PRA Group, Inc. Web Privacy Policy

Effective: 7/31/2020

This site is owned and controlled by PRA Group, Inc. (“PRA Group” or “we,” “our,” or “us”). This Web Privacy Policy describes the types of personal information we collect on www.pragroup.com (“the Website”), how we may use the information and the purposes for which we may use it, with whom we may share it, and the measures we take to safeguard your information.

Unless indicated otherwise, this Web Privacy Policy applies only to information collected through the Website. Please read this entire Web Privacy Policy before using the Website.

Information We Obtain

We may obtain personal information through the Website, including contact information (such as your name, email address, and phone number) and other information you submit to us including information you submit to us in connection with a job opportunity.

In addition, as you navigate through the Website, we may obtain certain information using various automated technologies, such as cookies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. The Website may use cookies or similar automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your IP address, identifiers associated with your device, web browser characteristics, device characteristics, language preferences, referring/exit pages, dates and times of visits to the Website, and clickstream data.

The Website is not designed to respond to “do not track” signals received from browsers. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that certain features of the Website may not work without use of automated information collection technologies.

Use and Disclosure of Information

We may use the information we obtain about you to:

• Provide the Website and other services to you.
• Communicate with you.
• Operate, evaluate, develop, manage, and improve the Website and our business (including operating, administering, analyzing, and improving our services; developing new services; managing and evaluating the effectiveness of our communications).
• Perform analytics (including market research, and trend analysis).
• Manage career opportunities, including for recruitment purposes, candidate screening, and evaluation, and employee onboarding.
• Increase and maintain the safety and security of our services and prevent misuse.
• Protect against, identify, and prevent fraud and other criminal activity, claims, and other liabilities.
• Comply with and enforce applicable legal requirements, relevant industry standards, and policies, including this Web Privacy Policy and our Terms & Conditions.

We also may use the information we obtain about you for other purposes disclosed at the time your information is collected.

In addition, we use information collected through automated technologies to (i) understand how you use and interact with the Website; (ii) measure the usability of the Website and the effectiveness of our communications; and (iii) otherwise manage and enhance the Website and our other services, and help ensure they are working properly.

We may share the information we obtain about you with third-party vendors to perform certain services on our behalf, such as to assist us with Website hosting and operations, data analytics, and other services designed to assist us with our business. We also may share your information with our affiliates and subsidiaries for the purposes described in this Web Privacy Policy.

In addition, we may disclose information about you: (i) if we are required to do so by law or legal process (such as a court order or subpoena); (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) to establish, exercise, or defend our legal rights; (iv) to protect, defend, or enforce our policies, terms, or agreements; (v) when we believe disclosure is necessary or appropriate to address security or to prevent physical or other harm or financial loss; (vi) in connection with an investigation of suspected or actual illegal activity; or (vii) otherwise with your consent.

In addition, we also reserve the right to transfer information we have about you in the event we sell or transfer all or a portion of our business or assets (such as in the event of a merger, acquisition, joint venture, consolidation, restructuring, divestiture, dissolution liquidation, or other corporate change), including during the course of any due diligence process.

Third-Party Analytics

We may use third-party analytics services on the Website, such as Google Analytics. The analytics providers that administer these services use automated technologies such as cookies to help us analyze your use of the Website. The information collected through these means (including IP address) may be disclosed to these analytics providers who use the information, for example, to evaluate use of the Website. To learn more about Google Analytics and how to opt-out, please visit google.com/dlpage/gaoptout.

Security

We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Children’s Privacy

We recognize the importance of protecting children’s online privacy. The Website is intended for a general audience and is not directed to children. We do not knowingly collect personal information online from children under the age of 13.

Other Online Services

For your convenience and information, the Website may contain content, links, or references to other third-party websites, apps, or services. Please be aware that this Web Privacy Policy does not apply to those websites. These companies may have their own privacy policies, which we encourage you to review. In addition, when you are on the Website you may be directed to other sites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any non-PRA websites, apps, or services.

Changes to this Web Privacy Policy

This Web Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a notice on our Website to notify you of significant changes to our Web Privacy Policy and indicate at the top of the notice when it was most recently updated.

How to Contact Us

If you have any questions, comments, or concerns about this Web Privacy Policy, please contact us at (888) 772-7326.

PRA Group, Inc.
CCPA Privacy Policy Supplement

For California Consumers

If you are a California resident, the information in this CCPA Privacy Policy Supplement (“Supplement”) may apply to you, in addition to our Web Privacy Policy. For clarity, the information below applies to personal information we collect both on the Website and offline. This Supplement does not apply to PRA Group personnel or job applicants.

This Supplement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Supplement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, or other similar identifier
• Online Activity: Internet and other electronic network activity information, including, but not limited to, information regarding your interaction with websites, applications or advertisements
• Sensory Information: audio, electronic, and similar information.

We may use (and may have used during the 12-month period prior to the effective date of this Supplement) your personal information for the purposes described in our Privacy Policy and for the following business purposes specified in the CCPA:

• performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
• auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
• short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• debugging to identify and repair errors that impair existing intended functionality
• undertaking internal research for technological development and demonstration
• undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Sources of Personal Information

During the 12-month period prior to the effective date of this Supplement, we may have obtained personal information about you from the following categories of sources:

• from you or your devices, for example, through your use of the Website
• our affiliates or subsidiaries
• vendors who provide services on our behalf
• data analytics providers

Sale of Personal Information

We have not sold personal information during the 12-month period prior to the effective date of this Privacy Policy.

Sharing of Personal Information

During the 12-month period prior to the effective date of this Supplement, we may have shared your personal information with certain categories of third parties, as described below.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties.

Category of Personal Information	Category of Third Party
Identifiers	Vendors who provide services on our behalf Data analytics providers
Online Activity	Vendors who provide services on our behalf Data analytics providers
Sensory Information	Vendors who provide services on our behalf Data analytics providers

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Supplement, we may have shared personal information about you with government entities, such as in response to a request from law enforcement authorities.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.
• Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

How to Submit a Request. To submit an access or deletion request, email us at pracustomercare@portfoliorecovery.com or call us at (888) 772-7326. To submit a request as an authorized agent on behalf of a consumer, please email us at pracustomercare@portfoliorecovery.com and provide us with a copy of the signed permission from the California consumer that authorizes you to act on the consumer’s behalf. For questions or concerns about our privacy policies and practices, please contact us as described in the How to Contact Us section of our Privacy Policy.

Verification. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you do not have an email address or other direct contact information on file with us, then there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that we do not link IP addresses, device identifiers or other information collected through automated means to named actual persons. Accordingly, if you do not have an email address or other direct contact information on file with us, and you request access to or deletion of your personal information, we will not be able to process your request at this time.

If you have an email address or other direct contact information on file with us, and request access to or deletion of your personal information, we may require you to provide your name and email address. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.