PRIVACY POLICY

Last Updated: June 18, 2026

Introduction

J.J. Marshall & Associates, Inc., dba of Ceteris Portfolio Services, LLC (hereinafter “J.J. Marshall,” “we,” “us,” or “our”), is a debt collector. This is a communication from a debt collector. This is an attempt to collect a debt, and any information obtained will be used for that purpose.

We believe that maintaining the privacy and confidentiality of an individual’s personal information is important. This Privacy Policy describes how we collect, use, maintain, and disclose information collected from consumers, website visitors, and other individuals who interact with our services.

This Privacy Policy applies to the information we collect:

• When providing debt collection services
• Through our website at jjmarshallinc.com
• Through email, text, or other electronic communications
• Through phone calls and other direct interactions

By using our services or website, you agree to this Privacy Policy.

2. PERSONAL INFORMATION WE COLLECT

2.1 For Debt Collection Purposes. We collect the following categories of personal information about consumers for debt collection purposes:

• Health insurance information, obtained from the debtor’s creditor or the consumer, if we are collecting a medical debt.
• Personal identifying information (name, address, account number, and other identifying information), obtained from the consumer’s creditor, credit reports, other skip trace tools, and the consumer.
• Characteristics such as age and gender, obtained from the consumer’s creditor and credit reports.
• Retail information, obtained from the consumer’s creditor and credit reports.
• Internet activity regarding online payments, collected if the consumer visits our website or payment portal.
• Geolocation data, obtained from process servers.
• Recordings, made when the consumer has a telephone conversation with us.
• Professional and employment-related information, obtained from the consumer’s creditor, credit reporting agencies, and other skip trace sources.
• Educational information, obtained from the consumer’s creditor, credit reporting agencies, and other skip trace sources.

All of the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

2.2 Website and Technical Information. When you access our website, emails, or web applications, we may collect technical and computer information, including: Internet Protocol (IP) address; browser type and language; Internet service provider (ISP); type of computer and operating system; date and time stamp; user interface interaction data (such as mouse clicks, navigation, and keystrokes); uniform resource locator (URL) information (showing where you came from or where you go next); and email open rates.

2.3 Sensitive Personal Information. In the course of providing debt collection services, we may collect or process certain categories of information classified as “sensitive” under applicable state privacy laws, including: health insurance information and medical debt-related information; Social Security numbers (full or partial); financial account numbers (bank account, debit card, credit card); and precise geolocation data (obtained from process servers). We do not collect or process sensitive personal information for the purpose of inferring characteristics about consumers. We process sensitive personal information only as necessary to fulfill our debt collection services, verify your identity, and comply with legal obligations. Where required by applicable state law, we will obtain your affirmative consent before processing sensitive personal information. You may revoke your consent at any time by contacting us.

3. SOURCES OF PERSONAL INFORMATION

We receive your personal information from the following sources:

• The creditor or current creditor of your account.
• You directly, through phone calls, email correspondence, or interactions with our website.
• Third-party vendors who help us confirm the validity of our information (addresses, phone numbers, bankruptcy status, deceased information).
• Credit reporting agencies and other skip trace sources.
• Service providers who assist us with payment processing, analytics, and other business functions.
• Publicly available sources, including government records and public databases.
• Other individuals, such as co-signers, authorized users, or individuals who provide referrals.

4. HOW WE USE INFORMATION

We use your personal information primarily for the following purposes:

• Sending you communications about your account
• Verifying your identity when you contact us
• Processing payments and other account activity you authorize
• Providing and improving our services
• Monitoring and securing our website and services
• Detecting and preventing fraud
• Providing customer service, addressing and resolving questions or disputes
• Complying with state, federal, and local laws
• Demonstrating compliance with applicable laws and regulations

Data Minimization: We limit the collection of personal information to what is adequate, relevant, and reasonably necessary for the purposes described in this Privacy Policy. We do not collect personal information beyond what is needed to fulfill our debt collection services, comply with legal obligations, and maintain the security of our systems.

Text Messaging: By providing us with your mobile number and opting in, you give J.J. Marshall permission to send you account-related text messages, such as payment reminders and notifications, in conjunction with the services you have requested. The number of messages will vary by account. By providing us with your mobile number and opting in, you agree you have ownership rights or permission to use the number given to us. Message and data rates may apply. To opt out of text messages, text STOP to any text message we send you. An opt-out confirmation message will be sent back to you.

Email Tracking: In our emails we use pixel tags. Depending on your email provider, pixel tags can enable us to tell whether the email has been opened. If you prefer not to be tracked this way, you should not open our emails. In most of our email messages, we use “click-through URLs” linked to web pages on our site. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications.

5. DISCLOSURE OF PERSONAL INFORMATION

We do not sell any personal information to third parties. We do not share personal information for cross-context behavioral advertising purposes. We have not sold or shared personal information in the preceding 12 months.

We may disclose information to the following categories of recipients:

• Credit reporting agencies.
• Service providers who assist us with payment processing, mailing, information verification, and improving our services.
• Law enforcement or judicial authorities pursuant to a court order, subpoena, or to cooperate with a law enforcement investigation.
• Local, state, or federal government authorities or courts when there is a lawful basis or when disclosure is reasonably necessary to demonstrate compliance with the law.
• Parties involved in actual or proposed corporate transactions, such as mergers, acquisitions, divestitures, asset sales, bankruptcy proceedings, or other changes in corporate structure or control.

When disclosing information, we provide only the minimum amount of information necessary for the particular vendor or recipient to assist us in providing our services.

6. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar technologies to help us understand how visitors use our site and to improve our services.

6.1 Types of Cookies We Use

Strictly Necessary Cookies: These cookies are essential for the website to function and cannot be disabled. They are set in response to actions you take, such as logging in, making a payment, or setting preferences.

Optional Cookies (Analytics): These cookies help us understand how visitors interact with our website by collecting information anonymously. You may opt out of these cookies through your browser settings.

The cookie vendor tables above should be populated based on J.J. Marshall’s actual technology stack.

6.2 Managing Cookies in Your Browser

You can control and delete cookies through your browser settings:

• Google Chrome: https://support.google.com/chrome/answer/95647
• Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
• Apple Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac

Disabling or deleting cookies may cause some features of our website to not function properly.

6.3 Do Not Track Signals

“Do Not Track” (DNT) is a privacy preference that users can set in certain web browsers. Our website does not currently respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

6.4 Universal Opt-Out Mechanisms

Certain states require that we recognize and respond to browser-based or device-based opt-out preference signals, such as the Global Privacy Control (GPC). If we detect a recognized universal opt-out signal from your browser, we will treat it as a valid request to opt out of the sale or sharing of personal information and the processing of personal information for targeted advertising purposes, to the extent applicable under the laws of your state of residence. You do not need to submit a separate request. For more information about Global Privacy Control, visit https://globalprivacycontrol.org.

7. DATA SECURITY

J.J. Marshall takes reasonable steps to protect the security, confidentiality, and integrity of the information we collect. We have implemented administrative, technical, and physical safeguards designed to provide your information with reasonable protection from accidental loss or destruction, improper use, alteration, or disclosure.

We protect your personal information during transit and at rest using encryption. When your personal information is stored by J.J. Marshall, we use computer systems with limited access housed in facilities using physical security measures.

No method of transmission over the Internet or electronic storage is 100% secure, and we cannot warrant or guarantee the absolute security of any information you transmit to us through our website or that we store in our systems. You should take special care in deciding what information you send to us over the Internet or via email.

8. DATA RETENTION

J.J. Marshall will retain your personal information for the period required to fulfill our services, meet our contractual obligations, and comply with applicable law. When assessing retention periods, we retain information only for the shortest period necessary unless a longer retention period is required by law.

We are required to retain your data due to the underlying contractual relationship between you and the creditor. We are also required to retain personal information for legal reasons as long as the statute of limitations period lasts for the type of account in collections and for other statutory obligations.

Retention periods vary by category of personal information. Account-related information is retained for the duration of the collection engagement and thereafter as required by the applicable statute of limitations and regulatory requirements. Internet activity data is retained for shorter periods consistent with our operational needs. When personal information is no longer needed for these purposes, we will securely delete or anonymize it in accordance with our data retention policies and applicable law.

9. CORPORATE TRANSACTIONS

We may disclose personal information in connection with actual or proposed corporate transactions, including mergers, acquisitions, divestitures, asset sales, bankruptcy proceedings, or other changes in corporate structure or control. In such events, personal information may be among the assets transferred or disclosed to prospective or actual parties to the transaction and their advisors.

Any acquiring or successor entity will be required to honor the commitments made in this Privacy Policy with respect to personal information collected prior to the completion of the transaction. If a successor entity intends to use your personal information in a manner materially different from that described in this Privacy Policy, the successor entity will provide you with prior notice and, where required by applicable law, obtain your consent.

10. YOUR PRIVACY RIGHTS

10.1 CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

This section applies to California residents and supplements the rest of this Privacy Policy.

GLBA Exception: Certain personal information we collect is subject to the Gramm-Leach-Bliley Act (“GLBA”) and the California Financial Information Privacy Act. Such information is exempt from the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”). For information about how we handle GLBA-covered information, please refer to any Privacy Notice provided to you in connection with your account.

Categories of Personal Information Collected: In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA:

Business Purposes for Collection and Use: We collect and use personal information for the following CCPA-defined business purposes:

• Performing services: maintaining and servicing accounts, processing payments, verifying consumer information, fulfilling transactions
• Auditing: verifying compliance with specifications, standards, and applicable law
• Security: detecting security incidents, protecting against fraudulent or illegal activity
• Debugging: identifying and repairing errors
• Short-term, transient use: such as non-personalized content displayed during a current interaction
• Internal research: technological development and service improvement
• Quality and safety: verifying and maintaining the quality of our services

Sale and Sharing: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes. We have not sold or shared personal information in the preceding 12 months.

Disclosure of Personal Information: In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of third parties for business purposes:

Your California Privacy Rights: As a California resident, you have the following rights:

• Right to Know: Request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of collection, the business purposes, and the categories of third parties with whom we share it. You may submit this request up to twice in a 12-month period.
• Right to Delete: Request deletion of personal information we have collected, subject to certain exceptions. The information J.J. Marshall holds generally falls within an exception to deletion (such as completing a transaction, complying with a legal obligation, or protecting against fraud), but we will evaluate each request individually.
• Right to Correct: Request correction of inaccurate personal information we maintain about you.
• Right to Opt Out of Sale/Sharing: We do not sell or share personal information. If our practices change, we will provide a “Do Not Sell or Share My Personal Information” link on our homepage.
• Right to Limit Use of Sensitive Personal Information: You may request that we limit our use of sensitive personal information to uses necessary to perform our services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

How to Submit a Request: You may submit a request by phone at 888-233-6910 or (586) 992-3200, by email at [email protected], or by mail to J.J. Marshall, 28820 Mound Rd., Warren, MI 48092.

Verification: To protect your privacy and security, we must verify your identity before processing your request. We will match at least two to three identifying data points you provide against information we already maintain. For requests to access specific pieces of personal information or to delete personal information, we may require a declaration under penalty of perjury confirming your identity. Possible verification outcomes are as follows:

1. Verified: Your request will be processed.
2. Partially verified: We may provide a more limited response (for example, categories of information rather than specific pieces).
3. Not verified: We will notify you that we were unable to verify your identity and cannot process the request.
4. No information found: We will notify you that we have no personal information associated with your verified identity.

Authorized Agents: You may designate an authorized agent to submit a request on your behalf. You must provide the authorized agent with a power of attorney pursuant to California Probate Code Sections 4121 through 4130, or signed, written authorization. We may require you to verify your own identity directly with us even when using an agent.

Response Timing: We will acknowledge receipt of your request within 10 business days. We will respond to your request within 45 calendar days of receipt. If we need additional time (up to an additional 45 days), we will notify you of the extension and the reason for it.

When We May Decline a Request: We may decline to process your request if we cannot verify your identity, cannot confirm the personal information relates to you, cannot verify an authorized agent’s authority, or the information is not subject to the CCPA (for example, because it is covered by the GLBA exemption). If we decline your request, we will explain the reason in our response.

Deidentified Information: If we maintain consumer information in a deidentified form, we will maintain and use the information in deidentified form and will not attempt to reidentify the information, except as permitted by law.

Financial Incentives: We do not offer financial incentives or price differences in exchange for the collection, retention, or sale of personal information.

10.2 OREGON PRIVACY RIGHTS (OCPA)

This section applies to Oregon residents and supplements the rest of this Privacy Policy, as required by the Oregon Consumer Privacy Act, ORS 646A.570 through 646A.589. As an Oregon resident, you have the following rights:

• Right to Access: Request confirmation of whether we are processing your personal data, and access the personal data we have collected about you.
• Right to a List of Specific Third Parties: Request a list of the specific third parties (other than natural persons) to which we have disclosed your personal data.
• Right to Correct: Request correction of inaccurate personal data.
• Right to Delete: Request deletion of your personal data, subject to applicable legal exceptions.
• Right to Data Portability: Obtain a copy of your personal data in a portable, readily usable format, to the extent technically feasible.
• Right to Opt Out of Targeted Advertising: Opt out of the processing of your personal data for targeted advertising purposes.
• Right to Opt Out of Sale: Opt out of the sale of your personal data. We do not currently sell personal data.
• Right to Opt Out of Profiling: Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Right to Revoke Consent: Revoke previously given consent to the processing of your personal data. Upon receipt of a revocation, we will cease processing within 15 days.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

How to Submit a Request: You may submit a request by contacting us at 888-233-6910 or (586) 992-3200 or [email protected]. We will respond within 45 days, which may be extended by an additional 45 days with notice to you. The first request per 12-month period is free of charge; subsequent requests may be subject to a reasonable administrative fee.

Appeal Process: If we decline your request in whole or in part, you may appeal our decision by contacting us at [email protected] with the subject line “Privacy Rights Appeal.” We will respond to your appeal within 45 days. If your appeal is denied, we will provide you with information on how to contact the Oregon Attorney General to submit a complaint.

Sensitive Data: We process sensitive personal data (including health-related information and precise geolocation data) only with your consent or as otherwise permitted by applicable law. You may revoke your consent at any time.

Universal Opt-Out Signals: We honor universal opt-out mechanisms, including the Global Privacy Control (GPC), as a valid opt-out request under Oregon law.

10.3 PRIVACY RIGHTS FOR RESIDENTS OF OTHER STATES

Residents of certain U.S. states have additional rights regarding their personal information under applicable state privacy laws. This section applies to residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Rhode Island, Tennessee, Texas, Utah, and Virginia. California and Oregon residents should refer to Sections 10.1 and 10.2 above.

Subject to applicable exceptions and variations by state, you may have the following rights:

• Right to Access: Confirm whether we are processing your personal data and access the personal data we have collected.
• Right to Correct: Request correction of inaccurate personal data.
• Right to Delete: Request deletion of personal data, subject to legal and contractual obligations.
• Right to Data Portability: Obtain a copy of your personal data in a portable, readily usable format (available in most states; not available in Iowa or Utah).
• Right to Opt Out of Targeted Advertising: Opt out of the processing of your personal data for targeted advertising purposes.
• Right to Opt Out of Sale: Opt out of the sale of your personal data. We do not currently sell personal data.
• Right to Opt Out of Profiling: Opt out of profiling that produces legal or similarly significant effects (available in most states; not available in Iowa or Utah).
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

Sensitive Data: In most states listed above, we process sensitive personal data only with your consent or as otherwise permitted by law. Maryland prohibits the processing of sensitive data except where strictly necessary to provide a requested product or service, regardless of consent. We process sensitive data only as necessary to fulfill our debt collection services and comply with legal obligations.

Appeal Process: If we deny your request in whole or in part, you may appeal our decision by emailing [email protected] with the subject line “Privacy Rights Appeal.” We will respond to your appeal within 45 days (or as otherwise required by your state’s law). If your appeal is denied, we will provide information on how to contact your state attorney general.

Universal Opt-Out Signals: In states that require recognition of universal opt-out mechanisms (currently including Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, and Texas), we honor browser-based opt-out signals such as the Global Privacy Control (GPC).

How to Submit a Request: You may submit a request by phone at 888-233-6910 or (586) 992-3200, by email at [email protected], or by mail to J.J. Marshall, 28820 Mound Rd., Warren, MI 48092. We will respond within the timeframe required by your state’s law (generally 45 days, with the possibility of a 45-day extension upon notice to you).

Connecticut and Minnesota Residents: You may also request a list of the specific third parties to which we have disclosed your personal data.

Maryland Residents: We limit the collection of personal data to what is reasonably necessary and proportionate to provide our services. We do not sell sensitive personal data.

Rhode Island Residents: Regardless of whether we meet statutory processing thresholds, we disclose the following as required by Rhode Island law: categories of personal data collected (identifiers, financial information, commercial information, internet activity); we do not sell personal data or use it for targeted advertising; categories of third parties receiving data include service providers, credit reporting agencies, and regulatory agencies. Contact: [email protected].

11. CHILDREN’S PRIVACY

Our website and services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from anyone under the age of 18.

If we become aware that we have collected personal information from a person under 18, we will take prompt steps to delete that information from our records.

If you believe we have inadvertently collected information from a minor, please contact us immediately at [email protected] or by phone at 888-233-6910 or (586) 992-3200.

12. THIRD-PARTY WEBSITES

This Privacy Policy applies only to the website and services of J.J. Marshall and does not extend to any third-party websites to which our website may contain links. The privacy practices of those third-party websites may differ from the privacy practices described in this Privacy Policy.

J.J. Marshall has no control over the content, privacy policies, or practices of any third-party websites. We have not reviewed those third-party websites or their associated links, and we do not endorse them or accept any responsibility with respect to them or any information you may provide in accessing or using them.

The inclusion of any link on our website does not imply endorsement by J.J. Marshall. We encourage you to review the privacy policy of every third-party website you visit before providing any personal information.

13. COMMUNICATION PREFERENCES

You may advise us of your communication preferences at any time, including the ability to opt out of or stop receiving communications from us. To cease receipt of future communications from J.J. Marshall, you may contact us using any of the following methods:

• Email: [email protected]
• Mail: J.J. Marshall, 28820 Mound Rd., Warren, MI 48092
• Phone: 888-233-6910 or (586) 992-3200

We will process your request in a reasonable timeframe and in accordance with applicable law. Please note that even if you opt out of certain communications, we may still contact you as permitted or required by law in connection with the servicing of your account or to fulfill legal obligations.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, legal or regulatory requirements, or for other operational reasons. When we make changes, we will post the revised Privacy Policy on this page with a new “Last Updated” date at the top of the document.

If we make material changes to this Privacy Policy, we will notify you by prominent notice on our website prior to the changes taking effect.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information. Your continued use of our website or services after any changes to this Privacy Policy constitutes your acknowledgment of the revised terms. The most current version of this Privacy Policy supersedes all previous versions.

15. CONTACT INFORMATION

Questions regarding this Privacy Policy should be directed to:

J.J. Marshall & Associates, Inc. 28820 Mound Rd. Warren, MI 48092 Phone: 888-233-6910 or (586) 992-3200 Email: [email protected]

J.J. Marshall & Associates, Inc. is a dba of Ceteris Portfolio Services, LLC.

RMAi Certified Receivables Business Number: C2501-1193

Send us a message!

Need assistance with your account, have questions before making a payment, or interested in our services? Don’t hesitate to reach out via email. We’re ready to help.

Contact Us

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.

We do not provide language access services or translation of any communications into a language other than English. A translation and description of commonly-used debt collection terms are available in multiple languages on the NYC Department of Consumer Affairs website, www.nyc.gov/dca.

Copyright 2026 | All Rights Reserved | Powered by Branding Arc | Privacy | Terms