HostCardEmualtion Privacy Policy
August 2014
Our Commitment to Privacy
HOSTCARDEMULATION.COM (“HCE”) is committed to maintaining the security, confidentiality and privacy of your personal information. This Privacy Policy outlines our on-going commitment to you (“End-User”) and has been developed in compliance with relevant privacy legislation.
Scope of Policy
This Policy addresses personal information about individuals only; it does not apply to information collected, used or disclosed with respect to corporate or commercial entities. However, corporate and commercial information is protected by other HCE policies and practices and through contractual arrangement
This Policy does not impose any limits on the collection, use or disclosure of the following information by HCE:
- business contact information; or
- publicly available information.
Accountability
HCE is accountable and responsible for personal information under its control. HCE has designated a Privacy Officer to oversee HCE’s compliance with this Policy.
Ultimate accountability for HCE compliance rests with the HCE’s Board of Directors who delegate day-to-day accountability to the Privacy Officer. Other individuals within HCE may be accountable for the day-to-day collection and processing of personal information or to act on behalf of the Privacy Officer.
HCE has adopted procedures to protect personal information, receive and respond to complaints and inquiries, train staff regarding privacy policies and procedures and communicate policies and procedures to you upon your request.
Purposes
HCE will provide, on request, contact information for the Privacy Office who can answer questions about the collection.
HCE collects your personal information for the following purposes:
- to communicate with you through the HCE Application or in respect of the HCE Application;
- to monitor your compliance with any of your agreements with us;
- to process any of your deals, offers, acceptances, payments and any other transaction activity through the HCE Application;
- to provide and administer products and services requested and to use and disclose the information for any purpose related to operation of accounts and provision of requested products and services;
- to provide personal information to third party suppliers, agents, subscribers and partners of HCE and in respect of the HCE Applications products and services
- to provide personal information in the form of a personal profile to third party suppliers, agents, subscribers and partners of HCE and in respect of the HCE Applications products and services
- to protect HCE, yourself and others from fraud and error and to safeguard the business interests of HCE;
- to authenticate your identity;
- to obtain quotations to provide products and services requested by you;
- to comply with legal and regulatory requirements; and
- to distribute to third parties including financial institutions, payment processors, landlords, lawyers, financial institutions and government licensing bodies for any of the above purposes.
HCE may be required by law to obtain social security numbers in order to report income or interest payments to the Internal Revenue Service.
The above collections, uses and disclosures are a reasonably necessary part of your relationship with HCE, its (other) distributors and suppliers.
Other uses:
- HCE may use your personal information to offer additional or alternate products and services to you and may add your personal information to customer lists which they prepare and use for this purpose.
- HCE may share your personal information with its distributors, suppliers, agents, subscribers and reputable third parties so that they may offer their products or services to you.
- HCE and any of its subscribers may contact you for survey or seminar invitation purposes.
- HCE will share your personal information with its co-branding partners and your information will be subject to our co-branding partners’ Privacy Policies. Please contact our Privacy Office for more information about and/or a copy of our co-branding partners’ Privacy Policies.
You may instruct HCE to refrain from using or sharing your personal information in any or all of the ways described above at any time by providing written notification to our Privacy Office. HCE acknowledges that the sharing of your personal information in any or all of the ways described above is at your option and HCE will not refuse you access to any product or service merely because you have advised HCE to stop using or sharing your personal information in any or all of the ways shown.
When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by law.
Consent
HCE will obtain your consent to collect, use or disclose personal information except where HCE is authorized or required by law to do so without consent. For example, HCE may collect, use or disclose personal information without your knowledge or consent where:
- HCE is collecting or paying a debt;
- HCE is obtaining legal advice; or
- HCE reasonably expects that obtaining consent would compromise an investigation or proceeding.
- HCE has received the information via third parties, subscribers, agents or partners licensed for the HCE Application
Your consent may be express or implied, or given through an authorized representative such as a lawyer, agent or broker.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify HCE that you do not wish your personal information collected/used/disclosed for optional purposes following reasonable notice to you) or otherwise. For example, oral consent could be expressed over the telephone when information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application.
You may withdraw your consent at any time, subject to legal or contractual restrictions, provided you give reasonable written notice of withdrawal to HCE. Upon receipt of your written notice, HCE will inform you of the likely consequences of the withdrawal, which may include the inability of HCE to provide certain products or services for which the delivery of that information is a prerequisite.
Limits On Collecting Personal Information
HCE will not collect personal information indiscriminately and will limit its collection of your personal information to what is reasonably necessary to provide a product or service either directly or indirectly and which is reasonably necessary for the purposes to which you consented. HCE may also collect information as authorized by law.
Limits For Using, Disclosing And Retaining Personal Information
Your personal information will only be used or disclosed for the purposes set out above and as authorized by law.
HCE will keep personal information used to make a decision affecting an individual for at least one year after using it to make the decision.
HCE will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes.
HCE will take due care when destroying personal information to prevent unauthorized access to such information.
Accuracy
HCE will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete. In most cases, HCE will rely on you to ensure that certain information, such as your street address, e-mail address or telephone number, is current, complete and accurate.
If you demonstrate the inaccuracy or incompleteness of personal information, HCE will amend the information as required. If appropriate, HCE will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, HCE will annotate the personal information under its control with a note that a correction was requested but not made.
Safeguarding Personal Information
HCE protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
HCE will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by its suppliers and agents who assist in providing products and services to you.
Please note that confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication.
Openness
HCE is open about the policies and procedures it uses to protect your personal information. Disclosure of our policies and procedures will be made available in writing and electronically. However, to ensure the integrity of our security procedures and business methods, HCE will not disclose sensitive information about its policies and procedures.
HCE will make available a description of the type of personal information held by HCE, and a general description of its use and disclosure.
Providing Access
You have a right to access your personal information held by HCE. Upon written request and authentication of identity, HCE will provide you with your other personal information under its control, information about the ways in which that information is being used and a description of the individuals and organizations to whom such information has been disclosed. HCE may charge a reasonable fee for providing personal information in response to an access request and will provide an estimate of any such fee upon receiving a written access to personal information request. HCE may require a deposit for all or part of the fee. HCE will make personal information available within 30 days or provide written notice where additional time is required to fulfill the request.
In some situations, HCE may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm the competitive position of HCE. HCE may also be prevented by law from providing access to certain personal information.
Where an access request is refused in whole or in part, HCE will notify you in writing, giving the reason for refusal and outlining further steps which are available to you.
California Residents
If you are a California resident and have an established business relationship with us, you may request from us a list of the categories of personal information we have disclosed to third parties for those third parties’ marketing purposes, and a list of all third parties to whom we have shared that information. We will include in that list the names and addresses of the third parties who received the information and used it (or who we believe may have used it) for their own marketing purposes.
To exercise your rights, you may make one request each year by emailing us at privacy@hostcardemulation.com or writing us at the email address listed below. Indicate in your communication that you are making a “Shine the Light” inquiry. Responses to requests sent to this email address listed below will be provided within 30 days.