PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY. BY ACCESSING THIS WEBSITE YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS BELOW. THESE TERMS AND CONDITIONS ARE SUBJECT TO CHANGE. ANY CHANGES WILL BE INCORPORATED INTO THE TERMS AND CONDITIONS POSTED TO THIS WEBSITE FROM TIME TO TIME. IF YOU DO NOT AGREE WITH THESE TERMS AND CONDITIONS, PLEASE DO NOT ACCESS THIS WEBSITE.

Unauthorized use of Halsted Financial Services, LLC's Websites and systems, including but not limited to unauthorized entry into Halsted Financial Services, LLC's systems, misuse of passwords, posting of objectionable or offensive content or your unauthorized use of legally protected third party content, or misuse of any information posted to a site, is strictly prohibited.

You acknowledge that Halsted Financial Services, LLC., may disclose and transfer any information that you provide through this Website to (i) its affiliates agents or information providers; (ii) to any other person or entity with your consent; or (iii) if we have a right or duty to disclose or are permitted or compelled to so disclose such information by law. You consent to the transmission, transfer or processing of such information to, or through, any country in the world, as we deem necessary or appropriate (including to countries outside the EEA), and by using and providing information through this Website you agree to such transfers. Use of this Website, including any patterns or characteristics concerning your interaction with it, may be monitored, tracked and recorded. Anyone using this Website expressly consents to such monitoring, tracking and recording.

You agree not to attempt to log on to the Website from any country under sanctions by the Office of Foreign Assets Control (OFAC). Information regarding which countries are under sanctions may be obtained on the U.S. Department of the Treasury website. Any attempt to log on to the Website from one of these countries may result in your access being restricted and/or terminated.

If you use Halsted Financial Services, LLC’s Website or systems to access data related to any account(s) of which you are not the owner or authorized user as reflected in Halsted

Financial Services, LLC’s systems, you shall indemnify, defend, and hold harmless Halsted Financial Services, LLC,. and all of its direct and indirect subsidiaries, officers, directors, employees, agents, successors, and assigns from any and all losses, liabilities, damages, and all related costs and expenses, arising from, relating to, or resulting (directly or indirectly) from such access. Further, without limiting Halsted Financial Services, LLC’s rights or your obligations under any other provision of these Terms and Conditions, and notwithstanding the same, in the event of any actual or reasonably suspected unauthorized access to the personal information of a customer (including but not limited to customer names, addresses, phone numbers, bank and credit card account numbers, income and credit histories, and social security numbers) under your control or subsequent to and arising from your past exercise of control, direct damages in connection with any such breach will include the cost and expenses of investigation and analysis (including by law firms and forensic firms), correction or restoration of any destroyed, lost or altered data, notification to affected customers, offering and providing of credit monitoring, customers service, or other remediation services, and any related cost. Halsted Financial Services, LLC’s rights to indemnity under this section are in addition to all other rights and remedies available at Law or in equity. Any exercise by Halsted Financial Services, LLC., of its rights to indemnification shall be without prejudice to such other rights and remedies. You manifest your assent to this indemnity by accessing account data through Halsted Financial Services, LLC’s Website or systems, notwithstanding the terms of any agreement you have with a customer or an account owner stating otherwise. This indemnity includes but is not limited to losses associated with (1) a data breach of your system(s) and (2) a data breach of the system(s) of any person or entity with whom you provided or shared Halsted Financial Services, LLC customer account data.

Copyright Notices

The works of authorship contained in the halstedfinancial.com Website (the "Website"), including but not limited to all design, text, sound recordings and images, are owned, except as otherwise expressly stated, by Halsted Financial Services, LLC. Except as otherwise expressly stated herein, they may not be copied, transmitted, displayed, performed, distributed (for compensation or otherwise), licensed, altered, framed, stored for subsequent use or otherwise used in whole or in part in any manner without Halsted Financial Services, LLC's prior written consent, except to the extent permitted by the

Copyright Act of 1976 (17 U.S.C. § 107), as amended, and then, only with notices of Halsted Financial Services, LLC's proprietary rights provided that you may download information and print out hard copies for your personal use, so long as you do not remove any copyright or other notice as may be contained in information, as downloaded.

Web Content and Materials

The information on this Website is for information purposes only. It is believed to be reliable, but Halsted Financial Services, LLC., does not warrant its completeness, timeliness or accuracy.

The information and materials contained in this Website-and the terms and conditions of the access to and use of such information and materials-are subject to change without notice.

Certain portions or pages of this Website are subject to additional disclosures and disclaimers. In the event of a conflict between those disclosures and disclaimers, and these terms and conditions, the additional disclosures and disclaimers will govern for those portions or pages.

You agree that (i) you will not engage in any activities related to the Website that are contrary to applicable law, regulation or the terms of any agreements you may have with Halsted Financial Services, LLC, and (ii) in circumstances where locations of the Website require identification for process, you will establish commercially reasonable security procedures and controls to limit access to your password or other identifying information to authorized individuals.

HALSTED FINANCIAL SERVICES, LLC OR ITS SUPPLIERS MAY DISCONTINUE OR MAKE CHANGES IN THE INFORMATION, PRODUCTS OR SERVICES DESCRIBED HEREIN AT ANY TIME WITHOUT PRIOR NOTICE TO YOU AND WITHOUT ANY LIABILITY TO YOU. ANY DATED INFORMATION IS PUBLISHED AS OF ITS DATE ONLY, AND HALSTED FINANCIAL SERVICES, LLC., DOES NOT UNDERTAKE ANY OBLIGATION OR RESPONSIBILITY TO UPDATE OR AMEND ANY SUCH INFORMATION. HALSTED FINANCIAL SERVICES, LLC., RESERVES THE RIGHT TO TERMINATE ANY OR ALL WEBSITE OFFERINGS OR

TRANSMISSIONS WITHOUT PRIOR NOTICE TO THE USER. FURTHERMORE, BY OFFERING THIS WEBSITE AND INFORMATION, PRODUCTS OR SERVICES VIA THIS WEBSITE, NO DISTRIBUTION OR SOLICITATION IS MADE BY HALSTED FINANCIAL SERVICES, LLC TO ANY PERSON TO USE THE WEBSITE OR SUCH INFORMATION, PRODUCTS OR SERVICES IN JURISDICTIONS WHERE THE PROVISION OF THE WEBSITE AND SUCH INFORMATION, PRODUCTS OR SERVICES IS PROHIBITED BY LAW.

Potential Disruption of Service

Access to the Website may from time to time be unavailable, delayed, limited or slowed due to, among other things:

1. Hardware failure, including among other things failures of computers (including your own computer), servers, networks, telecommunication lines and connections, and other electronic and mechanical equipment
2. Software failure, including among other things, bugs, errors, viruses, configuration problems, incompatibility of systems, utilities or applications, the operation of firewalls or screening programs, unreadable codes, or irregularities within particular documents or other content
3. Overload of system capacities
4. Damage caused by severe weather, earthquakes, wars, insurrection, riots, civil commotion, act of God, accident, fire, water damage, explosion, mechanical breakdown or natural disasters
5. Interruption (whether partial or total) of power supplies or other utility of service
6. strike or other stoppage (whether partial or total) of labor
7. Governmental or regulatory restrictions, exchange rulings, court or tribunal orders or other human intervention
8. Any other cause (whether similar or dissimilar to any of the foregoing) whatsoever beyond the control of Halsted Financial Services, LLC

Links to Other Sites

Links to non-Halsted Financial Services, LLC., Websites are provided solely as pointers to information on topics that may be useful to the Websites, and Halsted Financial Services, LLC., has no control over the content on such non-Halsted Financial Services, LLC., Websites. If you choose to link to a Website not controlled by Halsted Financial Services, LLC., Halsted Financial Services, LLC., makes no warranties, either express or implied, concerning the content of such site, including the accuracy, completeness, reliability or suitability thereof for any particular purpose, nor does Halsted Financial Services, LLC., warrant that such site or content is free from any claims of copyright, trademark or other infringement of the rights of third parties or that such site or content is devoid of viruses or other contamination. Halsted Financial Services, LLC., does not guarantee the authenticity of documents on the Internet. Links to non-Halsted Financial Services, LLC., sites do not imply any endorsement of or responsibility for the opinions, ideas, products, information or services offered at such sites, or any representation regarding the content at such sites.

LIMITATION OF LIABILITY

BECAUSE OF THE POSSIBILITY OF HUMAN AND MECHANICAL ERROR AS WELL AS OTHER FACTORS, THE WEBSITE (INCLUDING ALL INFORMATION AND MATERIALS CONTAINED ON THE WEBSITE) IS PROVIDED "AS IS" "AS AVAILABLE". HALSTED FINANCIAL SERVICES, LLC., AND THIRD PARTY DATA PROVIDERS ARE NOT PROVIDING ANY WARRANTIES AND REPRESENTATIONS REGARDING THE WEBSITE. HALSTED FINANCIAL SERVICES, LLC., AND THIRD PARTY DATA PROVIDERS DISCLAIM ALL WARRANTIES AND REPRESENTATIONS OF ANY KIND WITH REGARD TO THE WEBSITE, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT OF THIRD PARTY RIGHTS, FREEDOM FROM VIRUSES OR OTHER HARMFUL CODE, OR FITNESS FOR ANY PARTICULAR PURPOSE. FURTHER, HALSTED FINANCIAL SERVICES, LLC., WILL NOT BE LIABLE FOR ANY DELAY, DIFFICULTY IN USE, INACCURACY OF INFORMATION, COMPUTER VIRUSES, MALICIOUS CODE OR OTHER DEFECT IN THIS WEBSITE, OR FOR THE INCOMPATIBILITY BETWEEN THIS WEBSITE AND FILES AND THE USER'S BROWSER OR OTHER SITE ACCESSING PROGRAM. NOR WILL HALSTED FINANCIAL SERVICES, LLC., BE LIABLE FOR ANY OTHER PROBLEMS EXPERIENCED BY THE USER DUE TO CAUSES BEYOND HALSTED FINANCIAL SERVICES, LLC'S CONTROL. NO LICENSE TO THE USER IS IMPLIED IN THESE DISCLAIMERS.

HALSTED FINANCIAL SERVICES, LLC., AND THIRD PARTY DATA PROVIDERS DO NOT WARRANT THE ACCURACY, ADEQUACY, OR COMPLETENESS OF THE INFORMATION AND MATERIALS CONTAINED ON THE WEBSITE AND EXPRESSLY DISCLAIMS LIABILITY FOR ERRORS OR OMISSIONS IN THE MATERIALS AND INFORMATION. FURTHERMORE, HALSTED FINANCIAL SERVICES, LLC., AND ITS AFFILIATES WILL NOT BE LIABLE FOR ANY DELAY, DIFFICULTY IN USE, COMPUTER VIRUSES, MALICIOUS CODE, OR OTHER DEFECT IN WEBSITE, ANY INCOMPATIBILITY BETWEEN THE WEBSITE AND THE USER'S FILES AND THE USER'S BROWSER OR OTHER SITE ACCESSING PROGRAM, OR ANY OTHER PROBLEMS EXPERIENCED BY THE USER DUE TO CAUSES BEYOND HALSTED FINANCIAL SERVICES, LLC., AND ITS AFFILIATES' CONTROL. NO LICENSE TO THE USER IS IMPLIED IN THESE DISCLAIMERS. NOTHING HEREIN SHALL BE CONSTRUED AS LIMITING OR REDUCING HALSTED FINANCIAL SERVICES, LLC'S RESPONSIBILITIES AND OBLIGATIONS TO CLIENTS IN ACCORDANCE WITH APPLICABLE LAWS AND REGULATIONS.

UNDER NO CIRCUMSTANCES WILL HALSTED FINANCIAL SERVICES, LLC., BE LIABLE FOR ANY LOST PROFITS, LOST OPPORTUNITY OR ANY INDIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, PUNITIVE, OR EXEMPLARY DAMAGES ARISING OUT OF ANY USE OF OR INABILITY TO USE THE WEBSITE OR ANY PORTION THEREOF, REGARDLESS OF WHETHER HALSTED FINANCIAL SERVICES, LLC., HAS BEEN APPRISED OF THE LIKELIHOOD OF SUCH DAMAGES OCCURRING AND REGARDLESS OF THE FORM OF ACTION, WHETHER IN CONTRACT, WARRANTY, TORT, (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR OTHERWISE.

Enforceability and Governing Law

In the event any of the terms or provisions of these Terms and Conditions shall be held to be unenforceable, the remaining terms and provisions shall be unimpaired and the unenforceable term or provision shall be replaced by such enforceable term or provision as comes closest to the intention underlying the unenforceable term or provision. These Terms and Conditions shall be subject to any other agreements you have entered into with Halsted Financial Services, LLC. The user's access to and use of the halstedfinancial.com Website, and the terms of this disclaimer are governed by the laws of the State of Illinois.

This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose.

California: The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances, collectors may not contact you before 8 a.m. or after 9 p.m. They may not harass you by using threats of violence or arrest, or by using obscene language. Collectors may not use false or misleading statements or call you at work if they know or have reason to know that you may not receive personal calls at work. For the most part, collectors may not tell another person, other than your attorney, or spouse, about your debt. Collectors may contact another person to confirm your location or enforce a judgment. For more information about debt collection activities, you may contact the Federal Trade Commission at 1-877-FTC-HELP or www.ftc.gov.

You may request records showing the following: (1) that : the current creditor to whom the debt is owed has the right to seek collection of the debt; (2) the debt balance, including an explanation of any interest charges and additional fees; (3) the date of default or the date of the last payment; (4) the name of the charge-off creditor and the account number associated with the debt; (5) the name and last known address of the debtor as it appeared in the charge-off creditor’s or debt buyer’s records prior to the sale of the debt, as appropriate; and (6) the names of all persons or entities that have purchased the debt. You may also request from us a copy of the contract or other document evidencing your agreement to the debt. A request for these records may be addressed to: P.O. Box 828, Skokie, IL 60076

Cal. Health & Safety Code § 127430: State and federal law require debt collectors to treat you fairly and prohibit debt collectors from making false statements or threats of violence, using obscene or profane language, and making improper communications with third parties, including your employer. Except under unusual circumstances, debt collectors may not contact you before 8 a.m. or after 9 p.m. In general, a debt collector may not give information about your debt to another person, other than your attorney or spouse. A debt collector may contact another person to confirm your location or to enforce a judgment. For more information about debt collection activities, you may contact the Federal Trade Commission by telephone at 1-877-FTC-HELP (382-4357) or online at www.ftc.gov. Nonprofit credit counseling services may be available in the area.

Colorado: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COAG.GOV/CAR. A consumer has the right to request in writing that a debt collector or collection agency cease further communication with the consumer. A written request to cease communication will not prohibit the debt collector or collection agency from taking any other action authorized by law to collect the debt. Our office is licensed under the name of Halsted Financial Services, LLC by the Colorado Department of Commerce for the state of Colorado. Local Office information: Colorado Manager, Inc. Halsted Financial Services, LLC 8960 Wolff Ct., Suite 110, Westminster, CO 80031 Phone: 303-920-4763 or 877-833-1629.

Illinois: Our office is licensed under the name of Halsted Financial Services, LLC for the state of Illinois.

Minnesota: This collection agency is licensed by the Minnesota Department of Commerce.

Nevada: NRS 649.332 Verification of Debt

1. To verify a debt, a collection agency shall:

(a) Obtain or attempt to obtain from the creditor any document that is not in the possession of the collection agency and is reasonably responsive to the dispute of the debtor, if any; and (b) If such a document is obtained, mail the document to the debtor.

2. When collecting debt on behalf of a hospital, within 5 days after the initial communication with the debtor in connection with collection of the debt, a collection agency shall, unless the following information is included in the initial communication, send a written notice to the debtor that includes a statement indicating that:

(a) If the debtor pays or agrees to pay the debt or any portion of the debt, the payment or agreement to pay may be construed as: (1) An acknowledgement of the debt by the debtor; and (2) A wavier by the debtor of any applicable statute of limitations set forth in NRS 11.190 that otherwise precludes the collection of the debt; and (b) if the debtor does not understand of has questions concerning his or her legal rights or obligations relating to the debt, the debtor should seek legal advice.

3. As used in this section, “Hospital” has the meaning ascribes to it in NRS 444.012

(Added to NRS by 2007,2005) NRS 449.012 “Hospital” Defined. “Hospital” means an establishment for the diagnosis, care and treatment of human illness, including care available 24 hours each day from persons licensed to practice professional nursing who are under the direction of a physician, services of a medical laboratory and medical, radiological, dietary and pharmaceutical services. (Added to NRS by 1973, 1279; A 1985, 1737) If the consumer pays or agrees to pay the debt or any portion of the debt, the payment or agreement to pay may be construed as: (1) an acknowledgement of the debt by the consumer; and (2) a wavier by the consumer od any applicable statute of limitations set forth in NRS 11.190 that otherwise precludes the collection of the debt; and (3) if the consumer does not understand or has questions concerning his/her legal rights or obligations relating to the debt, the debtor shall seek legal advice.

New York City: New York City Department of Consumer Affairs License Number: 2039870-DCA. New York: Debt collectors in accordance with the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., are prohibited from engaging in abusive, deceptive, and unfair debt collection efforts, including but not limited to: the use or threat of violence; the use of obscene or profane language; and repeated phone calls made with the intent to annoy, abuse, or harass. If a creditor or debt collector receives a money judgment against you in court, state and federal laws may prevent the following types of income from being taken to pay the debt:

1. Supplemental security income, (SSI);
2. Social security;
3. Public assistance (welfare);
4. Spousal support, maintenance (alimony) or child support;
5. Unemployment benefits;
6. Disability benefits;
7. Workers’ compensation benefits;
8. Public or private pensions;
9. Veterans’ benefits;
10. Federal student loans, federal student grants, and federal work study funds; and
11. Ninety percent of your wages or salary earned in the last sixty days.

Debt collectors, in accordance with the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., are prohibited from engaging in abusive, deceptive, and unfair debt collection efforts, including but not limited to: (i) the use or threat of violence; (ii) the use of obscene or profane language; and (iii) repeated phone calls made with the intent to annoy, abuse, or harass. (The state does not provide sample language for this disclosure.) City of Yonkers, NY: In addition to any practices prohibited under any federal, state or local law, a debt collection agency shall not contact a consumer about or seek to collect a debt on which the statute of limitations for initiating legal action has expired unless such agency first provides the consumer such information about the consumer’s legal rights as the commissioner proscribes by rule.

New York, Yonkers: In addition to any practices prohibited under any federal, state or local law, a debt collection agency shall not contact a consumer about or seek to collect a debt on which the statute of limitations for initiating

legal action has expired unless such agency first provides the consumer such information about the consumer’s legal rights as the commissioner proscribes by rule.

North Carolina: Permit No. 112938 Halsted Financial Services, Suite 500, LLC 8001 Lincoln Ave Skokie, IL

60077 / Permit No. 113839 9th Floor, JELP Building #409, Shaw Boulevard Brgy Addition Hills, Mandaluyong

City, Philippines 1550

Tennessee: Halsted Financial Services, LLC is licensed by the Collection Service Board of the Department of Commerce and Insurance.

Washington: In addition to the rights listed above, you have the right to request the following information at any time: (1) The original account number or redacted original account number assigned to the debt; (2) The date of the last payment to the creditor; and (3) An itemized statement including: (a) The name and address of the medical creditor; (b) The date of service; (c) The health care services provided; (d) The amount of principal; (e) Any adjustment to the bill; (f) Any payments received; (g) Any interest or fees, if applicable; and (h) Whether the patient was found eligible for charity care or other reductions and, if so, the amount due after all reductions have been applied

West Virginia: The activities of collection agencies in West Virginia are regulated by the Attorney General’s Consumer Protection Division, 812 Quarrier St., Charleston, WV 25301. Federal law prohibits agencies from contacting you about your debt if you send a letter requesting that all contacts stop.

This Privacy Policy discloses the privacy practices of Halsted Financial Services, LLC.

Information Collection, Use, and Sharing

We do not allow third parties to collect personally identifiable information about a user’s online activities, over time and across different sites, services, and applications, when that user uses our site or service.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Policy and only to the extent permitted by the Fair Debt Collection Practices Act and applicable law:

1. To contractors, service providers, and other third parties we use to support our business, such as creditor clients, insurers, payment processor vendors, mailing vendors, consumer reporting agencies, and information technology providers, who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
2. To fulfill the purpose for which you provide it.
3. For any other purpose disclosed by us when you provide the information.
4. With your consent.

We may also disclose your personal information:

1. To comply with any court order, law or legal process, including to respond to any government or regulatory request.
2. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. We have implemented physical, electronic, and procedural security safeguards to protect against the unauthorized or unlawful release of or access to personal information, including any social security numbers. To further safeguard this information, access to sensitive information such as social security numbers is limited, and our employees must abide by standards of conduct and confidentiality agreements.

Your Access to and Control over Information

You can make changes to personal identifiable information we collect from you by contacting us via telephone at 888-348-9776, via e-mail at admin@halstedfinancial.com or via US Mail at P.O. Box 828, Skokie, IL 60076.

California Residents – California Consumer Privacy Policy Notice

This Privacy Policy Notice is intended for California residents pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), and supplements the information contained in the above Privacy Policy. Any terms defined in the CCPA and applicable California Attorney General regulations have the same meaning as used in this Privacy Policy Notice.

1. Information We Collect About You

We may collect and use personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be directly or indirectly linked, with a consumer, device, or household (“personal information”).

Personal Information does not include:

1. Publicly available information from government records.
2. Deidentified or aggregated consumer information.
3. 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”).

We regularly collect (and have collected in the past 12 months) several types of personal information about individuals offline regarding accounts we service, including: name, DOB, address, gender, account number, payment and other financial information, email address, insurance information, SSN, employment information, telephone number, IP address, military or veteran status, audio information, username, publicly available information, and information collected or shared pursuant to HIPAA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws. We also may collect additional categories of personal information users provide directly to us or our service providers.

2. How Your Personal Information is Collected

We collect most of this personal information from our creditor clients or from you or your authorized representative by telephone or written communications. However, we may also collect information:

1. From publicly accessible sources (e.g., property or other government records);
2. From our service providers (e.g., call analytics, information source, skip-tracing, payment processing, mailing, and other vendors)

3. Why We Use or Disclose Your Personal Information

We regularly use or disclose personal information for one or more of the following business purposes:

1. Fulfill the reason you provided the information. For example, if you share your personal information to make a payment, we will use that information to process your payment.
2. Perform services on behalf of a business or service provider, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing analytic services, or providing similar services on behalf of the business or service provider
3. Provide you with information or services that you request from us
4. Auditing related to consumer interactions
5. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
6. Debugging to identify and repair errors that impair existing intended functionality
7. Short-term, transient use, where the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction
8. Undertaking activities to verify or maintain the quality of a service or device that is owned, made by or for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, made by or for, or controlled by us
9. Respond to law enforcement requests and as required by applicable law or court order
10. As appropriate to protect the rights, property, or safety of us, our clients, or others
11. As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different purposes without providing you notice.

We regularly disclose (and have disclosed in the past 12 months) several types of personal information about individuals for one or more business purposes, including: name, DOB, address, gender, account number, previous payment and other financial information, email address, insurance information, SSN, employment information, telephone number, IP address, military or veteran status, audio information, username, and information collected or shared pursuant to HIPAA, FIPA, GLBA, FCRA, DPPA, and/or other applicable privacy laws.

We have not sold your personal information over the last 12 months and will not sell your personal information under the CCPA.

4. Verifiable Consumer Requests for Information

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

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

A business may charge a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to you by your 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.

Please note that we are not required to:

1. Carry out information access requests we receive from you if acting as a service provider to another entity regarding such information
2. 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;
3. 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;
4. Provide the requested information disclosure to you more than twice in a 12-month period.
5. 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
6. Provide the requested information disclosure if a CCPA or applicable exception applies.

5. Right to Request Deletion of Personal Information

Upon verification of identity, California residents may in some cases request that we delete personal information about you that we collected from you and retained, subject to certain exceptions.

We may deny your deletion request if we are acting in the role of a service provider to another business regarding the applicable personal information. If we deny your request on that basis, we will generally refer you to the relevant business. In addition, we may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
3. Debug to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided by law.
5. Comply with the California Electronic Communications Privacy Act.
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent.
7. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information; or
10. If another CCPA or applicable exception applies.

California residents may obtain more information about verifiable requests pursuant to the CCPA by contacting us via telephone at 888- 348-9776, via e-mail at CCPARequest@halstedfinancial.com or through the US Mail at P.O. Box 828, Skokie, IL 60076.

6. Verifying Your Identity If You Submit CCPA Requests

If you choose to contact us directly via the designated methods described above to exercise your CCPA rights, you will need to:

1. Provide enough information to reasonably identify you; and
2. Describe your request with sufficient detail to allow us to properly process and respond to your request.

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.

Security

We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.

Whenever we collect sensitive information (such as credit card data) that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the webpage.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

Notice of Change

Halsted Financial Services, LLC., notifies its customers of changes to this privacy policy by publishing the changes to this website.

We may change, add, modify or remove portions of this Policy at any time, which shall become effective immediately upon posting on this page. The date the Policy was last revised is identified at the bottom of the page. It is your responsibility to review this Policy for any changes. By continuing to use our website, you agree to any changes in the Policy.

This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose.

Last modified: December 31, 2019