Privacy Policy

Windham Professionals Privacy Policy

 (Last updated and effective January 1, 2020)

This Privacy Policy describes how we collect, use, and disclose the information we collect through the Windham Professionals, Inc. websites. California consumers: please see “California Consumer Privacy Act (“CCPA”) Policy”, below for a description of our practices regarding the collection, use, disclosure, and sale of personal information of California consumers and rights under the CCPA.

We operate this website to provide information to visitors, consumers, and customers about us and our services, solutions, and other information. As a customer, you may use our website to access accounts placed with us; as a consumer, you may use our website to access your account. We are committed to protecting your privacy online.

By using the website, you agree to this Privacy Policy. If you do not agree, please do not use the website.

A.  Information We Collect Through Our Website

We collect your information when you voluntarily provide it to us, such as when you use our services, register for account access, input data on your account, or submit questions or other data to us through the website. We may store your information or include such information in databases owned and maintained by our affiliates, agents or service providers, all subject to the terms of this Privacy Policy. However, data with respect to a consumer will not be communicated to a third party if doing so is prohibited by applicable laws, such as the federal Fair Debt Collection Practices Act or similar State laws.

 

Such information may include, without limitation, contact information, such as your name, address, email, phone number, or other information that identifies you; financial information, such as credit or debit card numbers, bank account numbers, and billing addresses; usernames, passwords, or similar security information provided when you access your account and job application information, such as your resume, references, and other information you provide to us during the application process. Depending on what services you seek, some information may be mandatory in order to utilize certain services. You may choose to not provide mandatory information required for certain services, and in such event, you will not be allowed to utilize those services.

B.    How We Use Information Collected Through Our Website

We use your information mainly to operate our business, provide you with our services, and communicate with you. We use your information:

To provide you with our services, such as carrying out transactions, processing payments, monitoring and securing our websites and services, and detecting and preventing fraud;

To provide you with customer service, such as addressing and resolving questions, concerns, requests, or disputes;

For communications, such as sending you emails, text messages, or phone calls relating to our services that we believe may interest you, or positions available for job applications, except that we will not communicate with a consumer if doing so is prohibited by applicable law such as the federal Fair Debt Collection Practices Act, the Telephone Consumer Protection Act, or similar State laws; and

For human resources purposes, such as evaluating your job application.

Some of our services will give you the opportunity to opt out or stop receiving communications from us. To stop the receipt of future communications from us, you may email us at ConsumerSolutions@windhampros.com, write to us at Windham Professional Inc., 380 Main Street, Salem, NH 030709 or call us at 1-800-394-4300.

C.  Our Disclosure of Information Collected Through Our Website

We share your information to operate our business, provide you with our services, and communicate with you. We may share your information:

  • With our affiliates, subsidiaries, or service providers consistent with the purposes identified in this Privacy Policy. For example, we may retain third parties to perform certain functions, such as payment processing, fraud prevention, mailing information, or maintaining databases for us, and your information may be shared with those third parties;
  • If we sell or buy businesses or assets, or engage in a merger, reorganization, dissolution or similar event and your information is part of the transferred assets or business units;
  • Where we are required to disclose your information to regulators, law enforcement agencies, or other government agencies. We may be required to disclose your information to comply with valid legal process, by law, where we believe in good faith that disclosure is necessary to comply with our obligations under law or agreements, or to protect and defend our rights or property (including to assure or enforce compliance with this Privacy Policy and applicable law or to protect against unauthorized use of our website or information contained on it) or the rights or property of others, or to protect against or mitigate our liability; and
  • With your consent.

However, data with respect to a consumer will not be communicated to a third party if doing so is prohibited by applicable law, such as the federal Fair Debt Collection Practices Act or similar State laws.

D.    Exclusions

This Privacy Policy does not apply to any of your information collected by us other than through our website. This Privacy Policy does not apply to any unsolicited information you provide to us through the website or through any other means. This includes, without limitation, information posted to any public areas of the website, such as bulletin boards or forums, any ideas for new products or modifications to existing services, and other unsolicited submissions. All unsolicited information is non-confidential, and we are free to reproduce, use, disclose, and distribute unsolicited information to third parties without limitation or attribution.

E.    Third-Party Sites

This Privacy Policy applies only to this website and not to any third-party websites for which this website may contain links. The privacy practices of those websites may differ from the privacy practices of Windham as described in this Privacy Policy. Windham has no control over those websites and links from this website do not imply that Windham endorses or has reviewed those third-party websites or takes any responsibility with respect to them or the information you may provide in accessing or using them.

F.    Security

Windham takes reasonable steps designed to protect the security, confidentiality, and integrity of the information we collect. We have implemented various physical, electronic, and managerial measures, to provide your information with reasonable protection from accidental loss or destruction, improper use, alteration, or disclosure. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us over the Internet or via email.

G.    Accessing, Updating or Correcting Information Collected Through Our Website

You can use this website without providing any information, but in that event, you may not be able to use certain website features, such as account access or applying for employment. You can adjust your communication preferences by using your account features or the hyperlinks sent to you via email.

If you wish to obtain a copy of the particular information you have provided to us, or if you become aware that any information you have provided is incorrect and you would like us to correct it, you may be able to correct it using your account or using the hyperlinks sent to you via email. You may also contact us at ConsumerSolutions@windhampros.com. Before we are able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us respond to your request. We will attempt to respond to your request within a reasonable timeframe.

H.    Changes to the Privacy Policy

We may change this Privacy Policy from time to time by posting a changed version of the Privacy Policy on this website or a website that replaces this website. When we do so, we will change the effective date of the Privacy Policy. If we make material changes to our Privacy Policy, we will notify you either by a prominent notice on our website or emailing you about those changes. Your continued use of our website means that you have accepted our updated Privacy Policy. Please review our website and policies frequently to learn how Windham uses your information.

I.    Other Terms

Your use of this website is subject to Windham’s Terms of Use, which is incorporated herein by reference. You may read the current version of our Terms of Use by selecting the “Terms of Use” link on our website, www.windhampros.com.

You must be at least 18 years old to use the website or our services. We do not knowingly collect, use, or disclose data about visitors or customers that are under 13 years of age. Please notify us, at either the email or postal address indicated below, if you believe that a child under the age of 13 has provided information to us through this website and we will promptly remove that information and not use it except as permitted by applicable law.

II.    California Consumer Privacy Act (“CCPA”) Policy (Last updated and effective January 1, 2020)

The following describes Windham Professionals, Inc.’s (“Windham”) practices regarding the collection, use, disclosure, and sale of personal information of California consumers and the rights of California consumers regarding their personal information as required under the California Consumer Privacy Act of 2018 (“CCPA’). California consumers with disabilities can receive a copy of this policy by calling Windham at (number) or writing to (address) or sending an email to (address)

A.    Information Windham Collects, Sources of Information and Uses

Windham collects the following categories of personal information:

–        information about the consumer debt placed with Windham, such as the nature, status and amount of the debt, payments made prior to placement with Windham, medical information including insurance (in the case of medical debt), “references” provided by the consumer, and to whom the debt is owed.  This information is provided to Windham by its clients.

–        information that identifies the consumer such as name, date of birth, social security or other identifying number, military and/or professional status, education.  This information is provided to Windham by its clients and may be provided to Windham by the consumer.

–        consumer contact information such as postal address, phone number and email address is provided to Windham by the consumer, by our client, or by third parties such as the consumer’s employer, neighbors or persons provided to the creditor as “references”;  other persons who are obligated on the debt such as co-signers or guarantors; letter vendors and data service providers such as credit reporting agencies and location information (“skip trace”) service providers.

–        information about payments made on the debts after placement with Windham including amount and date and account, credit and/or debit card number, and including usernames and passwords, or similar security information, needed to utilize Windham’s payment portal.  This information is provided to Windham by the consumer.

–        financial information such as savings, income, expenses, taxes and family size is provided to Windham by the consumer.

–        credit score information is provided to Windham by credit reporting agencies.

–        information regarding consumer’s employment is provided to Windham by the consumer, by our client, or by third parties such as the consumer’s employer, neighbors or persons provided to the creditor as “references”;  other persons who are obligated on the debt such as co-signers or guarantors; and data service providers such as credit reporting agencies and location information (“skip trace”) service providers.

–        medical information including health insurance (in the case of medical debt placed with Windham).  This information is provided to Windham by the consumer and/or our client.

This information is collected, used and disclosed by Windham only for the benefit and on behalf of Windham’s clients for the purpose of identifying, locating and contacting consumers and to assist consumers in addressing and resolving their debts.  Windham does not share or use any of this information in a manner that would constitute a violation of applicable federal or State law including the federal Fair Debt Collection Practices Act.

 B.    Windham does not and will not sell any consumer personal information.

C.    Rights Under the CCPA (The following is not a complete list of all consumer rights under the CCPA).

 

Under the CCPA, California consumers have the right to request disclosures regarding the collection, use, disclosure and sale of their personal information.

 

Under the CCPA, California consumers also have the right to request the deletion of their personal information; however, the CCPA also provides for exceptions to compliance with such requests.

 

All requests for disclosure or deletion with respect to personal information should be directed to the Windham client on whose behalf the information was collected.  Requests can be directed to Windham by calling us toll-free at (1-855-270-2733), sending an email to us at (consumersolutions@windhampros.com), or writing to us at (380 Main st, Salem, NH 03079) but will be forwarded to the client for response.  Client identity is provided in the Windham collection notices sent to the consumer and can be provided to the consumer by calling Windham toll free at (number), sending an email to (Consumersolutions@windhampros.com) or writing to Windham at (380 Main St, Salem, NH 03079).

 

Requests should include information identifying the consumer and the subject account so that the request can be verified.  Requests for deletion should include the information the consumer wishes to have deleted.

 

The CCPA requires requests to be verified by matching the consumer personal information provided in the request with information in client records, and the consumer must be notified if the request cannot be verified based on the information provided.   Depending on the request, two or more pieces of personal information and support may be required for verification.

 

California consumers also have a right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

 

California consumers can designate an authorized agent to make a request on the consumer’s behalf either by providing the agent with written permission, a copy of which is  provided along with adequate information identifying the agent for verification purposes,  or where the agent has power of attorney pursuant to California Probate Code sections 4000 to 4465.

 

III.    If You Have Questions

If you have any questions or concerns regarding our Privacy Policy or CCPA Policy, please contact us at (number) or via email to ConsumerSolutions@windhampros.com, or if you prefer, by writing to us at the following address: (Windham Professionals, Inc., 380 Main Street. Salem, NH 03079