Consumer complaint received 2023-12-03
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: GA
Product: Credit reporting or other personal consumer reports
Sub-product: Credit reporting
Issue: Improper use of your report
Sub-issue: Received unsolicited financial product or insurance offers after opting out

Complaint:
Transunion is not an affiliate of XXXX XXXX and therefore is a third party that makes profits from the sell of my information from XXXX XXXX. By law Transunion and XXXX XXXX should provide me notices to opt out of my private financial information being shared. I have not received such notice. Transunion is not just a credit bureau but a financial institution by definition provided under the XXXX which means they make a financial gain from the sell of my information. This means there should be accounting records to prove the accuracy of the transaction. Since this is my financial and personal information being sold I am requesting the accounting records from XXXX XXXX and Transunion immediately to view for accuracy. 


XXXX Delivering privacy and opt out notices. 
Regulation P XXXX ( i ) ( XXXX ) ( a ) How to provide notices. You must provide any privacy notices and opt out notices, including short-form initial notices, that this part requires so that each consumer can reasonably be expected to receive actual notice in writing or, if the consumer agrees, electronically. 

( b ) ( XXXX ) Examples of reasonable expectation of actual notice. You XXXX reasonably expect that a consumer will receive actual notice if you : ( i ) Hand-deliver a printed copy of the notice to the consumer ; ( ii ) Mail a printed copy of the notice to the last known address of the consumer ; ( iii ) For the consumer who conducts transactions electronically : ( A ) In the case of financial institutions other than those described in XXXX ( l ) ( XXXX ) of this part, post the notice on the electronic site and require the consumer to acknowledge receipt of the notice as a necessary step to obtaining a particular financial product or service; or ( B ) In the case of financial institutions described in XXXX ( l ) ( XXXX ), clearly and conspicuously post the notice on the electronic site and require the consumer to acknowledge receipt of the notice as a necessary step to obtaining a particular financial product or service; ( XXXX ) For an isolated transaction with the consumer, such as an ATM transaction, post the notice on the ATM screen and require the consumer to acknowledge receipt of the notice as a necessary step to obtaining the particular financial product or service. 

( XXXX ) Examples of unreasonable expectation of actual notice. You XXXX not, however, reasonably expect that a consumer will receive actual notice of your privacy policies and practices if you : ( i ) Only post a sign in your branch or office or generally publish advertisements of your privacy policies and practices; or ( ii ) Send the notice via electronic mail to a consumer who does not obtain a financial product or service from you electronically. 

( c ) XXXX notices only. You XXXX reasonably expect that a customer will receive actual notice of your annual privacy notice if : ( XXXX ) The customer uses your website to access financial products and services electronically and agrees to receive notices at the website, and you post your current privacy notice continuously in a clear and conspicuous manner on the website; or ( XXXX ) The customer has requested that you refrain from sending any information regarding the customer relationship, and your current privacy notice remains available to the customer upon request. 

( d ) Oral description of notice insufficient. You XXXX not provide any notice required by this part solely by orally explaining the notice, either in person or over the telephone. 

( XXXX ) XXXX or accessibility of notices for customers. 

( XXXX ) For customers only, you must provide the initial notice required by XXXX ( a ) ( XXXX ), the annual notice required by XXXX ( a ), and the revised notice required by XXXX so that the customer can retain them or obtain them later in writing or, if the customer agrees, electronically. 

( XXXX ) Examples of retention or accessibility. You provide a privacy notice to the customer so that the customer can retain it or obtain it later if you : ( i ) Hand-deliver a printed copy of the notice to the customer ; ( ii ) Mail a printed copy of the notice to the last known address of the customer, or, in the case of credit unions, mail a printed copy of the notice to the last known address of the customer upon request of the customer; or ( iii ) Make your current privacy notice available on a Web site ( or a link to another Web site ) for the customer who obtains a financial product or service electronically and agrees to receive the notice at the Web site. 

( f ) Joint notice with other financial institutions. You XXXX provide a joint notice from you and XXXX or more of your affiliates or other financial institutions, as identified in the notice, as long as the notice is accurate with respect to you and the other institutions. 

( g ) Joint relationships in the case of financial institutions other than credit unions and covered entities subject to FTC enforcement jurisdiction. For purposes of this paragraph ( g ), you is limited to financial institutions other than credit unions and the financial institutions described in XXXX ( l ) ( XXXX ). If XXXX or more consumers jointly obtain a financial product or service from you, you XXXX satisfy the initial, annual, and revised notice requirements of XXXX ( a ), XXXX ( a ), and XXXX ( a ), respectively, by providing XXXX notice to those consumers jointly. 

( h ) Joint relationships in the case of covered entities subject to FTC enforcement jurisdiction. For purposes of this paragraph ( h ), you is limited to the financial institutions described in XXXX ( l ) ( XXXX ). If XXXX or more consumers jointly obtain a financial product or service from you, you XXXX satisfy the initial, annual, and revised notice requirements of XXXX ( a ), XXXX ( a ), and XXXX ( a ) by providing XXXX notice to those consumers jointly, unless XXXX or more of those consumers requests separate notices. 

( i ) Joint relationships in the case of credit unions. 

( XXXX ) If XXXX or more consumers jointly obtain a financial product or service, other than a loan, from a XXXX XXXX, the XXXX XXXX XXXX satisfy the requirements of XXXX ( a ) by providing XXXX initial notice to those consumers jointly. 

( XXXX ) Special rule for loans in the case of credit unions. 

( i ) A credit union is required to provide an initial notice to a borrower or guarantor on a loan if the XXXX XXXX shares his or her nonpublic personal information with nonaffiliated third parties other than for purposes under XXXX, XXXX, and XXXX. 

( ii ) A credit union XXXX satisfy the annual notice requirements of XXXX by providing XXXX notice to those borrowers and guarantors jointly. 

( XXXX ) Customer information of a financial institution The term customer information of a financial institution means any information maintained by or for a financial institution which is derived from the relationship between the financial institution and a customer of the financial institution and is identified with the customer. 


( XXXX ) Financial institution ( A ) In general The term financial institution means any institution engaged in the business of providing financial services to customers who maintain a credit, deposit, trust, or other financial account or relationship with the institution.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation