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| Hong Lan Customer Privacy Policy and Procedure |
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Hong Lan Services, Inc., a California Corporation, is serious about protecting our customer’s privacy. This policy explains what personal information Hong Lan collect from customers, with whom we share it and how the customers can elect in certain situations to not share information with third parties.
“Personal Information” refers to information such as name and email that can be used to identity the customer’s individually.
Purpose
The privacy provisions of the Financial Services Modernization Act, Gramm-Leach-Bliley Act, 15 U.S.C. §§6801-6827 (“GLBA”) require financial institutions to adhere to specific requirements concerning the protection and disclosure of non-public personal information (“NPI”) about consumers and customers of the financial institution. Hong Lan Services, Inc. is a money transmitter registered as a Money Services Business (“MSB”.) In the course of offering and providing financial services, Hong Lan collects and maintains certain personal information including non-public personal information. Hong Lan falls within the GLBA definition of financial institution.
Customer’s Personal Information
In order to provide money transmission services Hong Lan collects and may disclose certain personal and non-personal information about its customer and the beneficiary of the wire transaction. In addition, depending on the services requested or the sending amount Hong Lan may ask and disclose personal and non-personal information such as Identification, date of birth, Social Security Number, occupation, source of fund and any other information necessary to verify and process the money transfer request.
Information we collect: Hong Lan will collect the following information about the customer, which may include non-public personal information.
- Customer’s personal and financial information as a result of using Hong Lan Money Transfer Service, such as full name, address, date of birth, phone number, social security number, ID number, bank statements, paycheck, W-2 forms or tax returns.
- Third party personal information the customer provides in order for Hong Lan to facilitate the funds transfer, such as recipient’s full name, physical address, email address and phone number.
However, Hong Lan will not contact the beneficiary except as instructed by the sender or as required to complete a transaction. This information is only used for the sole purpose of completing a money transmission transaction.
Why we collect customer’s information: Hong Lan collect personal and non-personal information for the following purposes.
- To process customer’s transactions
- To verify customer’s identity
- To collect payment for the use of Hong Lan money transfer service
- To track, improve and personalize our services, content and advertising
- To troubleshoot problems with the service.
- To comply with applicable laws and regulations, such as those relating to “Know Your Customer” and Anti-Money-Laundering requirements.
- To detect and prevent fraud and other illegal uses of Hong Lan service
- To send customer’s marketing notices and promotional offers
Hong Lan will retain and use customers’ information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Hong Lan may be required to provide customer’s private information to different government agencies as required and permitted by laws.
Safe Guard
Hong Lan store and process customer’s personal information on our company owned server and we protect it by maintaining physical, electronic and procedural safeguards in compliance with applicable state regulations. Hong Lan uses computer safeguards such as firewalls and data encryption we restrict physical access to certain rooms in our office and buildings where files are stored and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
Hong Lan main database server is hosted at a data center in downtown Los Angeles. Access is strictly controlled by the building security personnel. In order to access to the server, an authorized person on the approved access list must provide identification to gain access.
Privacy Practices of Third Parties
Hong Lan does not share customer’s personal data with anyone for commercial purposes. Hong Lan may use customer’s personal data such as name, address, phone number for our own advertising and marketing purposes.
Without obtaining your consent, Hong Lan has the right to share your personal information for the following reasons:
- For our everyday business purposes, such as to process your transactions; manage our consumer relationship; respond to court orders and legal investigations; report to credit bureau; make risk decisions; detect and prevent fraud and other illegal activity; or as otherwise permitted or required by law.
- For our marketing purposes such as to offer our new products and services to you or notify you about future events and promotions.
- Law enforcement, government officials or other third parties, but only in connection with a formal request, subpoena, court order, or similar legal procedure; or
- When we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, report suspected illegal activity, or to investigate violations.
Hong Lan does not share your personal information with non-affiliates and third-parties to market to you or to jointly offer products. In accordance with California Law, Hong Lan will not share information we collect about our customers with companies out of Hong Lan Services, Inc. except as required or permitted by law. For example, Hong Lan may share information to service your accounts, complete your requested wire transactions.
Hong Lan customers have the right to request that we delete any of the Personal Information collected from them and retained subjected to certain exceptions. The customers’ request to delete their collected Personal Information may be denied if it is necessary for Hong Lan to retain your information under one or more exceptions listed in the CCPA.
For State of California, State of California has a CFIPA laws known as “CALIFORNIA FINANCIAL INFORMATION PRIVACY ACT”. CFIPA is based on the (California Financial Code Section 4050, et seq.)
Specifically, CFIPA states that Effective July 1, 2004, a financial institution may not share or sell a consumer's "nonpublic personal information" without obtaining a consumer's consent.
To meet CFIPA requirements for financial institutions Hong Lan shall follow the CFIPA guidelines as follow:
- To obtain a consumer's written consent prior to sharing a consumer's information with a
nonaffiliated third party.
- To provide the consumer with the opportunity to "opt-out" of having the consumer's
information shared with an affiliated party prior to sharing a consumer's information with an affiliate.
- A financial institution shall utilize a form, statement, or writing to obtain consent to disclose
nonpublic personal information to nonaffiliated third parties. The form statement or writing shall meet all of the following criteria:
What are the requirements to obtain the consent of a consumer to share information with nonaffiliated third parties?
The CFIPA provides guidelines as follows:
A. The form, statement or writing is a separate document not attached to any other document.
B. The form, statement or writing is dated and signed by the consumer.
C. The form, statement or writing clearly and conspicuously discloses that by signing the
consumer is consenting to the disclosure to nonaffiliated third parties of nonpublic personal
information pertaining to the consumer.
D. The form statement or writing clearly and conspicuously discloses (1) that the consent will
remain in effect until revoked or modified by the consumer. (2) that the consumer may revoke
the consent at any time and (3) the procedure for the consumer to revoke consent.
E. The form statement or writing clearly and conspicuously informs the consumer that (1) the
financial institution will maintain the document or a true and correct copy (2) the consumer is
entitled to a copy of the document upon request and (3) the consumer may want to make a copy of the document for the consumer's records.
What information is "nonpublic personal information"?
The CFIPA defines "nonpublic personal information" as follows:
"Nonpublic personal information" means personally identifiable financial information
1. provided by a consumer to a financial institution,
2. resulting from any transaction with the consumer or any service performed for the consumer or
3. otherwise obtained by the financial institution.
Nonpublic personal information does not include publicly available information that the financial institution has a reasonable basis to believe is lawfully made available to the general public from
1. federal, state or local government records,
2. widely distributed media or
3. disclosures to the general public that are required to be made by federal, state or local law.
Nonpublic personal information shall include any list, description or other grouping of consumers, and publicly available information pertaining to them, that is derived using any nonpublic personal information other than publicly available information but shall not include any list, description or other grouping of consumers, and publicly available information pertaining to them, that is derived without using any nonpublic personal information.
"Personally, identifiable financial information" means information
- that a consumer provides to a financial institution to obtain a product or service from
the financial institution,
- about a consumer resulting from any transaction involving a product or service between the
financial institution and a consumer or
- that the financial institution otherwise obtains about a consumer in connection with providing a product or service to that consumer.
Any personally identifiable information is financial if it was obtained by a financial institution in connection with providing a financial product or service to a consumer. Personally, identifiable financial information includes all of the following:
- Information a consumer provides to a financial institution on an application to obtain a loan,
credit card or other financial product or service.
- Account balance information, payment history, overdraft history and credit or debit card
purchase information.
- The fact that an individual is or has been a consumer of a financial institution or has obtained a
financial product or service from a financial institution.
- Any information about a financial institution's consumer if it is disclosed in a manner that
indicated that the individual is or has been the financial institution's consumer.
- Any information that a consumer provides to a financial institution or that a financial institution
or its agent otherwise obtains in connection with collecting on a loan or servicing a loan.
- Any personally identifiable financial information collected through an Internet cookie or an
information collecting device from a Web server.
7. Information from a consumer report.
When must a consumer's consent be obtained?
The CFIPA requires a financial institution to obtain a consumer's written consent prior to sharing a consumer's information with a nonaffiliated third party.
A financial institution shall not disclose to, or share a consumer's nonpublic personal information with, any nonaffiliated third party […] unless the financial institution has obtained a consent acknowledgment from the consumer that complies with [this section] that authorizes the financial institution to disclose or share the nonpublic personal information. Fin. Code Sec. 4053(a)(1)
The CFIPA requires a financial institution to provide the consumer with the opportunity to "opt-out" of having the consumer's information shared with an affiliated party prior to sharing a consumer's information with an affiliate.
A financial institution shall not disclose to, or share a consumer's nonpublic personal information with, an affiliate unless the financial institution has clearly and conspicuously notified the consumer annually in writing [as provided in this section] that the nonpublic personal information may be disclosed to an affiliate of the financial institution and the consumer has not directed that the nonpublic personal information not be disclosed. Fin. Code Sec. 4053.
Information of Minor and Children
Hong Lan Money Transfer Services are not directed to children under the age of 13. We do not knowingly collect information including Personal Data from children or other individuals who are not legally able to use our Money Transfer Services. If Hong Lan obtain actual knowledge that we have collected Personal Information Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Please contact Hong Lan head office at (714) 891-8939 if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.
For more information about the Children Online Privacy Protection Act (COPPA) please visit the Federal Trade Commission Website.
Privacy Policy and Notice (Gramm-Leach-Bliley Act)
Pursuant to the requirements of Title V of the Gramm-Leach-Bliley Act HONG LAN Inc. and its related companies (“HONG LAN”) do not disclose any non-public personal information obtained during the course of processing the money remittance orders, about customers or former customer to anyone, except as permitted or required by law and as required to process the money transmission order in accordance with the customer’s instructions.
Under GLBA, a “consumer” is defined as an individual or that individual’s legal representative, who obtains or has obtained a financial product or service from a financial institution that is to be used primarily for personal, family or household purposes. A “customer” is a consumer who has a “customer relationship” with a financial institution. Under GLBA, all customers fall under the definition of consumers, but not all consumers are customers. All customers must receive a privacy notice. Consumers do not need to be provided a privacy notice as long as a company does not share consumers’ information with nonaffiliated third parties. All of Hong Lan customers are protected under the GLBA and therefore provided Hong Lan Privacy Notice.
Hong Lan adheres to the requirements of the GLBA and explains its information sharing practices to their customers and to safeguard sensitive data. Hong Lan does not have any affiliates and does not share customer’s information with nonaffiliates for marketing purposes.
Hong Lan Privacy Notices is therefore based on the Privacy model form for not providing opt out and not including affiliate marketing.
Hong Lan takes privacy very seriously and knows that the costumers care about their Personal Confidential Information is used and shared, therefore Hong Lan is committed to maintain the privacy and confidentiality of its customers’ personal information in full accordance with GLBA rules.
CALIFORNIA CONSUMER PRIVACY ACT
In 2018, California passed one of the most powerful privacy laws in the United States - the California Consumer Privacy Act (CCPA) which goes into effect on January 1, 2020. As a practical matter, companies need to have their data tracking systems in place by the start of 2019, since it gives consumers the right to request all the data a company has collected on them over the previous 12 months. The CCPA statue intended to enhance privacy rights and consumer protection for residents of California.
The CCPA provides California residents with specific rights regarding their Personal Information as described below:
Consumer Information Rights:
As Hong Lan customers you have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of Personal Information Hong Lan had collected about you.
- The categories of sources from which Hong Lan collected your Personal Information
- The business or commercial purposes for our collecting or selling your Personal Information
- The categories of third parties to whom we have shared your Personal Information
- The specific pieces of Personal Information we have collected about you.
- A list of the categories of Personal Information disclosed for a business purpose in the prior twelve months or that no disclosure occurred.
- A list of the categories of Personal Information sold about you in the prior twelve months or that no sale occurred. If Hong Lan sold your Personal Information we will explain:
- The categories of your Personal Information we have sold
- The categories of third parties to which we sold your Personal Information, by categories of Personal Information sold for each third party.
Customer’s Right to Request Deletion of Personal Information:
As Hong Lan customers you have the right to request that we delete any of your Personal Information that we had collected from you and retained, subjected to certain exceptions, including if we need the Personal Information for a reason related to Hong Lan business such as:
- Providing MSB Services to you
- Detecting and resolving issues related to security or functionality
- Complying with legal obligations
- Using your information for internal purposes that a consumer might reasonably expect.
After we receive and confirm your verifiable customer request, we will delete your Personal Information from our records within the time period required by the CCPA unless an exception applies.
Exercising your Rights:
To exercise the rights described above, please submit a verifiable consumer request to using the information on our website at www.honglanservices.us under “Contact Us”.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: providing your email and phone verification, known customer information, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the Personal Information in question.
Making a verifiable consumer request does not require you to create an account with us. Hong Lan will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Hong Lan will not discriminate against you for exercising any of your CCPA rights. In particular, we will not:
- Deny you our services
- Charge you different prices for services, whether through denying benefits or imposing penalties
- Provide you with a different level of services
- Threaten you with any of the above
Changes to Hong Lan Customer Privacy Policy
Hong Lan reserves the right to modify and update this Privacy Policy at any time to reflect changes to our Money Transfer Business or applicable laws. If Hong Lan modifies this Privacy Policy, we will post the revised Policy to our website with an updated “effective date”.
Hong Lan customers can get an updated Privacy Policy by calling us at 1-888-880-8345 or by visiting our website at http://www.honglanservices.us
Hong Lan customers can modify, delete or update their personal information by emailing our Customer Support at info@honglanservices.com or by contacting us by the telephone at the contact information listed below. We will respond to your request to access within a reasonable timeframe.
How you can contact Hong Lan Compliance Department about privacy questions.
If you have questions or concerns regarding this privacy policy, you may contact or writing to us at Hong Lan Services Inc. Attn: Compliance Department: 9113 Bolsa Ave # 122 Westminster, CA 92683 or call us toll free at 1-(888) 880-8345 – Fax (714) 891-9939 – Email: info@honglanservices.com
Effective Date of this revised Customer Privacy Policy: January 13, 2020 |
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