Last modified October 7, 2014
INFORMATION WE COLLECT:
Important Information for Debtors: We understand that falling behind on financial obligations can be extraordinarily stressful and difficult to navigate. Any interaction with us is an attempt to collect a debt and information provided by you to us may be used for such purposes. That said, we strive to provide Debtors the opportunity to facilitate payment of debts owed through the Sites. In addition to information that you may provide directly to us, we may collect personal information about you from your creditors and/or from third parties/publicly available information.
When you use the Underwriting Program, you will be giving information about your credit to your healthcare provider. YOU SHOULD ENSURE THAT YOU HAVE READ AND RECEIVED A COPY OF YOUR RIGHTS UNDER THE HEALTH INFORMATION PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA”) and your provider’s privacy and other policies. The information entered into the Sites by your provider is maintained only to allow the provider to communicate with Connexus and is not maintained for any other purpose. Your rights with respect to your medical information are governed by HIPAA and the policies and procedures of your individual provider. Your use of the Underwriting Program will be governed by a separate agreement between you and your provider.
HOW WE MAY USE AND SHARE YOUR INFORMATION:
To insure our clients and users of our company’s commitment to legal compliance, Company has enacted written policies and internal controls within our collection procedures to comply with various United States Codes and Acts governing the privacy, handling and dissemination of consumer information, including, without limitation the Gramm-Leach Bliley Act (“GLB”), Regulation P, and the Fair Debt Collection Practices Act (“FDCPA”). We will not use your PII in violation of applicable law.
HOW WE PROTECT YOUR INFORMATION:
Company uses industry standard Secure Sockets Layer encryption on all web pages where personal information is required or where stored. Additionally, we urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. We do everything reasonably possible to protect your information transmitted via the Internet. However, since no transmissions over the Internet or through other content/information sharing devices (such as a smart phone or a tablet) can be absolutely secured, WE DO NOT WARRANT OR REPRESENT THAT WE CAN GUARANTY THE SECURITY OF ANY INFORMATION THAT YOU TRANSMIT TO US AND YOU USE THE SITES AND PROVIDE SUCH INFORMATION SOLELY AT YOUR OWN RISK. In the event of a data or security breach in which your PII may be compromised, we make commercially reasonable efforts to notify you and/or the requisite governmental or other regulatory agency promptly and as required by law.
COMMUNICATING WITH YOU AND ADDITIONAL SECURITY INFORMATION
Hollis Cobb Associates, Inc. and affiliates utilize the latest technology available to increase the service level and effectiveness in debt recovery.
Most communication with our clients is performed via phone conversations. However, lately many of our clients appreciate the benefits of communicating over the internet:
Hollis Cobb Associates, Inc. and affiliates use electronic mail on a regular basis to communicate with the clients we serve. All client service representatives and managers have e-mail accounts that are checked on a regular basis.
Request for all of our standard reports can be submitted through our website, via a password protected screen. Most requests can be filled via an e-mail response, with attachment if needed.
Clients have the ability to view all the active accounts placed with Hollis Cobb and affiliates by dialing into our system at any time. The security we have in place will give our clients access to their accounts only. Clients can review the notes and activities on an individual file since being placed at our agency – clients can even leave a comment on the file for the actual collector to see!
Remote access can only occur after the proper security is set-up, but overall it is safe and simple – all you need is a PC and modem.
Email communication with consumer debtors is only performed with their EXPRESSED PERMISSION (verbal, written, or e-mail.)
In some cases, especially in our commercial collection area, the use of e-mail for communication has proven very efficient to bring an account to resolution.
File Exchanges/Business Placement:
Hollis Cobb and affiliates receives placement of accounts from our clients in many different formats and mediums. Manual placements (copies of over-due invoices) are still favored by many of our existing clients. Other options available include:
Data transfer of information on diskette
E-mail of information
Place of files directly on Hollis Cobb and affiliates FTP server
EDI transmission of industry standard formats through our VAN (i.e. Motor Carrier Standard 210 invoice.)
Hollis Cobb and affiliates have a static IP address which can be positively identified in the event a client wants us to retrieve/place files on their FTP server
Some clients choose to employ PGP Encryption prior to transferring files. Hollis Cobb and affiliates are equipped to comply with this procedure if the need arises.
Hollis Cobb and affiliates pride themselves on working closely with their clients to derive the best solution (for both parties) for data exchange.
Hollis Cobb and affiliates employ data programmers to convert data in your standard format to the record layout needed by our collection management software. Start-up cost of this nature is the responsibility of Hollis Cobb Associates and affiliates.
Hollis Cobb and affiliates treats information technology security as an extremely serious topic. Security precautions include the following:
Firewall protection limiting access to our network by “hackers”
The network containing confidential debtor account information is segregated from our internal PC network and
Manager and Client Services representatives are educated on the use of PGP encryption for exchanges of sensitive data over e-mail.
Company does not knowingly solicit personal information from children or send children requests for personal information. The Sites are intended for a general audience over the age of 18 only. We do not knowingly collect information from children under the age of eighteen  and we will delete any PII collected that we determine to be of a child less than eighteen  years of age. If you are not at least age 18, you are prohibited from using the Sites!
REVIEW AND CORRECTIONS TO YOUR PII
YOUR ACCEPTANCE OF THIS POLICY