HITACHI CAPITAL AMERICA’S DATA PROTECTION & PRIVACY POLICY STATEMENT

Collectively, the terms below are referred to as the “Policy.”

Hitachi Capital America Corp. and all of its subsidiaries and divisions (collectively “HCA”, “us” or “we”) respect and value your privacy. This Policy discusses how we work to protect your data and earn the trust that you put in HCA.

In the course of our business operations, HCA collects and uses data that may include information regulated by sovereign, federal, state and local laws. Please read this Policy carefully because, by submitting personal information to us, you indicate your consent to our processing, storage and use of your information as described within the scope of this Policy.

Please see the “Contact Us” information at the end of this Policy for any questions or concerns.

COLLECTION OF PERSONAL INFORMATION
HCA collects personal information for legitimate business purposes and to comply with our legal obligations. Categories of information that we may collect include:

    • Identifiers (e.g., name, postal address, unique personal identifier, IP address, email, account name, Social Security number, driver’s license or passport number)
    • Personal Information (e.g., name, signature, address, telephone number, education, employment history, income, tax returns, bank account and credit card numbers)
    • Protected Information (e.g., age, citizenship, marital status, sex, veteran or military status)
    • Commercial Information (e.g., EIN, business records, insurance, property records, financial records including assets and liabilities)

Note that personal information may overlap categories and that the definition of categories may vary by regulatory body.

We obtain the categories of personal information listed above directly and indirectly from the following sources:

    • From our customers or their agents. For example, information provided in an application for financing or from customers in the course of providing services to them.
    • From applications for employment.
    • From a visit to or activity on our Site (see the FURTHER INFORMATION ABOUT OUR SITE section below).

PROTECTION OF PERSONAL INFORMATION
We recognize that your personal information is confidential and valuable, and we take steps to protect that information to reduce the risk of loss, unauthorized access, misuse or alteration. All personal, private and confidential data is protected in compliance with HCA’s code of conduct, information security policy and internal control procedures.

There may be circumstances under which HCA may be legally compelled to disclose your personal information. In such cases, we will make good faith efforts to provide only that information which is the subject of the official order or request.

Your personal information will be retained for as long as necessary to fulfill HCA’s legitimate business purposes, unless a longer retention period is required by applicable law.

USE AND SHARING PERSONAL INFORMATION
We may use or share the personal information we collect for one or more of the following business purposes:

    • To fulfill or meet the reason for which the information is provided. For example, we use information that you provide to us on an application for a loan or for employment to make a decision on that request.
    • To provide you with information, products or services, such as email bulletins and other notices that may be of interest to you.
    • To improve our website and for testing, research, analysis and product development.
    • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
    • As necessary or appropriate to protect the rights, property or safety of us or others.
    • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

HCA will not sell, rent, or lease your personal information to others, however we may disclose personal information to a trusted third party for a business purpose. When we do so, we enter into a contract that describes the business purpose, requires the recipient to maintain confidentiality and prohibits use of the information outside the terms of the contract.

In the past 12 months, no personal data has been sold by HCA. In the past 12 months, the following categories of personal information have been disclosed to third parties for a business purpose: Identifiers, Personal Information, Protected Information and Commercial Information.

FURTHER INFORMATION ABOUT OUR SITE
HCA may use your personal information provided over the Site to better understand your needs and provide you with better service. Specifically, we may use your personal information to update you on the benefits and features of HCA products and services and to provide you with information and material requested by you.

We may also collect details of your visits to our Site for system administration and to report aggregate information, such as Site traffic data, location data, logs and other communication data, information about your computer (such as IP address, operating system, browser type). This statistical data is not intended to identify any specific individual. By accessing our Site, you explicitly consent to the collection of details of your visits for the purpose described above.

Our Site uses cookies. “Cookies” are text files containing small amounts of information that help us improve the functionality and performance of our Site. You may refuse to accept cookies by activating the appropriate setting in your browser’s software. By accessing our Site, you consent to HCA’s reasonable use of cookies for the purposes described above.

Please remember that transmission of information via the Internet is not completely secure. Although we work very hard to protect your personal information, we cannot guarantee the security of your personal information transmitted over our Site.

YOUR CHOICES
HCA respects your right to make your own choices about how your personal information is handled. Should you choose to subscribe to mailing lists or any registrations, you can later decide to opt out by clicking “unsubscribe” in any marketing email communications we send you, or use the “Contact Us” information at the end of this document.

The California Consumer Privacy Act (CCPA) provides California residents with specific rights regarding their personal information. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. The CCPA also provides the right to request that we delete any of your personal information, subject to certain exceptions. Please see the “Contact Us” information at the end of this document to make a request. Once we receive and confirm your verifiable consumer request, it will be handled in the timeframe and manner as required by the CCPA.

PRIVACY OF CHILDREN
Our Site, products and services are not directed to individuals under the age of eighteen. Please let us know if a person under the age of eighteen has provided HCA with personal information using the “Contact Us” information below.

MODIFICATIONS
Subject to the legal requirements of your jurisdiction of residence for notice and consent, HCA reserves the right to modify or amend this Policy at any time to reflect applicable laws or regulations, or changes to our practices or procedures. Where conflicts exist between the terms and conditions of this Policy and applicable data protection laws or regulations, the latter will take precedence. This Policy is not intended to, and does not, provide rights beyond those that are prescribed by any applicable laws.

We review this Policy regularly to reflect changes introduced by applicable legislation. If you continue using our Site after such revisions are in effect, you accept and agree to the revisions and to abide by them. This Policy was last updated on December 31, 2019.

CONTACT US
We welcome your inquiries or comments about this Policy and any queries or concerns that you may have about the Site. Please contact us at privacy@hitachicapitalamerica.com or at the following address:

Hitachi Capital America Corp.
Data Privacy Office
800 Connecticut Ave 4N
Norwalk, CT 06854