HISPANO CLUB’s PRIVACY POLICY

Last modified: October 2, 2017

Introduction

Hispano Club, LLC, a Delaware limited liability company (“Company” or “Hispano Club^®” or “we”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This policy describes how we collect, use, and share information that we gather about you on the www.hispanoclub.com website and other websites, software applications, mobile applications, connected TV applications, and other network-connected products and services that reference or link to this Privacy Policy (collectively, the “Sites”).  This Privacy Policy only addresses information collected directly through or from our Sites – it does not address or govern any information-gathering, use, or dissemination practices related to information collected from you other than directly through or from the Sites, such as from telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media, unless that information is combined with information collected from the Sites.

The purpose of this Privacy Policy is to inform you of the kinds of information we may collect, how such information may be used, with whom such information may be shared, your choices regarding the collection, use, and sharing of such information, your ability to access and correct such information and the security procedures we use to protect this information.

Please read this document carefully. By accessing or using the Sites and/or registering to become a Hispano Card holder or a Hispano Club^® Member or Independent Associate, you consent to the collection, use, and disclosure of your Personal Information as described in this Privacy Policy. We reserve the right to change or amend this Privacy Policy from time to time. Your continued use of Hispano Club’s Sites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. WHAT KIND OF INFORMATION DOES HISPANO CLUB COLLECT?

Hispano Club^® collects several types of information from and about you, some of which relates to you, your device or computer and which enables your identification (“Personal Information”).   We collect information from and about you in the following ways:

1. Information You Provide

When you choose to apply to become either a Member or an Independent Associate of Hispano Club^®, you will be required to provide certain information about yourself, including your name, postal address, e-mail address, telephone number, date of birth, credit card number, marital status, profession, gender, and other Personal Information. Additional information may be required in order to become an Independent Associate of Hispano Club^®, such as your driver’s license number, foreign identification number (such as a passport and/or consular card number), social security number, and bank account number.

Some elements of the Sites may ask you to submit Personal Information in order for you to benefit from the specified features (such as newsletter subscriptions) or to participate in a particular activity (such as sweepstakes or other promotions) or to submit a question or complaint.  You will be informed what information is required to utilize these features of the Sites, and what information is optional.

We may combine the information you submit through the Sites with other information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, including publicly available information sources (such as publicly available social media profiles) as well as our service partners and data licensors, in compliance with applicable laws.

If you disclose to Hispano Club^® any Personal Information about another individual, you represent to us that you have secured the consent of that individual before disclosing such information to Hispano Club^®.

2. User Contributions

Certain aspects of the Sites may allow you to post or otherwise submit photos, videos, graphics, information, comments, and other content to the Sites or to share such content with third parties (“User Contributions”).  Upon submission or transfer, all such content may become publicly available and may be viewed, read, collected, or used by others, outside of our control, including any geo-location, tags, or other metadata in such submissions. Accordingly, your User Contributions are posted on the Sites and transmitted to others at your own risk. Your User Contributions are subject to Hispano Club^®’s DMCA Policy at https://hispanoclub.com/legal/dmca-policy/

3. Social Media and Other Third Party Platforms

You may engage with our content, such as video, games, applications, and other offerings, on or through social media services or other third party platforms, such as Facebook, Twitter, and Pinterest. When you engage with our content on or through social media services or other third party platforms, plug-ins, integrations, or applications, we may have access to certain information in your profile with that service or platform. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third party platform or social media account user files, photos and videos, your list of friends or connections, people you follow and who follows you, and your posts and “likes.” For a description on how such social media services and other third party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

4. Information Hispano Club^® Collects Through Automatic Data Collection Technologies

As you navigate through and interact with our Sites, Hispano Club^® may use its own and/or third party automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: details of your visits to our Sites including traffic data, location data, logs, and other communication data and the resources that you access and use on the Sites; information about your computer and internet connection, including your IP address, operating system, browser type, information about your online activities over time and across third-party websites or other online services (behavioral tracking) (“Use Data”).

The Use Data we collect may be used or associated with your Personal Information and/or stored. It helps us to improve our Sites and to deliver a better and more personalized service, by enabling us to, for example: estimate our audience size and usage patterns; customize our Sites according to your individual interests and preferences; speed up your searches; and recognize you when you return to our Sites.

The technologies we use for this automatic data collection of Use Data may include, but are not limited to:

• Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.
• Through your device: If you access the Sites through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the Sites.
• Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Sites, pages visited, and language preferences. We and our service providers use this information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Sites. More specifically, we use cookies to:
  • recognize your computer or device to make your use of the Sites easier, such as to remember your locations of interest and other preferences with the Sites;
  • gather statistical information about use of the Sites in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it;
  • select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Sites and on other websites, applications, and online services that you use; and
  • track consumer responses to online advertisements.

To learn more about cookies, please visit http://www.allaboutcookies.org.

• Using Monitoring Tools: The Sites may utilize pixel tags, web beacons, clear GIFs, Flash Shared Objects, HTML5 Local Storage, HTML5 Mini Databases, and other similar technologies, both on certain aspects of the Sites and in HTML-formatted e-mail messages to you. These monitoring tools are used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Site usage and response rates, and tracking the activities of users of the Sites and e-mail recipients.
• IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Sites, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Sites usage levels, helping diagnose server problems, and administering the Sites.
• Analytic Tools: We also use tools and third party services to collect information about usage of the Sites, including Google Analytics. You can learn more about Google Analytics, and its privacy practices, at the Google Analytics Help Page. Generally speaking, Google Analytics collects information on how often users visit the Sites, what aspects of the Sites they visit when they do so, and what other websites users visited prior to accessing the Sites. The Sites makes use of Google Analytics services for Demographics and Interest Reporting as well as Display Advertising features, including Remarketing, Google Display Network Impression Reporting, and DoubleClick Campaign Manager integration. You may opt out of Google Analytics for Display Advertising or customize Google Display Network ads through the Google Ads Settings page. You may also prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on.
• Location-Based Features: The Sites include certain location-based features, such as promotions that are relevant to your geographic location. We may use information about your location to conduct analytics and improve the Sites and to provide certain location-based features and services, as further described in this Privacy Policy and as otherwise described to you at the point of collection. To provide these location-based features, in addition to the information that you voluntarily submit through the Sites, we may also access information about your location using automated means. For example, we may collect information about your approximate location using your cell ID, and about your precise location using GPS, WiFi, cellular signals, and other data gathered through location-based services and devices, such as beacons (small devices that send Bluetooth signals that can be received by Bluetooth-enabled devices). We may disclose location information as described in this Policy. Some services on the Sites may continuously track your location information to allow us and our third-party advertising partners to deliver advertisements that are relevant to your current location, including via text message and push notification. If you opt to utilize these features, you must enable your device to receive Bluetooth signals and accept push notifications. Depending on how you access the Sites, your web browser or your mobile device operating system may inform you that the Sites would like to collect your location and request permission to do so. If you allow such access, the Sites will collect your location information. If you decline, you will need to manually enter your location information to utilize certain features of the Sites.

If you are uncomfortable with the idea of your Personal Information being collected and used in these ways, most computer systems, devices, and web browsers offer privacy settings and options, such as disabling cookies, resetting your IDFA, turning off location-based services, or opting for “Do Not Track” features. See Section 4 below for more information on opting out of Interest-Based Advertising. We do not override these settings or options and encourage you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products, or benefits of the Sites, you may be required to provide us with certain information. If you do not wish to provide that information through the Sites or if you opt to utilize the aforementioned privacy features, you may be unable to obtain certain content, features, services, products, or benefits of the Sites. Changing these settings will not prevent you from seeing advertisements and offers, but those advertisements and offers may not be tailored to your interests and needs

2. HOW DOES HISPANO CLUB^® USE YOUR INFORMATION?

 
We use Personal Information and Use Data as described in this Privacy Policy and as otherwise described to you at the point of collection.  Specifically, we may use Personal Information about you:

• to provide the products and services related to your Hispano Club’s membership (the “Services”) and to respond to your requests regarding the same, such as additional registration for family members, contracting for additional Services, subscribing as an Independent Associate, and providing customer support, among others;
• to process your transactions and ship your orders;
• to give you notices about your Membership subscription, including expiration and renewal notices and changes to any Services we offer or provide;
• to validate sales made by Hispano Club’s Independent Associates;
• to send you important information regarding our relationship with you or regarding the Site, changes to our terms, conditions, and policies and other administrative information;
• to enable you to participate in interactive features on our Sites;
• to respond to your inquiries and fulfill your requests, such as to send you information you request or e-mail alerts;
• for our business purposes, such as data analysis, audits, developing new products, enhancing our Sites, improving our products and services, identifying Site usage trends, personalizing your experience on the Sites, and determining the effectiveness of promotional campaigns;
• to carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection; or
• as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others and to comply with applicable law or legal process.

Personal Information and Use Data may also be used to support, calculate and track product and services discounts and to provide you with information on special promotions. Information about Hispano Club’s Independent Associates may also be used to support, calculate and track discounts, earnings and bonuses, to issue payment to you and report income to taxing authorities, to provide training, to maintain the proper functioning of the sales & marketing plan, and to ensure compliance with applicable law and company policies, plans and agreements, including the Independent Associate Application and Agreement.

Personal Information and Use Data may also be used to promote our products and services and the products and services of our third-party business partners.

We may use any information that does not personally identify you, your computer, or your device for any purpose.

3. WITH WHOM DOES HISPANO CLUB^® SHARE YOUR INFORMATION?

 
We disclose your Personal Information and Use Data as described below and as specifically described elsewhere in this Privacy Policy or at the point we collect information from you: to our subsidiaries and affiliates; to contractors, third-party service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them; to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Hispano Club LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Hispano Club LLC about our Sites’ users is among the assets transferred; to unaffiliated third parties, such as data brokers and advertising partners, some of whom may use it to offer promotions to you for other products and services that you may enjoy; and with your consent.

We may also disclose your Personal Information and Use Data to comply with any court order, law, or legal process, including to respond to any government or regulatory request; to enforce or apply our terms of use https://hispanoclub.com/legal/terms-of-use/  and other agreements, including for billing and collection purposes, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Hispano Club, our customers, or others.

If you are a Hispano Club Independent Associate and participate in our multilevel marketing sales model, we may share your Personal Information with other Hispano Club Independent Associates, including as part of a Lineage Report which contains information on other Independent Associates in a Hispano Club Independent Associate’s “downline” (The downline organization consists of all Independent Associates that were personally sponsored by a particular Independent Associate, and in turn, all other persons sponsored by the subsequent Independent Associates). Lineage Reports are provided to Independent Associates in strict confidence and for the sole purpose of supporting the Independent Associates in further developing their Hispano Club businesses.  If you are a Member, we may share your Personal Information with Independent Associates to provide you with products and services you have requested. Hispano Club Independent Associates who receive your Personal Information are bound by the terms of their Independent Associate Agreement and the privacy and data protection covenants contained therein and in this Privacy Policy.

We may disclose any information that does not personally identify you, your computer, or your device without restriction.

4. INTEREST-BASED ADVERTISING

 
As described above, we work with a variety of third party business partners, including advertisers, advertising networks, and advertising and analytics companies that use various technologies to collect data about your use of the Sites, which may include location data. Hispano Club and our third-party business partners may use the aforementioned technologies to:

1. track how you use the Sites, how you arrived at the Sites, and what you do after you leave the Sites;
2. record and link your devices, including your personal computer and mobile device (this is called cross-device linking); and
• provide you with advertisements relevant to your interests, taking into account your use of the Sites and the other websites and online services that you use. Note that these advertisements may be delivered to you on the Sites, on third party websites and applications, and on a computer or device other than the device from which the information was collected.

This is called “Interest-Based Advertising” or “Online Behavioral Advertising.” While we work with our third-party business partners to improve your experiences with the Sites, we do not control their business practices.

Section 1.d of this Privacy Policy also explains various methods of preventing passive collection and use of your information by our third-party business partners. To learn more about Interest Based Advertising and your options with respect to these practices, please review our Interest Based Advertising Policy and visit www.networkadvertising.org/choices, https://www.datalogix.com/privacy, http://www.aboutads.info/choices, and https://choice.microsoft.com/en-US/opt-out.

If you wish to opt-out of participating in Interest Based Advertising, you can use some or all of the following methods:

1. Visit http://www.aboutads.info/choices (for web-based advertising), and http://www.aboutads.info/appchoices (for mobile advertising);
2. For mobile advertising, use your phone operating system’s opt-out setting. For instructions on how to “Limit Ad Tracking” on iOS, please visit https://support.apple.com/en-us/HT202074. For instructions on how to opt out of interest-based ads on Android, please visit https://support.google.com/ads/answer/2662922?hl=en;
3. Enable the “Do Not Track” feature on your web browser. For instructions on how to do so, please visit allaboutdnt.com; and
4. In accordance with industry self-regulatory principles, you should see an active link in or around Hispano Club advertisements that are delivered on other sites using information collected on our Sites, and in or around third-party advertisements that are delivered on our Sites using Interest Based Advertising programs. Clicking on this link will provide information about the companies and data practices that were used to deliver the ad and will also describe how you may opt-out of these advertising programs.
5. If you use more than one device, you should renew your opt-out choices on each such device.

 

5. CHOICES

 
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. Section 1.d and Section 3 describe methods of preventing passive collection and use of information by Hispano Club and our third-party business partners.

Direct Marketing Communications from the Company. If you do not wish to have your email address or postal contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by logging into the Sites and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by contacting us at contacto@hispanoclub.com. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.  Please note that if you opt out of receiving direct marketing messages from us, this does not impact other transactional and administrative messages which you will continue to receive (such as emails relating to changes in our Services or in our Terms and Conditions or this Privacy Policy, billing and payment information, outstanding balance on your account, and other emails relating to your account and/or your use of the Sites).

Sharing Personal Information for Direct Marketing.  If you would prefer that we not share your Personal Information on a going-forward basis with our affiliates or third parties for their direct marketing purposes (such as direct communications by email, text message, and mailings directed to you), you may opt out of this sharing by logging into the Sites and adjusting your user preferences in your account profile or by contacting us at contacto@hispanoclub.com.  Please note that if you opt out as described herein, we will not be able to remove your Personal Information from the databases of affiliates or third parties with which we have already shared your information.

Unsubscribe.  The easiest way to stop the collection of Personal Information about you is to discontinue using the Sites, including by no longer using our websites or by deleting our applications, products, and services from your devices. To uninstall our applications from your devices, such as smartphone applications, tablet applications, connected TV applications, and desktop, you may use the standard uninstall processes as may be available as part of your device or via the application marketplace or network.

6. ACCESSING AND CORRECTING YOUR INFORMATION

 
You can review and change some of your Personal Information by logging into the Sites and visiting your account profile page or by calling our toll-free number: 855-544-7726. You may also delete any Personal Information that you have provided to us. For Members: We cannot delete your Personal Information except by also deleting your user account, which will result in the termination of your Hispano Club membership. In addition, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Sites, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Sites users. Proper access and use of information provided on the Sites, including User Contributions, is governed by our terms of use.

7. INDIVIDUALS UNDER THE AGE OF 18

 
Hispano Club’s Sites are not directed to children. To use or access the Sites, and to become a Member, Independent Associate or user of Hispano Club’s services, You must be older than 18 years of age; notwithstanding, some of our memberships may include Services rendered by Third-Party Service providers that may require information of individuals under the age of 18 to appropriately render their services. Hispano Club will only collect Personal Information of underage individuals which can only be provided by their parents or legal guardians during the registration process. The information shall be only utilized for the Services and may be freely deleted and/or amended by the Cardholder at Hispano Club’s Website pursuant to the process set forth in Section 5 of this Privacy Policy. Hispano Club will never have any sort of contact with the underage individual. If we learn we have collected or received Personal Information from someone provided by someone under 18 years of age, we will immediately delete that information.

8. NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS:

 
Under California Civil Code Section 1798.83, if an individual who is a California resident has provided personal information to the Service Provider a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if the Service Provider has within the immediately preceding calendar year disclosed such individual’s personal information to a third-party and knows or should have known that such third-party used the information for its own direct marketing purposes, then the Service Provider is obligated to disclose in writing to such individual upon request, what personal information was shared and with whom it was shared. The Service Provider may comply with this law by: (1) having either a published privacy policy of not sharing a customer’s personal information for third-parties’ direct marketing use unless the customer has first affirmatively opted in to such sharing, or a published privacy policy of not sharing a customer’s personal information for third-parties’ direct marketing use if the customer has opted out to prevent his/her personal information from being shared for direct marketing use; and (2) notifying the customer of his/her right to opt out and providing a cost-free means for the Customer to exercise that right.

Any request for a disclosure required under this law should be sent to us via email at contacto@hispanoclub.com. Please note that under this law, we are not required to respond to a Customer‘s request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email address designated above.

9. DATA SECURITY

 
We have implemented measures intended to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.

10. INTERNATIONAL TRANSFERS

 
The Website is headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Website may be collected in your country and subsequently transferred to another country in accordance with applicable law. Using the Sites demonstrates your consent to the processing of information as described in this Policy.

11. THIRD-PARTY LINKS

 
The Services provided by Hispano Club are integrated with various third-party services, applications and sites that may make available to the customer their Services. We provide this access through the use of hyperlinks that automatically redirects the customer from Hispano Club’s website to the third-party site. These Third-Party Services may have their own terms and policies, and your use of them will be governed by those terms and policies. Your security when using Third Party Services is your responsibility. You also agree that we may, at any time and in our sole discretion, and without any notice, suspend, disable access to or remove any Third-Party Services. We are not liable for any such suspension, disabling or removal, including without limitation for any loss of profits, revenue, data, goodwill or other intangible losses experiences as a result thereof.

Hispano Club^® utilizes Stripe and Netzen for payment transactions.  Information regarding Stripe’s policies and data security can be found at https://stripe.com/us/privacy. Information regarding Netzen’s polices and data security can be found at http://www.netzen.com.mx/img/privacidad.pdf.   By agreeing to this Privacy Policy, you are also agreeing to Stripe, Netzen, and any other third party provider’s policies for all payment transactions.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

12. CHANGES TO OUR PRIVACY POLICY

 
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you so that we may provide you, in writing, with any changes to this policy.

13. CONTACT INFORMATION

 
To ask questions or comment about this privacy policy and our privacy practices, contact us at:

E-mail: contacto@hispanoclub.com or via our toll-free number: 855-544-7726.