Applicable Laws

The conduct of the Company and its employees are to be in compliance with the laws and regulations to comply with U.S. Federal privacy guidelines that apply to institutions that process financial information.

Protecting Customer Information

Protecting customer information is essential to delivering our privacy commitment. Safeguards to protecting information consists of physical, electronic and procedures. Employees will be allowed access to information only when their jobs require it.

Personally Identifiable Information to safeguard may include:

 Personal Debt Information (Credit Card / Loan Account Numbers & Balances)

  • Personal Information (Social Security Number, Address, Phone, E-Mail Address, Salary, Pay Period, Employer, Occupation, Age, Birth Date, Gender)
  • Demographic Information (Age, Birth Date, Gender)
  • Personal Budget Information (Assets, Monthly Expenses, Other Income)

This information is stored to use in counseling sessions, qualify the User for specific programs, make payments on the User’s behalf, provide the User an overview of where Users’ money is spent, work with Creditors and/or utilize for internal analysis only.

Release of Information to Third Parties

(In the event an employee is unsure as to whether to disclose customer information, the employee is to seek assistance from his/her supervisor, Interim Executive Director or the CFO.)

 Information to third parties is disclosed when required as follows:

  • Service Providers – Information with third party companies that perform services on our behalf or to other financial institutions with whom we have contractual agreements.
  • As Permitted/Required by Law – Information with third parties as permitted or required by law. The Company reserves the right to release such information to law enforcement or other included governmental offices as the Company, in its sole and absolute discretion, deem necessary to comply with the law.
  • Other Third Parties – Other third parties that may receive information include financial companies and non-financial companies, such as homebuilders, retailers, mortgage companies, down payment assistance providers, employee assistance providers, which may offer products or services that may be of interest clients.
  • Compilation of data and aggregate information received will not be disclosed in a manner that would personally identify the customer in any way.
  • Access to nonpublic personal information about customers is limited to only those employees that provide services to the customer.
  • Disclosure of any nonpublic personal information about customers or former customers to anyone as permitted by law (for instance, if the Company is compelled by legal process).

BBB ONLINE INVOLVEMENT NOTIFICATION

FCF participates in the Council of Better Business Bureau’s BBBOnLine Privacy Program, and complies with all BBBOnLine Privacy standards. By participating in the Council of Better Business Bureau’s BBBOnLine Privacy Program, FCF has made a commitment to meet the program’s strict requirements regarding how employees treat customer information and have it verified by BBBOnLine. Further information about this program and its dispute resolution process is available at http://www.bbb.org/council/about/privacy-policy.

FOR CUSTOMERS PARTICIPATING IN A DEBT MANAGEMENT PROGRAM

  1. If intervention with creditors is required on customer’s behalf through a Debt Management Program or a similar program, the customer’s express consent must be obtained to disclose with creditors nonpublic personal information about the customer. The customer cannot be assisted with a Debt Management Program without his/her consent to share information with his/her creditors.
  2. Access to nonpublic personal information about customers is limited to only those employees that provide services to the customer.
  3. Disclosure of any nonpublic personal information about customers or former customers to anyone as permitted by law (for instance, if the Company is compelled by legal process). 

Access to Customer Information

  • FCF automatically encrypts personal information in transit from the customer’s computer to the Company’s using the Secure Sockets Layer protocol (SSL) with an encryption key length of 128-bits.
  • Customer information will reside on a server that is heavily protected. Physical, electronic and procedural safeguards that comply with federal regulations to guard client information shall be maintained. Servers sit behind an electronic firewall and are NOT directly connected to the Internet.

Only authorized employees are permitted access to customer information. Authorized employees have been trained on how to handle information properly and are subject to strict limitations and guidelines in the handling of that information.

Privacy

  • Customers have the ability to view or update personal information, creditor information and bank account information any time by logging in to their FCF account at http://www.aaafaircredit.org/login.asp.
  • Customers have the ability to review FCF’s Privacy Policy anytime by clicking on the Privacy link at the bottom of the FCF website or by going to: http://www.faircredit.org
  • Customers may contact FCF about its privacy practices at 1-800-351-4195.

Using and Sharing Customer information

Industry Research: Information may be analyzed and aggregated internally for the purposes of compiling statistics, evaluating trends in the marketplace, and evaluating the overall effectiveness of services.

Technical and product support: Technical and product support requires a name and e-mail address. Contact information is used to contact customers regarding service updates or specific support questions and to ask for feedback on products and services. Customers have the right to request to stop receiving such communications.

Customer Satisfaction: Customer surveys will be requested upon completion of a service or from time to time. Customers have the right to opt out of participating in the survey. Any information gathered from the customer survey may be used to conduct research and improve performance levels of efficiency.

Resource Links: FCF Web sites may contain links to other sites. FCF is not responsible for the privacy practices of other sites. Users should be encouraged to be aware when they leave our site to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s Web site. Privacy statements of our partners should be reviewed by customers to determine how they will use the information they collect. FCF is not responsible for the actions of any third party.

Referrals: If users elect to use FCF referral service for informing others about FCF’s site or products, employees shall ask for a name, phone and e-mail address for the user and for the person/people being referred. FCF will contact the referred party/parties using the supplied information. The referred party may contact FCF directly to request the removal of this information from the referral database.

Former customers: Employees shall treat information concerning former customers the same way employees treat information about current customers. Access to customer information: FCF does not share personally identifiable information with third parties except as explained in this privacy statement or service agreement. The information provided by customers will only be shared under limited circumstances.

Service Providers: In some cases, FCF employs or works with service providers such as consultants, temporary workers, third-party software developers, internal auditors or outsourcers to complete a business process or provide a service on FCF’s behalf. For example, FCF may use service providers to process electronic payment disbursements, mail processing, or provide software applications. These services may require some information. Employees will only share information that the service provider must have to perform the requested services. For example, a service provider who delivers products on FCF’s behalf would need to have a delivery address. However, these service providers are strictly prohibited from using customer information for any purpose other than to act on behalf of FCF.

 

For legal reasons. In some cases, employees may be required to disclose certain information to comply with the law, an investigation or a legal process, such as a court order or subpoena.

In case of a merger or acquisition. Customer information may be transferred in connection with a sale, merger, transfer, exchange or other disposition (whether of assets or otherwise) of all or a portion of a business of FCF.

Employees may send site and service announcement updates. Customers are not able to unsubscribe from service announcements, which contain important information about service. Employees communicate with customers to provide requested services and in regards to issues relating to customer’s account by phone or e-mail.

DOES OUR WEBSITE COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

FCF is committed to protecting the privacy of children. FCF’s Website is not designed for or directed to children under the age of 13. Employees shall not collect Personally Identifiable Information from any person he/she actually knows is under the age of 13.

DOES THIS PRIVACY POLICY APPLY WHEN CUSTOMERS LINK TO OTHER WEBSITES?

FCF’s website contains links to other websites not owned or operated by FCF. FCF will attempt to make it obvious to customers when they leave FCF’s Website and enter these websites by opening a new browser or otherwise notifying the customer that he/she is leaving the FCF Website. FCF is not responsible for the privacy practices of such websites. Employees should encourage customers to be aware when the FCF Website links to other websites and to read the privacy policies or statements of each and every website. This Privacy Policy applies solely to information collected by FCF Website.

IS THE INFORMATION COLLECTED ON FCF’s WEBSITE SECURE?

Customer information (including Personally Identifiable Information) is to remain as secure as possible. Employees shall strive to provide secure transmission of customer information from their computer to FCF servers through industry-standard techniques. To help ensure the integrity and privacy of the Personally Identifiable Information the customer provides via the Internet, at the time of enrollment in the Debt Management Program, FCF utilizes Secured Socket Layer (SSL) encryption technology in transmitting such Personally Identifiable Information over the Internet to FCF servers. Secure servers located in a controlled, secure environment, protected from unauthorized access, use or alteration stores the Personally Identifiable Information. Only employees who need access to customer information to perform a specific task or function are granted access to such information. No personal data shall be stored on web servers. Sensitive information is encrypted within FCF’s database, to ensure internal security. All employees must abide by this Privacy Policy and are to be kept up-to-date on security practices. Any employee who violates this Privacy Policy is subject to disciplinary action, up to and including termination.

Notwithstanding the above commitments to protect customer information (including Personally Identifiable Information) from loss, misuse or alteration by third parties, FCF shall inform customers that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart FCF’s security systems. Employees cannot ensure or warrant the security and privacy of any information the customer transmits, and the customer does so at his/her own risk.

FCF employs industry-standard physical, electronic and procedural security safeguards to help protect the personally identifiable information that customers provide FCF from loss, misuse or unauthorized alteration. Whenever employees prompt customers to transmit sensitive information, such as an account number, FCF supports encryption of customer data as it is transmitted. FCF uses the latest technology to protect customer account information from exposure to unauthorized persons. Below are some of the components of this security system:

  • A username and password are required to access the FCF Member Service Center.
  • After entering a username or password incorrectly three times, access to an account is blocked.
  • Up to 256-bit encryption scrambles your sensitive transmissions made via the Internet.

Customers are responsible for protecting the secrecy of his/her Password in accordance with the terms contained in the Service Agreement. Employees shall recommend customers to not store secure pages in his/her cache or leave his/her computer unattended while logged in to the FCF online Member Service.

Although no security measures are foolproof, FCF works diligently to protect personally identifiable information stored on the sites’ servers from unauthorized access using industry-standard available computer security products, such as firewalls and carefully developed security procedures and practices.

Correcting and updating customer personal information: At FCF’s Web site, FCF provides customers the opportunity to update or correct their account. Customers may also review and update their personal account information by phoning FCF Client Support at 1-800-351-4195.

Questions/Concerns: In case of errors or questions, customers can call FCF’s customer service center at (800) 351-4195 or (801) 483-0999. Customers may also email FCF at clientsupport@faircredit.org, or write us at PO Box 3808, Salt Lake City, UT 84110.

When contacting FCF to report a possible error:

  1. Customer must state their name and FCF Customer Identification Number (if applicable).
  2. Customer must describe and explain as clearly as possible the question or why more information is needed. If customers request is orally, employees may require that customers send FCF their question or complaint in writing within 10 business days. FCF will determine whether an error occurred within 10 business days after the customer responds and FCF will correct any error promptly. If FCF needs more time, however, FCF may take up to 45 days to investigate customer’s complaint or question.

HOW WILL CUSTOMERS KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

FCF may amend this Privacy Policy from time to time. FCF will post any changes to this Privacy Policy on the website so that customers will always know what information is gather, how that information may be used, and whether that information will be disclosed to anyone. Employees shall encourage customers to refer back to this Privacy Policy on a regular basis. By using FCF’s Website or any of its products, offerings, features, tools or resources that FCF provides on our Website (collectively, FCF “Online Products”), customers agree to the terms of this Privacy Policy.

WHO DOES THE CUSTOMER CONTACT FCF IF HE/SHE HAS ANY PRIVACY QUESTIONS?

If customers has any questions about FCF’s Privacy Policy or feels that FCF is not abiding by the terms of FCF’s posted Privacy Policy, customers should contact FCF’s Privacy Coordinator by calling 1-800-351-4195.