Privacy Policy
This privacy policy (“Privacy Policy”) describes how data is collected by International Clearinghouse, Inc. (“ICH”), in relation to the use of our website, our mobile application and our products and services, and how data and personal information is collected and used, and your rights in relation to the collection, storage use and sharing of data and personal information.
Personal information may be requested any time you contact ICH or an ICH affiliated company. ICH and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. We reserve the right to change any provision of the Privacy Policy at any time. We will either post on the website or send out a notice or both when changes have been made to the Privacy Policy that materially affect you, and indicate by what time those changes will be implemented, unless otherwise dictated by law. You are encouraged to review the Privacy Policy from time to time.
1. Collection and Use of Personal Information
a. What We Collect
Personal information is information that can be used to specifically or explicitly identify or contact a single person. We may collect a variety of information, including your name, telephone number, address, email address and contact preferences when you create an account, register for special services, download updated software or participate in a survey, or contact customer support.
When you visit our website or use our services, we collect information sent to us by the means with which you contacted us, such as your computer, mobile phone or other device used to access us or the services. The information sent to us includes data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information. Web log data includes the browser type you are using and traffic to and from our site. When you visit the ICH website or use the ICH Services, we may also collect information about your transactions and your activities.
In the case you take advantage of our loyalty reward services, sending information, gift certificates or products, or invite others to join the services, ICH may collect the information you provide about those people such as name, address, email address, and telephone number.
In certain cases, we may work with social media sites. Information received from social media sites is controlled by them, and if information from a social media site is sent to us, you agree that we may collect store and use this information in accordance with our own Privacy Policy.
b. How We Use It
We use your personal information to provide you services, and to complete transactions in which you enter with us or using the services. We may also use your personal information for communications; from time to time, we may use your personal information to send updates and important notifications, such as changes to our documentation (terms, conditions, policies, and procedures) and because this communication pertains to the provision of your services, you may not opt out of receiving these updates. We may also use your personal information to improve our products, content & services. In the case of a promotion of any kind, any personal information given may be used to administer such promotion. We may also use this information to send target marketing and promotional offers based on your preferences.
2. Collection and Use of Non Personal Information
What We Collect & How We Use It
We may collect non-personal information; data we collect about the use of the services or about a group or category of services or users, from which individual identities or other personal information has been removed or in anonymized form that does not directly identify you.
We may also collect
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Demographical Information, such as age range, gender, time zone, state, city, area code, zip code, climate characteristics, language preference & device identifier. The items help us determine to whom we should tailor services.
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Transactional Data such as whether a transaction took place, what kind of device was used, was the transaction successful, over what route the transaction came, how long it takes to complete the transaction, et al. These items help us keep up the services and improve the service we provide to you.
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Behavioral Information where a transaction takes place, when a transaction, time of year, time of day, what was purchased, whether it is a repeat transaction. This information helps our corporate customers improve the products and services they provide to you as a consumer and helps us to determine how we should tailor services.
In the case non-personal information is combined with personal information, the result will be treated as personal information.
3. Cookies and Other Technologies
We may use small text or data files known as “Cookies” (or other technology such as web beacons, pixel tags, “Flash cookies” or other local storage provided by your web browser or other applications). These are tools which help us recognize you as a return user, customize your user experience (such as content and advertising), and measure our performance in servicing you. This technology can also prevent fraud and minimize risk, ultimately leading to a trusted and enjoyable experience.
Pixel Tags allow us to send messages to users, and also to verify whether a user has viewed a page, a message or email. We use this technology and information to minimize messages sent to users.
We use Cookies that are used during individual visits, which expire or are deleted or both, after each visit, and Cookies that remain on your devices until they are erased, or they expire or are otherwise destroyed.
Our Cookies are devised so that they will provide us with useful information to customize your experience at ICH. In the case you do not want to employ the use of Cookies, you may decline the use of them (should you be allowed by the browser) but doing so may interfere, delay or destroy the use of our services. Please refer to the support pages provided by your respective technology to learn how to able, disable, block, suspend or delete Cookies. Cookies may also be used to tailor a service, such as the provision of ads in an application or on a website. In such case, should those cookies be deleted, it may not stop ads from appearing, but would make the ads more random and of less use or interest to you. Cookies may also be used to remember preferences, and in doing so, speed up transactions and minimize wait times. Should those cookies be blocked or deleted, transactions may take longer.
In the case Cookies are somehow combined with personal information, the result would be treated as personal information.
Operation of Mobile Devices. The ICH Services will include connectivity and communication with mobile devices. In some cases, in order to ensure the Services are properly delivered, the ICH application may restart the Bluetooth connection in order to perform the services, and such restarting of the Bluetooth connection may interrupt other Bluetooth connections established with that mobile device.
4. Disclosure to Third Parties
From time to time we may make certain proprietary or personal information available to service providers and affiliates with whom we work in order to provide our products and services or who assist in promotional and marketing activities. Personal information will not be shared or sold to third parties for their marketing purposes, and only shared by us to fulfill or improve products, services and promotional and marketing activities.
We will from time to time employ or contract with service providers who provide services such as customer support, managing data, delivering products and services, conduct research, and assess your interest in the products and services. These service providers are obligated to keep your personal information protected.
When necessitated or compelled by law, legal process, legitimate requests from authorities (foreign or domestic) including subpoena, it may become necessary for ICH to disclose personal information. We may also disclose personal information for the purposes of public importance, such as enforcement of the law, public health and safety or national security.
5. Protection of Personal Information
ICH uses multiple safeguards to protect your personal information against misappropriation, loss, theft, unauthorized access, alteration and destruction. These include physical devices, technical knowhow, policies and procedures and administrative steps. In addition, Purchases made through ICH are made through an encryption known as a Secure Sockets Layer with a PCI level compliant service.
6. Integrity and Retention of Personal Information
ICH has a commitment to privacy which we communicate and reiterate to our employees, and strictly enforce privacy and security. Should you wish to close your account and end your relationship with ICH, we will “close” such account, but retain personal information to collect fees or redeem rewards value, resolve disputes, or assist with any action required or permitted by law.
7. Access to Your Information
We also commit to accuracy of information, and you may review and edit your personal information, including partial or total deletion of such information, by logging into your account settings and profile to verify it is accurate and change it as needed. Should this not be available to you, you may contact us through the contact information listed below for assistance.
8. Children
We do not knowingly collect information on children under the age of 13, unless through a special program, a parent has set up a student account on behalf of that child, and a verified consent from the parent has been provided. In the case we learn that information has been collected on a child under the age of 13 without the appropriate parental consent, action will be taken to remove such information as quickly as possible. For more information, please review ICH Terms of Use.
9. Location-Based Services
ICH may collect, use and share location data, including precise location data and real time geolocation data in combination with Transactional Data in order to provide other users product and service information in real time. This information is anonymized and aggregated and will not personally identify users.
10. Third Party Sites And Services
Our website and mobile application links to third party websites and locations are available to encourage use of their services. Our products and services may contain offers or offer products and services from third parties. Any information gathered by third parties is governed by those third parties’ privacy policies. You are encouraged to verify the privacy policy of every service you use.
11. International Users
ICH is not intended for international use at this time, therefore international participation is not expected but will be phased in over time as we develop and replicate our services in other countries and comply with international privacy laws. However, at this time, there are no reasonable means for ICH to determine whether personal information is coming from overseas and disclaims any liability should an unintended user somehow register personal information. In the case we learn that information has been collected on unintended user without the appropriate information “safe harbor” framework, action will be taken to remove such information as quickly as possible.
12. Who To Talk To About Your Privacy Questions
If you have any questions comments or concerns regarding this privacy policy, please contact us at privacy@internationalclearinghouse.com or writing to us at ICH Inc., 21050 Centre Pointe Pkwy. Santa Clarita, CA 91350.
13. Electronic delivery of communications. You agree and consent to receive electronically all communications, agreements, documents, notices and disclosures (collectively, “Communications”) that we provide in connection with your ICH account (“Account”) and your use of our services. You agree that ICH may rely on your information as complete and accurate. Communications include, but are not limited to: agreements and policies you agree to (e.g., the ICH Terms of Use, ICH Points Policy and the ICH Privacy Policy), including updates to these agreements or policies; information related to any Account, including transaction information or confirmations and history, as well as federal and state tax statements which we are required to make available to you, such as an IRS form 1099 as applicable.
14. Withdrawing Consent. You may withdraw your consent to receive Communications electronically by writing to us at International Clearinghouse, Inc., 21050 Centre Pointe Pkwy. Santa Clarita, CA 91350, or, ironically, contacting us by email at info@internationalclearinghouse.com. You may also withdraw consent to receive an electronic copy of your IRS Form 1099 yet maintain electronic communications with us by requesting paper copies of the IRS form 1099 in the manner described above.
15. Requesting paper copies of electronic Communications. If you would like a paper copy of any Communication previously sent to you, you may contact us and make a request for a paper copy, up to 6 months after the date of the Communication. Requests made after 6 months may not be able to be met. Paper copies of Communications will be sent by first class US mail. In order for us to send you paper copies, you must have a current street address on file or provide it to us.
16. Maintaining Accurate Contact Information. For receiving electronic communications, you agree to keep the email address you give us to use to communicate with you up to date, complete and accurate. You agree to update your contact information when needed and acknowledge that if we do not have accurate contact information, we may not be able to communicate with you. For receiving any written, physical communications from ICH, you must provide your complete and accurate physical address for receipt of US mail.
We may update our privacy policy. When such update is deemed material, we will post a notice describing the update as well as the update on our website.
ICH Inc., September 2020