The Commercial Collection Corporation of New York, Inc. – Privacy Policy

Effective Date: May 28, 2026

1. Introduction

This Privacy Policy explains how The Commercial Collection Corporation of New York, Inc. (CCCNY or “we”) collects, uses, discloses, and protects information about individuals and entities who visit or interact with our website (the “Site”) and related online services. This Privacy Policy also describes your options as a visitor to this website and rights that you have regarding your information.

In certain situations, including when we provide commercial collection services on behalf of our clients, we may process information about debtors or account holders under instructions from a CCC client (the entity to whom the debt is owed or the debt owner). In those situations, our client typically determines the purposes and means of processing the information that it has regarding the debtor. If you are a debtor/account holder and have questions about how your information could be used, please review the privacy notice of the creditor and contact them regarding your privacy rights. We will also respond to requests as required by law and applicable contracts.

2. Key Definitions

For purposes of this Privacy Policy:

• Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) to an individual.
• Usage Data means information collected automatically when you use the Site, including but not limited to, log data and device/connection information.
• Cookies are small text files stored on your device that help websites function by providing analytics and identifying preferences.
• Service Provider means a third party that processes information on CCC’s behalf for business purposes (e.g., hosting, analytics, payment processing, customer support).

3. Information CCC Collects

Depending on how you interact with the Site, CCC may collect the following categories of information:

• Identifiers and contact information, such as name, company name, job title, mailing address, email address, and telephone number.
• Account and login information, if the Site offers account functionality (such as username and authentication-related information).
• Payment and transaction information, such as payment method, payment amount, payment date, and limited payment identifiers. If you choose to make a payment through the Site, payment card information is submitted directly to CCC’s payment processor and is handled by the processor in accordance with its privacy policy and terms.
• Credit card information: We do not receive, collect, or store your full credit card number. Credit card payments are processed by a third-party payment processor that is responsible for handling payment card information in a PCI-compliant environment. Any payment information you submit is submitted on your behalf directly to the processor and is subject to the processor’s privacy policy and terms.

• Communications, such as information you provide when you contact us, submit a form, request information, or otherwise communicate with us.
• Job applicant information, such as resume/CV details, work history, education, qualifications, and other information you provide in connection with applying for a job.
• Internet or other electronic network activity, such as IP address, browser type and settings, device identifiers, operating system, referring/exit pages, pages viewed, date/time stamps, and diagnostic data.
• Approximate location information, such as location derived from your IP address.

4. How We Collect Information

• From you when you submit information through the Site, communicate with us, or otherwise interact with us.
• Automatically from your device through cookies and similar technologies when you use the Site.
• From our service providers that help us operate the Site and our business (e.g., website hosting, analytics, customer support, and payment processing).
• From clients and other parties in connection with collection activities and related business purposes, where permitted by law.
• From publicly available sources (for example, public records and business directories), where permitted by law.

5. Cookies, Analytics, and Similar Technologies

CCC and our service providers may use cookies, pixels, tags, scripts, and similar technologies to operate our Site, remember preferences, understand how the Site is used, and enhance security. These technologies may collect information such as your IP address, browser type, device identifiers, and activity on the Site.

You can control cookies through your browser settings and, where available, through any cookie preference tool presented on the Site. If you disable cookies, some features of the Site may not function properly.

Types of cookies we use:

• Session cookies help the Site work during your visit (for example, maintaining your session as you navigate between pages and helping with security-related functions). These cookies typically expire when you close your browser.
• Google Analytics cookies help us understand how visitors use the Site (for example, pages visited, time spent on pages, and how users arrive at the Site) so we can improve performance and user experience.
• Functional & Preference cookies remember choices you make and help provide enhanced features (for example, saving certain preferences so you do not need to re-enter them).

Some content or features on the Site may be provided by third parties (for example, embedded content or analytics providers). These third parties may use cookies or similar technologies to collect information about your online activities over time and across different websites and online services. Their collection and use of information is subject to their own privacy policies.

Google Analytics and automatic data collection: We may use analytics services (such as Google Analytics) to help us understand how visitors use the Site. These services may collect information sent by your browser as part of a web page request, including cookies and your IP address, as well as information such as pages viewed, links clicked, referring/exit pages, browser type, device identifiers, requested URL, referring URL, and timestamp information. We use this information for statistical and operational purposes, such as to administer the Site, measure interest in the Site, and improve performance. To the extent you voluntarily provide Personal Information to us, we may associate it with information collected automatically (for example, to better understand and respond to your requests).

6. How We Use Information

We may use the information we collect for purposes such as:

• Providing, operating, and improving the Site and our services.
• Responding to inquiries, requests, and providing customer service.
• Managing business relationships with clients, vendors, and other business contacts.
• Processing payments and transactions (if applicable) and maintaining related records.
• Communicating with you about updates, administrative information, and, where permitted, marketing communications (you may opt out as described in the message).
• Securing our systems, preventing fraud, and protecting the rights, safety, and property of CCCNY, our users, and others.
• Complying with legal and regulatory obligations and responding to lawful requests.
• Processing job applications and managing recruitment.

7. How We Disclose Information

We may disclose information as follows, and as otherwise permitted by law:

• Service providers who perform services on our behalf (such as website hosting, analytics, communications tools, payment processing, IT support, and professional services). These providers are authorized to use information only as needed to provide services to us.
• Clients and related parties in connection with the collection services we provide and related business purposes, consistent with applicable law.
• Legal and compliance recipients, including law enforcement, regulators, courts, or other parties when we believe disclosure is required or appropriate to comply with law, enforce our agreements/policies, or protect rights, safety, and security.
• With your direction or consent, such as when you ask us to share information with a third party.

We also do not disclose Personal Information to any third parties for their own direct marketing purposes unless you direct us to do so or we provide notice and obtain consent where required by law. To the extent we send marketing communications, those are communications from CCCNY (and you can opt out as described in the message).

8. Legal Bases for Processing (If Applicable)

If you are located in a jurisdiction that requires a legal basis for processing (such as the European Union), we process Personal Information when: (a) it is necessary to perform a contract or to take steps at your request prior to entering into a contract; (b) it is necessary to comply with a legal obligation; (c) it is in our legitimate interests and those interests are not overridden by your rights; or (d) you have provided consent, where required.

9. Your Privacy Rights and Choices

Depending on where you live and the nature of our relationship with you, you may have certain rights regarding your Personal Information, subject to applicable law and verification of your identity. These rights may include the right to:

• Request access to and a copy of your Personal Information.
• Request correction of inaccurate Personal Information.
• Request deletion of your Personal Information in certain circumstances.
• Opt out of certain marketing communications (by using the unsubscribe mechanism in our messages, where applicable).
• In some jurisdictions, request information about disclosures of Personal Information, or opt out of certain disclosures/processing.
• Not be discriminated against for exercising applicable privacy rights.

To submit a request, please contact us using the information in the “Contact Us” section below and include sufficient detail for us to understand and respond to your request. To protect privacy and security, we may take steps to verify your identity before responding.

Where permitted by law, you may designate an authorized agent to submit a request on your behalf. We may require proof of the agent’s authority and may also verify your identity directly with you.

10. Do Not Track

Some browsers transmit “Do Not Track” (DNT) signals. Because there is not yet an industry-standard approach to honoring DNT signals, our site does not respond to DNT signals at this time.

11. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this privacy policy, including to provide services, maintain business records, comply with legal obligations, resolve disputes, enforce agreements, and protect our rights. Retention periods vary depending on the type of information and the context in which it was collected.

Where applicable (for example, for visitors in and citizens of the European Union), you may request deletion of certain information you have provided to us. In those cases, and subject to legal requirements and exemptions, we will retain information for as long as needed for the purposes described above, unless an earlier deletion is required by law or we determine that continued retention is no longer necessary or appropriate.

12. Email Communications

If you choose to correspond with us by email, we may retain the content of your messages, your email address, and our responses. We are committed to keeping email addresses confidential and do not sell or rent email lists. If we send you commercial email communications, we will comply with applicable law (including the CAN-SPAM Act, where applicable) by providing a clear way to opt out (for example, an “unsubscribe” link or instructions). Please note that we may still send you non-marketing, administrative messages as permitted by law.

13. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

Where the Site collects sensitive information (such as through payment-related forms, if applicable), we use encryption in transit when supported by your browser and our systems (for example, via HTTPS, which you may be able to verify by looking for a lock icon in your browser’s address bar). We also help protect information offline by limiting access to personal information to employees and contractors who need it to perform their job responsibilities, and by using security controls appropriate to the nature of the information.

14. International Transfers

If you access the Site from outside the United States, please note that your information may be transferred to, stored in, or accessed from the United States or other jurisdictions where our service providers operate. Where required by law, we use measures intended to provide appropriate safeguards for such transfers.

15. Children’s Privacy

The Site is not directed to children under 13, and we do not knowingly collect Personal Information from children under 13. If you believe a child has provided Personal Information to us, please contact us and we will take appropriate steps to address the issue.

16. Links to Other Websites

The Site may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties, and your use of third-party sites is subject to their terms and privacy policies. We encourage you to review the privacy policy of every site you visit.

17. Sharing or Posting Content

If the Site allows you to post comments or otherwise share information publicly, please be aware that anything you submit may be visible to others and may be collected and used by third parties. Use caution before posting information you consider private or confidential.

18. Changes to This Privacy Policy

We may update this privacy policy from time to time. We will post the updated version on this page and update the Effective Date above. Changes are effective when posted unless otherwise stated.

19. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

The Commercial Collection Corporation of New York, Inc.
34 Seymour Street
Tonawanda, NY 14150
800-873-5212
Email: info@commercialcollection.com