1 Purpose
1.1 To formalize the HOV Services Inc.’s (“HOV Services”) approach to securing personally identifiable information and overall privacy. HOV Services respects the privacy of its employees, customers and shareholders and takes its responsibilities regarding the security of information seriously. In accordance with HOV Services commitment to exceed expectations for every one of its customers, HOV Services has placed into effect the following Privacy Policy
1.2 This Privacy Policy and Safe Harbor Policy shall apply to all HOV Services subsidiaries with the exception of the following: Lason India Pvt. Ltd.
2 Guiding Principles
2.1 As a leading provider of business process outsourcing, HOV Services’ customers include over 50% of FORTUNE 100® companies across key verticals such as financial services, telecommunications, healthcare, insurance, construction, publishing, finance and accounting and government, we have occasion to collect, store and use personal information from a variety of different sources. HOV Services believes in protecting that information and has established this Privacy Policy as a guiding document for the collection, use and storage of personal information.
2.2 HOV Services expects employees, independent contractors, vendors and other users of systems and documents that may contain personal information to protect such personal information from unauthorized disclosure or use; and destroy or delete such personal information when no longer required for the purpose intended or by law, whichever is longer.
2.3 HOV Services expects each employee, independent contractor, vendor or other user of personal information to apply appropriate measures to protect personal information where collected, used or stored in accordance with the applicable and enforceable laws of those countries in which HOV Services is operating. As global laws and ethical concerns of privacy are constantly evolving, HOV Services will continue to adopt reasonable policies and information security measures to meet these evolving standards.
3 Policy
3.1 HOV Services adheres to the US Safe Harbor privacy policies of Notice, Choice, Onward Transfer, Security, Data Integrity and Access and Enforcement.
3.2 Collection of Information. HOV Services collects personally identifiable information when voluntarily submitted by our online and onsite visitors. The information provided is used to fulfill specific requests. This information is only used to fulfill the specific request, unless given permission to use it in another manner. In order to provide our full range of services, HOV Services may collect the following types of information:
3.2.1 Personally Identifiable Information. This includes names, postal addresses, email addresses, phone numbers, company information, etc., as provided by HOV Services’ clients and website visitors.
3.2.2 Cookies. When a visitor visits the HOV Services website, HOV Services sends out one or more cookies to the visitor’s computer that will identify the visitor’s browser. Cookies are small files that are temporarily stored on the visitor’s hard drive, enabling the HOV Services website to recognize the visitor’s computer the next time the visitor visits the HOV Services website. HOV Services will use cookies exclusively to collect information concerning the use of its website. Cookies contain no personally identifiable data, so the protection of the visitor’s privacy is ensured. Depending on the visitor’s settings, the internet browser will automatically accept cookies. However, the visitor may change his/her browser settings at any time and choose to access this website without accepting cookies.
3.2.3 User Communications. When a visitor sends an email or other communication to HOV Services, HOV Services may retain those communications in order to process inquires, respond to requests, and improve our overall services.
3.2.4 Affiliated Sites. HOV Services offers some of its services in connection with other websites. Personal information that a visitor provides to those sites may be sent to HOV Services in order to deliver the service. HOV Services processes such information in accordance with this Policy. The affiliated sites may have different privacy practices and policies and HOV Services encourages all visitors to read and familiarize themselves with the affiliated company’s privacy policies.
3.2.5 Other Sites. This Privacy Policy applies to websites and services that are owned and operated by HOV Services, with the exceptions listed in section 3.19 below. HOV Services does not exercise control over the sites displayed as search results or links from within our various services. Once a visitor has used these links to leave our site, the visitor should note that HOV Services does not have any control over that other website. Therefore, HOV Services cannot be responsible for the protection and privacy of any information, which a visitor provides while visiting such sites and such sites are not governed by this privacy statement. These other sites may also place their own cookie or other files on the visitor’s computer, collect data or solicit personal information from the visitor.
3.3 Notice and Choice. To the extent permitted by the Safe Harbor Agreement, HOV Services reserves the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved. Where HOV Services collects personal information directly from individuals in the European Union, HOV Services will inform them about the types of personal information HOV Services collects from them, the purposes for which HOV Services collects and uses such information, and the types of non-agent third parties to which HOV Services discloses that information. HOV Services will also inform those individuals about the choices and means, if any, HOV Services offers individuals for limiting the use or disclosure of their information.
3.4 Disclosure and Transfers. In general, HOV Services will not disclose any of a visitor’s personally identifiable information except when HOV Services has a visitor’s permission under special circumstances, such as when HOV Services believes in good faith that the law requires it or under other circumstances outlined in this Policy. HOV Services may share information with governmental agencies or other companies assisting HOV Services
3.4.1 HOV Services may share information with governmental agencies or other companies assisting HOV Services in fraud prevention or investigation. HOV Services may do so when: (1) permitted or required by law; or, (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions; or, (3) investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes.
3.4.2 Permitted transfers of information, either to third parties or within HOV Services, include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the personal information originated.
3.5 Data Security. HOV Services takes reasonable steps to protect all personally identifiable information that we handle. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of personally identifiable information, either for its own purposes or on behalf of our clients, HOV Services has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal information we possess. However, HOV Services cannot guarantee the security of personally identifiable information on or transmitted via the Internet.
3.6 Data Integrity. HOV Services possesses personally identifiable information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current and otherwise reliable with regard to its intended use.
Access and Correction. If an individual becomes aware that personally identifiable information HOV Services maintains about that individual is inaccurate, or if an individual would like to update or review his or her personal information, the individual may contact HOV Services using the contact information below.
3.7.1 HOV Services will take reasonable steps to permit individuals to correct, amend, or delete personally identifiable information that is demonstrated to be inaccurate. The individual will need to provide sufficient identifying personal information, such as name, address, birth date, and social security number. HOV Services may request additional identifying personal information as a security precaution.
3.7.2 HOV Services may limit or deny access to personally identifiable information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, HOV Services may charge a reasonable fee, where warranted, for access to personally identifiable information
3.7 Enforcement and Dispute Resolution. HOV Services utilizes the self-assessment approach to ensure its compliance with our privacy policy.
3.8.1 HOV Services periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles.
3.8.2 HOV Services encourages interested persons to raise any concerns with us using the contact information below. HOV Services will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.
3.8.3 With respect to any complaints relating to this Policy that cannot be resolved through our internal processes, HOV Services has agreed to participate in the dispute resolution procedures of the panel established by the European Union Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles.
3.8.4 If HOV Services or the European Data Protection Authorities determine that HOV Services did not comply with this Policy, HOV Services will take appropriate steps to address any adverse effects and to promote future compliance.
3.8.5 Any person who HOV Services determines is in violation of our Privacy Policy will be subject to disciplinary process.
3.8 Sale of Assets, Merger or Acquisition. In the event HOV Services merges, is acquired by or sells its assets to a third party, HOV Services may disclose personally identifiable information as is reasonably necessary to affect any such merger, acquisition or sale. Individuals will be afforded the opportunity to opt-out of the HOV Services offering consistent with our opt-out provisions.
3.9.1 Any such party with whom HOV Services merges or whom acquires some or all of the assets of HOV Services may not have the same or similar privacy guidelines as set forth in this Policy and may use personally identifiable information in a manner other than as set forth herein.
3.9 This Policy may be changed from time to time, consistent with the requirements of the Safe Harbor Agreement. HOV Services will post any revised Policy on its website, or a similar site that replaces that site.
3.10 Certain information is subject to HOV Services policies that may differ in some respects from the general policies set forth in this statement.
3.11 Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice to the client, any contract or other agreement with the client, and applicable and enforceable laws
3.12 Questions and comments regarding this Privacy Policy shall be directed to the Privacy Officer of HOV Services.
3.13 Formal written complaints should be sent to the attention of the Privacy Officer at 1305 Stephenson Highway, Troy, Michigan 48083.
3.14 The Privacy Officer shall contact all individuals regarding his or her concerns and questions as they may relate to this Privacy Policy.
3.15 HOV Services 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 HOVS Services and an individual.
3.16 If a complaint is not satisfactorily addressed by HOVS within a reasonable time frame, you may contact the Federal Trade Commission at www.ftc.gov/ftc/complaint.htm, or via phone at 202.382.4357.
3.17 A version of this Privacy Policy shall be available on HOV Services’ website, at HOV Services’ corporate headquarters and at all HOV Services sites
4 Definitions
4.1 “Visitor” shall mean any individual or business, which visits the HOV Services website. This term may have been used synonymously with the term “individual” throughout this Policy.
5 References
None |
