This notice discusses Fresh Start Now Inc.(“FSN”) privacy practices with respect to guarding the confidentiality and security of your personal information and the information you submit through this website. If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, any notices we provide and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by means of a notice on our homepage and/or any other acceptable means.
What information does FSN collect through its website?
On our website, we collect personal information about you that you willingly provide to us for purposes of generating a free debt analysis. This information includes your name, address, email address, state of residence, phone number, amount of unsecured debt, your IP address, your website interaction on the site and how you heard about us. FSN wishes to convey to its users that the only type of communications that are sent out are service-related emails that are in response to a user’s online inquiry requesting a free consultation. Users cannot opt out from receiving these service-related emails while engaged in ongoing transactions with FSN. If your personally identifiable information changes, or if you no longer desire our service, you may contact us at the contact information provided at the end this policy to correct, update, delete or deactivate your personal information.
We reserve the right to disclose your personally identifiable information as required to complete the requested transaction, service your account, as required by law or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our website.
We also may collect information that is not personally identifiable. Our website automatically collects clickstream information about your visit. This can include the address of the website from which you originated before visiting our website, the pages you visit on our website, and the browser you use.
If you become a client of FSN, we will collect additional personal information about you, including information about your education, home address, employment, debts, creditors, life events and financial condition.
How does FSN use the information it collects?
FSN does not share any information that it collects through its website with any other person or entity except as permitted by law and indicated in our privacy policy. The personal information we collect is initially used to develop your free debt consolidation analysis. After developing an analysis, we will use the information you submitted to contact you with the results of the analysis, explain how FSN can help relieve your debt burden or.suggest alternate options if FSN is unable to assist you.
We may share personal information about you to service and maintain your account with us. Thus, we may share personal information about you with your creditors and with other parties that help us to service and maintain your account. We may receive personal information about you from other parties such as credit reporting agencies, third parties who assist in identifying prospective consumers, data brokers, social media and marketing sources or your creditors.
Does FSN have safeguards in place to protect my personal information?
We restrict access to your personal information only to those employees who need to know that information to service and maintain your account with us. We also maintain physical, electronic and procedural safeguards that comply with federal requirements to guard your personal information. All employees are trained on information security expectations to ensure the confidentiality and proper usage of data and the systems protecting the data.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the chart below depicts the categories of personal information relating to consumers we have collected within the last twelve (12) months:
| Category | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO for customers
YES for certain employees |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | YES |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.freshstartnow.com). For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform. For example, from affiliate marketers who place ads and forward activity to us or from credit reporting agencies (“CRA”).
- Information that is publicly available online or elsewhere and
- Employees and job applicants.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to assist you in debt consolidation activities.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, newsletters and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To assist you in identifying appropriate resources if we cannot serve you for any of a number of reasons including, but not limited to, inability to operate in the state of request or lack of eligible debt
- To provide a third party with qualified leads for a program that they may administer
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- To conduct audit, compliance or other legal work associated with our business.
- To perform financial reporting and accounting and other general business administration
- To assess third party vendors and services providers
- As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category D: Commercial information
- Category E: Biometric data
- Category F: Internet or other similar network activity.
- Category I: Professional or employment-related information.
- Category K: Inferences drawn from other personal information
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
We may also disclose your personal information to a third party for a commercial purpose. When we disclose personal information for a commercial purpose, which may include providing your information to a provider which can assist you, we have a compensatory relationship which requires the recipient to abide by data privacy regulations and not use it for any purpose except as described.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a commercial purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category D: Commercial information
We disclose your personal information for a commercial purpose to the following categories of third parties:
- Our affiliates
- Corporate credit facility lenders
- Service providers
- Vendors
- Other third parties including marketers
For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:
- info@freshstartnow.com
Notice of Right to Opt-Out
You have the right to direct FSN not to sell your personal information and to refrain from doing so in the future. If you wish to opt-out of such sales, please do so in one of the following ways:
- 866-945-9586
- info@freshstartnow.com
Please consult the other sections of our Privacy Policy for further information on our practices regarding your personal information.
Contact Us
If you have any questions or concerns about this privacy statement, please send them to us by emailing info@freshstartnow.com.