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At D+H USA Corporation (“D+H USA Corporation,” “D+H,” “we” or “us”), we know how important privacy is to you. Because of our interest in protecting your privacy and that of your customers, D+H USA Corporation has adopted the following general privacy principles. These general privacy principles apply throughout D+H USA Corporation except where varied to accommodate a specific business unit, product, or service, as specified below.
OUR COMMITMENT TO PRIVACY
There are two types of information that may come into our possession: (i) information specific to you as a financial institution; and (ii) Nonpublic Personal Information (as that term is defined by Title V, subtitle A of the Gramm-Leach-Bliley Act, 15 U.S.C. § 6801-6809) about your customers. We understand the importance of maintaining and protecting information that we maintain about you or that we receive from you. We also understand the regulatory requirements imposed on you with respect to the sharing of Nonpublic Personal Information, and we respect and adhere to the redisclosure and reuse rules set forth in the Gramm-Leach-Bliley Act and its implementing regulations.
Information We Gather And What We Do With This Information
In order to deliver the quality of service you expect from us, we may gather entity-specific information (contact, financial, and other general entity information), as well as information relating to your business needs and preferences and non-identifiable information (such as your core system or third party vendor, domain server, computer operating system, or web browser). We collect this information when you become a customer using methods described below and by other publicly available means (such as by accessing the FDIC’s institution database).
We collect, retain, and use this information to: (i) protect and administer your records and accounts; (ii) comply with certain laws and regulations; (iii) help us design or improve our products and services; (iv) maintain your accounts or otherwise meet your needs; and (v) understand your financial needs so that we can provide you with quality products and superior service. We may also access your information when considering a request from you for additional services or when exercising our rights under the law or any agreement with you. We may share the fact that you are a customer of ours if allowed by our agreement, but do not otherwise share your information with third parties except as described below.
We do not provide this information to third parties for the purpose of independent telemarketing or direct mail marketing of any non-financial products or services of those companies, except as may be allowed by an agreement with you. Further, we do not reveal specific information about your accounts or business to parties outside the combined operations and affiliates of D+H USA Corporation unless: (a) you request or authorize it; (b) the information is provided to help complete a transaction or perform a service initiated or authorized by you or contemplated by our agreement; or (c) the disclosure is otherwise lawfully required.
We do not intentionally collect or retain Nonpublic Personal Information about your customers unless specifically contemplated by our agreement or as specifically provided below. However, in providing services to you we may come into possession of, or gain access to, Nonpublic Personal Information about your customers. Such services include providing software maintenance, support, processing, implementation, training, customization or other services with regard to the software or services we provide, or to otherwise meet needs that you specifically express to us. When we obtain Nonpublic Personal Information for any of these purposes, we utilize it to accomplish the task for which we received the information. Once the task is completed, or it is no longer necessary for us to maintain the Nonpublic Personal Information, such information will either be returned to you or destroyed.
As a customer of ours, we may contact you occasionally to introduce you to new products and services that may be of interest, or to point out different ways you may be able to take advantage of your current products. You can choose not to receive marketing offers from us by direct mail, telephone, fax and/or e-mail by simply mailing your request to:
D+H USA Corporation
Corporate Marketing Department
605 Crescent Executive Court, Suite 600
Lake Mary, FL 32746
However, because of the nature of our operations, D+H customers who elect not to receive marketing information by direct mail, telephone or e-mail may still be contacted:
Agents and Independent Contractors
To perform certain software upgrades or changes, or to provide you with certain services, it may be necessary to allow agents or independent contractors of D+H access to information about you or your customers. If so, the agents or independent contractors must have signed an appropriate D+H nondisclosure agreement before receiving access to information about you or your customers and will be bound to treat your information consistent with our commitment to privacy and data security.
Sometimes we may provide information about you to an "alliance provider" or "strategic business provider" outside of D+H and its affiliates so that they may provide support or services for one or more of the products we offer. These "alliance providers" or "strategic business providers" have agreed to safeguard confidential information received from us, including information about you or your customers and to abide by applicable law.
When we must disclose Nonpublic Personal Information to an “alliance provider” or “strategic business provider” in order to provide a service for which you have contracted, your agreement with us will provide for this arrangement.
D+H utilizes the following extranet networks. An extranet is a private secure network that controls and limits access to authorized users through an established set of strict internal access authorizations, rights, and privileges. In addition, special hardware and software are used to build a "firewall" to protect data from a public network like the Internet. D+H utilizes encryption technology for sensitive communications between your computer and our extranet networks. In addition, some sites utilize "digital certificates" that use a protected method of communicating with your browser called Secure Sockets Layer Protocol, or SSL. This means that we are establishing a unique, private connection between your computer and our extranet to recognize and verify your identity and that the information we send you is really from an authorized user of one of our extranet networks.
Links to third parties: We may allow you to link to various third party sites. D+H does not control or access information you provide to third parties. D+H is not responsible for the privacy practices of unaffiliated third party sites to which this Web site may link, and we encourage you to become familiar with the privacy practices of such sites before you provide them with personal information.
Cookies: A cookie is a piece of text that your browser asks permission to place on your computer's hard drive. If you agree, then your browser adds the text in a small file. If you have set your browser to notify you before accepting a cookie, you may notice that an extranet requests that a cookie be placed on your computer. This cookie only tells us when you visit our site and what information you access. It doesn't tell us your e-mail address or who you are. If you want to give us that information later via registration, that's your choice. Cookies are a handy way to give you better service and personalize application session mapping by user. You will need to set your browser to accept cookies if you wish to add items to a shopping cart for online purchase. Information collected or stored via cookies includes purchases and log in data, among other data. This information is kept in a secure area within the extranet.
Personal Information Related to Children: D+H does not intend to collect personal information from children who identify themselves as being less than 13 years of age. Such children should not provide personal information on any D+H website, and should ask their parents to submit a request on their behalf if they want to receive information related to this site.
POLICIES APPLICABLE TO SPECIFIC PRODUCTS OR SERVICES
Because we offer such a variety of goods and services to financial institutions, there are certain situations in which our treatment of information you provide to us (about you or your customers, including Nonpublic Personal Information) will differ from the above. In short, some products or services require us to maintain and/or disclose information about you or your customers. When such treatment is required, our agreement with you will specifically address any information sharing requirements.
OUR COMMITMENT TO DATA SECURITY
We realize that a meaningful commitment to privacy requires that policies and procedures be in place to assure data security. We also realize that just as you will assess our privacy policies, you may be required to assess our security practices. We pride ourselves on understanding the need to safeguard sensitive information that you have entrusted to us. D+H values your trust and will handle your information with care.
We safeguard information according to established security standards and procedures, and we continually assess new technology designed to protect the integrity of information. Where information includes Nonpublic Personal Information of your customers, these standards include internal administrative, technical, and physical safeguards designed to:
We have implemented procedures that limit access to Nonpublic Personal Information to only those employees with a business reason to know such information, and our employees are trained to understand our information sharing principles and comply with these procedures. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our policies. We take reasonable disciplinary measures to enforce employee privacy responsibilities.
HOW YOU CAN HELP
D+H understands that consumer privacy is important to you. You can assist in protecting your information by recognizing the following principles.
We reserve the right to change these privacy and security principles, along with related provisions and policies, at any time. Notwithstanding our information sharing practices described in the above statement, information about you or your customers may be disclosed to regulators, as required by law, or as allowed by our agreement with you.
Last revised 02/08/2013