Effective Date: May 2, 2019
- What Types of Information Does HACC Collect About its Users?
- Other Information. “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. This might include, for instance, browser and device information; App usage data; information collected through cookies, pixel tags, and other technologies; demographic information and other information provided by you; or aggregated information. We use this information to facilitate our operation of the Sites and for other purposes described below.
- IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the Sites, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. HACC uses IP Addresses to calculate usage levels of the Sites, help diagnose problems with its servers, administer the Sites, and monitoring the regions from which you navigate to HACC’s Sites.
- How Does HACC Collect Information?
Personal Information. We and our service providers may collect Personal Information in a variety of ways, including:
- Through the Sites: We may collect Personal Information through the Sites, e.g., when you request information, contact us, subscribe to our email newsletter, download content, become a member.
- Offline: We may collect Personal Information from you offline, such as when you attend one of our events or during phone calls.
- Through You: HACC may collect information such as your location or your preferred means of communication when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you or any other user of the Sites. Note that there is no legal obligation for you to provide us with Personal Information and any information collected by us will be provided by you at your own will and with your consent.
Other Information. We and our service providers may collect Other Information in a variety of ways, including:
- Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Sites (such as the Apps) you are using.
- Through Cookies and Other Similar Technologies: Cookies and other similar technologies may be used to collect Other Information. We may use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our Sites and other websites. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags and web beacons). Please review our Cookies Policy for more information. HACC does recognize automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions.
HACC also uses web analytics services, which currently includes Google Analytics.
- By Aggregating Information: Aggregated Personal Information does not personally identify you or any other user of the Sites (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code)
- How Does HACC Use Personal Information?
We may use Personal Information:
- To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials.
- To send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies.
- To communicate with you and provide you with related customer service.
- To send you marketing communications.
- To personalize your experience on the Sites by presenting products and offers tailored to you.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Sites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our Affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our Affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- For recruiting purposes.
- How Will HACC Share Personal Information It Receives?
Subsidiaries and Affiliates:
Agents and Service Providers:
We contract with other companies and people to perform tasks on our behalf and may share your Personal Information with them to provide products or services to you, or to otherwise communicate with you, such as to provide marketing or offers on our behalf. Examples may include removing repetitive information from customer lists, analyzing data, providing marketing assistance, conducting billing, processing credit card payments, engaging technical support for our services, providing customer service, and performing analysis related to our products or services. We may also provide your Personal Information to agents and service providers to verify or compile aggregate usage data that we provide to our partners. When we share this information in this way, we seek to require the agent or service provider to maintain the privacy, confidentiality and security of the Personal Information.
Protection of HACC and Others:
We may release Personal Information when we believe that release is necessary or appropriate (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce or apply our conditions of use and other agreements; (e) to protect our operations or those of any of our Affiliates; (f) to allow us to pursue available remedies or limit the damages that we may sustain; and (g) to protect the rights, privacy, property, or safety of HACC, our employees, our Affiliates, our users, or any other person or entity. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
- How Does HACC Use and Disclose Other Information?
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.
In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we do, we will treat the combined information as Personal Information for as long as it is combined.
- How Does HACC Secure Personal Information About Me?
We have implemented organizational, technical, and administrative measures to protect Personal Information within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Information from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Information online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us at firstname.lastname@example.org
- How Can I Access, Correct, Amend or Remove Information About Me?
If you would like to access, correct, amend, remove or limit the use or disclosure of any Personal Information about you that has been collected and stored by HACC, please notify us at email@example.com so that we may consider and respond to your request in accordance with applicable law.
For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will respond to your request within 45 days.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such access, change or deletion.
- What Choices Do I Have?
You can always opt not to disclose information. However, if you elect to do so, we may be limited in responding to your inquiry or providing services to you.
You may opt-out of receiving marketing messages from HACC or our Affiliates by sending an email to firstname.lastname@example.org, by unsubscribing through the unsubscribe or opt-out link in an email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages.
- Third Party Sites
Similarly, please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or the Social Media Pages.
- Sensitive Information
We ask that you not send us or disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Sites or via other means.
- Questions, Concerns or Complaints
Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information, please contact us by email at email@example.com or by mail at 340 Madison Avenue, New York, NY 10173.
HACC will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.