PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
HALL collects, uses and discloses your Personal Information in its normal course of business for the following purposes:
- Establishing and maintaining communications with you;
- Where you have requested information from HALL, assisting you in the completion of your request and the assessment of your eligibility for any such request;
- Responding to your inquiries about our properties or services;
- Making proposals for future service needs;
- Allowing our affiliated companies to notify you of certain products or services offered by our affiliated companies;
- Meeting legal, security, processing and regulatory requirements;
- Protecting against fraud, suspicious or other illegal activities; and
- Compiling statistics for analysis of our sites and our business.
WHAT INFORMATION WE COLLECT
The information gathered by HALL from this Site falls into two categories: (1) information voluntarily supplied by visitors to our Site and (2) tracking information gathered as visitors navigate through our Site.
Information voluntarily provided by you
When using this Site, you may choose to provide us with information to help us serve your needs. The Personal Information that we collect will depend on how you choose to use this Site.
Where you request a brochure or subscribe to a newsletter
If you subscribe to a newsletter, request a brochure, or inquire for further information from us, we require you to submit your name, e-mail address, the name of your organization, and any other necessary contact information so we may send you the material you have requested, and to enable us to identify if you are an existing client of HALL.
Where you register with us and/or request services
If you register with the Site, or request a service available on the Site, we may ask you for your name, e-mail address, country, telephone number and the reason for your communication, as well as information about your position and organization and such other information as is reasonably necessary so that we can provide you with the requested information or service. On the data submission form, we shall indicate by way of an asterisk, which information is optional and which information is mandatory. This information can include:
- Information you provide on applications or other forms, which may include your name, address, email address, and credit card numbers;
- Information we acquire from and/or transfer to other persons (such as government agencies, industry associations, auditors, claims adjusters, your insurer and your employer) to verify your identity and the accuracy of the information you have provided;
- Where you submit content
Finally, if you submit content regarding any of the information that you view on our Site, we will ask for your name and e-mail address, so that, if you choose, we can update you by e-mail when others also comment on the content. You should be aware that the information you provide there will be made publicly available to HALL employees and other users of the Site.
Website Navigational Information
As you navigate the Site, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Site (such as the web pages viewed and the links clicked).
Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
First-party cookies: the function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between HALL’s servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
Third-party cookies: the function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the Third-party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.
The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, HALL’s Sites are not compatible with DNT.
For information on all of these categories of cookies, and for more information generally on cookies please refer to www.aboutcookies.org.
We use generally cookies as follows:
These cookies allow our Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a Site may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access our Site. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on an article. The information these cookies collect is usually anonymized. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.
These cookies collect information about how visitors use a Site, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that our Site works. The information these cookies collect is normally anonymous and is used to improve how our Site works. However, some of these cookies may include Personal Information.
Please consult your web browser’s ‘Help’ documentation or visit www.aboutcookies.org. for more information about how to turn cookies on and off for your browser.
These cookies are used to deliver content relevant to your interests on our Site and third party sites based on how you interact with our advertisements or content.
The Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with e-mails from HALL. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications. We may use information from web beacons in combination with other data we have about our clients to provide you with information about HALL and our services. We will conduct this review on an anonymous basis.
When you visit our Sites, HALL collects your Internet Protocol (“IP”) addresses to track and aggregate non-Personal Information. For example, HALL uses IP addresses to monitor the regions from which users navigate the Sites. IP addresses will be stored in such a way so that you cannot be identified from the IP address.
DISCLOSURE OF INFORMATION TO OTHERS
Third parties to whom we generally disclose information are required by law or a contract with us, to keep your Personal Information confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances and for purposes as follows:
- To provide the information and services you have requested from us;
- To notify you or allow our affiliated companies to notify you of certain products or services offered by our affiliated companies;
- To process transactions through data processing service providers;
- To other financial institutions with whom we have joint marketing agreements.
In the normal course of performing services for our clients, Personal Information may be shared within HALL and its affiliates for research and statistical purposes, system administration, joint marketing, and crime prevention or detection.
Because a number of the service providers we use are located in the United States, including certain HALL affiliates, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under US laws.
HALL’s service suppliers adhere to the same protections regarding the collection, use, and retention of data as we do.
As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either HALL itself or substantially all of HALL assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third party purchaser in these circumstances
Other Legally Required Disclosures
HALL preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site if HALL has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of HALL, employees, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request
CALIFORNIA’S “SHINE THE LIGHT” LAW
California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what personal information the operator disclosed to third parties for direct marketing purposes, for the preceding calendar year; and the addresses and names of such third parties. HALL does not share any personal information collected from this site with third parties for their direct marketing purposes.
Your knowledge of and consent to HALL’s collection, use and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:
- Your voluntary provision of Personal Information to us directly;
- Your express consent or acknowledgement contained within a written, verbal or electronic application or claims process; and
- Your verbal consent solicited by HALL (or our agent) for a specified purpose.
In some cases, refusing to provide certain Personal Information or withdrawing consent for HALL to collect, use or disclose your Personal Information could mean that we cannot provide requested services or information for you.
However, there are a number of instances where HALL does not require your consent to engage in the processing or disclosure of Personal Information. HALL may not solicit your consent for the processing or transfer of Personal information for the those purposes which have a direct legal basis, such as:
- The transfer or processing is necessary for the performance of a contract between you and HALL (or one of its affiliates);
- The transfer or processing is necessary for the performance of a contract, concluded in your interest, between HALL (or one of its affiliates) and a third party;
- The transfer or processing is necessary, or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests; or
- The transfer or processing is required by applicable law.
We have in place reasonable safeguards appropriate to the sensitivity of the information we maintain. Safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Note that due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information disclosed over the Internet, and HALL expressly disclaims any such obligation.
ACCURACY, ACCOUNTABILITY, AND OPENNESS
Our knowing about changes to some of your Personal Information (e.g. email address) may be key to effectively communicating with you at your request. If any of your details change you can update us by e-mailing us at firstname.lastname@example.org. Please keep us informed of changes to your Personal Information.
You have the right to access your Personal Information and request changes to Personal Information we have that may be obsolete, incomplete or incorrect. However, to secure your Personal Information, HALL does not provide online access to its customers to view or amend Personal Information in its database.
QUESTIONS OR TO WITHDRAW CONSENT
You may exercise your right to withdraw your consent to applicable uses or disclosures of your Personal Information (which may limit or terminate the products and services that HALL provides to you) by writing or sending an email to us at: Hall Financial Group, Ltd., 2323 Ross Avenue, Suite 200, Dallas, Texas 75201; email@example.com. You may also opt-out of the receipt of receiving targeted marketing emails from us by sending an email to firstname.lastname@example.org.
We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to such information.
Normally we will respond to access requests within 30 days.