- Summary of Key Points
- Types of Personal Data We Collect
- Personal Data You Provide Directly to Us
- Personal Data Collected from Third-Party Organizations
- Using or Sharing Your Personal Data
- Using Personal Data You Provide Directly to Us
- Using, Sharing, and Selling Personal Data Collected from Third-Party Organizations
- Sharing With Service Providers and for Legal Purposes
- No Collection or Processing of EU Personal Data
- Data Retention and Storage
- Children’s Privacy
- Consumer Privacy for Residents of California and Nevada
- Your Rights Under the California Consumer Privacy Act
- Your Rights Under Nevada Consumer Privacy Law
- Communications Preferences
- Data Privacy and Security
- Contact Us
Any references to “HD Information”, “HD Information, LLC,” “we,” “us,” “our,” or the “Company” is a reference to HD Info.
- Receiving communications from us, including emails, texts, phone calls, or faxes;
- Requesting more information from HD Info about our products and services;
- Receiving Personal Data from our affiliates and governmental organizations;
- Obtaining publicly available Personal Data about you through legally permissible means.
Summary of Key Points
- We collect certain, limited Personal Data when you access our website.
- We may incorporate Personal Data we collect from Third Party Organizations into our products and services where permissible by law.
- If you are a resident of California or Nevada, you may have certain rights related to our handling of your Personal Data.
- We may disclose your Personal Data to other companies within the HD Info corporate family. We also may share Personal Data with third parties we engage to process information on our behalf or when such sharing is required by law, or in certain other situations.
- We may collect, store, process, and use your Personal Data in the U.S. and other countries, including Poland and the United Kingdom.
Types of Personal Data We Collect
Personal Data You Provide Directly to Us
When you use our website, the Personal Data that we may collect directly from you may include the following: contact information and device and usage information, as well as any other information type that we expressly ask you to enter and submit to our website:
- Contact Information: If you express an interest in obtaining additional information about our products or services, request customer support, or use our “Contact Us” or similar features, we generally require you to provide us with your contact information, such as:
- your name, interest, job title, company name, address, phone number, email address, communications preferences, or username and password;
- Device and Usage Information: If you use and interact with our website, we automatically collect device and usage information, through common information-gathering tools such as:
- log files and other information about your computer or mobile device and your usage of our website through cookies, web beacons, or similar technologies, such as IP-addresses or other identifiers, which may qualify as Personal Data.
Personal Data Collected from Third-Party Organizations
We also collect Personal Data from HD Info suppliers, data providers, and customers, as well as governmental or other third-party organizations (collectively, “Third-Party Organizations”). In these situations, we do not have a direct relationship with you. Such Third-Party Organizations may include but are not limited to: governmental or public service entities with which you interact, the public or private organization with which you are employed, or with which you are affiliated for purposes of a transaction or for one or more other lawful purposes, as well as data providers, biographical sources, broadcast content providers, social media providers and public source information such as government watch and sanction lists or criminal record information, all or any of which may be aggregated.
The categories of Personal Data we collect from Third-Party Organizations may include, but are not limited to, the following:
- Contact details, such as your name and phone number;
- Address history information;
- Date of birth;
- Census data;
- Full or partial government identification numbers such as social security number; and
- Other information lawfully made publicly available.
Using or Sharing Your Personal Data
Using Personal Data You Provide Directly to Us
When we collect Personal Data directly from you, we may utilize it for following purposes:
- Fighting spam and other forms of abuse;
- Generating aggregate, non-identifying information about how you participate in the HD Info Activities; and
- Complying with our legal obligations, resolving disputes, and enforcing our agreements.
Where we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide that required Personal Data when requested, we may not be able to perform the contract.
We do not sell the Personal Data we collect directly from you.
Using, Sharing, and Selling Personal Data Collected from Third-Party Organizations
We may sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate some or all of the Personal Data we receive from Third Party Organizations to our customers. Our products and services enable our customers to achieve any one or more of the following purposes, among others:
- Complying with legal and regulatory obligations to conduct due diligence and other screening activities;
- Conducting risk management activities for which there is a substantial public interest;
- Providing information that may impact a customer’s organization, brand, or customer base; and/or
- Enabling informed commercial and business risk decisions.
Your Personal Data may include personal information which is a matter of official court, public, and/or criminal record, in which circumstance such Personal Data has been supplied to HD Info for publication to our customer organizations by the public entities concerned in the interests of upholding and protecting the rule of law, and promoting the safety interests of the public.
It is important to note that HD Info has no power over what is reported in official court, public, or criminal records. It is for the courts and applicable law enforcement entities to decide what Personal Data is to remain within the records that they disclose, and the balance to be struck between the public interests in disclosure and the privacy rights of individuals.
Sharing with Service Providers and for Legal Purposes
We may share Personal Data with third parties in some additional circumstances, including but not limited to:
- With your consent;
- To a service provider or partner who meets our data protection standards;
- For educational purposes, including academic or other research;
- When we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; and/or
- When we have a good faith belief that doing so will help to (i) prevent imminent harm to someone; (ii) detect, investigate or prevent security, fraud or technical issues; (iii) protect the rights, property or safety of HD Info, our users, employees or others; and/or (iv) as part of a corporate or other business transaction.
No Collection or Processing of EU Personal Data
HD Info does not knowingly collect or otherwise process any Personal Data within the scope of data privacy laws and regulations applicable to the EU, including but not limited to the General Data Protection Regulation (GDPR) (EU) 2016/679.
Data Retention and Storage
HD Info may retain your Personal Data for a period of time consistent with the original purpose of collection. HD Info transfers, stores, and uses your information in the United States and any other country where we operate.
Our website and HD Info Activities are not directed at children. HD Info does not knowingly collect or process Personal Data from children under the age of 13, and HD Info does not target its website to children under the age of 13. Where a child is between the ages of 13 and 16 years, HD Info will only undertake the collection or processing of his or her Personal Data if and to the extent that consent is given or authorized by the holder of parental responsibility over the child.
Consumer Privacy for Residents of California and Nevada
Your Rights Under the California Consumer Privacy Act
The California Consumer Privacy Act of 2018 (“CCPA”) gives California residents certain rights with respect to the processing of certain portions of their Personal Data that constitute “personal information” under CCPA, subject to several conditions and qualifications. The following data rights under CCPA may be available to California residents with respect to “personal information” under CCPA:
Right to Know
Under the CCPA, California residents have a right to request information about our collection, use, and disclosure of “personal information” over the prior 12 months, and ask that we provide you with the following information:
- Categories of Personal Data we have collected about you;
- Categories of sources from which we collect Personal Data;
- Purposes for collecting or selling Personal Data;
- Categories of third parties with which we share Personal Data;
- Categories of Personal Data that we sold in the last 12 months, and the categories of third parties to which it was sold; and
- Categories of Personal Data that we disclosed for a business purpose in the last 12 months, and the categories of third parties to which it was disclosed.
To make a verifiable request, you may contact us by clicking on the Individual Rights link located on our website homepage. You may also contact us at HDI_Support@hygenicsdata.com. We will process your request within 45 calendar days, as required under CCPA, and will contact you promptly if we need additional information from you in order to process your request. Processing may take up to 90 days depending on the nature and complexity of your request.
Right to Opt-Out of Sale
Under the CCPA, California residents have a right to request that we do not sell your Personal Data to third parties. To make a verifiable request, you may contact us by clicking on the Individual Rights link located on our website homepage. You may also contact us at HDI_Support@hygenicsdata.com or call us toll free at 833-307-0306. We will verify your identity by sending you a link to the email you provide. We will process your request within 15 calendar days, as required under CCPA, and will contact you promptly if we need additional information from you in order to process your request.
Note: HD Info does not sell any Personal Data we may collect directly from residents of California to any third parties.
Limitation on Certain Rights
Although HD Info takes steps to validate your identity when receiving your request, we are unable to fully protect your sensitive Personal Data from the risks of identity theft or fraud due to the wide availability of basic identifying information on the internet. In accordance with CCPA Regulations Section 999.313(c)(1), and in order to protect your Personal Data from unauthorized use or access, where we do not have a direct relationship with you HD Info will not honor any requests for specific pieces of Personal Data. All requests for specific pieces of Personal Data will be evaluated as requests for disclosure of categories of Personal Data. Taking this stance helps us better protect your Personal Data from the risk of identity theft and fraud.
In accordance with the exceptions enumerated in CCPA Section 1798.105(d)(2) and (d)(8), HD Info will not honor any requests for deletion of Personal Data. The Personal Data we collect directly from you is used (i) to comply with legal and statutory obligations; and (ii) for risk management activities that include detection of security incidents and protection against malicious, deceptive, fraudulent, or illegal activity. We are not obligated by CCPA to delete this type of Personal Data.
Right to Non-Discrimination
Businesses cannot discriminate against you for exercising your rights under CCPA. HD Info will never discriminate against you in any way for exercising these rights.
You have a right under CCPA Section 1798.135(c) to designate an authorized agent to make a Right to Know or Opt-Out request on your behalf. In order for us to process your request through an authorized agent, you will be required to take the following steps:
- Provide the authorized agent with signed permission to act on your behalf;
- Verify your own identity directly with us; and
- Directly confirm with us that you have provided the authorized agent with permission to act on your behalf.
See CCPA Regulations Section 999.326 for more information on designating an authorized agent.
Your Rights Under Nevada Consumer Privacy Law
Right to Opt-Out of Sale
Under a 2019 amendment to the Nevada Privacy of Information Collected on the Internet from Consumers Act, Nevada residents have a right to request that we do not sell your Personal Data to third parties. To make a verifiable request, you may contact us by clicking on the Individual Rights link located on our website homepage. You may also contact us at HDI_Support@hygenicsdata.com or call us toll free at 833-307-0306. We will verify your identity by sending you a link to the email you provide. We will process your request within 60 calendar days, as required under the law, and will contact you promptly if we need additional information from you in order to process your request.
Note: HD Info does not sell any Personal Data we may collect directly from residents of Nevada to any third parties.
You can manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link located on the bottom of our emails, by replying or texting ‘STOP’ if you receive SMS communications, or by turning off push notifications on our apps on your device. Additionally, you may unsubscribe by contacting us using the information in the “Contact Us” section below.
Please note that opting-out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as information about your subscriptions, service announcements, or security information.
Data Privacy and Security
HD Info implements a variety of data privacy and security measures, including organizational, technical, and physical measures, which are designed to protect the integrity, confidentiality, and availability of Personal Data. While we follow generally accepted standards to protect Personal Data, no method of storage or transmission can be totally secure. You are solely responsible for protecting your password, limiting access to your computer and mobile devices, and signing out of websites, apps, and mobile platforms after your sessions.
HD Information, LLC
Attn: Data Protection Officer
9901 Linn Station Rd., Suite 500
Louisville, Kentucky 40223, USA
Toll Free Phone: 833-307-0306
Last update: June 2020