- How Personal Identifying Information is collected;
- How and when Personal Identifying Information is used;
- How Personal Identifying Information is protected; and
- How Personal Identifying Information is disposed.
A. “Business record” means letters, words, sounds, or numbers, or the equivalent of letters, words, sounds, or numbers, recorded in the operation of a business by: (i) handwriting; (ii) typewriting; (iii) printing; (iv) photograph; (v) mechanical or electronic recording; or (vi) any other form of data compilation.
B. “Personal Identifying Information” means an individual’s first name or initial and last name in combination with any one or more of the following items: (i) date of birth; (ii) social security number or other government-issued identification number; (iii) mother’s maiden name; (iv) unique electronic identification number, address, or routing code; (v) telecommunication access device, including debit and credit card information; or (vi) financial institution account number or any other financial information.
How Personal Identifying Information is collected
A. The Sinclair Group Website. If you are visiting the Sinclair Group website (www.sinclairgroup.com), Sinclair Group collects the following information: the full Uniform Resource Locator (“URL”) of the Web page from which you came to the website; your Internet Protocol (“IP”) address, which may include a domain name; the date and time for each page you view; the name of and information about any advertisement that brought you to the Sinclair Group website; searches you perform, links you click on; and computer and connection information such as browser type and version, operating system, and platform. Sinclair Group also transmits cookies to your computer so we can track the pages of our website that you view and the order in which you view them. Any other information that you might submit to the Sinclair Group website, including Personal Identifying Information, may be maintained by Sinclair Group.
B. Communications with Sinclair Group. If you communicate with Sinclair Group, we may store copies of such communiqués (including email or similar communications). This can result in the collection of Personal Identifying Information you may have disclosed in your communiqués.
How and when Personal Identifying Information is used
A. Personal Identifying Information voluntarily provided by or on behalf of Sinclair Group’s clients may be used by Sinclair Group as part of our credit application process. This would include both the establishment of credit with Sinclair Group, and, if necessary, for use by Sinclair Group and its legal representatives in enforcing and/or collecting delinquent accounts.
B. Personal Identifying Information may also be used by Sinclair Group as part of its providing goods and/or services to its customers and in respond to billing and/or other such questions related to such goods and services.
D. Sinclair Group may use IP addresses to diagnose problems with our servers and to administer our website. Your IP address also is used by Sinclair Group to gather broad demographic information, such as your general geographic location and Internet Service Provider. IP addresses are further used to help determine the number of Sinclair Group users. This demographic information may also be used by Sinclair Group to analyze aggregate Web usage behavior.
E. If you gave Sinclair Group your email address, we may use it to send you Sinclair Group newsletters, product updates, service-related information, and other offers and information from Sinclair Group. Sinclair Group also may contact you by email to respond to your submissions and customer service inquiries.
F. Sinclair Group may disclose any information we possess in response to subpoenas, court orders, or legal requirements, and such information might be used by the receiving party to determine your identity, your Web usage and online shopping behavior, or other things about you.
G. Sinclair Group may employ other companies and individuals to perform functions on our behalf, such as technical support services. To perform those functions, it may be necessary for them to obtain access to Sinclair Group databases and servers, which may contain Personal Identifying Information.
H. Sinclair Group may also employ attorneys, financial advisors, accountants and/or auditors who, in their performance of services on behalf of Sinclair Group might have access to Personal Identifying Information.
How Personal Identifying Information is protected
A. All Personal Identifying Information received in the normal course of business is treated as Sinclair Group’s other Proprietary Information.
B. Sinclair Group attempts to physically secure “hard copies” of our Business Records containing Personal Identifying Information.
C. Sinclair Group uses commercially reasonable computer security safeguards to protect our databases and servers against risks of loss, unauthorized access, destruction, misuse, modification, or inadvertent or improper disclosure of data. These risks, however, cannot be completely eliminated and Sinclair Group therefore cannot guarantee complete security.
If you send Sinclair Group an email, you should know that email is not necessarily secure against interception. So, if your communication includes Personal Identifying Information and you prefer not to contact us by postal mail or telephone rather than email.
How Personal Identifying Information is disposed
When Sinclair Group disposes of a Business Record that contains Personal Identifying Information, Sinclair Group will modify the Personal Identifying Information by shredding, erasing, or other means, to make it unreadable or undecipherable. Sinclair Group shall not be required to contract with a person engaged in the business of disposing of records for the modification of Personal Identifying Information.
Last update: 2 Aug 2012 Version 1.0