HITRUST Control Requirements
- 19 Data Protection & Privacy: 19134.05j1Organizational.5
Revised June 25, 2022
We are committed to protecting your personal information and your right to privacy.
If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org
Depending on the context of the personal information you provide, Paubox may be the data controller (“Controller”) or data processor (“Processor”) of your personal information under this policy. We are a Processor of personal information submitted to our products and services, or collected through our products and services on behalf of or at the direction of our subscribers.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information.
We collect personal information that you voluntarily provide to us when registering at the Sites expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. We collect your first and last name, email address, postal address, phone number, job title, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites.
We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.
Like many businesses, we collect information through cookies and similar technologies.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third party account (such as your Google account), we may use the information you allowed us to collect from those third parties to facilitate an admin account creation and logon process.
- To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our third party marketing partners may use the personal information you send us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” section below).
- To send administrative information to you for Business Purposes, Legal Reasons and/or possibly for Contractual reasons. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- Fulfill and manage your orders for Contractual reasons. We may use your information to fulfill and manage your orders and payments made through the Sites.
- Deliver targeted advertising to you for our Business Purposes and/or with your Consent. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
- Request Feedback for our Business Purposes. We may use your information to request feedback and to contact you about your use of our Sites.
- To protect our Sites for Business Purposes and/or for Legal Reasons. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or possibly Contractual reasons.
- To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We only share and disclose your information in the following situations:
- Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- With your Consent. We may disclose your personal information for any other purpose with your consent.
Cookies are small text files which are downloaded to your device when you visit a website or application. The website or application may retrieve these cookies from your web browser each time you visit, so they can recognize you, remember your preferences and provide you with a more secure online experience.
Cookies generally do not hold any information to identify an individual person, but are instead used to identify a browser on an individual machine.
If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. Please note, if you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers visit: http://www.aboutads.info/choices/.
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in the United States. If you are accessing our Sites from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in the United States and other countries.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. Specific information on how we secure your information can be found on our Security Information page.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We extend this protection up to minors under the age of 18. We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area and California), you have certain rights under applicable data protection laws such as the California Consumer Privacy Act (CCPA). These may include the right (i) to request access and obtain a copy of your personal information; (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you would at any time like to review or change the information in your account or terminate your account, you can contact us at firstname.lastname@example.org.
Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers visit: http://www.aboutads.info/choices/.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.
Under the CCPA, California residents also have rights regarding their personal information.
Right of Access. You have the right to request we disclose certain information to you about our collection and use of your personal information over the past 12 months. What we collect and how we use your information has also been shared in the above sections.
Right to Deletion. You have the right to request any of your personal information that we collect is deleted, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct any service providers to delete) your personal information from our records, unless an exception applies.
Right to Opt-Out. As mentioned in the previous section (“WHAT ARE YOUR PRIVACY RIGHTS”), you may opt-out of interest based cookies and from our email marketing at any time. But you also have the right to opt-out of the sale of your personal information. However we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. Information is only securely shared for the purpose of providing goods or services.
Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including discounts, benefits or penalties; (iii) provide you a different level of quality of goods or services; (iv) suggest that you may receive a different price or rate or quality for goods or services.
To make requests related to these rights, you or an Authorized Agent may submit a request using the contact details provided below.
An Authorized Agent is a person making a request on your behalf, if we receive a request from an Authorized Agent, we will ask that person to give us proof that you gave written permission to make the request for you. If no proof is provided, we will deny the request so we can protect your personal information.
11. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have any questions or comments about this policy, you may contact our Data Protection Officer (DPO), Rick Kuwahara by email at email@example.com, or by post to:
5 Third Street, Suite 324
San Francisco, CA 94103
If you have any further questions or comments about us or our policies, email us at firstname.lastname@example.org or by post to:
5 Third Street, Suite 324
San Francisco, CA 94103
Phone: (415) 795-7396