Privacy Policy

This Privacy Policy (the "Policy") describes how Overdue LLC ("Overdue," "we," "us," or "our") collects, uses, discloses, retains, and protects information in connection with the website located at overdue.inc, our online dashboard, our mobile and electronic communications, and all related products and services (collectively, the "Service").

Overdue LLC is a Delaware limited liability company with its principal place of business at 111 NE 1st Street, Suite 8125, Miami, Florida 33132.

Overdueprovides two principal services to creditors (each, a "Client"): (i) contingency-based collection of past-due accounts that the Client retains, in which Overduecollects on Client's behalf (the "Direct Collection Services"); and (ii) purchase of past-due accounts from Clients for an immediate cash payment, with subsequent collection efforts undertaken by Overdueas the new creditor of record (the "Purchase Services"). Under either service line, Overduemay escalate a Case to a partner attorney licensed in the Debtor's jurisdiction when warranted; attorney engagement is governed by separate engagement letters as further described in Section 3.1.

Overdue's services apply to commercial obligations (including obligations on which a natural person has executed a personal guaranty of a commercial obligation) and to consumer obligations (debts arising out of transactions in which the money, property, insurance, or services that are the subject of the transaction were primarily for personal, family, or household purposes, within the meaning of 15 U.S.C. § 1692a(5)). The compliance framework applied to a given account varies based on the account's characterization; consumer accounts are subject to additional protections under the Fair Debt Collection Practices Act, the Consumer Financial Protection Bureau's Regulation F (12 C.F.R. Part 1006), and applicable state consumer collection statutes as described herein.

This Policy applies to information processed in connection with both Direct Collection Services and Purchase Services, to visitors to the overdue.incwebsite, and to individuals and entities whose information is provided to or obtained by us in connection with our collection activities (each, a "Debtor").

By accessing or using the Service, you acknowledge that you have read, understood, and consented to the practices described in this Policy. If you do not agree, do not use the Service.

1. Information We Collect

1.1 Information Provided by Clients

When you create an account, submit an account for collection, accept a purchase offer, or otherwise interact with the Service, we collect information you provide directly, including: business legal name, address, and contact information; names, email addresses, and phone numbers of authorized representatives; account, invoice, and receivable data, including amounts, dates, terms, and payment history; contracts, purchase orders, delivery confirmations, and other supporting documentation; account characterization (commercial or consumer) and consent records relevant to applicable compliance regimes; and banking, payment, and tax information necessary for Recovery remittance and tax reporting.

1.2 Information About Debtors

In the course of providing Direct Collection Services and Purchase Services, we receive, process, and develop information about Debtors. For commercial Debtors and personal guarantors, this typically includes: business legal name, address, and contact information of the debtor entity; names, email addresses, mobile and landline phone numbers, titles, and business affiliations of debtor contacts, officers, principals, and personal guarantors; payment and transaction history between the originating creditor and the debtor; and contract terms, security interests, and correspondence related to the underlying obligation.

For consumer Debtors, this typically includes: name, mailing address, email address, mobile and landline telephone numbers; date of birth and partial or full Social Security Number where lawfully obtained for identity verification, skip tracing, or judgment enforcement under the permissible purpose of 15 U.S.C. § 1681b(a)(3)(A); account number and balance; payment and transaction history with the originating creditor; consent records evidencing prior express consent to electronic and telephonic communications; and information relating to disputes, validation requests, attorney representation, cease-and-desist requests, bankruptcy filings, and other communications affecting collection.

Where applicable, we also obtain financial condition information including consumer credit reports obtained for the permissible purpose of collecting an account under 15 U.S.C. § 1681b(a)(3)(A).

1.3 Information Collected Automatically

When you access the Service, we and our service providers automatically collect certain technical information, including: IP address, browser type, operating system, and device identifiers; pages viewed, links clicked, and actions taken on the Service; date, time, and duration of visits; and referring URLs and search terms used to reach the Service. We use cookies, local storage, and similar tracking technologies to facilitate Service functionality, maintain session state, and analyze usage patterns. You may adjust your browser settings to refuse non-essential cookies, but some Service features may not function properly without them.

1.4 Information from Third Parties

We obtain or develop information about Debtors from third-party sources to supplement our records and facilitate collection, including: consumer reporting agencies and business credit reporting agencies regulated under the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq.; public records, court records, and commercially available databases; skip tracing, contact verification, and identity verification services; bankruptcy and litigation monitoring services; reassigned number databases including the Federal Communications Commission's Reassigned Numbers Database; and information provided by partner attorneys, co-counsel, or local counsel in connection with collection escalation. All consumer report information is obtained and used exclusively for the permissible purpose specified in 15 U.S.C. § 1681b(a)(3)(A) — the collection of an account of the consumer — and is handled in accordance with Overdue's Written Information Security Program adopted pursuant to the Gramm-Leach-Bliley Act Safeguards Rule, 16 C.F.R. Part 314.

2. How We Use Information

We use the information we collect for the following purposes: to provide, operate, monitor, and improve the Service and our collection services; to generate, personalize, and transmit collection communications, including through artificial-intelligence-assisted drafting; to deliver validation information and other notices required by the Fair Debt Collection Practices Act, Regulation F, or applicable state law in connection with consumer accounts; to communicate with Clients about their accounts, submitted invoices, collection activity, and Purchase Service offers; to verify the identity and authority of Client representatives; to evaluate, monitor, and manage accounts placed for collection or acquired by purchase, including Debtor disputes; to comply with applicable federal, state, and local laws, regulations, and legal obligations; to prevent fraud, unauthorized access, and misuse of the Service; to analyze Service usage and improve our artificial-intelligence models, templates, and collection strategies; to enforce our Terms of Service, Collection Agreements, Purchase Agreements, and other agreements; to facilitate legal escalation to partner attorneys; to file information returns (including Forms 1099-C) where Overdue is the creditor of record on an account acquired through Purchase Services; and to maintain records required by applicable laws and regulations.

3. How We Share Information

Overdue does not sell personal information. We do not share mobile phone numbers, opt-in records, or text-messaging consent information with any third party for marketing, promotional, or any purpose unrelated to providing collection services. We share information only as set forth below.

3.1 With Partner Attorneys

When a Case is escalated for an attorney demand letter, an unfiled complaint, or litigation, we share the relevant case file — including Debtor information, account data, communication history, and supporting documentation — with the partner attorney licensed in the Debtor's jurisdiction. Attorney escalation may occur under either Direct Collection Services or Purchase Services. Under Direct Collection Services, the partner attorney undertakes legal representation of the Client under a separate engagement letter between the Client and the partner attorney; communications between the Client and the partner attorney in furtherance of legal advice may be protected by the attorney-client privilege under applicable rules of professional conduct. Under Purchase Services, Overdue (as creditor of record) engages the partner attorney directly under a separate engagement letter. Partner attorneys operate as independent legal professionals; information shared with Overdue during pre-litigation collection is not attorney-client privileged.

3.2 With Service Providers

We share information with third-party service providers who perform services on our behalf, including: cloud hosting and infrastructure providers; email and electronic communication delivery services; SMS and telecommunications providers operating under registered A2P 10DLC campaigns; payment processing providers; analytics and monitoring tools; consumer reporting agencies; skip tracing, identity verification, and contact-data providers; reassigned-number-database query services; and recordkeeping and document management providers. These providers are contractually obligated to use information only for the purposes of providing services to Overdue, to maintain administrative, technical, and physical safeguards consistent with applicable law, and to comply with the requirements of the Gramm-Leach-Bliley Act Safeguards Rule where applicable.

3.3 For Legal and Regulatory Compliance

We may disclose information when we believe disclosure is necessary to: comply with applicable law, regulation, legal process, subpoena, court order, or governmental or regulatory request; respond to inquiries from federal or state regulators with jurisdiction over our activities, including the Consumer Financial Protection Bureau, the Federal Trade Commission, state attorneys general, and state collection-licensing authorities; enforce our Terms of Service, Collection Agreement, Purchase Agreement, and other agreements; protect the rights, property, or safety of Overdue, our Clients, Debtors, or others; and detect, prevent, or address fraud, security, or technical issues.

3.4 Restrictions on Third-Party Disclosure (Consumer Accounts)

For accounts subject to the Fair Debt Collection Practices Act, Overduedoes not communicate with third parties regarding the existence or details of a consumer's debt except as expressly permitted under 15 U.S.C. § 1692b and § 1692c(b) and CFPB Regulation F (12 C.F.R. § 1006.6). Permitted third-party contacts include the consumer's attorney, a consumer reporting agency, the creditor, the creditor's attorney, the debt collector's attorney, and persons contacted solely to acquire location information about the consumer within the limits prescribed by 15 U.S.C. § 1692b.

3.5 In Connection with Account Assignment

For accounts acquired by Overdue through Purchase Services, information may be shared with successor purchasers, assignees, or servicers in the event Overdue later assigns or services-transfers the account. Any such successor will be contractually obligated to handle the information consistent with this Policy and applicable law.

3.6 Business Transfers

In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, information may be transferred as part of the transaction. We will notify affected parties of any change in ownership or control of their information to the extent required by applicable law.

3.7 With Client Authorization

We may share information as directed or authorized by the Client, including to third parties designated by the Client in connection with the resolution of a specific account.

4. SMS and Text Messaging Program

Overdueuses SMS text messaging as one of the communication channels in connection with its collection activities. Our text-messaging program is registered with The Campaign Registry under the "Debt Collection" use case in accordance with the Application-to-Person 10-Digit Long Code ("A2P 10DLC") framework adopted by U.S. wireless carriers.

4.1 Mobile Information Not Shared

Overdue does NOT share mobile phone numbers, text-messaging opt-in records, or any text-messaging consent information with any third party or affiliate for marketing, promotional, or any other purpose unrelated to providing Overdue's collection services. All text-messaging-related data is treated as confidential and is disclosed only to (a) service providers acting on Overdue's behalf to deliver text messages under contractual confidentiality obligations, (b) partner attorneys retained on a specific account, and (c) as required by law, court order, or regulatory authority.

4.2 Consent

Recipients of text messages from Overduehave provided their mobile telephone number either (i) directly to the original creditor in the credit application, lease, financing agreement, personal guaranty, or other transaction document that gave rise to the underlying obligation, which under the Federal Communications Commission's 2008 Declaratory Ruling, 23 FCC Rcd 559, and applicable case law constitutes prior express consent to be contacted at that number regarding the resulting debt; (ii) directly to Overdue or its partner attorneys in the course of resolving an account; or (iii) through an opt-in reply (e.g., YES, START, or SUBSCRIBE) to a previous Overdue message. Consent given to the original creditor travels to Overdue as assignee or servicer of the account. Overdue does not text mobile numbers obtained solely through skip tracing without separately captured consent.

4.3 Limited Content Messages (Consumer Accounts)

For accounts subject to CFPB Regulation F, certain initial text messages may be structured as "limited content messages" within the meaning of 12 C.F.R. § 1006.2(j), which contain only the business name of the debt collector, a request that the consumer reply to the message, the name of one or more natural persons whom the consumer can contact, a telephone number the consumer can use to reply to the debt collector, and one or more permitted opt-out instructions. Limited content messages are designed to minimize the risk of inadvertent third-party disclosure under 15 U.S.C. § 1692c(b).

4.4 Opt-Out

Recipients may opt out of further text messages at any time, by any reasonable means, consistent with the Federal Communications Commission rules codified at 47 C.F.R. § 64.1200(a)(9)(i)(F), (a)(10), (a)(11), and (d)(3), as amended effective April 11, 2025. Reply STOP, STOPALL, QUIT, END, REVOKE, OPT OUT, OPTOUT, CANCEL, or UNSUBSCRIBE to any message to discontinue further text messages. Reasonable natural-language opt-out requests (for example, "stop texting me," "do not contact me at this number," or "please leave me alone") will also be honored. Overduewill process and honor opt-out requests within ten (10) business days of receipt. One confirmation message acknowledging the opt-out may be sent in accordance with FCC guidance. For consumer accounts, opt-out requests are also honored as cease-of-electronic-communication notices under CFPB Regulation F § 1006.6(e) where applicable.

4.5 Help and Information

Reply HELP, INFO, or SUPPORT to any Overdue text message to receive contact information for Overdue customer support and assistance.

4.6 Message Frequency

The number of text messages Overduesends in a given period varies based on the status of the account, the stage of collection activity, and Recipient responses. Message frequency is not fixed and may change over the life cycle of an account. For consumer accounts, message frequency is calibrated to the harassment principles of 15 U.S.C. § 1692d and the call-frequency principles of 12 C.F.R. § 1006.14.

4.7 Message and Data Rates

Standard message and data rates from your wireless carrier may apply to messages sent to or received from Overdue. Overdue is not responsible for charges imposed by your wireless carrier.

4.8 Carrier Liability

Wireless carriers are not liable for delayed or undelivered messages. If your handset does not support multimedia messaging service (MMS), any MMS messages may be delivered as SMS.

4.9 No Marketing

All text messages sent by Overdue through the Service are operational and account-related communications relating to a specific debt. Overdue does not use text messaging for marketing, promotional, telephone-solicitation, or telemarketing purposes.

4.10 Identification

Every text message sent by Overdue identifies Overdue LLCas the sender in compliance with the identification requirements of the Telephone Consumer Protection Act, the Fair Debt Collection Practices Act (15 U.S.C. § 1692e(11)), CFPB Regulation F (12 C.F.R. § 1006.18(e)), and applicable Federal Communications Commission regulations.

5. Artificial Intelligence Processing

Overdue uses artificial intelligence to draft collection communications, classify Debtor responses, optimize collection strategies, and generate documents for partner attorney review. All artificial-intelligence-generated communication templates and escalation protocols are designed, reviewed, and approved under internal compliance oversight. Overdue conducts periodic quality audits of artificial-intelligence-generated content for accuracy and compliance with applicable laws and regulations, including the Fair Debt Collection Practices Act and CFPB Regulation F where applicable.

Information provided by Clients and obtained or developed about Debtors may be processed by our artificial-intelligence systems to personalize communications, determine escalation timing, and improve collection outcomes. We do not use Client or Debtor data to train artificial-intelligence models for purposes unrelated to our collection services, and we do not provide Client or Debtor data to third-party model providers for training purposes. Artificial-intelligence-generated content is used solely in connection with the specific account to which it relates.

6. Data Retention

We retain information for as long as reasonably necessary to fulfill the purposes described in this Policy, including: for the duration of the Client relationship and any active collection engagement; for the life cycle of accounts acquired through Purchase Services; for a reasonable period following the conclusion of collection activity, to support potential litigation, audit, regulatory inquiry, or dispute resolution; and as required by applicable law, regulation, or legal obligation, including without limitation the recordkeeping requirements of CFPB Regulation F (12 C.F.R. § 1006.100), federal and state tax law, and state collection-licensing requirements.

Communication records, account records, consent records, validation-notice records, and opt-out records are retained for a minimum of three (3) years following the close of the account, or longer where required by law. When information is no longer needed, we delete, de-identify, or anonymize it in accordance with our data retention schedule and applicable law.

7. Security Measures

Overduemaintains a Written Information Security Program ("WISP") adopted pursuant to the Gramm-Leach-Bliley Act Safeguards Rule, 16 C.F.R. Part 314. The WISP establishes administrative, technical, and physical safeguards reasonably designed to protect the security, confidentiality, and integrity of Nonpublic Personal Information and Consumer Report Information processed by Overdue. The WISP includes, without limitation: designation of a Qualified Individual to oversee the program; periodic risk assessments; access controls, multi-factor authentication, and the principle of least privilege; encryption of data in transit (TLS) and at rest (AES-256 or equivalent); service-provider diligence and contractual security requirements; security awareness and training for authorized users; periodic monitoring, testing, and audit-log review; and an Incident Response Plan.

While we strive to protect information, no method of transmission over the Internet or electronic storage is one hundred percent secure. We cannot guarantee absolute security.

8. Cookies and Tracking Technologies

We use the following types of cookies and similar technologies: (a) Essential Cookies, required for the Service to function, including authentication session tokens; these cannot be disabled. (b) Analytics Cookies, which help us understand how users interact with the Service so we can improve it; you may opt out of analytics cookies through your browser settings.

We do not use advertising cookies or sell information collected through cookies. We do not currently respond to "Do Not Track" browser signals because no industry consensus has emerged on how such signals should be honored.

9. Your Privacy Rights

Depending on the jurisdiction in which you reside, you may have the following rights with respect to personal information about you: the right to know what personal information has been collected, used, disclosed, and sold or shared; the right to request a copy of personal information in a portable, machine-readable format; the right to request correction of inaccurate personal information; the right to request deletion of personal information, subject to legal and regulatory retention requirements; the right to opt out of the sale or sharing of personal information for cross-context behavioral advertising (Overdue does not engage in either practice); the right to limit use and disclosure of sensitive personal information; the right to non-discrimination for exercising privacy rights; and the right to appeal a denial of a privacy request.

To exercise these rights, contact support@overdue.inc. We will respond within the timeframes required by applicable law. We will take reasonable steps to verify your identity before fulfilling your request. You may designate an authorized agent to make a request on your behalf.

10. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA"), provides you with rights with respect to personal information we collect.

10.1 Categories of Personal Information Collected

In the preceding twelve (12) months, we may have collected the following categories of personal information from California residents: identifiers (name, email address, phone number, IP address, account number, partial or full Social Security Number where lawfully obtained); commercial information (account, invoice, and payment data); internet or network activity (browsing history on the Service); professional or employment information (job title, business affiliation, role at debtor entity); financial information (account balances, payment instruments where provided); and inferences (payment behavior patterns, resolution likelihood assessments). Where required, additional sensitive personal information may be collected solely in connection with collection activity (e.g., partial Social Security number for skip tracing under the permissible purpose of 15 U.S.C. § 1681b(a)(3)(A)).

10.2 Sources, Business Purposes, and Disclosures

Sources of personal information are described in Section 1. Business purposes for collection are described in Section 2. Categories of third parties to whom we disclose personal information are described in Section 3. We do not sell personal information. We do not share personal information for cross-context behavioral advertising.

10.3 Your CCPA Rights

California residents have the rights described in Section 9, including the right to know, the right to delete, the right to correct, the right to opt out of sale or sharing (we do not sell or share), the right to limit use of sensitive personal information, and the right to non-discrimination. To submit a request, contact support@overdue.inc. You may designate an authorized agent. Overdue will verify the identity of the requestor before fulfilling a request.

10.4 Shine the Light

California Civil Code Section 1798.83 permits California residents to request information about disclosure of personal information to third parties for direct marketing purposes. Overdue does not disclose personal information to third parties for direct marketing purposes.

11. Other State Privacy Rights

11.1 Comprehensive State Privacy Laws

Residents of states with comprehensive consumer privacy statutes — including the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, the Texas Data Privacy and Security Act, the Oregon Consumer Privacy Act, the Montana Consumer Data Privacy Act, the Iowa Consumer Data Protection Act, the Delaware Personal Data Privacy Act, the New Jersey Data Privacy Act, the Tennessee Information Protection Act, the Minnesota Consumer Data Privacy Act, the Maryland Online Data Privacy Act, the Indiana Consumer Data Protection Act, the Kentucky Consumer Data Protection Act, the New Hampshire Privacy Act, the Rhode Island Data Transparency and Privacy Protection Act, and similar laws as enacted from time to time — have rights to access, correct, delete, and obtain a portable copy of personal information, to opt out of certain processing activities including targeted advertising and sale of personal information, and to appeal a denial of a privacy request. Overdue does not engage in targeted advertising or the sale of personal information. To exercise rights or submit an appeal, contact support@overdue.inc.

11.2 Florida Digital Bill of Rights

Residents of Florida may have rights under the Florida Digital Bill of Rights, Fla. Stat. § 501.701 et seq., where applicable. Overdue does not process "sensitive data" within the meaning of the FDBR for any purpose other than where strictly necessary to provide collection services and to comply with applicable law. To exercise rights or submit an appeal, contact support@overdue.inc.

11.3 Nevada

Nevada residents may opt out of the sale of certain "covered information" as defined by Nevada Revised Statutes Chapter 603A. Overdue does not sell covered information as defined under Nevada law. To submit a request, contact support@overdue.inc.

12. Debtor Rights and Communications

Overdue collects and processes Debtor information provided by Clients and obtained from third-party sources solely for the purpose of collecting the underlying obligation. Debtor information is not used for unrelated marketing, profiling, cross-context behavioral advertising, or other commercial purposes.

12.1 Rights Applicable to All Debtors

Debtors may inquire about the information Overdue holds about them, dispute the accuracy or validity of an obligation, request that communications be directed only to an attorney representing them, or request to opt out of text-messaging communications as described in Section 4.4. To submit any such request, contact support@overdue.inc or the address set forth in Section 17.

12.2 Additional Rights for Consumer Accounts under the FDCPA and Regulation F

For accounts that constitute "debt" within the meaning of the Fair Debt Collection Practices Act, 15 U.S.C. § 1692a(5), Debtors have the following additional rights, which Overdue and any partner attorney handling the account will honor:

• Validation Notice.Within five (5) days after the initial communication with the consumer in connection with the collection of any debt, the consumer will receive a written notice containing the information required by 15 U.S.C. § 1692g(a) and CFPB Regulation F § 1006.34, including the amount of the debt, the name of the creditor to whom the debt is owed, a statement of the consumer's right to dispute the debt within 30 days, and information about how to dispute or request verification.
• Right to Dispute. The consumer has the right to dispute the validity of the debt, in whole or in part, within thirty (30) days after receipt of the validation notice. Upon receipt of a written dispute, Overdue or the partner attorney will cease collection activity until verification of the debt is obtained and mailed to the consumer.
• Right to Designate Attorney. If the consumer notifies Overdueor the partner attorney that the consumer is represented by an attorney with respect to the debt, all further communications regarding the debt will be directed exclusively to the attorney, unless the attorney fails to respond within a reasonable period or consents to direct communication, per 15 U.S.C. § 1692c(a)(2).
• Cease Communication Request. The consumer has the right to notify Overdue or the partner attorney in writing that the consumer refuses to pay the debt or wishes Overdue to cease further communication. Upon receipt of such notice, Overdueand the partner attorney will not communicate further with the consumer with respect to the debt except as permitted by 15 U.S.C. § 1692c(c).
• Time and Place Restrictions.Communications with the consumer will not occur at any unusual time or place known or which should be known to be inconvenient to the consumer. In the absence of knowledge of circumstances to the contrary, the convenient time for communicating with the consumer is between 8:00 a.m. and 9:00 p.m. local time at the consumer's location, per 15 U.S.C. § 1692c(a)(1).
• Workplace Restrictions. Overduewill not communicate with the consumer at the consumer's place of employment if Overdueknows or has reason to know that the consumer's employer prohibits the consumer from receiving such communication, per 15 U.S.C. § 1692c(a)(3).
• Third-Party Disclosure Restrictions. Overduewill not communicate with third parties regarding the consumer's debt except as expressly permitted under 15 U.S.C. § 1692b and § 1692c(b) and CFPB Regulation F § 1006.6.
• Communication Frequency.Telephone calls in connection with the collection of the debt will not exceed seven (7) calls within seven (7) consecutive days or one call within seven (7) consecutive days following a telephone conversation with the consumer about the debt, per CFPB Regulation F § 1006.14(b).
• Electronic Communications Opt-Out.Each electronic communication will include a reasonable and simple method for the consumer to opt out of receiving further electronic communications, per CFPB Regulation F § 1006.6(e).

12.3 Disputes and Inquiries

All debtor disputes, validation requests, cease-communication notices, and attorney representation notices may be submitted to support@overdue.inc, by mail to the address set forth in Section 17, or through any communication channel through which Overdue or a partner attorney has previously contacted the consumer.

13. Children's Privacy

The Service is directed at adults and is not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under eighteen, we will take steps to delete such information promptly. If you believe we have collected information from a child, please contact support@overdue.inc.

14. International Data Transfers

The Service is operated in the United States. If you access the Service from outside the United States, you acknowledge that your information may be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using the Service, you consent to such transfer and processing.

15. Changes to This Policy

We may update this Policy from time to time by posting the revised version on the Service. We will notify Clients of material changes via email to the address associated with the Client account or through the Service at least thirty (30) days before the changes take effect, except where a shorter notice period is required by law. The "Effective Date" at the top of this Policy indicates when the most recent revision took effect. Your continued use of the Service after a revised Policy becomes effective constitutes your acceptance of the revised Policy.

16. Compliance with Applicable Laws

Overdue conducts its services in compliance with all applicable federal, state, and local laws and regulations, including without limitation:

• The Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., and the Consumer Financial Protection Bureau's Regulation F, 12 C.F.R. Part 1006, with respect to accounts that constitute "debt" within the meaning of 15 U.S.C. § 1692a(5);
• The Telephone Consumer Protection Act, 47 U.S.C. § 227, and the implementing regulations of the Federal Communications Commission at 47 C.F.R. Part 64, including the consent revocation rules effective April 11, 2025;
• The Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq., including the permissible-purpose provisions of 15 U.S.C. § 1681b(a)(3)(A);
• The Gramm-Leach-Bliley Act, 15 U.S.C. § 6801 et seq., and the Federal Trade Commission's Safeguards Rule, 16 C.F.R. Part 314;
• The Electronic Signatures in Global and National Commerce Act, 15 U.S.C. § 7001 et seq., and applicable state E-SIGN counterparts;
• The TRACED Act, Pub. L. No. 116-105, and FCC implementing rules concerning caller-identification authentication;
• State consumer collection statutes (including without limitation the California Rosenthal Fair Debt Collection Practices Act, the Texas Debt Collection Act, the North Carolina Debt Collection Act, the Florida Consumer Collection Practices Act, and similar state statutes) with respect to consumer collection activities in each state where Overdue conducts such activities;
• State commercial collection statutes with respect to commercial collection activities;
• State telephone-solicitation, anti-spam, and consumer-privacy laws to the extent applicable;
• State debt collection licensing and bond requirements in each jurisdiction where Overdue conducts collection activities; and
• The A2P 10DLC standards adopted by U.S. wireless carriers and administered through The Campaign Registry.

Overduemaintains all licenses, registrations, surety bonds, and other regulatory authorizations required in each jurisdiction in which it conducts collection activities. The applicable compliance regime for a given account depends on the account's characterization (commercial or consumer), the debtor's location, and the channel of communication.

17. Contact Information

If you have questions or concerns about this Policy or our privacy practices, or to exercise your privacy rights, please contact us at:

Overdue LLC
Attn: Privacy Officer
111 NE 1st Street, Suite 8125
Miami, Florida 33132
Email: support@overdue.inc
Website: overdue.inc