HALCASH NORTH AMERICA, INC. – PRIVACY POLICY (UNITED STATES)

OVERVIEW:

In the United States, HCNA is a technology service provider to Mastercard International in relation to the Mastercard Cash Pick-Up solution. HCNA is also an authorized sales organization and program manager for several Mastercard Cash Pick-Up issuing banks, marketing and selling Mastercard Cash Pick-Up to approved businesses (sending entities).

Although HCNA does not market or sell Mastercard Cash Pick-Up or any other products or services directly to consumers or establish direct customer relationships with consumers, HCNA may receive nonpublic personal information about consumers as described below. HCNA’s U.S. Privacy Policy will establish the privacy promise to consumers on the data HCNA processes and/or receives regarding consumers, security safeguards for protecting nonpublic personal information, consumer notification and consent options, and sharing of information.

This policy is relevant to all employees who engage or participate in the processing, collecting, using, protecting, updating, and sharing nonpublic personal information of consumers in relation to HCNA’s activities in the U.S.

PURPOSE:

The purpose of this policy is to outline expectations and accountability, while adhering to industry standards, for protecting the confidentiality, integrity, and availability of consumer information.

SCOPE:

This policy applies to all employees, contractors, vendors, business partners and anyone who acts as an agent of HCNA or who uses or accesses HCNA facilities, information assets, or IT assets in relation to HCNA’s activities in the U.S.

EXCEPTIONS:

If there is an exception to any requirement of this policy, a valid business case must be documented and approved. The exception approval will be retained for the duration of the exception in a secure and centralized location. Any request for exceptions will be made using the Exception Request Form.

POLICY:

PRIVACY PROMISE

Federal and certain state laws require us to inform consumers how we collect, share, and protect their nonpublic personal information. Federal and certain state laws also give consumers the right to limit some but not all sharing. This privacy notice explains our Privacy Promise to consumers to help them understand what we do and don’t do with their information.

Security is Paramount

At HCNA, it is our goal to ensure the privacy of all consumer nonpublic personal information that we receive. The following outlines some of the steps we take on a daily basis to ensure that this information is secure, private, and used only in a manner consistent with the consumer’s wishes. We will safeguard, according to our strict standards of security and confidentiality, any and all information we receive. We use administrative, physical, and technological security techniques and processes designed to protect the integrity and privacy of this information.

Data Collected

In performing the roles described above, HCNA may receive nonpublic personal information about consumers from the following sources:

  1. Information we receive from businesses (sending entities) in relation to orders sent or received by consumers;
  2. Information we receive directly from consumers sending or receiving orders; and
  3. Information we receive from other parties, including Mastercard Cash Pick-Up issuing banks, government organizations,

We advise consumers about the general uses of the information we receive about them, and we will gladly and promptly provide additional explanation, if requested.

Use of Information

We will use consumer information solely for the purpose of processing, managing and servicing orders, operating the Mastercard Cash Pick-Up solution and providing reports with respect to the solution.

Sharing of Information

We will share your information solely for the purpose of processing, managing and servicing orders, operating the Mastercard Cash Pick-Up solution and providing reports with respect to the solution.

We will only permit authorized employees and authorized third parties such as consultants or contract employees, who are trained in the appropriate handling of sensitive customer information, to have access to consumer information, and only if required by their business responsibilities. Employees or others who violate our Privacy Policy are subject to our disciplinary process, up to and including termination and prosecution.

Customer Notification & Consent

We do not currently conduct any consumer marketing activities using any consumer information. Should this change, we will provide consumers with the opportunity to remove their names used for marketing upon initial consumer contact and subsequently on an annual basis. This opt-out choice includes any products and services offered by HCNA and any marketing partners, as permitted by law. Consumers may notify us that they want to opt out of such choices by contacting us via U.S. mail or telephone.

Except as permitted by law and outlined above, we limit the release of consumer information. We release information only with a consumer’s consent or request, or when we are required to do so by law or other regulatory authority. When a court order or subpoena requires us to release consumer information, we notify the consumer promptly in order to provide the consumer with the opportunity to exercise their legal rights. The only exception to this policy is when we are prohibited from notifying the consumer by law or due to a court order, or in cases in which fraud, money laundering or criminal or illegal activity is suspected.

If our privacy policy is modified, we will attempt to notify any impacted consumers of these changes via e-mail, U.S. mail, or via telephone. We will post our annual privacy policy notice to our website.

Should consumers have any questions, they may e-mail us at customerservice@pin4.com.

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