Privacy

Last Updated Date: October 19, 2020

Consumer Credit Counseling Service of Maryland (“CCCSMD,” “we,” “us” or “our”)  is a non-profit community service organization that provides credit counseling, housing counseling, educational programs/seminars, and debt management plans. This Privacy Policy applies to the websites and services operated by CCCSMD, including https://cccsmd.org/, where this Privacy Policy is posted (collectively, the “Sites”). BY USING THE SITES, YOU CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, TO OUR PROCESSING OF PERSONALLY IDENTIFIABLE INFORMATION FOR THE PURPOSES STATED BELOW, AND TERMS OF USE. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TERMS OF USE, PLEASE DO NOT USE THE SITES.

Information Collected

This Privacy Policy applies only to information collected on the Sites. “Personally Identifiable Information” or “PII” is information that identifies you personally, such as your name, address, telephone number, or email address. CCCSMD collects and stores the PII that you have provided to us. We will retain PII provided for as long as it is needed to fulfill the purpose for which it is collected. Some examples of manners in which we may collect your PII on the Sites include:

(1) Active Collection

We collect and store PII from you directly, at the time you supply information to us via the Sites. If you do not want CCCSMD to collect your PII, please do not provide it to us. The information we actively collect from you may include:

  • Email address, first and last names, telephone number, and address information if you provide it via the Sites, such as to sign up for services or an account;
  • Email address, first and last names, telephone number, and address information if you donate to CCCSMD via the Sites;
  • First and last name, date of birth and email address if you choose to participate in in-person workshops or web-based workshops;
  • Financial information, such as your total debt information, income, living expenses and PII concerning your financial circumstances;
  • Demographic information such as your gender, age, zip code and interests, which you voluntarily provide to us on the Sites. We may use this information to analyze trends to ensure the information provided by the Sites meets your needs; and
  • First and last name, telephone number, and email address if you contact us with a question.

(2) Passive Collection

We may collect information passively while you are visiting or interacting with the Sites. We call this “passive” collection because you may not know this information is being collected. The information we passively collect from you may include:

  • Internet Protocol (IP) address – Your IP address is a number that lets computers attached to the Internet know where to send you data — such as the webpages you view. We may use this information to deliver our webpages to you upon request.
  • Cookie – A “cookie” is a small text file that may be used to collect information about your activity on the Sites. For example, when someone visits a page within the Sites, a cookie may be placed on the user’s machine (if the user accepts cookies) or may be read if the user has visited the Sites previously. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Please see our section titled “Cookies” below for more information.
  • Web Beacons (also known as “clear gifs,” “web bugs” or “pixel tags”) – “Web Beacons” are tiny graphics with a unique identifier, similar in function to cookies, and are used to count users who have visited certain pages of the Sites. When used in HTML-formatted email messages, web beacons can tell the sender whether and when the email has been opened. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on web pages.

Cookies

Like many websites, we use “cookies” to ascertain which web pages are visited and how often, to make our Sites more user friendly, and to give you a better experience when you return to the Sites. For example, cookies allow us to save your password so you do not have to re-enter it every time you visit our Sites. Most browsers accept cookies automatically but allow you to disable them. Please check your browser and browser settings to determine where these types of cookies are stored and whether and how they may be deleted. The Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit www.networkadvertising.org to learn more. In any event, if you reject our cookies, you may still use the Sites, but you may be limited in some of the features. We may also work with service providers that use cookies and web beacons to collect information, and to serve advertisements to you across the Internet based on that information.

  • Google Analytics. To help facilitate the delivery of relevant content, we use Google Analytics. Google Analytics uses cookies to report on user interactions on our and others’ websites. We use the data collected for optimizing marketing, refining advertising and/or programming strategies, and generally improving user experience. For more information about Google Analytics and how it collects and processes data, please visit: https://policies.google.com/technologies/partner-sites and instructions on opting out of Google Analytics using a specific plug-in is available at the following link: https://tools.google.com/dlpage/gaoptout. Note that this opt-out is specific to Google activities and does not affect the activities of other ad networks or analytics providers that we may use.
  • We also use Facebook Analytics to measure your use of our Sites, tailor our Sites to your interests, and improve our products and services. Please note, Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://facebook.com/about/privacy/. Please click here if you would like to withdraw your consent.

How We Use Information Collected via the Sites

We use PII that is collected on these Sites primarily for the following purposes:

  • To complete a transaction or service requested by you;
  • To notify you about a material change to this Privacy Policy, if necessary;
  • To notify you about services that may be of interest to you;
  • To contact you in response to sign up forms; or
  • As otherwise disclosed at the time of collection.

How We Share the Information Collected via the Sites

We may share or disclose your PII in the following instances:

  • To fulfill a service to you. For example, if you email us a question, we may use your email address to process your request and respond to your question. As another example, if you authorize us, your PII will be provided to creditors and others to fulfill your requested services.
  • To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Sites and provide other administrative services to us (including, but not limited to, order processing and fulfillment, hosting and website content management system services, and maintaining and analyzing data). Because such unaffiliated third-party service providers that help us administer our Sites may have access to users’ PII, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not submit any PII to us.
  • To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of CCCSMD and its Sites, or act in urgent circumstances to protect the personal safety of our end users.
  • To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets. You grant us the right to disclose or assign the PII collected via the Sites to third parties following completion of such transaction and/or during the assessment process pending transfer. If transferred in such a case, the third party will abide by the terms and conditions of this Privacy Policy.
  • To protect against potential fraud, we may verify with third parties the information collected from these Sites. In the course of such verification, we may receive PII about you from such services.

Except as described in this Privacy Policy, we do not otherwise use, share or otherwise disclose your PII to any third parties. When we do share information with others, we take steps to require them to treat your information securely and in accordance with applicable law.

International Transfer of Information

If you choose to provide us with PII, we may transfer that information to affiliates or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your PII to the United States, which does not have the same data protection laws as the EU and does not offer the same consumer rights and protections as EU law, and by providing your PII you understand that: (i) we will use your PII for the uses identified above in accordance with this Privacy Policy; and (ii) we will transfer your PII to the United States as indicated above, in accordance with applicable law.

Opt-Out

We may communicate with users of the Sites who subscribe to services we offer on a regular basis via email. For example, we may use your email address to confirm your request, to send you notice of payments, to send you information about changes to our services, and to send notices and other disclosures as required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature rather than promotional. However, we provide you the opportunity to exercise an opt-out choice if you do not want to receive other types of communication from us, such as emails or updates from us regarding new services offered on the Sites. The opt-out choice may be exercised by ticking or un-ticking the appropriate box if such checkbox is available at the points where PII is collected or by contacting us. We will process your unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed. You also may opt-out of receiving such emails by clicking on the “unsubscribe” link within the text of the email.

Third Party Websites

This Privacy Policy applies solely to information collected on the Sites. The Sites may contain links to other websites. We are not responsible for the privacy practices or the content of these other websites. If you have any questions about how these other websites use your information, you should review their policies and/or contact them directly.

Security

CCCSMD is conscious of the security concerns of our clients. The online budget section is available through the use of a secure server. The secure server software encrypts the information you input before it is sent to us. The budget information we collect is protected from unauthorized access and will only be used for counseling purposes. We assure you that all information shared both orally and in writing will be managed within legal and ethical considerations. Your personal financial information, such as your total debt information, income, living expenses and personal information concerning your financial circumstances will be provided to your creditors and possibly others with your specific authorization. We may also use aggregated case file information for the purpose of evaluating our services, gathering valuable research information and designing future programs. Your anonymity will be maintained through the use of your client number or by using aggregate data in all circumstances. In all other situations, your information may be released to appropriate individuals or agencies ONLY UPON YOUR WRITTEN REQUEST OR when our staff has been served by a valid subpoena. If you create an account or register on our Sites, you are responsible for maintaining the secrecy of your password at all times.

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to CCCSMD is done at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Sites or providing PII to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Sites. We may post a notice on our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

 Your California Privacy Rights and How We Respond to Do Not Track Requests

The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them.

California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of PII to third parties for their direct marketing purposes. We do not disclose PII to third parties for their direct marketing purposes

Age Limitation

The Sites are not intended for use by persons under the age of 18. If you are under the age of 18, please do not use the Sites unless you have appropriate consent.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy from time to time. When we do, we will revise the “last updated on” date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we will send a notice to the primary email address specified in your account and/or place a prominent notice on the Sites.

Contact US

If you have any questions about this privacy policy or our privacy practices, please contact us at:

CCCSMD
6315 Hillside Court, Suite B,
Columbia MD 21046

1-800-642-2227
info@cccsmd.org