Viking Client Services, LLC
This Privacy Notice describes the privacy practices of Viking Client Services, LLC (collectively, "VCS, "we", "us", or "our"). We recognize the importance of maintaining the security of your personal information and understand that your privacy is important to you. We are committed to protecting your privacy. This Privacy Notice explains what information we collect, how we use that information, how we protect your privacy, and your rights in connection with this information.
- We do not sell or otherwise share non-public information with non-affiliated third parties who may wish to use the information for their own benefit or who are not performing a function necessary to support of billing, payment processing or collection-related services (collectively, "business" or "services") as described below.
- We have policies and security safeguards in place to protect your information.
Nothing in this Privacy Notice is intended to contradict your rights under the Fair Debt Collection Practices Act ("FDCPA").
Non-public Information means information about you that we receive in the due course of our business. Non-public information does not include information that is available from public sources, such as telephone directories or government records.
Affiliate means a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership but means owning enough to have control.
Non-affiliated Third Parties means companies that are not an affiliate of VCS.
Client means creditors, providers, organizations, and/or companies that have retained VCS to provide our services.
Service Providers means companies, vendors, and agents retained by VCS to assist in providing our services including, but not limited to, mail vendors, payment processors, and vendors who assist in location and verification of consumer information.
We only disclose information to Affiliated and Non-affiliated Third Parties as permitted or required by law including, but not limited to, the FDCPA. We may share information we collect with third parties incidental to the collection process including mailing and/or other collection-related vendors that assist us in the collection process. When we share your information with such companies, they are required to limit their use of your information to the particular purpose for which it was shared, and they are not allowed to share it with others except to fulfill that limited and permissible purpose. In addition, we may also share your information with our affiliates and non-affiliated third parties if also permitted by applicable law.
We restrict access to Non-public Information about you to only our employees who need to know that information to service your account or to assist in the administration of our business. We maintain physical, electronic, and procedural security measures to protect your information.
You may have other privacy protections under state laws. We reserve the right to amend this Privacy Notice at any time.
Collection and Use of Non-public Information
We collect Non-public Information about you from the following sources:
- Information we receive from you either directly or indirectly, such as information on applications or agreements, which may include your name, address, social security number, and phone number.
- Information about your transactions with us or others, such as your account balance and payment history.
- Information we receive from consumer reporting agencies.
Important Information for California Consumers
This information is in addition to the Privacy Notice provided above. This section applies only to California residents and is effective as of January 1, 2022. For purposes of this section, "Personal Information" has the meaning given in the California Consumer Privacy Act of 2018 ("CCPA") but does not include information exempted from the scope of the CCPA.
Personal Information we may have collected within the last 12 months:
|Category of Private Information||Examples||Do we Collect?|
|Identifiers||Name, alias, name suffix, mailing address, account number, email, date of birth, telephone and fax numbers||YES|
|Government-Issued Identifiers||Social Security Number, driver's license or state ID card number, passport number||YES|
|Biometric Identifiers||Imagery of the iris or retina, fingerprint, face, hand, and voice recording from which and identifier template is extracted||NO|
|Relationship Information||Age; gender; marital status; household level information; demographic data; acquired scores (other than FCRA-regulated credit scores)||YES|
|Professional or Employment-related Information||Current or past employment||YES|
|Inferred and Derived Information||Inferred data (propensities, attributes) generated by the company and associated with a consumer, household device; internally generated scores; ad targeting information||NO|
|On-line and Technical Information||IP address; UUID, AOID, GUID device identifiers; data from cookies, web beacons, etc.; clickstream data; device "fingerprinting" records; server log records (including page requests); data collected by automated means to measure consumer response to online content||NO|
|Audio/Visual Information||Photographs; video images; CCTV records; call center recordings; voicemail||YES|
|Financial Information||Financial account numbers; insurance account numbers; payment card data; consumer reporting data, credit scores;||YES|
|Health Information||Information about payment for healthcare services||YES|
How We Obtain Your Information
We obtain the categories of personal information listed above from the following category sources:
- Directly or Indirectly from you. For example, (i) by your communicating with us via mail, phone, email, or fax or (ii) through providing information to a third party who will relay the information to us (attorneys, government agencies, etc.)
- Directly from our Clients or their agents. For example, from account files that our Clients or their agents provide us.
- Directly or Indirectly from activity on our websites. For example, if you utilize the "Contact Us" button on our website.
- From Third Parties that contract with us or interact with us in connection with the services we perform. For example, from vendors that help us locate current addresses and phone numbers, provide credit bureau information, and send letters.
How We Use Your Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided us the information. For example, (i) if you share your contact information so we can send a letter or (ii) if you provide your bank account information so we can process a payment.
- To process your requests or payments and to prevent transactional fraud.
- To provide responses to your inquiries, including investigating and responding to your concerns and monitoring and improving our responses.
- To perform services on behalf of our client, including maintaining or servicing records, providing customer service, processing transactions, verifying consumer information, or processing payments.
- To comply with legal obligations including, but not limited to, document retention obligations, lawsuits, legal and regulatory obligations, and responding to law enforcement requests court orders, or other governmental agencies.
- For internal purposes reasonably aligned with consumer expectations and/or in a lawful manner compatible with the collection of accounts.
How We Share Your Information
VCS may share Non-public Information it collects with its employees who need to know that information to provide services with respect to your account. VCS may share your Non-public Information with third parties to the extent it is reasonably necessary and permitted under applicable law to manage or service your account, verify employment, determine location, process payment, provide customer service, or as otherwise authorized by law.
We may disclose personal information to a third party for a business purpose. We disclose your personal information for a business purpose to the following categories of third parties.
- Service Providers
- Governmental authorities and parties to judicial and administrative proceedings
- Third parties to whom you have provided consent to receive the information
How We Protect Information
VCS has implemented physical, electronic, and procedural security safeguards to protect against the unauthorized release of or access to Non-public Information. We employ internal and external system safeguards designed to protect security and confidentiality of Non-public Information.
Your Rights and Choices
Right to Request to Know
California consumers have a right to request what personal information we collect, use, disclose, and sell. (Details on how to submit a request can be found under the section Submitting a Request.)
Right to Request Deletion
California consumers have the right to request the deletion of Non-public Information that we have collected and maintain. (Details on how to submit a request can be found under the section Submitting a Request.)
An exception may exist, and we may deny your request if retaining the information is necessary for us or our Service Providers to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of our ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right protected by law.
- Comply with the California Electronic Communication Privacy Act (Cal Penal code §1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, of the consumer has provided informed consent.
- To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
- Comply with legal obligation.
- Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Submitting a Request
Only you or someone who is legally authorized to act on your behalf may submit a request regarding your personal information.
A request can be submitted by the following methods:
- Phone: 1-800-215-2109
- Email: email@example.com
To prevent inappropriate disclosure of information, you are required to provide us with the following verifiable information:
- First Name
- Last Name
- Your phone number on file
- Viking Account or Claim Number
Additionally, if you are an authorized representative, you will need to provide information to reasonably verify that you are authorized to receive the information.
Describe your request with enough detail that it will allow us to understand, evaluate, and respond to it.
We will only use the personal information provided in your request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
After your submission we will confirm receipt of the request within 10 business days unless we provide a response within that timeframe. We will respond to your request within 45 days of receipt unless more time is necessary, in which case we will inform you.
Any disclosures we provide will only cover the 12-month period preceding the receipt of the request.
We will not respond to more than two (2) requests from the same consumer during a 12-month period.
We will not discriminate against California residents who exercise their rights described in this Notice.
Privacy Notice Changes
VCS may change this Privacy Notice at any time. Notice of any new or revised Privacy Notice, as well as the location of the new or revised statement, will be posted on the website after the change. It is the obligation of the users visiting the website before the change to learn of changes to the Privacy Notice since their last visit.
Last Updated: May 25, 2022