MINOL USA PRIVACY POLICY

Here at Minol USA (“Minol”), we take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect and use certain personal information about you. When we do so we may be subject to various laws in the United States.

1.      Key Terms. It would be helpful to start by explaining some key terms used in this policy:

 

Account

The unique account created for you to access the resident utility services provided by Minol on behalf of your landlord, property owner, homeowner’s or condominium association, city, municipality, or utility department.

Account Holder

You, the holder of the Account.

Personal Information

Information that is linked or reasonably linkable to an identified or identifiable individual.

Resident Utility Services

Services contracted between Minol and Your landlord, property owner, homeowner’s or condominium association, city, municipality, or utility department to provide You with the billing and payment collection of utility and other ancillary services for your apartment dwelling, condominium, townhome, single-family home, manufactured home, or any other dwelling type rented or owned by You.

You or your

You, or any representative or agent on your behalf

We, us, our

Minol, Inc. d/b/a Minol USA

 

2.       Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

 

Categories of Personal Information

Specific Types of Personal Information Collected

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)

·    Account Holder’s Name

·    Address of Account Holder

·    Email address of Account Holder

·    Internet Protocol address of Account Holder

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

·    Contact Information of Account Holder (i.e., home phone number, wireless mobile number, work phone number)

·    Date of Birth of Account Holder

·    Social Security Number (truncated) – Last 4 digits only of Account Holder

·    ACH Banking, Debit and/or Credit Card Number(s)

 

 

This personal information is required to provide the Resident Utility Services to you. If you do not provide the personal information we ask for, or request deletion of, it may delay or prevent us from providing the Resident Utility Services to you and may cause a breach of your lease, homeowner’s agreement, or utility agreement with your landlord, property owner, homeowner’s or condominium association, city, municipality, or utility department.

3.      How Your Personal Information is Collected. We collect most of this personal information either directly from you (i.e., in person, by telephone, text, email, and/or via our website) or from your landlord, property owner, homeowner’s or condominium association, city, municipality, or utility department as part of our Resident Utility Services. However, we may also collect information:

·          From publicly accessible sources (e.g., property records);

·          Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);

·          From a third party with your consent (e.g., your bank);

·          From cookies on our website; and

·          Via our IT systems, including:

o   Automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems; and

o   Any other relevant servers or systems.

4.      How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, e.g.,:

·          To comply with our contractual, legal, and regulatory obligations;

·          For the performance of our agreement with your landlord, property owner, homeowner’s or condominium association, city, municipality, or utility department as part of our Resident Utility Services as required by the terms of our agreement;

·          For our legitimate interests or those of a third party; or

·          Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

 

What we use your personal information for

Our reasons

To provide Resident Utility Services to you

For the performance of our agreement with your landlord, property owner, homeowner’s or condominium association, city, municipality, or utility department as part of our Resident Utility Services as required by the terms of our agreement.

Conducting checks to identify our customers and verify their identity, and other processing necessary to comply with professional, legal and regulatory obligations that apply to our business

For purposes of complying with our legal and regulatory obligations.

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures related to our provision of Resident Utility Services

For our legitimate interests to be as efficient as we can so we can deliver the best service for you.

Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal and/or malicious activity that could be damaging for us and for you; and

To comply with our legal and regulatory obligations.

Updating and/or enhancing customer records and services

For the performance of our agreement with your landlord, property owner, homeowner’s or condominium association, city, municipality, or utility department as part of our Resident Utility Services;

To comply with our legal and regulatory obligations; and

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing account matters and new services.

Statutory requests, reporting and/or responses

To comply with our legal and regulatory obligations.

Credit reference checks via external credit reference and/or collection agencies

For the performance of our agreement with your landlord, property owner, homeowner’s or condominium association, city, municipality, or utility department as part of our Resident Utility Services;

To comply with our legal and regulatory obligations; and

For our legitimate interests or those of a third party, i.e. to ensure proper reporting of consumer credit data.

 

The above table does not apply to special category personal information, which we will only process with your explicit consent.

5.      Promotional Communications. We may use your personal information to send you updates (by email, text message, or telephone) about our services, including exclusive offers, promotions, and/or new services. For purposes of this Section 5, “promotional communications” shall not include communication(s) by us for purposes of performing our obligations under the agreement with your landlord, property owner, homeowner’s or condominium association, city, municipality, or utility department.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell OR share it with unauthorized organizations for marketing purposes. For purposes of this policy, the term “unauthorized organization” shall not include your landlord, property owner, homeowner’s or condominium association, city, municipality, utility department, or third-party service provider contracted with Minol to perform our Resident Utility Services.

You have the right to opt out of receiving promotional communications at any time by:

·          Contacting us at compliance@minolusa.com ; or

·          Using the “unsubscribe” link in emails.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

6.      Who We Share Your Personal Information With. We routinely share personal information with:

·          Our subsidiaries and/or affiliates, including companies within the Minol group;

·          Third-party service providers we use to help deliver our Resident Utility Services to you, such as payment service providers, print and mail vendors, and third-party IT-related outsourcing companies, among others whom are subject to the same data protection standards as Minol;

·          Other third parties we use to help us run our business, such as marketing agencies or website hosts, whom are subject to the same data protection standards as Minol;

·          Credit reporting agencies;

·          Our financial institutions; and

·          Any law enforcement agencies, regulatory agencies, or courts of law as required by law.

 

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to the use of your personal information to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7.      Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we may have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, with the specific personal information as listed under the column labeled “Specific Types of Personal Information Collected” within the table provided in Section 2 of this privacy policy:

·          Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers); and

·          Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Please note that we do not sell your personal information to third parties.

8.      Where Your Personal Information is Held. Information may be held at our offices and those of our subsidiaries, affiliates, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

9.      How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing Resident Utility Services to you. Thereafter, we will keep your personal information for as long as is necessary:

·          To respond to any questions, complaints or claims made by you or on your behalf;

·          To show that we treated you fairly; or

·          To keep records required by law.

We will not retain your personal information for longer than necessary other than for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

10.  Website Traffic Data and Cookies. We automatically track and collect the following information when you visit our websites: (i) IP address, (ii) domain server, (iii) type of computer, and (iv) type of web browser (collectively "Traffic Data"). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on our websites. In addition, similar to many companies, we use "Cookie(s)" technology on our websites. Cookies are small text files a website can use to recognize repeat users, facilitate the user's ongoing access to and use of the websites and allow a website to track usage behavior and compile aggregate data that will allow content improvements. Cookies are not programs that come onto a user's system and damage files. Cookies do not obtain any personal information about you, provide us with any way to contact you, or extract any information from your computer. Cookies allow us to customize content specific to your interests to ensure that you do not see the same advertisement repeatedly and to store your password so you do not have to re-enter it each time you visit our websites .

11.  Your Rights Under the CCPA and CPRA (California Residents Only). You have the right under the California Consumer Privacy Act of 2018 (CCPA), California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

 

Disclosure of Personal Information We Collect About You

You have the right to know:

·          The categories of personal information we have collected about you;

·          The categories of sources from which the personal information is collected;

·          Our business or commercial purpose for collecting or selling personal information;

·          The categories of third parties with whom we share personal information, if any; and

·          The specific pieces of personal information we have collected about you.

Please note that we are not required to:

·          Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

·          Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

·          Provide the personal information to you more than twice in a 12-month period.

Personal Information Used for a Business Purpose

In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know:

·          The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California CCPA, CRPA, and certain other privacy and data protection laws, as applicable, to opt-out of the disclosure, correct, request deletion of, limit the use, or obtain a copy of your personal information. Deletion of your personal information may be limited or not available if your personal information is required to complete the transaction for which the personal information was collected, among other reasons as identified under Cal. Civ. Code §1798.105(d). If you exercise your right to opt-out of the disclosure of your personal information, and such request is permissible, we will refrain from disclosing your personal information, unless you subsequently provide express authorization for the disclosure of your personal information or the disclosure is necessary to perform our contracted services. To opt-out of the disclosure of your personal information, please contact us in writing using our contact information listed below.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

·          Delete your personal information from our records; and

·          Direct any service providers to delete your personal information from their records.

·          Please note that we may not delete your personal information if it is necessary to:

Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

·          Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

·          Debug to identify and repair errors that impair existing intended functionality;

·          Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

·          Comply with the California Electronic Communications Privacy Act;

·          Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

·          Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

·          Comply with an existing legal obligation; or

·          Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA and CPRA. This means we cannot, among other things:

·          Deny goods or services to you;

·          Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

·          Provide a different level or quality of goods or services to you; or

·          Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

 

12.  Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems and have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

13.   How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

·          Call us, toll-free, at (888) 766-1253, ext. 422; or

·          Email or write to us using the Contact Information listed below.

Please note that you may only make a CCPA-related or CPRA-related data access or data portability disclosure request twice within a 12-month period.

Upon contacting us, you will need to provide us with:

·          Enough information to identify you (e.g., your full name, address and Account number);

·          Proof of your identity and address (e.g., verification of personal information we have on file); and

·          A description of what right you wish to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

We will use commercially reasonable efforts to honor your request. Please note that if you request deletion of your information, we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives due to our contractual, legal and regulatory obligations.

14.  Privacy Protection for Children Using the Internet. Our websites contain utility-related information that may be of educational interest to children. We do not seek to gather personal information online from or about children under the age of 13. We encourage all children and young teens to always seek consent from their parents before providing any information about themselves or their household to anyone or any website on the Internet. If a child under 13 submits information to us and we learn that the information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any information from a child under 13, please contact us at compliance@minolusa.com.

15.  Changes to This Privacy Notice. This privacy notice was published on May 06, 2016 and last updated on August 24, 2022.

We may change this privacy notice from time to time without notice to you. Please check back frequently for any changes or amendments to this Privacy Policy. Your continued access or use of our websites or any of our services after any such changes to this Privacy Policy constitutes your acceptance of the Privacy Policy as revised.


 

16.  How to Contact Us. Please contact us by mail, email, or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Minol USA

Attn: Legal Dept.

15280 Addison Road, Suite 100

Addison, Texas 75001

Tel: (888) 766-1253, ext. 422

Email: compliance@minolusa.com

 


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