PRIVACY POLICY

This Privacy Notice sets forth the information gathering, use, and dissemination practices of Transworld Systems, Inc. (“TSI”) in connection with the website located at www.tsico.com (the “Site”). This Privacy Notice addresses TSI’s practices regarding information collected only directly through or from its Site – it does not address or govern any information gathering, use, or dissemination practices related to information collected other than directly through or from its Site, including, without limitation, from or via telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media.

This Privacy Policy is incorporated into TSI‘s Terms and Conditions for the Site, which must be reviewed and accepted by you.

The Site is not intended for children under the age of 18. It does not knowingly collect personal information online from visitors in this age group.

IMPORTANT DISCLOSURE ABOUT THE FDCPA: Nothing in this Site Privacy Notice is intended to contradict your rights under the Fair Debt Collection Practices Act. TSI will not disclose any information to third parties that is otherwise prohibited by the FDCPA.

TSI collects, uses, and stores information on the domain you use to access its Site, the Internet address of the site from which you linked directly to its Site, and the date and time of your visit to its Site. This information may be used to measure the number of visitors to the various pages on the TSI Site, to help make improvements to the information contained on the site, and to better serve site visitors through special marketing and service programs, among others. TSI also collects, uses, and stores the e-mail addresses of users that communicate with TSI via e-mail, information knowingly provided by Site users, and information regarding which Site pages users’ access. TSI may also use Internet cookies and other identifiers or methods of web analysis (such as Google Analytics) to gather, store, and track certain information related to your visit to and activity on the Site. If you are uncomfortable with the idea of your information being used in this way, most computer systems and web browsers offer privacy settings and options, such as disabling cookies or opting for “Do Not Track” features. TSI does not override these settings or options, and encourages you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products or benefits on the Site, you may be required to provide TSI with certain information, including some types of personally identifying information such as your email, your address, and your phone number. If you do not wish to provide such information through the Site or if you opt to utilize the aforementioned privacy features of your computer system or web browser, you may be unable to obtain certain content, features, services, products or benefits of the Site.

Personal information contained in e-mail sent by individuals may be used by TSI to answer questions, follow-up on suggestions or complaints, process requests or transactions, or improve the level of service TSI provides.

TSI may share personally identifiable information obtained on its Site with any company or marketing group internal to TSI or its affiliates. Except as provided below, TSI does not share any personally identifiable information obtained on its Site with or sell information obtained on this Site to any company or marketing group external to TSI and its affiliates. TSI may, however, share aggregate information with other persons or entities for purposes determined by TSI to be appropriate.

TSI may disclose identifiable information (i) to another entity with which TSI enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase, (ii) to a third party pursuant to a subpoena, court order, or other form of legal process or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process, or (iii) to a third party if determined by TSI in its sole judgment that such disclosure is appropriate to protect the life, health, or property of TSI or any other person or entity. (The foregoing is not intended to obviate or displace any legal obligations or duties applicable to TSI.) Your personal information and data, whether personally identifying or not, may also be provided to third parties that contract with TSI to provide products, information or other services that TSI believes that visitors to the Site may be interested in obtaining. While TSI may undertake efforts to see that any third party to which TSI discloses personal information is under an obligation to use the personal information solely for the purposes for which the information was disclosed such third parties are independent third parties over which TSI exercises no control. TSI is not responsible for, and will not be liable for, the conduct, actions, omissions, or information handling or dissemination practices of third parties.

Except as necessary for TSI to provide the services, information, or products requested by a Site user, or except for the disclosures identified in the preceding paragraph, the user may opt out of having his or her personally identifiable information, which has been voluntarily provided to TSI through or from its Site, prospectively retained by TSI, used by TSI for secondary purposes, or disclosed by TSI to third parties, by contacting TSI via postal mail at the address set out below or at the following e-mail address: TSI-Marketing@tsico.com. This provision does not apply to collection of the type of web browser used to visit the Site or to information provided or collected that does not meet the description hereunder.

While TSI may undertake efforts to see that another party to which TSI shares personal information is under a contractual obligation to use the personal information solely for the purposes for which the information was disclosed by TSI, TSI exercises no control over such parties and TSI is not responsible for their conduct, actions, omissions, or information handling or dissemination practices.

California Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request by mail to the address below or to the following email address: TSI-Marketing@tsico.com.

The Site may also contain links to third party websites, for the convenience of users in locating information, products, or services that may be of interest. If you access a third-party website from a link on this Site, any information you disclose on that website is not subject to this Privacy Policy. It is possible that these links may be used by third parties or others to collect personal or other information about you. TSI is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. TSI does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties.

E-mail posted or sent through this Site may not be secure against interception by unauthorized individuals. To protect against interception by unauthorized individuals, we will not respond to e-mail requests concerning accounts placed for collection. Therefore, if you are communicating with TSI regarding a debt that has been placed for collection with Transworld Systems Inc., all correspondence regarding that account should be sent by U.S. Postal Service. Be sure to include your name, your mailing address, the TSI account number, creditor name, and creditor account number so that we may process your inquiry and respond promptly. Without complete information, we will be unable to respond to your request.

TSI has implemented physical, electronic, and procedural security safeguards to protect against the unauthorized release of or access to personal information. Additionally, to further safeguard this information, our employees are asked to agree to TSI’s Standards of Conduct and Work Rules as well as Confidentiality Agreements, and are subject to disciplinary action up to and including termination of employment if they fail to follow signed agreements. However, the confidentiality of any communication or material transmitted to or from TSI via the Site or via email cannot be, and is not, guaranteed. You acknowledge that the technical processing and transmission of the Site’s content may be transferred unencrypted and involve: (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices. Accordingly, TSI is not responsible for the security of information transmitted via the Internet.

You have the right to control whether we share some of your personal information. Please read the following information carefully before you make your choices below.

We will collect the IP Address for internal security and other proprietary purposes. We will do so even if you have included a Do Not Track request. We do not release this data outside of our corporate environment nor utilize this data other than for internal purposes.

You have the following rights to restrict the sharing of personal and financial information with our affiliates (companies we own or control) and outside companies that we do business with. Nothing in this form prohibits the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.

Restrict Information Sharing With Companies We Own or Control (Affiliates): Unless you contact us and state otherwise, we may share personal and financial information about you with our affiliated companies.

Restrict Information Sharing With Other Companies We Do Business With To Provide Financial Products And Services: Unless you contact us and state otherwise, we may share personal and financial information about you with outside companies we contract with to provide financial products and services.

You may make your privacy choice(s) at any time. Your choice(s) will remain unless you state otherwise. However, if we do not hear from you we may share some of your information with affiliated companies and other companies with whom we have contracts to provide products and services.

To exercise your choice to restrict information sharing, please contact us by doing one of the following:

1. Call us toll free: (877) 282-1250
2. Or, you may submit them online (your privacy preferences) using the Questions/Complaints Inquiry Form on our Consumer Support
3. Or, you may print, complete and send back the form below to us at:

PO Box 15618
Wilmington, DE 19850

Opt-out Form

Please print a copy of this form and complete it in pen and printed handwriting. Mail it to the address noted above. You may want to make a copy for your records.

TSI reserves the right at any time to modify, alter or update this Privacy Policy. Your use of the Site following any changes means that you agree to follow and be bound by the Privacy Policy as changed. Any change to this Privacy Policy shall be effective as to any visitor who has visited the Site before the change was made. It is the obligation of users visiting the Site before the change to learn of changes to the Privacy Policy since their last visit.

CALIFORNIA RESIDENTS: PRIVACY POLICY NOTICE