Privacy Policy

First Associates Loan Servicing, LLC including its subsidiary Activate Financial, LLC (collectively “FALS”) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  FALS has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

FALS may collect personally identifiable data including name, mailing or email address, etc. for the purposes outlined in FALS agreements with clients. These services may include document custodial services, backup loan and lease servicing and primary loan or lease servicing.

Sometimes forwarding information to a third party is a necessary part of FALS’ ordinary business process. Third party agents include debt rating agencies, contact tracking and contact tracking and communication agencies. FALS never sells customer information for marketing purposes. FALS contractually requires the third party:

  • To protect your customer information in line with principals outlined in the U-US Privacy Shield Framework.
  • To ensure the information is only used for purposes outlined in the contract.
  • To never to share any information with a third party without written approval by FALS.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, FALS is potentially liable.

You have the right to review, limit use and disclosure of your personal information. Each request is reviewed in line with the legitimate use of the information in the normal course of business. Requests must be submitted in writing to FALS or via email to privacy@1stassociates.com. All requests require certification that the requestor is actually the person identified by the information.

You have the right to choose whether or not FALS shares your information with third parties who are not our agent or uses the information for purposes other than for which it was originally collected or subsequently authorized. You will be contact to allow such use (opt in) and you may request to opt out submitting a request in writing to FALS or via email to privacy@1stassociates.com. Note, currently FALS never shares information with third parties who are not our agents or uses your information for purposes other than it was originally collected.

In compliance with the EU-US Privacy Shield Principles, FALS commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact FALS at privacy@1stassociates.com. FALS has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

In addition, FALS complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland.  FALS has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern.  To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/

In compliance with the US-Swiss Safe Harbor Principles, FALS commits to resolve complaints about your privacy and our collection or use of your personal information.  Swiss citizens with inquiries or complaints regarding this privacy policy should first contact FALS at privacy@1stassociates.com.

FALS has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

FALS is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

FALS also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Some types of personal information may be subject to other privacy-related requirements and policies, which are consistent with Privacy Shield and US-Swiss Safe Harbor. FALS also complies with all U.S. and U.S. state privacy laws and regulations.