Last Updated: February 5, 2016
Collection, Use and Disclosure of Personal Information
Personal Information We May Collect
“Personal Information” is information that identifies someone as an individual. In addition to Personal Information, Other Information (as defined below) may be collected in connection with HFA Platform; the collection, use and disclosure of Other Information is addressed separately below, under the heading “Other Information”.
We and our third-party service providers may collect the following Personal Information:
Certain Personal Information is voluntary and not required to access or use HFA Platform; other Personal Information may be mandatory and required to access or use HFA Platform or certain portions of HFA Platform.
How We May Use Personal Information
We and our third-party service providers may use Personal Information:
How Personal Information May Be Disclosed
Personal Information may be disclosed:
Collection, Use and Disclosure of Other Information
Other Information We May Collect
“Other Information” is any information that does not reveal a person’s specific identity, such as:
How We May Collect Other Information
We and our third-party service providers may collect Other Information in a variety of ways, including:
How We May Use and Disclose Other Information
Because Other Information does not personally identify you, we may use and disclose Other Information for any purpose. In some instances, we may combine Other Information with Personal Information (such as combining your zip code with your name). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is so combined.
Third Party Advertisers
We may use third-party advertising companies to serve ads when you visit HFA Platform. Please note that these companies may use information about your visit to HFA Platform to provide ads about goods and services that may be of interest to you. In the course of serving ads to HFA Platform, these companies may place or recognize a unique cookie on your browser. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit http://networkadvertising.org/optout_nonppii.asp.
Do Not Track Signals
We seek to use within HFA reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system is guaranteed to be 100% secure. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that are generally non-negotiable; accordingly, although we seek to conduct reasonable due diligence on such service providers, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Personal Information. We are not responsible for the data security measures of any third parties.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.
Choices and Access
Your choices regarding our use and disclosure of your Personal Information for marketing purposes:
We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of our related legal entities and other third parties with which we have already shared your Personal Information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt-out request). Please also note that if you do opt-out of receiving marketing-related e-mails from us, we may still send to you administrative messages, messages related to the fulfillment of our products and services, and messages that are sent to you in your capacity as a representative of your business entity; you cannot opt-out from receiving such messages.
How You Can Access Your Personal Information
If you would like to review or update your Personal Information that has been previously provided to us, you may do so by logging into your account within HFA Platform, or, for certain Personal Information that is not reviewable through HFA Platform, you may contact us in accordance with the “Contacting Us” section below.
We will try to comply with your request to update your Personal Information as soon as reasonably practicable. We are not responsible for changing information from the databases of third parties with whom we have already shared your Personal Information.
Use of HFA Platform by Minors
HFA Platform is not directed to individuals under the age of eighteen (18), nor are such individuals permitted to use HFA Platform; accordingly, we request that such individuals do not provide Personal Information in connection with HFA Platform. If you are the parent or guardian of such an individual who has disclosed Personal Information to us in connection with HFA Platform, please contact us in accordance with the “Contacting Us” section below, and we will exercise commercially reasonable efforts to remove such information from our databases and storage systems; we are not liable, however, for any consequences of such information, including any delay or failure to remove such information.
Your California Privacy Rights
California Civil Code Section 1798.83 permits customers of HFA who are California residents to request certain information regarding HFA’s disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please write us at:
40 Wall Street, 6th Floor
New York, NY 10005