Privacy Policy
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Recovery Management Systems Corporation (“RMSC”) provides bankruptcy-related services and values the trust that its clients have placed in RMSC to provide those services efficiently and effectively. RMSC understands that much of the information that clients provide to it is nonpublic personal financial information relating to the clients’ customers (“Account Debtors”), the disclosure of which is regulated under federal, and in some cases state, law. RMSC is committed to protecting the confidentiality of this information in compliance with all applicable laws and regulations.

Confidentiality Generally

In connection with providing bankruptcy-related services to its clients RMSC will use commercially reasonable efforts to maintain the confidentiality of the confidential information it maintains, including, but not limited to, information concerning business objectives of its clients, specific bankruptcy-related services provided by RMSC to any particular client, operating procedures of its clients, and the names, addresses and other nonpublic personal information of Account Debtors, computer software, other proprietary technological information, and the terms of any contract between RMSC and any of its clients (collectively, “Confidential Information”). Notwithstanding the foregoing,
(a) RMSC may disclose to an Account Debtor any Confidential Information that pertains to that Account Debtor, and
(b) Confidential Information shall not include any information that (i) is already known to RMSC prior to the time it is provided to RMSC in the performance of its bankruptcy-related services, (ii) is obtained by RMSC free of any confidentiality obligation,
(iii) was independently developed by or on behalf of RMSC;
(iv) was publicly known before it was provided to RMSC in the performance of its bankruptcy-related services, or
(v) becomes publicly known after disclosure to, and without fault of, RMSC.

Confidential Information shall be used by RMSC solely in the performance of RMSC’s obligations under any agreement between it and its client. RMSC will take commercially reasonable steps to ensure that its officers, directors, shareholders, employees, and agents take such actions as shall be necessary and advisable to preserve the confidentiality of the Confidential Information.

Nonpublic Personal Information (“NPI”) of Account Debtors

An Account Debtor’s NPI is subject to special protection under federal law and, in some instances, state law.

Account Debtors are not customers or consumers of RMSC and thus RMSC will not provide to the Account Debtors any privacy notices that federal or state law might require to be provided by the clients to the Account Debtor. It is the client’s responsibility to provide all required privacy notices to Account Debtors and, if applicable, to reflect in those privacy notices that the client may disclose an Account Debtor’s NPI to RMSC in the course of receiving bankruptcy-related services from RMSC.

Categories of NPI that We May Collect

In connection with the provision of bankruptcy-related services to clients, RMSC gathers information, pertinent to its provision of bankruptcy related services, on the clients’ Account Debtors, either directly from the client or from other sources including but not limited to US Bankruptcy Court filings, credit bureaus or the Account Debtors;

Categories of NPI That we Disclose And To Whom We Make Disclosures

RMSC may disclose the name, address, social security number, account number, account balance, payment history, account usage (for a credit card account, for example), credit history and creditworthiness of an Account Debtor, and any other NPI in its possession relating to that Account Debtor, to the client with whom RMSC has contracted to provide bankruptcy-related services concerning that Account Debtor, to the Bankruptcy Court, to the Account Debtor, and to any other person who may have a need to know such information in order for RMSC provide bankruptcy-related services to its client, or as otherwise required by applicable law. RMSC will not sell, rent, or lease Account Debtor NPI to others.

Cookies

A cookie is a small data file that certain websites write to a person’s computer hard drive when the person visits the website. A cookie can contain information such as a user ID that the site uses to track the pages visited, but the only personal information a cookie can contain is information supplied by the visitor to the website. The website cannot read other data from hard drives, including cookie files created by other websites.

RMSC may use cookies to track user traffic patterns in order to determine the usefulness of the information RMSC supplies to its clients and to see how effective the website’s navigational structure is in helping users reach that information. RMSC does not correlate this information with data about individual clients, nor does RMSC share this information or sell it to any third party. If a client prefers not to receive cookies from the website, the browsers on the client’s computers can be set either to refuse all cookies, or to alert the client to the presence of a cookie and allow the client to accept or refuse the cookie. A client does not need to accept cookies to use any pages within RMSC’s website.

Security

RMSC restricts access to NPI concerning Account Debtors to those employees and consultants who need to know that information in order for RMSC to be able to provide bankruptcy-related services to its clients. RMSC has implemented safeguards designed to:
(1) insure the security and confidentiality of NPI;
(2) protect against any anticipated threats or hazards to the security or integrity of such information;
(3) protect against unauthorized access to or use of information that could result in substantial harm or inconvenience to any customer; and
(4) properly dispose of such information and protect against unauthorized access to or use of it in connection with its disposal.
RMSC uses a variety of security measures to protect against unauthorized access, use or disclosure of information, including the use of Secure Socket Layer (SSL) encryption when it transmits Confidential Information, including NPI, over the Internet.

Amendment of This Policy

RMSC reserves the right to amend and change this privacy policy. RMSC will post all changes on its website. Notice of change will be deemed given to all RMSC clients upon the posting of such change on the website. The revised privacy policy at that instant will supersede all prior privacy policies. RMSC clients who continue to utilize the website after the posting of any change to the privacy policy are deemed to have reviewed and accepted the changes. Clients therefore should check this privacy policy statement periodically for changes. In the event of any privacy policy change, the effective date of the policy, as recited therein, will also change.

Applicability of this Policy

The representations set forth in this privacy policy are directed only to those clients who have contracted with RMSC to receive bankruptcy-related services. This policy confers no rights on, and no ability to contest the provisions of this policy to, anyone other than RMSC’s clients and Account Debtors.

Third Party Web Sites

This website may contain links to other web sites. Any such links are provided solely as a convenience. A person using such a link enters a website for which RMSC has no responsibility and to which this Privacy Policy does not apply. RMSC does not control these other websites and cannot guarantee their practices regarding privacy and security. RMSC does not endorse or make any representations about these other websites, or any information, software or other products or materials found there, or any results that may be obtained from using them. If a client decides to access any third party \ linked to this website, RMSC recommends a close review of that website’s privacy policy.

For Further Information

Any client who has questions, concerns or complaints about RMSC’s privacy policy or data protection practices may contact RMSC by writing to:

Ramesh Singh
Financial Controller at Recovery Management Systems Corporation
25 S.E. 2nd Avenue, Suite 1120
Miami, FL 33131
or by sending a facsimile to RMSC at 305.374.8113
or by sending an e-mail to RameshS@recoverycorp.com


Policy Effective March, 2006.

© Copyright 2005. Recovery Management Systems Corporation. All rights reserved. RMSC Privacy Policy