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PIC-CLUB uses the
latest technology to provide you with a fast, secure way of transferring
funds to and from our merchants and other PIC-CLUB members. The
security and integrity of your personal information is our top priority,
and in order to protect it, we employ all available measures.
Military-grade encryption
is used for the transmittal of all sensitive information, and the
information is stored in a highly secured data center. Highly redundant
systems and regular backups are used to ensure that your transaction
history remains safe.
At PIC-CLUB we
help protect your information by keeping all of your personal information
in a secure environment. When you make a transfer to or from any of our
merchants, your personal financial information is not shared and your
payment method is not disclosed. By using PIC-CLUB, you reduce the
possibility of your personal information being exposed over the Internet.
In order to
protect your PIC-CLUB account, please keep the following
guidelines in mind:
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Never share your PIC-CLUB
Password or Secure ID with anyone. You will never be asked to disclose your password or
Secure ID by a PIC-CLUB representative or anyone affiliated with
PIC-CLUB.
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Create a secure
password by ensuring that it is not easy to guess. The best passwords are at least 8 characters in
length, and combine letters, numbers and symbols. Combining a simple
phrase with a couple of significant numbers or symbols is an easy way to
create an easy to remember and secure password.
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Do not use the same
password at
PIC-CLUB
that you use for other online services.
Using the same password at multiple sites will increase the chances of
someone being able to access your account.
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Remember to
periodically update your password.
By changing your password on a regular basis, you reduce the chance of
it being compromised. Also, if you ever suspect that someone might have
discovered your password, be sure to reset it as soon as possible.
PIC-Club
Privacy Policy
PIC-Club.com
("PIC-Club" or "we") is committed to maintaining your privacy, and
the accuracy and security of your personal information pursuant to
applicable legislation. This Privacy Policy ("Policy") summarizes the
principles and guidelines we follow in collecting, using and disclosing
personal information about you and other individuals ("you") and in
responding to requests for information in our custody or control.
Please note that we
reserve the right to modify or amend this Policy at any time and for any
reason. Please check the PIC-Club website, currently at
www.picclub.com at any time for the most current
version of our Policy. The current effective date of this Policy is March
1, 2007.
Other than
as required or permitted by law, we will not change the purposes for which
we collect, use or disclose your personal information without (a) giving
you notice and (b) obtaining your consent to do so. We will give you such
notice by posting any modification, change or amendment on our website or
otherwise corresponding with you.
In this
Policy, "personal information" or "personally identifiable information"
means information or data about an individual who is or can be identified
by the information or data, or who can be identified by our using that
information or data in connection with other information or data that we
may obtain about the same individual.
We collect,
use and disclose personal information in order to provide the services we
offer, to operate our business and to comply with applicable law. It is
our policy to do so lawfully and fairly and for reasonable purposes.
Unless otherwise required by applicable law, PIC-Club will
collect, use and disclose your personal information only in accordance
with this Policy. If you register with us as a Member (as defined in our
Terms of Use), we will be entitled to use and disclose your personal
information for purposes reasonably related to our contract with you and
the services we provide to you or on your behalf or at your request or as
set out in this Policy.
Unless
otherwise required or permitted by applicable law, we will first notify
you of the purposes for which we collect, use or disclose personal
information about you.
It is our
policy to require consent from you before collecting, using or disclosing
your personal information Consent may be given orally, electronically (for
example, by clicking a button) or in writing. There may be situations in
which your consent may be implied or inferred from the circumstances,
taking into account reasonable expectations of individuals and the
sensitivity of the personal information in question.
If you
register with us as a Member, we will advise you of this Policy. If you
object to any of your personal information being collected, used or
disclosed as described in this Policy or as otherwise required or
permitted by law, you should not register with us as a Member.
It is our
policy to obtain only as much personal information as is required for the
purposes identified or as otherwise required or permitted by law.
Once you
have provided personal information to us, your continuing to do so and to
deal with us with knowledge of this Policy will be considered by us to
confirm your ongoing consent to our collection, use and disclosure of your
personal information in accordance with this Policy unless and until you
advise us otherwise.
Third party
web sites are governed by their own privacy statements and not by this
Policy. Third party sites may also be subject to the laws of different
countries where requirements and obligations to you are different.
PIC-Club has no control over and is not responsible for the
privacy practices or the content of third party web sites, third party
referrals or web site links.
Specifically, PIC-Club is not responsible for the operations of
our registered Merchants (as defined in the Terms of Use), including but
not limited to their information practices. Members submitting information
to or through third-party websites should review the privacy statement of
such sites before providing the operators of those sites with personal
information.
To open and
maintain an Account (as defined in our Terms of Use), we require that you
provide us with the following information (please see the purposes for
doing so as set out in Section G, "Our Use and Disclosure of Personal
Information" below):
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your name, address and telephone number;
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your birth date and gender;
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your e-mail address;
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certain government issued identification.
To register your bank account with us
so you may transfer funds to and from your bank account, we require that
you provide us with information about your bank account. To be eligible
for certain services and so that we may verify and validate your
identification, we may require that you provide us with additional
identification, which could include, without limitation, copies of credit
cards, government issued photo identification, utility or phone bills,
credit card or bank statements, and we may also contact you by phone or
email to confirm the contact information provided. We also require that
each Member choose a security question to answer (such as your city of
birth or your pet's name). This information is necessary for us to process
transactions, issue a new password if you forget or lose your password,
protect you, PIC-Club and our other Members and Merchants against
identity theft, credit card fraud and bank account fraud, and to contact
you should the need arise in administering your Account. Depending on the
circumstances, we may request further personal information from you at
which time we will notify you of our purposes for doing so and obtain your
consent.
We may collect the
Internet address (IP address) of the computer or device you use to access
your PIC-Club Account, as well as information about the computer
or device you use, such as the CPU identifier or hard disk identifier, in
order to analyze trends, administer the site, improve site performance,
gather broad demographic or user profile information for aggregate use,
and to help detect or prevent fraud, illegal activity or unauthorized
transactions.
In order to
verify with third party verification service providers the personal
information provided by you, we disclose your personal information to
those providers. In the course of such verification, we may also receive
personal information about you from such service providers. For example,
if you register a credit card or bank account with PIC-Club, we
will use card authorization and fraud screening services to verify that
your card information and address matches the information that you
supplied to PIC-Club, and that the card has not been reported as
lost or stolen.
In order to
detect or prevent fraud, illegal activity or in order to assist us in
investigating suspected violations of our Terms of Use, we may collect and
disclose personal information from and to third parties. We may conduct a
credit check or obtain a consumer report on you from a credit bureau or
consumer reporting agency for identification verification and collection
purposes.
PIC-Club, at its sole discretion, reserves the right to suspend or
terminate an Account or decline a transaction based on information
obtained from third parties.
Because of
the way that World Wide Web communication standards work, when you arrive
at or leave the PIC-Club website, our servers automatically
receive the Web address of the site that you came from or are going to. We
also collect information on which pages of our Web site you visit while
you are on the PIC-Club site, the type of browser you use and the
times you access our Web site. We use this information only to try to
understand our Members' preferences and user profiles better and to manage
the load on our servers, so as to improve our service and your experience
with PIC-Club. We may use the services of a third party to collect
and analyze click stream or other user data. In such cases, we may then
tie the data from such third party to your personal information stored by
us internally.
"Cookies"
are small files of data that reside on your computer and allow us to
recognize you as a PIC-Club customer if you return to the PIC-Club site using the same computer and browser. We send a
"session cookie" to your computer if and when you log in to your Account
by entering your e-mail address and password. These cookies allow us to
recognize you if you visit multiple pages in our site during the same
session, so that you don't need to re-enter your password multiple times.
Once you log out or close your browser, these session cookies expire and
no longer have any effect.
Most
browsers allow you to turn off cookies. If you want to know how to do this
please look at the help menu on your browser. However, switching off
cookies will severely restrict your ability to use the PIC-Club
site.
If you send
us correspondence, including e-mails and faxes, we retain such information
in the records of your Account. We will also retain customer service
correspondence and other correspondence from PIC-Club to you. We
retain these records in order to measure and improve our customer service,
and to investigate potential fraud and violations of our Terms of Use. We
may, over time, delete these records if permitted by law and will destroy
or render them anonymous once there is no legal or business purpose for
retaining them.
In addition,
your phone calls to and from us will be monitored and/or recorded for
quality assurance, training and security protection purposes.
From time to
time, we offer optional questionnaires and surveys to our Members for such
purposes as collecting demographic information or assessing Members'
interests and needs. The use of the information collected will be
explained in detail in the survey itself. If we collect personal
information from our Members in these questionnaires and surveys, the
Members will be given notice of how the information will be used prior to
their participation in the survey or questionnaire.
We will
consider that your consent for us to use your personal information in a
particular manner will be and remain in effect on an ongoing basis unless
you revoke your consent. We may use your personal information without
confirming your continuing consent for purposes including:
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To verify and validate your identity and
financial information;
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To process your transactions, including using
your bank account information to access your bank account to obtain
payments owing to us;
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To analyze your personal information to assist us
in developing and enhancing our services and our website and to conduct
market analysis and strategic planning;
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To use your personal information for the purpose
for which it was provided and certain other activities that are
reasonably ancillary to that purpose. For example, if you send us an
e-mail with a question or comment, we will use your e-mail address to
respond to you. Further, we may store your e-mail and e-mail address and
a copy of our response for future reference;
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To conduct quality assurance testing and to
facilitate training of our employees;
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6. To provide you with ongoing information about
the products and services of USPPINC/PIC-Club, its parent and affiliated
companies and any updates, new offers, changes, enhancements, new
features and similar information.
USPPINC/PIC-Club
will not sell or rent any of your personal information to third parties.
USPPINC/PIC-Club
will not share any of your personal information with third parties except
in the limited circumstances described below, or as required or permitted
by applicable law, or with your express permission. These third parties,
where possible, are limited by law or by contract from using personally
identifiable information for secondary purposes beyond the purposes for
which the information is shared.
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We may share personal information with organizations that help us
process the transactions you request, such as payment processing
companies or credit card processing companies, or organizations that
verify and validate your identification and financial information, or
that help protect our Members' transactions from fraud, such as sharing
your credit card number with a service that screens for lost and stolen
card numbers. We may also share personal information with organizations
that provide support for our internal operations, including, without
limitation, contact center support service providers and server and
database service providers, so that we may fulfill our obligations to
you. Additionally, if you go into a negative balance and owe us money,
we may share information with processing companies including collection
agencies and consumer reporting agencies and credit bureaus for the
purposes of collection of debts owed and general credit reporting
purposes.
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In order to detect or prevent fraud, illegal activity or in order to
assist us in investigating possible instances of fraud, illegal activity
or suspected violations of our Terms of Use, we may disclose personal
information to third parties where we believe it is reasonable to do so.
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We disclose personal information to government agencies, court or law
enforcement personnel in response to applicable legislation or
regulations, or to any subpoena, warrant, court order, levy, attachment,
order of a court-appointed receiver or other comparable legal process,
including subpoenas from private parties in a civil action. We reserve
the right to cooperate with legal authorities having actual or potential
jurisdiction over us.
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We may disclose personal information to your agent or legal
representative (such as the holder of a power of attorney that you
grant, or a guardian appointed for you).
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For identity validation and verification purposes, the following
information is provided to Merchants with whom you transact: name,
Account number, jurisdiction, postal code, e-mail address, and/or IP
address.
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We may disclose personal information to third party service providers
who manage various marketing programs or promotional initiatives on our
behalf or who provide us with demographic information.
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As with any other business, it is possible that USPPINC/PIC-Club in the
future could amalgamate or merge with or be acquired by another company.
If such an acquisition occurs, the successor company would have access
to personal information maintained by USPPINC/PIC-Club, including
customer account information, but would continue to be bound by this
Policy unless and until it is amended as described in this Policy.
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We share your personal information with our
parent and affiliated companies to help coordinate the products and
services provided to you and to enforce our Terms of Use.
We communicate with users
on a regular basis via e-mail to provide and assist in requested services,
and we also communicate by phone to resolve customer complaints or
investigate suspicious transactions. We use your e-mail address to confirm
your opening of a USPPINC/PIC-Club Account, to send you notice of payments
that you send or receive through USPPINC/PIC-Club, to send information
about important changes to our products and services, and to send notices
and other disclosures required by law. Generally, Members cannot opt out
of these communications, but they will be primarily informational in
nature rather than promotional.
We may also
use personal information to send you other types of communications that
you can control, including marketing communications, surveys,
questionnaires, and promotions for products or services of
USPPINC/PIC-Club, its parent or affiliated companies or their carefully
selected business partners, that may be of interest to you. By agreeing to
the USPPINC/PIC-Club Terms of Use you will also be indicating your consent
to receiving such communications. However, you can choose whether to
receive all or none of these communications from us. An explanation of how
to do this will be contained within each promotional e-mail that you
receive. You can select not to receive these types of communications by
accessing your Account on the USPPINC/PIC-Club website, choosing the
"Options" tab, selecting "mailing list" and selecting the "no" option.
USPPINC/PIC-Club is committed to handling your personal information with
high standards of information security. We restrict access to your
personally identifiable information to employees who need to know that
information in order to provide products or services to you. We maintain
physical, electronic and procedural safeguards to guard your nonpublic
personal information.
We protect
your information from error, loss, and unauthorized access. Our employees
who have access to your information are made aware of how to keep it
confidential. Each employee must sign an agreement stating that
maintaining confidentiality is a condition of employment with
USPPINC/PIC-Club. All of your personal information is collected, used, and
disclosed for business purposes only.
The security
of your USPPINC/PIC-Club account also relies on your protection of your
USPPINC/PIC-Club security identification. You may not share your password
or Account with anyone. USPPINC/PIC-Club will never ask you to send your
password to us in an e-mail, though we may ask you to enter this and other
personal information on the USPPINC/PIC-Club website, which will always
have a URL beginning with https://www.picclub.com/.
Any e-mail
or other communication asking you to provide personal information via
email, or linking to a website with a URL that does not begin with
https://www.picclub.com/PIC-Club.com/ should be treated as unauthorized and
suspicious and should be reported to USPPINC/PIC-Club immediately. If you
do share your password or Account with a third party for any reason,
including because the third party has promised to provide you additional
services such as account aggregation, the third party will have access to
your Account and your personal information, and you will be responsible
for actions taken using your password or Account. If you believe someone
else has obtained access to your security identification or password,
please change it immediately by logging in to your account at
www.picclub.com and changing your Options
settings, and also contact us right away as described in Section I below.
We retain
your personal information for as long as required to provide services to
you. Following the end of any relationship we may have with you, your
personal information will be retained for as long as is necessary for
reasonable business or legal purposes, following which it will be securely
destroyed or rendered anonymous. If we or you terminate your Account, we
will mark your Account in our database as "Closed," but will keep your
Account information in our database. This is necessary in order to
investigate potential fraud, for instance by ensuring that persons who try
to commit fraud will not be able to avoid detection simply by closing
their Account and opening a new Account. However, if your Account is
terminated, your personally identifiable information will not be used or
disclosed by us for any further purposes, nor sold or shared with third
parties, except as necessary to detect or prevent fraud and assist law
enforcement, or as required by law.
You can
review the personal information you provided us and make any desired
changes to such information, or to the settings for your Account, at any
time by logging in to your Account on the USPPINC/PIC-Club web site and
changing your preferences in the Options page of your Account.
You may
refuse to provide personal information to us. You may also withdraw your
consent at any time, subject to applicable legal or regulatory
restrictions, and reasonable notice. We do require that withdrawal of
consent be in writing. However, if you refuse to provide personal
information or withdraw your consent to our using or disclosing your
personal information, this may severely limit our ability to provide our
services to you as we may be unable to process your transactions. If you
do withdraw your consent, it is our policy to advise you of the
consequences of doing so.
You may
contact us at any time to pursue your rights to access personal
information about you in our custody or control. All such requests must be
in writing. To make a request, simply contact us as set out below in
Section L. Upon request and subject to applicable law, we will respond in
writing with, as applicable in the circumstances, the following
information:
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Whether we have personal information about you;
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If so, details of what information we have, the
purposes for which it is being processed or used and disclosed, and the
recipients or classes of recipients to which such information is or may
be disclosed; and
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Any information available to us with respect to
the source of information where we are able to determine that and where
we are legally able to disclose such information to you.
It
is our policy to respond to such requests within 30 days wherever
possible. We reserve the right to charge any fee permissible by law to
provide a response to your request. We will also require that you provide
sufficient information to allow us to locate your information to deal with
your request. In some circumstances, we may be able to extend the period
of time within which we respond and, if we do so, we will advise you of
that.
An individuals ability to access his or her personal information is not
absolute. The law imposes restrictions on our ability to provide you with
access. For example, where responding to a request requires providing
personal information about another individual, we generally cannot do so
without that individuals consent, which may not be granted. However, we
will provide as much information as we can without breaching any other
legal requirements or the privacy rights of other individuals. There are
also situations, such as the prevention, detection or investigation of
crime or breaches of the law, in which our ability to provide information
may be restricted. We reserve all our rights under applicable law.
You may
contact us if you have any questions or concerns about this Policy, our
personal information practices, or the accuracy or completeness of any
personal information concerning you in our files, or to update any of your
personal information. You can contact us via e-mail at
support@picclub.com, or call
Costa Rica 506-263-2902 Monday through Friday between the hours of 10am
and 7pm EST.
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