Privacy policies

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

Mitsubishi HC Capital America, Inc. and all of its subsidiaries and divisions (collectively “MHCCNA”, “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 MHCCNA.

In the course of our business operations, MHCCNA 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

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). MHCCNA collects personal information for legitimate business purposes and to comply with our legal obligations. The categories of information we collect and have collected in the last 12 months include:

• Identifiers — Personal unique identifiers, such as full name and federal or state issued identification numbers, including Social Security number, driver’s license number, and passport number;
• Personal Information — Personal information, including contact details such as telephone number and address, financial information (e.g., account number and balance), payment card details (e.g., credit and debit card numbers), and medical and health insurance information;
• Characteristics of Protected Classes — Characteristics of protected classes or groups under state or federal law, such as sex, disability, citizenship, primary language, immigration status, and marital status;
• Purchase Information — Purchase information, such as products and services obtained and transaction histories;
• Biometric Information — Biometric information, such as fingerprints and voiceprints;
• Internet or Online Information — Internet or online information (e.g., browsing history) and information regarding interaction with our websites, applications, or advertisements;
• Geolocation Data — Geolocation data, such as device location;
• Audio and Visual Information — Audio, electronic, visual, or similar information, such as call and video recordings;
• Employment Information — Professional or employment-related information, such as work history and prior employer, information from background checks, resumes, and personnel files;
• Education Information — Education information subject to the federal Family Educational Rights and Privacy Act, such as student records and confirmation of graduation;
• Inferences — Inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics; and
• 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.

Sources of personal information

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).
• From our partners.
• From publicly available sources.

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 MHCCNA’s code of conduct, information security policy and internal control procedures.

There may be circumstances under which MHCCNA 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.

We will keep personal information no longer than necessary to fulfill the purposes described in this Policy. Under our record retention policy, we are required to destroy personal information after we no longer need it according to specific retention periods. However, we may need to hold personal information beyond these retention periods due to regulatory requirements or in response to a regulatory audit, investigation, or other legal matter. These requirements also apply to our third-party service providers.

Use personal information

We may use 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 Site 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.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
• 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.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• 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.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

Sharing personal information

MHCCNA will not sell your personal information to others, nor do we share personal information for purposes of the California Consumer Privacy Act (“CCPA”). However we may disclose personal information to a trusted third party for a business purpose.

The types of entities with whom we disclose and have disclosed information in the last 12 months include the following:

• Service Providers. We disclose information with entities that process information on our behalf for our business purposes. Service providers assist us with services such as data analytics, marketing, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
• Affiliates. We disclose information with our related entities including our parent and sister companies.
• Merger, Acquisition or Asset Sale. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Security and Compelled Disclosure. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
• Facilitating Requests. We disclose information for purposes of facilitating your requests.
• Consent. We disclose information with notice to you and your consent.

Notwithstanding the above, we may disclose information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we disclose information about you, please see the “Your Rights and Choices” section below.

Further information about our site and emails

MHCCNA may use your personal information provided over the Site or emails 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 MHCCNA 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 MHCCNA’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.

Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of our Site may not function correctly.

We may incorporate tracking technologies into our Site and emails as well as into other websites and services. For example, we use analytics services, such as Google Analytics, to help us understand how users access and use the Service. You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/ and downloading the Google Analytics Opt-out Browser Add-on.

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link or emailing us at [email protected] with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your transactions, servicing, or our ongoing business relations.

Privacy of children

Our Site, products and services are not directed to individuals under the age of eighteen. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children under the age of eighteen and we do not knowingly sell or disclose personal information of children under the age of eighteen. Please let us know if a person under the age of eighteen has provided MHCCNA with personal information using the “Contact Us” information below.

Data security

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

International transfer

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Policy.

To see our policy on human rights, click here.

Modifications

Subject to the legal requirements of your jurisdiction of residence for notice and consent, MHCCNA 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.

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 [email protected] or at the following address:

Mitsubishi HC Capital America, Inc.
Data Privacy Office
800 Connecticut Ave 4N
Norwalk, CT 06854

Additional disclosures for California residents

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

California residents have the right to request that we disclose certain information to them about our collection and use of their personal information over the past 12 months (the "right to know"). Once we receive their request and confirm their identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. 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 the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise any of these rights, please submit a request to [email protected] or call our toll-free number at 888-283-8840. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You do not need to create an account with us to submit a request to know or delete. You may only submit a request to know twice within a 12-month period. In the request, please specify which right you are seeking to exercise and the scope of the request.

We will confirm receipt of your request within 10 days. If you do not receive confirmation within the 10-day timeframe, send a notice to [email protected]. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete. Please note that we may retain and use information in accordance with applicable law.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Shine the Light

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write to us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.