Privacy Policy

Purpose The purpose of this policy is to outline how we collect, use, and disclose the information we collect in our interactions with consumers, our clients and through the KM² Solutions, LLC (“KM² Solutions”) website and to provide consumers with disclosures required under state and federal regulations
Scope This policy applies to all employees, contractors, consultants, partners, service providers, and all affiliated third parties. (“Representatives”) This policy applies to all consumer and employee information collected processed or stored by KM² Solutions.
Policy

I. Privacy Policy
(Last updated and effective October 11, 2022)
This Privacy Policy describes how we collect, use, and disclose the information we collect in our interactions with consumers, our clients and through the KM² Solutions, LLC (“KM² Solutions”) website. California consumers: please see “California Consumer Privacy Act (“CCPA”) Policy”, below for a description of our practices regarding the collection, use, disclosure, and sale of personal information of California consumers and rights under the CCPA.

We operate this website to provide information to visitors, consumers, and customers about us and our services, solutions, and other information. You may use our website to contact us or apply for employment. We are committed to protecting your privacy online.

By using the website, you agree to this Privacy Policy. If you do not agree, please do not use the website.

A. Information We Collect Through Our Website
We collect your information when you voluntarily provide it to us, such as when you inquire about or use our services, apply for employment, or submit questions or other data to us through the website. We may store your information or include such information in databases owned and maintained by our affiliates, agents or service providers, all subject to the terms of this Privacy Policy. However, data will not be communicated to a third party if doing so is prohibited by applicable laws.

Such information may include, without limitation, contact information, such as your name, address, email, phone number, and job application information, such as your resume, references, and other information you provide to us during the application process. Depending on the services you seek, some information may be mandatory in order to utilize certain services. You may choose to not provide mandatory information required for certain services, and in such event, you will not be allowed to utilize those services.

B. How We Use Information Collected Through Our Website We use your information mainly to operate our business and communicate with you. We use your information: To provide you with customer service, such as addressing and resolving questions, concerns, or requests; For communications, such as sending you emails, text messages, or phone calls relating to our services that we believe may interest you, or positions available for job applications, except that we will not communicate with a consumer if doing so is prohibited by applicable law such as, the Telephone Consumer Protection Act, or similar State laws; and some of our services will give you the opportunity to opt out or stop receiving communications from us. To stop the receipt of future communications from us, you may email us at privacy@km2solutions.com.

C. Our Disclosure of Information Collected Through Our Website
We share your information to operate our business, provide you with our services, and communicate with you. We may share your information:

With our affiliates, subsidiaries, or service providers consistent with the purposes identified in this Privacy Policy,
o For example, we may retain third parties to perform certain functions, email information, or maintain databases for us;
If we sell or buy businesses or assets, or engage in a merger, reorganization, dissolution, or similar event and your information is
part of the transferred assets or business units;
Where we are required to disclose your information to regulators, law
enforcement agencies, or other government agencies;
We may be required to disclose your information to comply with valid
legal process, by law, where we believe in good faith that disclosure is necessary to comply with our obligations under the law or agreements, or to protect and defend our rights or property (including to assure or enforce compliance with this Privacy Policy and
applicable law or to protect against unauthorized use of our website or information contained on it), or the rights or property of others, or to protect against or mitigate our liability; and
With your consent.

However, data with respect to a consumer will not be communicated to a
third party if doing so is prohibited by applicable law.

D. Exclusions
This Privacy Policy does not apply to any unsolicited information you provide to us through our website or through any other means. This includes, without limitation, any ideas for new products or modifications to existing services, and other unsolicited submissions. All unsolicited information is non-confidential, and we are free to reproduce, use, disclose, and distribute unsolicited information to third parties without limitation or attribution.

E. Third-Party Sites
This Privacy Policy does apply not to any third-party websites for which our website may contain links. The privacy practices of those websites may differ from the privacy practices of KM² Solutions as described in this Privacy Policy. KM² Solutions has no control over those websites and links from this website do not imply that KM² Solutions endorses or has reviewed those third-party websites or takes any responsibility with respect to them or the information you may provide in accessing or using them.

F. Security
KM² Solutions takes reasonable steps designed to protect the security, confidentiality, and integrity of the information we collect. We have implemented various physical, electronic, and managerial measures, to provide your information with reasonable protection from accidental loss or destruction, improper use, alteration, or disclosure. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us over the Internet or via email.

G. Accessing, Updating or Correcting Information Collected Through Our Website You can use our website without providing any information, but in that event, you may not be able to use certain website features, such as applying for employment. If you wish to obtain a copy of the particular information you have provided to us, or if you become aware that any information you have provided is incorrect and you would like us to correct it, you may email us at privacy@km2solutions.com. Before we are able to provide you with any information or correct any inaccuracies, however, we will ask you to verify your identity and to provide other details to help us respond to your request. We will attempt to respond to your request within a reasonable

H. Changes to the Privacy Policy
We may change this Privacy Policy from time to time by posting a modified version of the Privacy Policy on our website or a website that replaces this website. When we do so, we will change the effective date of the Privacy Policy. If we make material changes to our Privacy Policy, we will notify you by a prominent notice on our website. Your continued use of our website means that you have accepted our updated Privacy Policy. Please review our website and policies frequently to learn how KM² Solutions uses your information.

I. Other Terms
Your use of this website is subject to KM² Solutions’ Terms of Use, which is incorporated herein by reference. You may read the current version of our Terms of Use by selecting the “Terms of Use” link on our website, www.km2solutions.com.

You must be at least 18 years old to use the website or our services. We do not knowingly collect, use, or disclose data about visitors or customers that are under 13 years of age. Please notify us, at the email address indicated below, if you believe that a child under the age of 13 has provided information to us through this website and we will promptly remove that information and not use it unless required in order to comply with applicable law.

II. California Consumer Privacy Act (“CCPA”) Policy (Last updated and effective October 9, 2020) The following describes KM² Solutions, LLC (“KM² Solutions”) practices regarding the collection, use, disclosure, and sale of personal information of California consumers and the rights of California consumers regarding their personal information as required under the California Consumer Privacy Act of 2018 (“CCPA”). California consumers with disabilities can receive a copy of this policy by writing to KM² Solutions, Attn: Compliance Dept., 600 Eagleview Blvd. Ste. 300, Exton, PA 19341 or by sending an email to privacy@km2solutions.com.

A. Information KM² Solutions Processes, Sources of Information and Uses KM² Solutions processes the following categories of personal information on behalf of our clients:

information that identifies a consumer such as name, date of birth, social security or other identifying number, military and/or professional status, education. This information is sometimes provided to KM² Solutions by its clients and may be provided to KM² Solutions by the consumer;
consumer contact information such as postal address, phone number and email address is provided to KM² Solutions by the consumer, by our client, or by third parties such as the consumer’s employer, neighbors or persons provided to the creditor as “references”; and other persons who are authorized to receive information about an account;
information about transactions with our client, including amount, date, and account, financial institution and credit and/or debit card number that is provided to KM² Solutions by the consumer or by our client;
financial information such as savings, income, expenses, or taxes is provided to KM² Solutions by our clients, or the consumer;
credit report information is provided to KM² Solutions by our clients;
information regarding consumer’s employment is provided to KM² Solutions by the consumer, by our client, or by third parties such as the consumer’s employer, neighbors or persons provided to the creditor as “references”; other persons who are obligated on the debt such as co-signers or guarantors; and data service providers such as credit reporting agencies; and
medical information including health insurance provided to KM² Solutions by the consumer and/or our client.

This information is collected, used and disclosed by KM² Solutions only for the benefit and on behalf of KM² Solutions’ clients for the purpose of identifying, locating and contacting consumers and to assist consumers with their account services. KM² Solutions does not share or use any of this information in a manner that would constitute a violation of applicable federal or State law including the federal Fair Debt Collection Practices Act. We will not collect additional categories of personal information or use the personal information we collected for materially different purposes without providing you notice. Personal Information does not include:

Publicly available information from government records;
Deidentified or aggregated consumer information;
Information excluded from the CCPA’s scope, such as (but not limited to) information governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the California Confidentiality of Medical Information Act (“CMIA”), the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach- Bliley Act (“GLBA”), California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”);

B. KM² Solutions does not and will not sell any consumer personal information and has not sold any consumer information in the last 12 months under the CCPA.

C. Rights Under the CCPA

(The following is not a complete list of all consumer rights under the CCPA).

Under the CCPA, California consumers have the right to request disclosures regarding the collection, use, disclosure and sale of their personal information.

Upon verification of identity, California residents may in some cases request that a business:

Disclose the categories of personal information the business collected about the consumer;
Disclose the categories of sources from which the personal information is collected;
Disclose the categories of personal information that the business sold about the consumer;
Disclose the categories of personal information that the business disclosed about the consumer for a business purpose;
Disclose the categories of third parties with whom the business
shares personal information;
Disclose specific pieces of personal information the business has collected about the consumer; and
Disclose any financial incentives offered by the business for
collection, sale, or deletion of personal information.

For applicable personal information access and portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Under the CCPA, California consumers also have the right to request the deletion of their personal information; however, the CCPA also provides for exceptions to compliance with such requests.

Please note that we are not required to:

Carry out information access requests we receive from you if acting as a service provider to another entity regarding such information;
Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information;
Provide the requested information disclosure to you more than twice in a 12-month period;
Provide the requested information disclosure if we cannot verify
that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf; or
Provide the requested information disclosure if a CCPA or applicable exception applies.

All requests for disclosure or deletion with respect to personal information should be directed to the KM² Solutions client on whose behalf the information was processed. Requests can be directed to KM² Solutions by sending an email to us at privacy@km2solutions.com, or writing to us at KM² Solutions, Attn: Compliance Dept., 600 Eagleview Blvd., Suite 300, Exton,PA, 19341 but will be forwarded to our client for response. Client identity is provided in each communication with a consumer and must be provided by the consumer in order to properly process any inquiries or requests.

All requests should include information identifying the consumer and the subject account so that the request can be verified. Requests for deletion should include the information the consumer wishes to have deleted.

The CCPA requires requests to be verified by matching the consumer personal information provided in the request with information in client records, and the consumer must be notified if the request cannot be verified based on the information provided. Depending on the request, two or more pieces of personal information and support may be required for verification.

We are not obligated to make an information disclosure or carry out a deletion request pursuant to the CCPA if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you in order to verify your identity in connection with your CCPA request will be used solely for the purposes of verification.

California consumers also have a right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

California consumers can designate an authorized agent to make a request on the consumer’s behalf either by providing the agent with written permission, a copy of which is provided along with adequate information identifying the agent for verification purposes, or where the agent has power of attorney pursuant to California Probate Code sections 4000 to 4465.

III. If You Have Questions If you have any questions or concerns regarding our Privacy Policy or CCPA Policy, please contact us at 888-249- 5021 or via email to privacy@km2solutions.com, or if you prefer, by writing to us at the following address: (KM² Solutions, Attn: Compliance Dept., 600 Eagleview Blvd., Suite 300, Exton, PA 19341.)

Version	Date	Created/ Amended	Approved	Summary of Change
V1.0	5/24/17	Michele Ward, VP Compliance	Compliance Committee	Document creation.
V2.0	10/09/2020	Michele Ward, VP Compliance	Compliance Committee	Rewrite, CCPA Section added.
V2.1	10/11/2022	Michele Ward, VP Compliance	Compliance Committee	Update to information processed, change of address and minor grammatical corrections.

Privacy Policy

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