Pinnacle Recovery, Inc. (hereinafter “We,” “us”) values your privacy and maintains standards to secure your private information. This privacy policy discloses the privacy practices for this website. This privacy notice applies solely to information collected by this web site.

You acknowledge this Privacy Policy is part of our Site Terms of Use, and by accessing or using our site, you agree to be bound by all terms and conditions. If you do not agree to these terms, please do not access or use this site.

The information below explains how we currently use Personal Information, but we may change or broaden our use at any time. This Privacy Policy changes from time to time and changes are effective upon posting. Please check back for updates as it is your responsibility to be aware of changes. We do not provide notices of changes in any manner other than by posting the changes on this website.

We collect, use, and retain information about you only where we reasonably believe that it will help administer our business or provide services to both you and our clients. We collect and retain information about you only for specific business purposes. We use information to administer your records and accounts; to comply with certain laws and regulation; and to protect your accounts from fraud and misuse. By using our website, you consent to contact from us in accordance with this Privacy Policy, to contact you by phone or email regarding your account status or in response to general inquiries you submit. We do not sell your information to third parties. We store Personal Information in a database on computers or servers owned or accessed by us. These computers and servers have security measures in place to protect against the loss, misuse, and alteration of the information under our control. Data transmitted through our website, including Personal Information you submit, is encrypted to make your connection confidential. Notwithstanding such measures, we cannot guarantee that our computers and servers will not be illegally accessed and your Personal Information from being stolen or altered.

Some areas of our web site may use “cookies” which are a feature on your browser software. If enabled, we may write cookies that may store small amounts of data on your computer about your visit to any of the pages of this website. We may use cookies to keep track of the number of return visits to this site; accumulate and report aggregate, statistical information on website usage or save your password for ease of access to our website. You can disable cookies. Your browser preferences can be modified to accept or reject all cookies or request notification when a cookie is set.

We use standard software to collect non-identifying information about our visitors such as date and time our site was accessed, IP addresses and web browser used by city, state, and country. We may use this information to create summary statistics and to determine the level of interest in information available on our site.

Please note that our Privacy Policy only applies while you are visiting our website and does not apply if you leave our website by following links that we may have provided for your convenience.

If you have questions about this policy, please e-mail us at info@pinnaclerecovery.com or call us at 888-831-1804.

Updated October 2021

CALIFORNIA RESIDENTS: PRIVACY POLICY NOTICE

This Privacy Policy Notice is intended for California residents pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), and supplements the information contained in the above Privacy Policy. Any terms defined in the CCPA and the applicable California Attorney General regulations have the same meaning as used in this Privacy Policy Notice.

Information We Collect About You

We may collect (and have collected in the last twelve (12) months) and use personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be directly or indirectly linked with a consumer, device, or household (“personal information”). Personal information does not include: publicly available information from government records, deidentified or aggregated consumer information or information excluded from CCPA’s scope, such as, but not limited to, information governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the California Confidentiality of Medical Information Act (“CMIA”), the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

We regularly collect several types of personal information about individuals offline regarding accounts we service including: name, date of birth, address, gender, account number, payment and other financial information, email address, social security number, employment information, telephone number, IP address, military or veteran status, audio information, user name, publicly available information and information collected or shared pursuant to HIPAA, FIPA, GLBA, FCRA, DPPA and/or other applicable privacy laws.

How We Collect Your Personal Information

We collect most of this personal information from our client(s) that assigned your account to our office for accounts receivable servicing or directly from you or your authorized representative(s) via telephone or written communication. However, we may also collect information from publicly accessible sources, from our third party service providers (i.e. call analytics, skip-tracing, payment processing, mailing, consumer reporting agencies (i.e. your credit history) and from transactions with us (i.e. your account balance, payment history and payment information).

Why We Use or Disclose Your Personal Information

We only use your Personal Information for our business purposes which include:

• Performing services on behalf our clients related to your account(s).

• Verifying your identity.

• Providing you with information and services.

• Processing your payment(s).

• Auditing related to consumer interactions.

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

• Identifying and debugging errors that impair functionality.

• Permissible short-term transient use, where the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction.

• Responding to law enforcement requests and as required by applicable law or court order.

• As appropriate to protect the rights, property, or safety of us, our clients, or others.

• As described to you when collecting your Personal Information or as otherwise described in the CCPA.

We regularly disclose and have disclosed in the last twelve (12) months the following types of Personal Information for one or more business purposes: name, address, email address, social security number, date of birth, employment information, IP address or other similar identifier, contact information, payment and financial information, age, marital status, sex and veteran or military status, audio information, and information collected or shared pursuant to HIPAA, GLBA, FCRA, DPPA, and/or other applicable privacy laws.

Do We Sell Your Personal Information?

We have not sold your personal information over the last twelve (12) months and will not sell your personal information under the CCPA.

Verifiable Consumer Requests for Information

Upon verification of identity, California residents may in some cases request that a business:

• Disclose the categories or personal information the business collected about the consumer.

• Disclose the categories of sources from which the personal information is collected.

• Disclose the categories of personal information that the business sold about the consumer.

• Disclose the categories of personal information the business disclosed about the consumer for a business purpose.

• Disclose the categories of third parties with whom the business shares personal information.

• Disclose specific pieces of personal information the business has collected about the consumer.

• Disclose any financial incentives offered by the business for collection, sale, or deletion of personal information.

Please note that we are not required to:

• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained.

• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information.

• Provide the requested information disclosure to you more than twice in a twelve (12) month period.

• Provide the requested information disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

• Provide the requested information disclosure if a CCPA or applicable exception applies.

Right to Request Deletion of Personal Information

Upon verification of identity, California Residents may in some cases request that we delete personal information about you that we collected from you and retained, subject to certain exceptions.

We may deny your deletion request if we are acting in the role of a service provider to another business regarding the applicable personal information. If we deny your request on that basis, we will generally refer you to the relevant business. In addition, we may deny your request for deletion if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which the personal information was collected, provide a service requested by you, or reasonably anticipated within the context of our business relationship with 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.

• Comply with the California Electronic Communications Privacy Act.

• Engage in solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

• Comply with a legal obligation.

• Otherwise use your personal information internally, in a lawful manner that is compatible with the context in which you provided the information.

• If another CCPA or applicable exception applies.

California residents may submit verifiable requests for information or deletion described herein by emailing us at info@pinnaclerecovery.com or calling us at 888-831-1804.

Verifying Your Identity If You Submit CCPA Requests

If you contact us via the designated methods above to exercise your rights under the CCPA, you will need to provide enough information to reasonably identify you (i.e. your name, account number and potentially other identifying information) and describe your request with sufficient detail to allow us to properly process and respond to your request. Upon receiving your request, we will attempt to respond within no more than forty-five (45) days as required by CCPA. If we reasonably need additional time to comply, we will notify you of such.

Right to Nondiscrimination

We will not discriminate against you because you elect to exercise any of your rights under the CCPA including, but not limited to denying a service to you, charging different prices or rates for services, providing a different level or quality of service or suggesting that you will receive a different price, rate, level or quality of service.

Last Modified: October 2021