security principles
such as:
  • Employees are authorized to access personal information based on job responsibilities.
  • Authentication is used to prevent unauthorized access to personal information stored electronically.
  • JMC provides secure processing areas for mail collection, mail opening, payment posting, reconciliation and remittances.
  • Physical security is maintained over personal information stored in hard copy form, and encryption is used to prevent unauthorized access to personal information sent over the internet.
  • Additional security safeguards are applied to sensitive information.
Parties To Whom We Disclose Information
Joseph, Mann & Creed does not sell, release, or distribute any nonpublic information
obtained except as required or permitted by law. Personal information is disclosed to
third parties only for the purposes identified in this notice and for which you have
provided implicit or explicit consent unless a law or regulation specifically allows or
requires otherwise. Third parties may include our clients, vendors, and credit card
processors with whom we have agreements to protect your personal information in a
manner consistent with the relevant aspects of our privacy policy. All information is
transmitted in accordance with our security policy and may be transmitted in paper or
electronic form.
Access to Your Information
JMC collects information fairly and lawfully from others, such as credit bureaus,
affiliates, or other companies. JMC may collect information regarding your whereabouts
or financial information from third- party sources. You have the right to obtain certain
items of information that we have collected about you. You also have the right to request
correction of information if you feel it is not accurate. These requests must be made in
writing. If we agree, we will correct our records and may notify our client. If we do not
agree, we will be sure to communicate this to you.
Inquiry, Complaint and Dispute Process
Any inquiries, complaints or disputes should be directed to our corporate compliance
officer in writing to the address listed at the end of this policy.
JMC Online Privacy Policy
As is true of most web sites, our servers automatically collect and store certain technical
information when you visit our web sites, including information such as the internet
protocol (IP) address of the device you use to connect to the Internet, browser type,
internet service provider (ISP), the web site you came from and exited to, operating
system, date/time stamp, and pages visited. In addition, we or our third-party service
providers may place and read session and/or persistent "cookies" on the computer you are
using, and use other technologies such as Web beacons, clear GIFs, tracking pixels and
tags, when you visit our websites or open our email. JMC and our service providers may
use information from our server logs, cookies and other technologies, in combination
with information you provide, transaction information, and information that we or they
collect from others, to process your transactions, to fulfill legal and regulatory
requirements, and as otherwise permitted by applicable law. We do not intend to collect
personal information from children under 13 years of age. If we learn that we have
collected this information from a child under the age of 13, we will promptly take all
reasonable steps to delete the data from our system. Unless prohibited by law, you have
the right, upon reasonable notice, to view any personally identifiable information
collected from you through your visits to or use of our websites, to make corrections to
such information if necessary, or to request that such information be removed from our
systems. You may do so by contacting us at the address indicated at the end of this
policy. Our website also permits you to access non-JMC sites directly from our website.
It is important to remember that if you link to a non-JMC site from any of our websites
that party's privacy policy and its terms and conditions of use apply to you. We
encourage you to learn about each third party's privacy policy before giving your
information to them.
Further Information
For further information or questions, please feel free to contact us by phone at (877) 369-
5092 or in writing at 20600 Chagrin Blvd, Suite 550, Shaker Heights, OH 44122.