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Credit USA, Inc. Privacy Policy
May 3, 2007
At CUSA we recognize that privacy is important.
This Policy applies to all of the products, services and
websites offered by CUSA. or its subsidiaries or affiliated
companies (collectively, Credit USA, Inc. "services").
CUSA adheres to the US safe harbor privacy
principles of Notice, Choice, Onward Transfer, Security,
Data Integrity, Access and Enforcement, and is registered
with the U.S. Department of Commerce's safe harbor program.
If you have any questions about this Policy,
please feel free to contact us through our website or write
to us at Privacy Matters, c/o Credit USA, Inc., One Cherry
Hill, Suite 400, Cherry Hill, NJ 08002.
Information we collect and how we use it:
We offer a number of services that do require
you to register for an account or provide any personal
information to us. In order to provide our full range of
services, we may collect the following types of information:
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Information you provide - When you sign up
for a CUSA Account or other CUSA service or promotion that
requires registration, we ask you for personal
information (such as your name, email address and an
account password). For certain services, such as our
member programs, we also request credit card or other
payment account information which we maintain in
encrypted form on secure servers. We may combine the
information you submit under your account with
information from other CUSA services or third parties in
order to provide you with a better experience and to
improve the quality of our services. For certain
services, we may give you the opportunity to opt out of
combining such information.
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CUSA cookies - When you visit
CUSA, we send one
or more cookies - a small file containing a string of
characters - to your computer that uniquely identifies
your browser. We use cookies to improve the quality of
our service by storing user preferences and tracking
user trends, such as how people search. Most browsers
are initially set up to accept cookies, but you can
reset your browser to refuse all cookies or to indicate
when a cookie is being sent. However, some CUSA features
and services may not function properly if your cookies
are disabled.
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Log information - When you use
CUSA services,
our servers automatically record information that your
browser sends whenever you visit a website. These server
logs may include information such as your web request,
Internet Protocol address, browser type, browser
language, the date and time of your request and one or
more cookies that may uniquely identify your browser.
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User communications - When you send email or
other communication to CUSA, we may retain those
communications in order to process your inquiries,
respond to your requests and improve our services.
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Affiliated sites - We offer some of our
services in connection with other web sites. Personal
information that you provide to those sites may be sent
to CUSA in order to deliver the service. We process such
information in accordance with this Policy. The
affiliated sites may have different privacy practices
and we encourage you to read their privacy policies.
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Links -
CUSA may present links in a format
that enables us to keep track of whether these links
have been followed. We use this information to improve
the quality of our services, customized content.
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Other sites - This Privacy Policy applies to
web sites and services that are owned and operated by
CUSA. We do not exercise control over the sites displayed
as search results or links from within our various
services. These other sites may place their own cookies
or other files on your computer, collect data or solicit
personal information from you.
CUSA only processes personal information for the
purposes described in the applicable Privacy Policy and/or
privacy notice for specific services. In addition to the
above, such purposes include:
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Providing our products and services to users,
including the display of customized content;
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Auditing, research and analysis in order to
maintain, protect and improve our services;
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Ensuring the technical functioning of our network;
and
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Developing new services.
CUSA processes personal information on our
servers in the United States of America and in other
countries. In some cases, we process personal information on
a server outside your own country. We may process personal
information to provide our own services. In some cases, we
may process personal information on behalf of and according
to the instructions of a third party, such as our affiliate
partners.
Choices for personal information
When you sign up for a particular service that
requires registration, we ask you to provide personal
information. If we use this information in a manner
different than the purpose for which it was collected, then
we will ask for your consent prior to such use.
If we propose to use personal information for
any purposes other than those described in this Policy
and/or in the specific service notices, we will offer you an
effective way to opt out of the use of personal information
for those other purposes. We will not collect or use
sensitive information for purposes other than those
described in this Policy and/or in the specific service
notices, unless we have obtained your prior consent.
You can decline to submit personal information
to any of our services, in which case CUSA may not be able to
provide those services to you.
Information sharing
CUSA only shares personal information with other
companies or individuals outside of CUSA in the following
limited circumstances:
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We have your consent. We require opt-in consent for
the sharing of any sensitive personal information.
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We provide such information to our subsidiaries,
affiliated companies or other trusted businesses or
persons for the purpose of processing personal
information on our behalf. We require that these parties
agree to process such information based on our
instructions and in compliance with this Policy and any
other appropriate confidentiality and security measures.
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We have a good faith belief that access, use,
preservation or disclosure of such information is
reasonably necessary to (a) satisfy any applicable law,
regulation, legal process or enforceable governmental
request, (b) enforce applicable Terms of Service,
including investigation of potential violations thereof,
(c) detect, prevent, or otherwise address fraud,
security or technical issues, or (d) protect against
imminent harm to the rights, property or safety of CUSA,
its users or the public as required or permitted by law.
If CUSA becomes involved in a merger,
acquisition, or any form of sale of some or all of its
assets, we will provide notice before personal information
is transferred and becomes subject to a different privacy
policy.
We may share with third parties certain pieces
of aggregated, non-personal information, such as the number
of users who searched for a particular term, for example, or
how many users clicked on a particular link. Such
information does not identify you individually.
Please contact us at the address below for any
additional questions about the management or use of personal
data.
Information security
We take appropriate security measures to
protect against unauthorized access to or unauthorized
alteration, disclosure or destruction of data. These include
internal reviews of our data collection, storage and
processing practices and security measures, as well as
physical security measures to guard against unauthorized
access to systems where we store personal data.
We restrict access to personal information to
CUSA employees, contractors and agents who need to know that
information in order to operate, develop or improve our
services. These individuals are bound by confidentiality
obligations and may be subject to discipline, including
termination and criminal prosecution, if they fail to meet
these obligations.
Data integrity
CUSA processes personal information only for the
purposes for which it was collected and in accordance with
this Policy or any applicable service-specific privacy
notice. We review our data collection, storage and
processing practices to ensure that we only collect, store
and process the personal information needed to provide or
improve our services. We take reasonable steps to ensure
that the personal information we process is accurate,
complete, and current, but we depend on our users to update
or correct their personal information whenever necessary.
Accessing and updating personal information
When you use
CUSA services, we make good faith
efforts to provide you with access to your personal
information and either to correct this data if it is
inaccurate or to delete such data at your request if it is
not otherwise required to be retained by law or for
legitimate business purposes. We ask individual users to
identify themselves and the information requested to be
accessed, corrected or removed before processing such
requests, and we may decline to process requests that are
unreasonably repetitive or systematic, require
disproportionate technical effort, jeopardize the privacy of
others, or would be extremely impractical (for instance,
requests concerning information residing on backup tapes),
or for which access is not otherwise required. In any case
where we provide information access and correction, we
perform this service free of charge, except if doing so
would require a disproportionate effort. Some of our
services have different procedures to access, correct or
delete users' personal information. We provide the details
for these procedures in the specific privacy notices or FAQs
for these services.
Enforcement
CUSA regularly reviews its compliance with this
Policy. Please feel free to direct any questions or concerns
regarding this Policy or CUSA's treatment of personal
information by contacting us through this web site or by
writing to us at Privacy Matters, c/o Credit USA, Inc., One
Cherry Hill, Suite 400, Cherry Hill, NJ 08002. When we receive formal written complaints at this
address, it is CUSA's policy to contact the complaining user
regarding his or her concerns. We will cooperate with the
appropriate regulatory authorities, including local data
protection authorities, to resolve any complaints regarding
the transfer of personal data that cannot be resolved
between CUSA and an individual.
Changes to this policy
Please note that this Privacy Policy may change
from time to time. We will not reduce your rights under this
Policy without your explicit consent, and we expect most
such changes will be minor. Regardless, we will post any
Policy changes on this page and, if the changes are
significant, we will provide a more prominent notice
(including, for certain services, email notification of
Policy changes). Each version of this Policy will be
identified at the top of the page by its effective date, and
we will also keep prior versions of this Privacy Policy in
an archive for your review.
If you have any additional questions or
concerns about this Policy, please feel free to contact us
any time through this web site or at Privacy Matters, c/o
Credit USA, Inc., One Cherry Hill, Suite 400, Cherry Hill,
NJ 08002. |