1. PIN4 CASH
HCNA provides services to banks, e-money entities, other financial institutions, businesses, governmental bodies and other entities (the “Issuer Parties”) in connection with the Issuer Parties providing Pin4 Cash and other ATM cash access services to consumers in the UK and EU. In connection with providing these services, HCNA will receive and process personal data (primarily mobile phone numbers) of consumers from, or on behalf of, the Issuer Parties. In this case, under UK and European data protection laws, the Issuer Parties are the “data controllers” and HCNA is the “data processor” in regard to the personal data.
HNCA has written agreements with the Issuer Parties and will only process personal data (a) as specified in those written agreements and (b) only for purposes of providing services to the Issuer Parties and not for its own purposes.
HCNA also has written agreements with entities providing services to HCNA in relation to the above activities. These entities may receive and process personal data as “sub-processors” to HCNA. In this case, the Issuer Parties will continue to be the data controllers. In HCNA’s agreements with these entities, the entities agree to only process personal data (a) as specified in the written agreements and (b) only for purposes of providing services to HCNA and the Issuer Parties and not for its own purposes.
For additional information regarding the use and processing of your personal data relating to the programs described above, please refer to the privacy policies of the applicable Issuer Parties.
2. OTHER DATA OR PERSONAL INFORMATION
In HNCA’s other activities, such as the operation of its website and other interactions with consumers not related to operating the Pin4 Cash program and being a data processor for the Issuer Parties, HCNA may collect and use other information regarding consumers, including personal information: Identity data (e.g., name, username, date of birth, gender); Profile data (e.g., user preferences, comment); Contact data (e.g., email address, phone numbers); Content data (e.g., personal information contained in messages); Support data (e.g., comments made in customer support efforts); Technical data (e.g., IP address, browser information); Usage data (e.g., how our services are used); and Marketing data (e.g., user preferences relative to marketing efforts).
In these cases, we are the data controller in respect of this data for UK and European data protection laws. We collect and process this data as set forth below:
2.1 Information Collection
We may use your information to form a view on what we think you may want or need, or what may be of interest to you and provide marketing materials regarding same. At your request (through our unsubscribe process), we will cease sending messages or otherwise contacting you.
2.3 Sharing Information
We may share your personal data with certain other parties to carry out our lawful objectives. Such parties may include our services providers and business partners. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
2.4 Data security
We engage appropriate security measures to prevent the loss, misuse or destruction of personal information. Additionally, we limit access to your personal information to those employees, agents, contractors and other third-party service providers who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have policies in place to address suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
2.5 Data retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We take into consideration the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and the applicable legal requirements, when considering retention terms.
By law we may have to keep basic information about our Users for such periods as may be required by such laws.
2.6 Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information. This may include the following rights:
- Access Rights. This is the right to receive a copy of the personal information we hold about you.
- Correction Rights. This is the right to have any incomplete or inaccurate information we hold about you corrected.
- Removal Rights. This is the right to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
- Process Restriction. This right applies where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Transfer Rights. This is the right to request the transfer of your personal information to another party.
- Withdraw consent. This right applies only if we are relying on your consent to process any of your personal information. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact HCNA’s Data Protection officer at the email address below. You will not have to pay a fee to access your personal information (or to exercise any of the other rights), unless such request is unfounded or excessive (in which case, a reasonable fee may apply, or we may refuse to comply with your request).
2.7 Data Protection Officer
Our “Data Protection Officer” is responsible for matters relating to privacy and data protection and can be reached at the following address:
HalCash North America, Inc.
11 S. Passaic Avenue
Chatham, NJ 07928
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