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.
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
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.
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.
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.
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.
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
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
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 email@example.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.
ICH Inc., September 2020