Privacy Policy

LB Gray, LLC
Online Privacy Policy
Last Updated: April 25, 2026
Effective Date: April 25, 2026

At LB Gray, LLC ("LB Gray," "we," "us," or "our"), we are committed to protecting your privacy and handling your personal information responsibly. This Privacy Policy ("Policy") explains how we collect, use, disclose, and protect personal information when you visit our website, https://lbgrayllc.com/ (the "Site"), or when we process your information in connection with our debt collection services.

LB Gray, LLC is a licensed debt collection agency operating in approximately 30 states across the United States. As a debt collector and financial services company, we are subject to a number of federal and state laws governing the collection, use, and protection of consumer information.

This Policy is designed to comply with, among others:

Gramm-Leach-Bliley Act (GLBA) — federal law governing the privacy of nonpublic personal financial information (NPI) held by financial institutions, including debt collectors
Fair Debt Collection Practices Act (FDCPA) — federal law governing debt collection practices and the permissible use of consumer information
Fair Credit Reporting Act (FCRA) — federal law governing the use and furnishing of consumer credit information
California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)
Applicable state debt collection and privacy statutes in the states in which we operate (see Section 9.5)
General Data Protection Regulation (GDPR) (to the extent applicable to EU/EEA/UK individuals)

By using our Site, you agree to the collection and use of information in accordance with this Policy.

1. Introduction and Scope

This Policy applies to all personal information processed by LB Gray, LLC in connection with: (a) visitors to and users of our website at https://lbgrayllc.com/; and (b) consumers whose information we process in the course of our services.

This Policy does not apply to information processed by third-party websites, services, or applications that may be linked from our Site. Please review those parties' privacy policies separately.

Our Contact Details:
LB Gray, LLC
9100 Keystone Crossing, Ste. 850
Indianapolis, Indiana 46240
Phone: (317) 236-0233

If you have questions or concerns about this Policy or our data practices, please contact us using the information above. We encourage you to read this Policy carefully to understand our practices regarding your information and how we will treat it.

2. Information We Collect
We collect personal information from multiple sources in the ordinary course of our debt collection business and through the operation of our website.

2.1 Information Collected Directly from Consumers
When you interact with us, whether by phone, mail, email, or through our website, we may collect:

Identifiers: Full name, date of birth, government-issued identification numbers (such as Social Security Number (SSN), Individual Taxpayer Identification Number (ITIN), or driver's license number), and other information used to identify you
Contact Information: Current and prior home addresses, mailing addresses, phone numbers (home, work, and mobile), and email addresses
Communications: Records of calls, letters, emails, and other correspondence between you and LB Gray
Payment Information: Bank account or payment card information when you submit a payment (processed securely; we do not retain full payment card numbers)
Financial Account Information: Account numbers, outstanding balance amounts, payment history, creditor information, and details of the debt being collected
Employment Information: Employer name, address, and phone number
Income Information: Income details relevant to establishing repayment arrangements

2.2 Information Received from Third Parties
As a debt collection agency, we regularly receive personal information from third parties, including:

Original Creditors / Clients: Account information, balance owed, prior payment history, and consumer contact information provided by the creditor who placed the account with us for collection
Credit Reporting Agencies (CRAs): Consumer credit information obtained from Equifax, Experian, and TransUnion as permitted under the FCRA for a permissible purpose (i.e., collection of a debt owed by the consumer)
Skip Tracing and Locate Services: Updated contact and location information — such as current address, phone number, and employer — obtained through commercially available skip tracing databases and services when we are unable to locate a consumer using information already on file
Public Records: Court records, property records, and other publicly available information
Other Debt Collectors or Servicers: In the event an account is transferred or purchased

2.3 Website Usage Data
When you visit our Site, we may automatically collect:

Device Information: IP address, browser type and version, operating system, and unique device identifiers
Usage Patterns: Pages visited, time spent on pages, referral source, navigation paths, and clickstream data
Location Data: General location derived from your IP address (not precise geolocation)
Cookies and Tracking Technologies: Information collected through cookies and similar technologies (see Section 2.5 below)

2.4 Sensitive Personal Information
Given the nature of our debt collection business, LB Gray necessarily collects, uses, stores, and otherwise processes certain categories of personal information that are considered sensitive, special category, or protected under applicable law, including:

Government-Issued Identifiers: Social Security Numbers (SSNs), Individual Taxpayer Identification Numbers (ITINs), driver's license numbers, and similar identifiers
Financial Account Information: Bank account numbers, payment card information, outstanding balance and debt information considered sensitive financial data under applicable state and federal law
Income and Employment Information: Details used to evaluate and establish repayment capacity
Contact and Location Information: Current and historical addresses used to locate consumers for collection purposes

We process this sensitive information only when:

It is necessary to carry out our debt collection services in connection with a valid debt
It is required or permitted by applicable federal or state law (including the FDCPA, FCRA, and GLBA)
It is necessary to protect your vital interests or those of another person
It is necessary for the establishment, exercise, or defense of legal claims
You have provided explicit consent (where required by applicable law)
We implement the following safeguards to protect sensitive personal information:
Encryption of data in transit (SSL/TLS/HTTPS) and at rest where feasible
Role-based access controls limiting access to authorized personnel only
Employee training on applicable data protection and compliance obligations, including FDCPA, FCRA, and GLBA compliance requirements
Data minimization — collecting only the information necessary for our stated purposes
Secure deletion or anonymization of data no longer needed
Contractual data protection obligations imposed on all third-party service providers

We will not use sensitive personal information for marketing or profiling purposes without your explicit consent where required by law.

2.5 Tracking Technologies
We and our third-party partners may use the following technologies on our Site:

Cookies: Small text files stored on your device that help us remember your preferences, enable functionality, and analyze site usage (including both first-party and third-party cookies)
Analytics Tools: Software such as Google Analytics that collects information about how you interact with our Site. We configure these tools consistent with applicable privacy requirements, including IP anonymization where available, and do not collect sensitive information or user-entered form data through these tools
Web Beacons / Pixels: Tiny images or scripts embedded in web pages or emails that track whether you have accessed certain content
Log Files: Automatically recorded information about your device and usage upon each visit
Session Storage: Temporary data stored during your browser session that is cleared when you close your browser

You may adjust your browser or device settings to limit or disable cookies and other tracking technologies, though certain features of our Site may not function properly without them. Our Site is designed to respect Global Privacy Control (GPC) signals where required by applicable law.

3. How We Use Your Information
We use personal information for the following purposes, each based on an applicable lawful basis:

Debt Collection Services: To identify consumers, verify and validate debts, locate consumers (including through skip tracing), contact consumers regarding outstanding debts, accept and process payments, and facilitate resolution of accounts placed with us for collection. Legal Basis: Performance of a contract (between LB Gray and the original creditor/client); legitimate interests in conducting lawful debt collection; legal obligation under the FDCPA, FCRA, GLBA, and applicable state law.

Credit Bureau Reporting: To furnish accurate information about accounts to Equifax, Experian, and TransUnion as permitted and required by the FCRA. We are required to maintain the accuracy of information we report and to correct inaccurate information promptly. Legal Basis: Legal obligation (FCRA); legitimate interests in accurate credit reporting.

Skip Tracing and Consumer Location: To locate consumers whose contact information is unavailable, inaccurate, or outdated, using commercially available skip tracing tools and databases, as permitted by the FDCPA and applicable law. Legal Basis: Legitimate interests in conducting lawful debt collection; legal obligation.

Legal and Compliance Purposes: To comply with our obligations under applicable federal and state laws, court orders, subpoenas, regulatory requirements, and other legal process; to establish, exercise, or defend legal claims; and to maintain required business records. Legal Basis: Legal obligation; legitimate interests in protecting our legal rights.

Website Operation and Improvement: To operate, maintain, and improve our Site; to monitor and analyze usage trends; and to detect and prevent fraud or unauthorized access. Legal Basis: Legitimate interests in maintaining a functional and secure website.

Client and Customer Support: To respond to your inquiries and other communications in a timely and effective manner. Legal Basis: Legitimate interests in providing responsive service; legal obligation (where applicable).

Security and Fraud Prevention: To detect, investigate, and prevent fraud, identity theft, and other illegal or unauthorized activities in connection with our services and website. Legal Basis: Legitimate interests in protecting our business and the individuals we serve; legal obligation.

We do not sell or use consumer personal information for advertising, marketing, or any purpose unrelated to the lawful collection of debts or the operation of our business.

4. How We Share Your Information
We may share personal information with the following categories of recipients. We do not sell personal information to third parties for marketing purposes.

4.1 Original Creditors / Clients
We share information about accounts and collection activity with the original creditor or client who placed the account with us, as required to fulfill our contractual obligations and to report on collection status.

4.2 Consumer Reporting Agencies
We furnish consumer account and payment information to Equifax, Experian, and TransUnion as permitted by the FCRA. We maintain procedures to ensure the accuracy of information reported and to promptly investigate and correct disputed information.

4.3 Skip Tracing and Locate Service Providers
We share limited consumer identifying information with licensed skip tracing and data append services to obtain updated contact information for consumers. These providers are contractually prohibited from using consumer information for any purpose other than providing the requested locate services.

4.4 Collection Attorneys and Law Firms
In cases where legal action is required to collect a debt, we may refer account information to licensed collection attorneys or law firms in the relevant jurisdiction.

4.5 Payment Processors

We engage third-party payment processors to securely process consumer payments. These processors are subject to PCI-DSS compliance requirements. We do not retain full payment card numbers.

4.6 Service Providers and Technology Vendors
We may engage third-party service providers and technology vendors such as hosting providers, IT and security services, compliance software, analytics providers, and similar vendors to support the operation of our business and website. These parties access personal information only as necessary to perform contracted services and are bound by confidentiality and data protection obligations that prohibit them from using your information for any other purpose.

4.7 Courts and Legal Process
We may disclose personal information to courts, opposing counsel, or other parties as required by court order, subpoena, civil process, or other applicable legal process.

4.8 Legal and Regulatory Authorities
We may disclose personal information to law enforcement, regulatory agencies, or government authorities as required by law or in response to a lawful request.

4.9 Business Transfers
If we are involved in a merger, acquisition, portfolio sale, or asset transfer, personal information may be transferred as part of that transaction. We will provide notice before personal information is transferred and becomes subject to a different privacy policy, to the extent required by applicable law.

4.10 With Your Consent
We may share your personal information for any other purpose with your explicit consent.

4.11 Aggregated or De-Identified Data
We may share aggregated or de-identified information that cannot reasonably be used to identify any individual.

5. Gramm-Leach-Bliley Act (GLBA) -- Financial Privacy
To the extent that LB Gray, LLC qualifies as a "financial institution" under the Gramm-Leach-Bliley Act (15 U.S.C. § 6801 et seq.), we are required to protect the privacy of nonpublic personal financial information (NPI) that we collect and maintain about consumers.

We collect NPI about you — including account numbers, Social Security Numbers, income information, and payment history — in the ordinary course of providing debt collection services. We use and disclose this information only:

As necessary to carry out the debt collection transaction or service you would reasonably expect
To service or process a financial product or service you request
As required or permitted by law (including the FDCPA, FCRA, and applicable state law)
With your authorization or consent
As otherwise permitted by GLBA exceptions (e.g., law enforcement, legal process, fraud prevention)

We do not share your NPI with nonaffiliated third parties for their marketing purposes without your prior opt-out opportunity, as required by GLBA.

6. Fair Credit Reporting Act (FCRA) -- Consumer Credit Information
LB Gray, LLC furnishes consumer account information to consumer reporting agencies (CRAs) including Equifax, Experian, and TransUnion as a "furnisher" under the FCRA, 15 U.S.C. § 1681 et seq. As a furnisher, we are required to:

Report only accurate and complete account information to CRAs
Promptly investigate consumer disputes regarding the accuracy of information we have furnished
Correct or delete inaccurate, incomplete, or unverifiable information
Not furnish information we know or have reasonable cause to believe is inaccurate
Maintain reasonable written policies and procedures regarding accuracy of furnished information (FCRA § 1681s-2(e))

If you believe that information we have furnished to a CRA is inaccurate or incomplete, you may dispute it directly with the applicable CRA or by contacting us at (317) 236-0233. We will investigate and respond within the timeframes required by the FCRA.

We obtain consumer credit information from CRAs only for a permissible purpose under the FCRA specifically, in connection with the collection of a debt owed by the consumer.

7. International Data Transfers
LB Gray, LLC is based in the United States, and our operations are conducted primarily within the United States. Personal information collected and processed by us is stored on servers located in the United States.

To the extent we receive personal information from individuals located in the European Economic Area (EEA), the United Kingdom, Switzerland, or other jurisdictions with data transfer restrictions, we implement appropriate safeguards for such transfers, including Standard Contractual Clauses (SCCs) approved by the European Commission or equivalent mechanisms required under applicable law.

Where consent is the legal basis for an international transfer, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal.

8. Data Security and Retention

8.1 Data Security
We implement industry-standard technical and organizational security measures to protect personal information from unauthorized access, alteration, disclosure, or destruction. Our measures include:

Encryption: SSL/TLS (HTTPS) encryption for data in transit, and encryption of sensitive data at rest where feasible
Access Controls: Role-based access controls limiting access to personal information to authorized personnel on a need-to-know basis
Data Minimization: Collecting only the information that is necessary for our stated purposes
Employee Training: Educating our staff on applicable data protection, security, and compliance obligations, including FDCPA, FCRA, and GLBA requirements
Regular Security Reviews: Conducting periodic assessments and audits of our security practices and systems
Vendor Due Diligence: Imposing contractual data protection requirements on all third-party service providers with access to personal information
Incident Response: Maintaining procedures for identifying, containing, and responding to data security incidents

No method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we are committed to maintaining commercially reasonable protections for your personal information.

8.2 Data Retention
We retain personal information only for as long as is necessary to fulfill the purposes for which it was collected, including to:

Complete our engagement and satisfy our contractual obligations
Comply with applicable federal and state record-keeping requirements, including the FDCPA, FCRA, GLBA, and applicable state statutes of limitations
Defend against legal claims or regulatory inquiries
Comply with tax, accounting, and audit obligations

When personal information is no longer required for any of the above purposes, we will securely delete, destroy, or anonymize it in accordance with our data retention policies and applicable law.

9. Your Data Protection Rights

9.1 General Rights
Depending on your location and applicable law, you may have the following rights regarding your personal information:

Right to Be Informed: The right to know what personal information we collect, why, and how we use it.
Right of Access: The right to request a copy of the personal information we hold about you.
Right to Rectification: The right to request correction of inaccurate or incomplete personal information.
Right to Erasure / Deletion: The right to request deletion of your personal information under certain circumstances, subject to legal exceptions.
Right to Restrict Processing: The right to request restriction of processing under certain conditions.
Right to Data Portability: The right to receive your personal information in a structured, machine-readable format.
Right to Object: The right to object to processing based on legitimate interests.
Right to Withdraw Consent: Where processing is based on consent, the right to withdraw consent at any time without affecting prior lawful processing.

9.2 FDCPA Consumer Rights
As a consumer whose debt is being collected, you have specific rights under the Fair Debt Collection Practices Act (FDCPA), including:

The right to request written verification of the debt within 30 days of our initial communication
The right to dispute the validity of the debt
The right to request that we cease contact with you (subject to limited exceptions under 15 U.S.C. ss. 1692c(c))
The right to be free from harassment, false statements, and unfair collection practices
The right to bring a private lawsuit for FDCPA violations within one year of the violation

To exercise your FDCPA rights, please contact us at (317) 236-0233.

9.3 FCRA Consumer Rights
As a furnisher of consumer information to credit reporting agencies, LB Gray, LLC advises you that you have rights under the FCRA, including the right to:

Know if information in your credit file has been used against you in a credit, employment, or other decision
Request and access your credit file from consumer reporting agencies
Dispute inaccurate or incomplete information with the CRA and with us as the furnisher
Have inaccurate, incomplete, or unverifiable information corrected or deleted from your credit file
Seek damages from violators under the FCRA (15 U.S.C. ss. 1681n, 1681o)

9.4 California Residents -- CCPA/CPRA Rights
California residents have the following additional rights under the CCPA/CPRA:

Right to Know: Request disclosure of categories and specific pieces of personal information collected, sources, business purposes, and third parties with whom it is shared.
Right to Delete: Request deletion of personal information we have collected, subject to exceptions for debt collection, legal compliance, and fraud prevention.
Right to Correct: Request correction of inaccurate personal information.
Right to Opt-Out of Sale or Sharing: Opt out of the sale or sharing of personal information for cross-context behavioral advertising. See the "Do Not Sell or Share My Personal Information" link in our website footer.
Right to Limit Use of Sensitive Personal Information: Limit the use and disclosure of sensitive personal information to purposes necessary to provide services. See the "Limit the Use of My Sensitive Personal Information" link in our website footer.
Right to Non-Discrimination: We will not discriminate against you for exercising any CCPA/CPRA rights.

9.5 State-Specific Rights and Applicable State Laws
LB Gray, LLC operates in multiple states and is committed to complying with the applicable debt collection and consumer privacy laws of each state in which it operates. LB Gray adopts privacy protection practices designed to meet or exceed the requirements of all applicable state laws, including state debt collection statutes, data breach notification laws, and consumer privacy laws, as they apply to our business activities.

If you are a resident of a state with specific consumer privacy or debt collection rights, you may have additional rights beyond those described in this Section 9. To learn more about your state-specific rights or to submit a request, please contact us using the information provided in Section 9.6. We will respond in accordance with the requirements of your applicable state law

9.6 How to Exercise Your Rights
To exercise any of the rights described in this Section, please contact us at:

LB Gray, LLC
9100 Keystone Crossing, Ste. 850
Indianapolis, Indiana 46240
Phone: (317) 236-0233

We will respond within the timeframes required by applicable law (e.g., 45 days under CCPA, 30 days under GDPR). We may verify your identity before fulfilling your request. Most requests may be submitted free of charge, unless manifestly unfounded or excessive.

10. Children's Privacy
Our Site and services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from minors without verified parental or guardian consent.

If we become aware that we have inadvertently collected personal information from a child under the age of 13 without the required parental or guardian consent, we will take immediate steps to delete that information from our systems. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at (317) 236-0233.

11. Links to Other Websites
Our Site may contain links to third-party websites or resources that are not operated by LB Gray, LLC. We provide these links for your convenience only and do not endorse, control, or assume any responsibility for the content, privacy policies, or security practices of any third-party sites or services. We strongly encourage you to review the privacy policy and terms of use of every website you visit.

12. Changes to This Privacy Policy
We may update this Policy from time to time to reflect changes in our data practices, applicable law, or business operations. We will notify you of any material changes by:
• Posting the revised Policy on this page and updating the "Last Updated" date at the top of the Policy
• Providing a prominent notice on our website or via email prior to the change becoming effective, where required by law

We recommend reviewing this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page. Your continued use of our Site or services following the posting of an updated Policy constitutes your acceptance of the changes.

13. Complaints and Supervisory Authorities
If you have concerns about our privacy practices or the handling of your personal information, we encourage you to contact us first using the contact information provided in Section 1. We take all complaints seriously and will work to resolve your concern promptly.

If you are not satisfied with our response, you may have the right to submit a complaint to a regulatory authority, data protection agency, or consumer protection agency with jurisdiction over your location and the nature of your complaint. We encourage you to contact the appropriate authority in your jurisdiction for guidance on how to submit such a complaint.