© 2024 HMD Financial
California Consumer Privacy Act Notice
This California Consumer Privacy Act Notice (“Notice”) is provided by the members of the HMD Group of Companies described below. These companies are referred to in this Notice as “we” or “us.”
This Notice explains how we collect, use, and disclose personal information about California residents. The Notice also explains certain rights that California residents have under the California Consumer Privacy Act (“CCPA”). For example, this Notice explains how California residents can exercise their rights under the CCPA to request that we: (1) provide certain personal information that we have collected about them during the past 12 months, along with related information described below, or (2) delete certain personal information that we have collected from them. The CCPA only applies to information about residents of California.
Under the CCPA, “personal information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household. This information is referred to in this Notice as “Personal Data.”
1. Categories of Personal Data that We Collect
We collect Personal Data in a variety of contexts. For example, we collect Personal Data to provide commercial financial products and services, for our employment and human resource purposes, and for our relationships with independent contractors.
The Personal Data that we collect about a specific California resident will depend on, for example, our relationship or interaction with that individual.
During the past 12 months, we have collected the following categories of Personal Data.
- Personal Identifiers – Personal unique identifiers, such as full name and federal or state issued identification numbers including Social Security number and driver’s license number
- Personal Information – Personal information, including contact details such as name, phone number, postal address, and e‑mail address
- Characteristics of Protected Classes – Characteristics of protected classes or groups under state or federal law, such as sex or marital status
- Purchase Information – Purchase information, such as products and services obtained and transaction histories
- Internet or Online Information – Internet or online information such as 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, thermal, olfactory, or similar information, such as call and video recordings
- Employment Information – Professional or employment‑related information, such as work history and prior employer
- Education Information – Education information, such as school and related information; and
2. Why We Collect Personal Data and How We Use It
The reasons we may collect and use Personal Data depend on, among other things, our relationship or interaction with a specific California resident. The table below lists the purposes for which we may collect and use Personal Data in different contexts.
Purposes for Collection and Use
Examples
Provide and manage products and services
- Establish and process transactions for our products and services
- Support the ongoing management and maintenance of our products and services
- Perform accounting, monitoring, and reporting
- Enable information security and anti‑fraud operations, as well as credit, underwriting, and due diligence
- Support audit and investigations, legal requests and demands, as well as exercise and defend legal claims
- Enable the use of service providers for business purposes
- Comply with policies, procedures, and contractual obligations
- Market, personalize, develop, as well as improve our products and services
- Conduct research and analysis
- Support customer relationship management
- Evaluate and engage in mergers, acquisitions, and other transactions involving transfers of all or part of a business, or a set of assets
- Provide benefits to employees and dependents, including healthcare and retirement plans
- Manage pay and compensation activities
- Manage and operate our facilities and infrastructure
- Process employment applications
- Process independent contractor agreements
3. Sources of Personal Data
The sources from which we collect Personal Data depend on, among other things, our relationship or interaction with a specific California resident. The information below lists the categories of sources from which we collect Personal Data in different contexts.
- From California residents directly, or other individuals acting on their behalf, through physical (e.g., paper application), audible (e.g., phone), or electronic (e.g., website, social media) sources.
- Public records or widely available sources, including information from the media, and other records and information that are made available by federal, state, or local government entities.
- Outside companies or organizations that provide data to support activities such as fraud prevention, underwriting, and marketing. Examples may include internet service providers, social networks, operating systems and platforms, data brokers, advertising networks, and data analytics providers
- Outside companies or organizations from whom we collect Personal Data to support human resource and workforce management activities or to satisfy regulatory obligations.
- Outside companies or organizations from whom we collect Personal Data as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development.
4. Categories of Third Parties and Our Disclosure of Personal Data
The categories of third parties to whom we disclose Personal Data about a specific individual depend on, among other things, our relationship or interaction with a specific California resident. During the past 12 months, we have disclosed for our business purposes the categories of Personal Data listed above to the following categories of third parties:
- Outside companies or organizations, including service providers subject to appropriate confidentiality and use restrictions, to whom we disclose Personal Data as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development. Examples may include internet service providers, social networks, operating systems and platforms, data brokers, advertising networks, software or information system providers, and data analytics providers; companies or organizations to whom we provide products or services; other parties, partners, and financial institutions; and parties involved with mergers, acquisitions, and other transactions involving transfers of all or part of a business, or a set of assets.
- Companies or individuals that represent California residents such as an accountant, financial advisor, or person holding power of attorney on behalf of a California resident
- Government agencies including to support regulatory and legal requirements
- Outside companies or organizations, including service providers subject to appropriate confidentiality and use restrictions, to whom we provide Personal Data to support human resource activities and workforce management, safety functions, and sales functions.
- Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties.
- Outside companies or organizations in connection with litigation.
The table below shows, for each Personal Data category we have collected, the categories of third parties to whom we may have disclosed for our business purposes information from that Personal Data category. The table below contains briefer descriptions of the categories of Personal Data and third parties. The full descriptions of the categories of Personal Data and third parties are available above.
Personal Data Type
Third Party Category to Whom We Disclosed Personal Data
Personal Identifiers
- Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
- Representatives of California residents
- Government agencies
- Outside organizations in connection with human resource activities and workforce management, safety functions, and sales functions or to satisfy regulatory obligations
- Outside companies in connection with routine or required reporting
- Outside companies or organizations in connection with litigation
- Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
- Representatives of California residents
- Government agencies
- Outside organizations in connection with human resource activities and workforce management, safety functions, and sales functions or to satisfy regulatory obligations
- Outside companies in connection with routine or required reporting
- Outside companies or organizations in connection with litigation
- Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
- Representatives of California residents
- Government agencies
- Outside organizations in connection with human resource activities and workforce management or to satisfy regulatory obligations
- Outside companies in connection with routine or required reporting
- Outside companies or organizations in connection with litigation
- Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
- Representatives of California residents
- Government agencies
- Outside organizations in connection with human resource activities and workforce management
- Outside companies in connection with routine or required reporting
- Outside companies or organizations in connection with litigation
- Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
- Representatives of California residents
- Government agencies
- Outside organizations in connection with human resource activities and workforce management
- Outside companies in connection with routine or required reporting
- Outside organizations in connection with supporting our everyday operations or business management and development
- Representatives of California residents
- Government agencies
- Outside organizations in connection with human resource activities and workforce management, safety functions, and sales functions
- Outside companies in connection with routine or required reporting
- Outside companies or organizations in connection with litigation
- Outside organizations in connection with supporting our everyday operations, or business management and development, safety functions, and sales functions
- Representatives of California residents
- Government agencies
- Outside companies or organizations in connection with litigation
- Outside organizations in connection with supporting our everyday operations, or business management and development
- Representatives of California residents
- Government agencies
- Outside organizations in connection with human resource activities and workforce management or to satisfy regulatory obligations
- Outside companies in connection with routine or required reporting
- Outside companies or organizations in connection with litigation
- Outside organizations in connection with supporting our everyday operations, or business management and development
- Representatives of California residents
- Government agencies
- Outside organizations in connection with human resource activities and workforce management or to satisfy regulatory obligations
- Outside companies in connection with routine or required reporting
- Outside companies or organizations in connection with litigation
California residents have the right to opt out of the sale of their information by businesses that sell Personal Data. The CCPA defines a “sale” as the disclosure of Personal Data for monetary or other valuable consideration. We do not offer an opt out from the sale of Personal Data because we do not and have not within at least the last 12 months sold Personal Data. The CCPA also requires that we state that we have no actual knowledge that we have sold Personal Data of California residents 15 years of age and younger.
5. Requests Under the CCPA
If you are a California resident, you have the right to request that we: (1) disclose to you the following information covering the 12‑month period prior to your request (“Access Request”): (a) The categories of Personal Data we collected about you and the categories of sources from which we collected the Personal Data; (b) The business or commercial purpose for collecting Personal Data about you; (c) The categories of third parties to whom we disclosed Personal Data about you, and the categories of Personal Data disclosed; and (d) The specific pieces of Personal Data we collected about you; and (2) delete Personal Data we collected from you (“Deletion Request”). In addition, you have the right to be free from discrimination by a business for exercising your rights under the CCPA.
6. Responding to Requests
Privacy and data protection laws, other than the CCPA, apply to much of the Personal Data that we collect, use, and disclose. When these laws apply, Personal Data may be exempt from, or outside the scope of, Access Requests and Deletion Requests. For example, information subject to certain federal privacy laws, such as the Gramm‑Leach‑Bliley Act or the Health Insurance Portability and Accountability, is exempt from CCPA Requests. As a result, in some instances, we may decline all or part of an Access Request or Deletion Request related to Personal Data exempt from CCPA Requests. This means that we may not provide some or all of this Personal Data when you make an Access Request. Also, we may not delete some or all of this Personal Data when you make a Deletion Request.
As examples, our processing of or response to an Access Request or Deletion Request may not include some or all of the following Personal Data:
- Consumer Accounts. Personal Data connected with consumer accounts used for personal, family, or household purposes. We have other privacy notices providing certain information on use and sharing of this data, for example, the Digital Privacy Policy, available at https://hmdfinancial.com/privacy.
- Employment. Personal Data about an individual who is a current or former employee (team member) or job applicant, and we use that Personal Data within the context of that individual’s role as a current or former employee (team member) or job applicant.
- Business‑to‑Business Relationships. Certain Personal Data we collect in the course of providing a product or service to another business, or in the course of receiving a product or service from another business.
The types of Personal Data described above are examples. We have not listed all types of Personal Data that may not be included when we respond to or process Access Requests or Deletion Requests.
In addition to the above examples, we may not include Personal Data when we respond to or process Access Requests or Deletion Requests when the CCPA recognizes another exception. For example, we will not provide the Personal Data about another individual where doing so would adversely affect the data privacy rights of that individual. As another example, we will not delete Personal Data when it is necessary to maintain that Personal Data to comply with a legal obligation.
7. How to Make Requests
If you are a California resident, you can make an Access Request or a Deletion Request by contacting us by telephone at (708) 398‑6237 and asking to speak with the EVP of MIS.
We will ask you to provide information to identify yourself. When you make a request, we will attempt to verify that you are who you say you are. For example, we will attempt to match information that you provide in making your request with other sources of similar information to reasonably verify identity.
8. Authorized Agents
If you are a California resident, you may authorize an agent to make an Access Request or a Deletion Request on your behalf. A California resident’s authorized agent may make a request on behalf of the California resident by contacting us at the number listed above. As part of our verification process, we may request that you provide, as applicable:
- For an individual (“requestor”) making a request on behalf of a California resident:
o The name; contact information; social security or individual taxpayer identification number; date of birth; and Driver’s License, State ID, or Matricula Card of the California resident on whose behalf the request is being made.
o A document to confirm that the requestor is authorized to make the request. We accept as applicable, a copy of a power of attorney, legal guardianship or conservatorship order, or a birth certificate of a minor if the requestor is the custodial parent.
- For a company or organization (“legal entity requestor”) making a request on behalf of a California resident:
o Proof that the California resident has authorized the legal entity requestor to make the request. We accept as applicable, a copy of power of attorney, or legal guardianship or conservatorship order.
o The name; contact information; social security or individual taxpayer identification number; data of birth; and Driver’s License, State ID, or Matricula Card of the California resident on whose behalf the request is being made. From the individual who is acting on behalf of the legal entity requestor, proof that the individual is authorized by the legal entity requestor to make the request. We accept a letter on the legal entity requestor’s letterhead, signed by an officer of the organization. We provide a template to use via the URL provided above for making requests.
9. Changes to this Notice
We may change or update this Notice periodically. When we do, we will post the revised Notice on this webpage indicating when the Notice was “Last Updated.” The changes will go into effect on the “Last Updated” date posted in the new notice. The new notice will apply to all current and past users of the Site and to all information collected before the date of the change.
The new notice will replace this Notice. Please check periodically for changes to this Notice, and especially before you provide any personal information to us.
10. Companies Providing this Notice
This Notice is provided by the members of the HMD Group of Companies, including: HMD Trucking, Inc.; HMD LLC; Benefit Trucking LLC; HMD Financial LLC; HMD Transport, Inc.; HMD Motorsports LLC; and HMD Bar & Grill LLC.
11. Contact Us
If you have any questions or concerns about our privacy policies and practices, you may contact us by telephone at (708) 398-6237. Please ask to speak with the EVP of MIS.
Last Updated: April 18, 2022