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Rocket Receivables®, owned and operated by Transworld Systems Inc.®, a California corporation, and/or TSI’s affiliates (collectively, “TSI”), take very seriously the protection and proper use of TSI’s users’ (“you”) personal and non-personal information in connection with providing account receivable collection services (“Services”) through TSI’s websites (such as www.rocketreceivables.com and www.tsico.com) , including the mobile versions of TSI’s websites (collectively, the “Websites“), and, if applicable, through TSI’s mobile application (“App“), regardless of how accessed (collectively, the Website and the App are referred to as the “Properties“). By accessing or using TSI’s Properties, you agree to the terms and conditions of this policy (“Privacy Policy”). TSI wants you to understand the information may be collected from you, how such information is used, and the choices you have regarding TSI’s use of this information. Accordingly, this Privacy Policy explains how TSI collects, use, and disclose your personal information (“PII”) and other information (collectively, “your information”). This Privacy Policy applies only to those Properties, websites, services, and applications included within the Services and does not apply to any information gathering, use, or dissemination practices related to information collected other than directly through or from its Properties, including, without limitation, from or via telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media. TSI will treat your information consistent with this Privacy Policy unless you consent otherwise.

Information TSI Collects

Information You Authorize TSI to collect.

TSI collects your information in various ways when you use the Services. For example, when you register for and use the Services, TSI collects information, including personal and account information, you submit to TSI. This may include information such as your name, username, email and mailing address, credit card number, cellular or mobile telephone number, and telephone number. If you choose to register for TSI’s Services via a third-party service with which you have an account, such as a trade association, TSI may collect certain information from your third-party account, such as name, email address, and other personal information. TSI may also collect other demographic information you submit. It is always your choice whether to provide this personal information; however, without providing some of the requested information, certain features will not be accessible, and you may not be able to conduct transactions through the Properties. If you use the Services, TSI may also collect survey responses, or other information that you submit in connection with the Services, such as the information you submit regarding your eligibility to participate in a study. Please note TSI may obtain information about you from other sources, including third-party sources, and combine that information with data collected through the Properties, including personal information. This combined information may result in, among other things, a profile about you, which TSI may use in accordance with this Privacy Policy.

Information Collected with Your Express Consent.

In addition to the information collected pursuant to this Privacy Policy, TSI may collect additional information about you if TSI has your express consent to do so. For example, if you opt to participate in a study via the Services, TSI will collect that information necessary for us to run the study, including information you submit and information obtained from third parties. As part of your participation you will be presented with and will need to agree to the terms of an Informed Consent, or an equivalent consent agreement, in order to participate. Please review that document carefully as it will outline the specific information to be collected and how it will be used for a given study.

Automatically Collected Information.

Like many other websites and applications, TSI may automatically collect certain non-personally identifiable information regarding TSI’s Properties’ users. When you utilize TSI’s Services, certain information is automatically collected. For example, TSI may automatically collect your Internet Protocol (IP) address, computer operating system, browser type and language, IP address of your Internet service provider, your zip code, the date and time you access the Properties, the operating system you are using, the sections or pages of the Properties you visit and images and content viewed, and the website you visited before visiting TSI’s Properties. TSI may also collect information such as your Device ID and geo-location data. Most mobile devices provide you with the ability to turn off location services. For more information regarding location services, please contact your device manufacturer or mobile carrier. Turning off location services may impact certain features of the Services. Even if you do not register with TSI’s Services, or submit information directly, visiting TSI’s Properties may collect this automatically collected information. Some of the ways in which TSI or the Properties may collect and use non-personally identifiable and aggregated information are further described below.

Clickstream Data.

As you use the Internet, a trail of electronic information is left at each website you visit. This information, sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. For example, clickstream data can tell the type of computer and browsing software you use and the address of the website from which you linked to the Properties. TSI and the Properties may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of TSI’s Properties, how visitors navigate throughout the Properties and how TSI may tailor the Properties to better meet the needs of visitors. This information often will be used to improve the Properties and TSI’s Services. Any collection or use of clickstream data will be anonymous and aggregated, and will not intentionally contain any personal information.

Cookies, Tracking Pixels, and Similar Technologies.

TSI’s Properties may use cookies, a type of technology that installs a small amount of information on a website user’s computer or other device to permit a website to, for example, recognize future visits using that computer or device. A “cookie” is a small data file sent from a website, or email, and stored on your computer or mobile phone to identify you and your device in the future and allow for an enhanced personalized user experience based on your previous activity on the website. A “session cookie” disappears after you close your web browser, or may expire after a fixed period of time. A “persistent cookie” remains after you close your web browser and may be accessed every time you use TSI’s Services. The Properties also may use session and persistent cookies and similar technologies on the Properties to customize your visit, to enable us to enhance TSI’s Services, or for other purposes. For example, information provided through cookies is used to recognize you as a previous user of the Properties so you do not have to enter your personal information every time and to offer personalized content. Cookies and similar technologies also may be used by TSI’s affiliates, a tracking utility company, and other third parties to, for example, make it easier for you to navigate TSI’s Properties. TSI does not have access to or control over these cookies and technologies and TSI cannot control whether these parties comply with this Privacy Policy. You may choose to decline cookies by adjusting your browser preferences, but doing so may affect your use of TSI’s Properties and your ability to access certain features of the Properties or engage in transactions through the Properties. If you delete your cookies, change browsers or change devices, cookies the Properties may use (or an opt-out cookie) may no longer work.

TSI’s Properties may use other, either directly or through trusted third parties, similar technologies (including, without limitation, tracking pixels, as described further below, and other anonymous identifiers) to gather non-personally identifiable information. Tracking pixels are tiny, transparent graphics with a unique identifier, similar in function to cookies, and are used to provide analytical information concerning the user experience as well as to support custom marketing activities for users of the Properties. In contrast to cookies, which are stored on a user’s computer hard drive, tracking pixels are embedded invisibly on web pages. The Properties may use tracking pixels to help TSI better manage content, such as by improving the user interface or improving TSI’s marketing programs. The Properties also may use non-personally identifiable information to create aggregate tracking information reports regarding user demographics, traffic patterns and purchases and may link tracking information with personal information provided by users.

As disclosed in this Privacy Policy, TSI may utilize the services of third parties in conjunction with this automatically collected information. These third parties may collect information about you over time such as about your use of TSI’s Services, as well as your online activities across other websites or online services. Some third parties may allow you to opt-out of targeted advertising based on this information. You can find more information about these opt-outs from the Network Advertising Initiative and the Digital Advertising Alliance.

Interest-Based Advertising.

TSI may engage third-party vendors to use non-personally identifiable information in connection with their own information to deliver targeted advertising to you when you visit the Properties or other websites. Cookies, described above, may be used in this process. For example, if you are searching for information on a particular product, TSI’s vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “behavioral advertising,” is based on anonymous information and not on any personal information. As a result, TSI and TSI’s vendors know your interests, but do not know who you are in connection with the delivery of that specific ad. TSI believes such advertising is helpful because you will see advertisements that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please see the Opt-Out of Further Communications section below. TSI believes such advertising is helpful because you will see advertisements that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please see the Opt-Out of Further Communications section below.

Information from other sources.

TSI may, at times, seek to obtain information about you from other sources. TSI may receive, or affirmatively gather information about you from such sources and may combine it with the information TSI already has for any purpose described throughout this Privacy Policy. The extent to which TSI may obtain information from such sources is governed by the terms of your relationship with that source.

How TSI Uses Information

How TSI Uses Personal Information.

TSI may use your PII to contact and correspond with you, to respond to your inquiries, to process transactions and payments, to facilitate and enhance your use of the Properties, to alert you to TSI’s Services and those of TSI’s affiliates and partners, and for other purposes not prohibited by this Privacy Policy. For example, if you make a purchase through the Properties, TSI may use your PII collected during that transaction to market products and services to you that TSI thinks may interest you. If you participate in TSI’s referral program, TSI may email the friend you referred inviting him or her to visit TSI’s Properties, and may store the email address for the purpose of sending such email(s) and to track the success of that program. Your friend may contact TSI at Marketing@rocketreceivables.com to request that TSI remove this information from TSI’s database. Additionally, TSI may ask you to provide information about your friends, colleagues who might be interested in TSI’s Services. TSI will treat such information as PII when it is associated with PII provided by you. When such information is not associated with PII provided by you, this information will be treated as non-personally identifiable information.

TSI uses the information collected to provide the Services to you or as otherwise described in this Privacy Policy. For example, TSI may use your information to: (a) operate and improve TSI’s Services, including development of new features and functionalities; (b) contact you about your account, referrals, and current and future Services offered by TSI; (c) respond to your feedback, comments, or questions, or to otherwise send you information about TSI’s Services; (d) ask you to complete surveys about TSI’s Services; (e) perform research; (f) analyze how you use and interact with TSI’s Services; (g) TSI may aggregate your information to prepare analyses or reports for TSI’s partners, or potential partners regarding the use of TSI’s Services and/or data about TSI’s user population; (h) protect TSI’s Services and the information collected against fraudulent, illegal, or otherwise unauthorized activity, including any investigation into such activity; (i) for any other purpose described in this Policy, Terms of Use or Service Agreement (as may be applicable); (j) for third parties to provide products, information or other services that TSI believes that you may be interested in obtaining; or (k) when TSI has your consent.

By providing your mobile phone number, you expressly consent to receive text or other SMS messages at the number provided to TSI. Standard message and data rates may apply.

How TSI Uses Non-Personally Identifiable Information.

Your non-personally identifiable information can be used by TSI for any lawful purpose and may be shared with any number of third parties. Such information may be permanently archived for future use. Some examples of how TSI may use non-personal information are for system administration purposes, analytics and to improve the Properties. Other examples of how TSI may use such information are provided above, such as “Interest-Based Advertising” and push notifications. TSI also may use general location data, preferences, or other information received from the Properties, including through your mobile device, to send you tailored marketing messages. Additionally, TSI may use non-personally identifiable information to engage in interactive, real-time discussions with users, which TSI or the users may initiate.

How TSI Shares Information

TSI will not sell, rent, or otherwise share your PII with third parties for such third party’s direct marketing purposes. In certain circumstances, TSI may share your information with TSI’s affiliates, service providers, and third party business partners. 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 you 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. Such companies will be obligated to protect the confidentiality of your PII. TSI may also share your PII with the service providers who work with TSI to administer and provide the Services. If you access the Services through TSI’s partners’ websites and applications, in order to provide and administer the Services, those partners may require TSI share user identification information, such as a logon name, associated with your Account. TSI may share your PII if TSI reasonably believes it is necessary in order to comply with laws, regulations, legal processes (such as subpoenas or warrants) or any other legal or regulatory request. TSI may disclose or transfer your PII to a third party if TSI sells, transfers, divests, or discloses all or a portion of TSI’s business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding. For the avoidance of doubt, nothing in this Privacy Policy prohibits the sharing of information, including PII, necessary for TSI to follow the law, as permitted by law, or to give you the best service on your accounts with TSI. This includes sending you information about some other products or services.

De-Identified Data

TSI may sell or otherwise share aggregated data, or other data that does not identify you personally, for industry analysis, market research, demographic profiling, or for any other permitted purpose. TSI may also use such de-identified data for research purposes, and may publicize the results of such research.

Opt-Out from Further Communications

You may opt-out of receiving certain communications from us. To opt out of further communications with TSI, please contact TSI by email at Marketing@rocketreceivables.com or by phone at 844-822-3534.

Security

TSI uses a combination of commercially reasonable technical and administrative safeguards to protect the integrity of your information. When you enter sensitive information, such as a credit card number on TSI’s order forms, TSI encrypts the transmission of that information using secure socket layer technology. TSI uses reasonable security measures to protect the confidentiality of the PII submitted both during transmission and after TSI receives it. However, the confidentiality of any communication or material transmitted to or from TSI via the Internet cannot be, and is not, guaranteed. You acknowledge that the technical processing and transmission of TSI’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.

Links to Third Party Websites

TSI’s Services may contain links to other websites and services. Any information you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. TSI’s Privacy Policy does not apply to such websites or services and TSI has no responsibility or liability for, or control over the content, privacy, or security practices and policies of those websites or services. To protect your information, TSI recommends you carefully review the privacy policies of other websites and services that you access.

Other Notices and Important Information

Children’s Privacy.

TSI’s Services are not intended for children under the age of 18. If you make a purchase on TSI’s Properties, you are representing that you are an adult.

International Transfer.

Your information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. TSI’s Services are intended for use only in the United States. If you’re located outside the United States and choose to provide your information, TSI may transfer your information to the United States and process it there (or any other country in which TSI operates). Your submission of information using the Services represents your agreement to such transfer.

California Privacy Rights.

Pursuant to the California Civil Code, California residents have the right to request for a disclosure from companies doing business in California of all disclosures of their PII during the prior year to third parties, for such third parties direct marketing purposes. As noted above, TSI does not share your PII with third parties for their direct marketing purposes. For any questions regarding this section of TSI’s Privacy Policy, please contact TSI at the information below.

Changes to this Privacy Policy.

TSI may update this Policy from time to time to reflect changes or updates to TSI’s technology, data practices, and other factors. Changes to this Policy will become effective when published in the revised Policy, unless otherwise noted. Please check the “Last Updated” date at the bottom of this page to see when this Policy was last revised. Your continued use of the Services following the effective date of these changes indicates your consent to the practices disclosed in the update Privacy Policy.

Terms and Conditions.

Use of the Properties is governed by, and subject to, the Terms of Use, and this Privacy Policy is incorporated therein. Your use or accessing of the Properties constitutes your agreement to be bound by the Terms of Use.

Contact Information.

For any questions regarding this Privacy Policy, or TSI’s data practices, please direct your inquiry to:

Transworld Systems, Inc., Attn: Privacy, PO Box 15630 Wilmington, DE 19850

Last Updated: 1/12/17