Privacy Policy

Last Updated: 04/10/2025

Superlative RM believes that maintaining the privacy and confidentiality of an individual’s personal information is important. We provide the following privacy policy (the “Privacy Policy”) in order to demonstrate our firm commitment to privacy. Superlative RM may need to change this Privacy Policy from time to time in order to address new issues and to reflect changes on our Site or in applicable law. Please refer back to this Privacy Policy regularly because your use of the Site signifies that you agree to be bound by the terms and conditions of this Privacy Policy, as amended from time to time.

This Privacy Policy applies to personal information we collect from California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), and to personal data we process from Oregon residents under the Oregon Consumer Privacy Act, ORS 646A.570-589 (the “OCPA”), to the extent those laws apply to Superlative RM.

1. Categories of Personal Information We Collect

We typically collect the following categories of personal information about a consumer for debt collection purposes only:

a. Health insurance information, which we obtain from the debtor’s creditor or the consumer, if we are collecting a medical debt. This category may constitute sensitive personal information under California law and sensitive data under Oregon law.

b. Personal identifying information, such as name, address, Social Security number, and account number, as well as other identifying information, which we obtain from the consumer’s creditor, credit reports and other skip trace tools, and the consumer. To the extent this includes Social Security numbers, driver’s license numbers, or financial account information, this category may constitute sensitive personal information under California law and sensitive data under Oregon law.

c. Characteristics such as age, gender, and similar demographic information, which we obtain from the consumer’s creditor and the consumer’s credit report. To the extent this includes racial or ethnic origin, this category may constitute sensitive personal information under California law and sensitive data under Oregon law.

d. Retail information, which we obtain from the consumer’s creditor and the consumer’s credit report.

e. Internet activity regarding online payments, which we collect if the consumer visits our website or payment portal.

f. Recordings, which are made when the consumer has a telephone conversation with us.

g. Professional and employment-related information, which we obtain from the consumer’s creditor, credit reporting agencies, and other skip trace sources.

h. Educational information, which we obtain from the consumer’s creditor, credit reporting agencies, and other skip trace sources.

2. Categories of Sources

We collect personal information from the following categories of sources:

  • The consumer directly
  • The consumer’s creditor
  • Credit reporting agencies
  • Skip trace tools and data providers
  • Process servers
  • The consumer’s interactions with our website or payment portal

3. Purposes for Collecting Personal Information

  • We collect and use personal information for the following purposes:
  • To collect debts owed to our clients
  • To verify consumer identity and locate consumers
  • To communicate with consumers regarding their accounts
  • To process payments
  • To comply with legal and regulatory obligations
  • To exercise or defend legal claims

4. Disclosure of Personal Information

We do not sell or share personal information as those terms are defined under the CCPA. We do not sell personal data as defined under the OCPA.

We may disclose personal information to the following categories of third parties for business purposes:

  • Credit reporting agencies
  • Our clients (the original creditors)
  • Courts and legal authorities as required by law
  • Service providers that assist with our debt collection operations

5. Retention of Personal Information

Superlative RM retains each category of personal information for as long as is reasonably necessary to fulfill the purpose for which it was collected, to comply with legal and regulatory obligations (including applicable statutes of limitations and record retention requirements), and to exercise or defend legal claims. When personal information is no longer needed for any of these purposes, it will be securely deleted or de-identified.

6. Your Rights Under California Law (CCPA)

If you are a California resident, you have the following rights under the CCPA:

a. Right to Know. You have the right to request that Superlative RM disclose the following:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information was collected;
  • The business or commercial purpose for collecting the personal information;
  • The categories of third parties with whom we have shared your personal information; and
  • The specific pieces of personal information we have collected about you.
  • You may also request personal information collected prior to the 12-month period preceding your request, going back to January 1, 2022.

b. Right to Delete. You have the right to request that Superlative RM delete personal information we have collected about you, subject to certain exceptions. The information that Superlative RM maintains generally falls within an exception (such as information necessary to complete a transaction, comply with a legal obligation, or exercise or defend legal claims) and may not be required to be deleted upon request. Nonetheless, we will evaluate each deletion request individually.

c. Right to Correct. You have the right to request that Superlative RM correct inaccurate personal information that we maintain about you. Upon receiving a verified request, Superlative RM will use commercially reasonable efforts to correct the inaccurate personal information.

d. Right to Opt Out of Sale or Sharing. You have the right to opt out of the sale or sharing of your personal information. Superlative RM does not sell or share personal information as those terms are defined under the CCPA.

e. Right to Limit Use of Sensitive Personal Information. You have the right to direct Superlative RM to limit its use and disclosure of your sensitive personal information to uses that are necessary to perform the services reasonably expected by you, or as otherwise permitted by law. Superlative RM uses sensitive personal information only for debt collection purposes and as required by law, and does not use sensitive personal information for purposes that would trigger additional limitation obligations under the CCPA.

f. Right to Non-Discrimination. You have the right not to receive discriminatory treatment from Superlative RM for exercising any of your privacy rights under the CCPA.

g. Opt-Out Preference Signals. Superlative RM recognizes opt-out preference signals, including the Global Privacy Control (GPC), as valid requests to opt out of the sale or sharing of personal information. When we detect such a signal, we will process the request without requiring additional action from the consumer.

How to Exercise Your California Rights

To submit a request to know, delete, or correct, contact Superlative RM by:

Mail: 4343 N Scottsdale Rd, Suite 150, RM 104, Scottsdale, AZ 85251
Email: [email protected]
Phone: 888-441-4544

Once we receive your request, we will verify your identity by matching two to three identifying data points you provide against the information we already maintain. If we cannot verify your identity, we will notify you. We will respond to your request within 45 days of receipt. If we need additional time, we will notify you of the extension (up to an additional 45 days) and the reason for it.

Authorized Agents

You may designate an authorized agent to submit a request on your behalf. You must provide the authorized agent with written permission (such as a power of attorney or signed written authorization), and we may require you to verify your own identity directly with us.

7. Your Rights Under Oregon Law (OCPA)

If you are an Oregon resident, you have the following rights under the Oregon Consumer Privacy Act (ORS 646A.570-589):

a. Right to Confirm and Access. You have the right to confirm whether Superlative RM is processing your personal data and to access the categories of personal data being processed.

b. Right to Correct. You have the right to request that we correct inaccuracies in the personal data we maintain about you.

c. Right to Delete. You have the right to request that we delete personal data we hold about you, including data obtained from third-party sources, subject to applicable legal exceptions.

d. Right to Data Portability. You have the right to obtain a copy of your personal data in a portable, readily usable format, including a list of the specific third parties to which Superlative RM has disclosed your personal data.

e. Right to Opt Out. You have the right to opt out of the processing of your personal data for:

  • Targeted advertising;
  • The sale of personal data; and
  • Profiling in furtherance of solely automated decisions that produce legal or similarly significant effects.

f. Sensitive Data. Superlative RM will obtain your consent before processing sensitive data as defined by Oregon law, including health information, precise geolocation data, racial or ethnic origin, and data concerning children under the age of 16, except where processing is necessary to comply with a legal obligation or is otherwise permitted under the OCPA.

g. Universal Opt-Out Mechanism. Superlative RM honors universal opt-out mechanisms, including the Global Privacy Control (GPC), as valid opt-out requests for targeted advertising and the sale of personal data.

How to Exercise Your Oregon Rights

To submit a request, contact Superlative RM by:

Mail: 4343 N Scottsdale Rd, Suite 150, RM 104, Scottsdale, AZ 85251
Email: [email protected]
Phone: 888-441-4544

Superlative RM will respond to your request within 45 days of receipt. If we need additional time, we will notify you of the extension and the reason for it.

Right to Appeal

If we decline to take action on your request, you have the right to appeal that decision. To submit an appeal, contact us using the information above and include “Privacy Appeal” in the subject line. We will respond to your appeal within 45 days. If we deny your appeal, we will provide you with information on how to contact the Oregon Attorney General to submit a complaint.

8. Children’s Privacy

Superlative RM does not knowingly sell the personal data of consumers under the age of 16, nor does it use such data for targeted advertising or profiling. If Superlative RM becomes aware that it has collected personal data from a child under 16, it will take steps to delete that data unless retention is required by law.

9. Changes to This Privacy Policy

Superlative RM may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post the revised Privacy Policy on our Site with an updated “Last Updated” date. We encourage you to review this Privacy Policy periodically.

10. Contact Us

Questions regarding this Privacy Policy should be directed to:

Email: [email protected]
Mail: 4343 N Scottsdale Rd, Suite 150, RM 104, Scottsdale, AZ 85251
Phone: 888-441-4544