On May 24, 2000, the Federal Trade Commission released Title 16 CFR Part 313 a final
policy rule as required by section 504(a) of the Gramm-Leach-Bliley Act ("GLBA").
Under this rule document preparation companies, as well as tax preparation companies,
may be considered to be financial institutions, and as such are required to provide written
notice of their privacy policy to all clients.
This rule is effective November 13, 2000 with full compliance being required by July 1,
2001.
In the absence of any direct regulatory body, the interpretation of all GLBA provisions is
undertaken by the Federal Trade Commission.
On May 23, 2002, in accordance with the GLBA, the Federal Trade Commission released
Title 16 CFR Part 314, a final policy rule as required by section 504(b) of the GLBA entitled,
"Standards for Safeguarding Customer Information; Final Rule."
This rule is effective May 23, 2003 |
Summary of Information Safeguards |
- ICC automatically encrypts your confidential information in transit from your computer
to ours using the Secure Sockets Layer protocol (SSL) with an encryption key
length of 128-bits. Even before you register or log in to our site, our server checks
that you're using an approved browser - one that uses SSL 3.0 or higher.
- Once your information reaches us, it resides on a server that is protected, both
physically and electronically. Our servers are located behind electronic firewalls and
are NOT directly connected to the Internet, so your private information is available
only to authorized computers.
- Only authorized employees are permitted to access customer information. Authorized
employees have been trained on how to handle information properly and are
subject to strict limitations and guidelines in the handling of that information.
- When you open an ICC document preparation account, we require certain information,
such as your name, address, phone number and email address.
- When you send, receive or request documents through ICC, we collect transaction
information needed to perform the service.
- When we cannot verify the information you provide online or your document request
contains conflicting information, we may contact you by various means to request
additional information. Contact may be established by telephone, fax, e-mail or other
electronic means.
- We do not share information with any third-parties unless you specifically direct and
control the information and the recipient. ICC does not have any affiliates or other
third-parties with whom we do business. However, we do anticipate offering our clients
the ability to use third-party services to order compliance reports. In such case, ICC does not participate or benefit from the contractual obligations between our client
and their designated report vendor. ICC’s role is limited to providing non-GLBA
data over a secure link to the report vendor and, using the same secure link, retrieves
the vendor’s report to display within the context screens of ICC’s document
preparation system.
- We may provide information to agencies or authorities with whom we are legally required
to cooperate. We may disclose information during the investigation of fraud or
illegal activity. For example, we may disclose information in response to a subpoena,
warrant, court order, or comparable legal process.
- You have the ability to view or update your account information any time by contacting
ICC customer service.
- You have choices in the types of communications you wish to receive from ICC. ICC
may send you e-mails with information to beneficially improve document preparation
activities or assist you in improving your own internal processes.
- You have the ability to review ICC's Privacy Policy anytime by clicking on the Privacy
link located on the right side of ICC's main website at http://www.iccdocs.com .
- If you have any other questions about ICC's privacy practices, please feel free to
contact us toll-free at (888) 437-3627, e-mail us at info@iccdocs.com.
- In Case of Errors or Questions about Your Account or Document Preparation activities,
you can call our customer service center at 1-888-437-3627 or fax us at 1-888-
242-9622. These numbers are also shown on our web site. Or write us at 1500 South
Sunkist Street – Suite “H”; Anaheim, CA 92806.
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Thank you for using ICC's state-of-the-art document preparation services.
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Basic Information Practices Philosophy |
INTERACTIVE COMPUTER CORPORATION FUNCTIONS ONLY AS A DOCUMENT PREPARATION SERVICE
ACTING ON BEHALF OF ITS CLIENT AND/OR THEIR DESIGNEE. |
- In providing any forms and/or document sets, Interactive Computer Corporation is acting
under the instruction and supervision of the party requesting the documents provided.
Interactive Computer Corporation will disclose only those information items requested
by its client, or designee, and in a manner deemed appropriate by its client or
designee.
- Interactive Computer Corporation has made a reasonable effort to ascertain the true
and correct identity of its clients and/or their designees and will use this information to
authenticate, whenever and wherever practical, requests for services from Interactive
Computer Corporation. Services requested by any party not a client of Interactive Computer
Corporation and/or its designees will be denied.
- Any information provided to Interactive Computer Corporation by its clients and/or
designees remains the property of said clients and/or designees. Interactive Computer
Corporation asserts no right, title or interest in client-supplied information and
accepts said client-supplied information with the sole purpose of rendering specific
document preparation services to its clients and/or designees. Interactive Computer
Corporation only asserts rights, title and interest in the forms and/or document sets
that were developed by Interactive Computer Corporation and the default data that is
provided by third-parties empowered to provide such data. This aforesaid information,
whether developed by Interactive Computer Corporation or provided by a thirdparty,
is held to be the proprietary intellectual property of Interactive Computer Corporation
as it may embody trade secrets or other proprietary methods involved with
the production and/or presentation of said information in the normal course of its
business as a document preparation company. Included within this class of claimed
interest are all computer programs, programming, systems analysis and other methodology used by Interactive Computer Corporation to render its services.
- Interactive Computer Corporation hereby notifies all parties, be they client, designee,
intermediary, financial institution, consumer, or legal entity, that it is not responsible
for the disclosure of data contained within these forms or document sets which are
provided to any party whether picked-up (will-call), transferred by private courier,
transferred by the United States Postal Service or transmitted electronically to the
client and/or their designees by facsimile, computer system download, e-mail or any
technology which may become available from time-to-time for the transmission of
forms and/or document sets.
- Any information contained within individual forms and/or document sets that are produced
in error will be destroyed by shredding or other means designed to protect the
privacy of Interactive Computer's clients and/or the subject of the individual form or
document set. Retrieval of forms and/or document sets produced in error, once distributed
per the instructions of the client or its designee is the responsibility of the
client or its designee.
- Interactive Computer Corporation is not responsible for the amendment and/or correction
of any form and/or document set. The responsibility for the amendment and/
or correction of any form and/or document set is the sole responsibility of the client or
their designee. Interactive Computer Corporation sole liability is to replace any erroneous
documents upon notification of error.
- All information retained by Interactive Computer Corporation is retained on behalf of
the client and is not transferred to any third-party or otherwise used for any purpose
other than backup data for the client's sole and exclusive use. Unless retained information
is subject to a lawful subpoena, this information will be destroyed by deletion
from ICC's active systems and backup tapes will be erased from time-to-time as warranted
by operational considerations.
- Any information contained within a single document and/or document set that is
made public by means of public recording and/or a court filing is the sole responsibility
of the party requesting the documents and/or document sets from Interactive
Computer Corporation.
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| Specific Information Practices |
This privacy statement defines privacy aspects specific to the Interactive Computer Corporation's
web site. All of ICC's policies, procedures and privacy practices are consistent and
compliant with all legislative rules and regulation then in effect.
Federal legislation such as the Gramm-Leach-Bliley Act and the Federal Trade Commission's
Safeguards rule requires ICC to provide information regarding ICC's information handling
practices on its website. Especially those policies, procedures and practices involving
"nonpublic personal information." |
| ICC and Children |
| Although ICC is a family-owned firm with a child-friendly environment, ICC's web site is not
designed to appeal to children of any age or solicit their participation in ICC's business offerings
in any manner. Therefore, judicial notice is hereby given that ICC does not solicit or
attempt to solicit the participation of children, especially under the age of 13, for any reason.
Any attempt of a child to access ICC's site for the purposes of attempting to initiate any
business transaction will promptly reported to the appropriate authorities. |
| ICC's Basic Information Policy and Practice |
ICC wants its clients to feel comfortable and secure when using the ICC website. The following
information policy and practices govern the usage of ICC's website.
To maximize the value of ICC's services, we may request information from you when you
visit ICC's website and we collect information from you, we'll tell you what is collected, by
whom it is collected, to whom it may be disclosed, and how it will be used. |
| Here is how and why we collect and use information from you: |
- Information Required for Access
You are required to logon to the non-public portion
of ICC's website using an assigned Client ID, User ID and Password. The User
ID and Password may be assigned and controlled by the client. This information is
considered nonpublic personal information and is never divulged to any third-party
without adequate controls as inappropriate disclosure of these data items may compromise
ICC's operational control and security.
- Data Entry for Document Preparation
Clients may enter both public and nonpublic
personal information in order to prepare financial documents. This information is
presently secured and controlled by both legislatively-mandated controls and ICC's in
-house security policy.
- Data Entry for 1099 Reporting
Clients may enter both public and nonpublic personal information in order to prepare financial documents. This information is presently secured and controlled by both legislatively-mandated controls and ICC's in-house security policy.
- Contact
You can use your assigned logon to gain access to ICC's systems. ICC
may use the e-mail address that you provide to contact you if you choose to receive
e-mail alerts or other communications from us. ICC does not share your contact information
with any third-parties for any reason.
- Newsletters
ICC may provide you with the opportunity to subscribe to mortgagerelated
e-mail newsletters and other e-mail communications. You may unsubscribe
at the subscription center or by following the instructions provided in each e-mail
newsletter.
- Customer Service/Support
In order to provide you with customer service, we may
ask for your name and e-mail address. We may use your contact information in order
to contact you regarding service updates or specific support questions and may contact
you for additional opportunities to provide feedback on our products and services.
- Efficiency or Other Surveys
From time to time, we may conduct certain performance
and related surveys. This information is treated as being company confidential
and is not shared with anyone outside of ICC. In many cases, while the survey may
be considered anonymous, the associated respondent e-mail to IP (Internet Protocol)
address may be attached to the communication by the system. Since these data elements
are required for information transfer, there is no way to eliminate them from
the process.
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| ICC's General Information Procedure and Practice |
- Mandatory and Optional Information
We identify the information that is necessary
to fulfill your request. Whenever we ask for additional or optional information, we
identify those fields appropriately so that you know what is required to provide the
requested service. If you choose not to provide mandatory information, we will not be
able to provide the service you are requesting.
- ICC, Subsidiaries and Strategic Partners
ICC does not have any subsidiaries or
strategic partners. All information is controlled by ICC and the exposure of any client
information to any third-party such as a subsidiary or strategic partners is eliminated.
ICC, at the clients request and specific direction, may transmit the client’s data to a
vendor of a client’s choosing over a secure data link and/or retrieve data from the
client’s vendor for use or display within ICC’s document preparation system.
- E-mail Messaging
When sending you e-mail we reserve the right to use a process
involving an image called a single pixel GIF, that allows us to further control access
and the use of information to better suit the client's needs. Although ICC does not
currently use this process, some future programs may require the use of this feature
to determine the identity of respondents who receive and open ICC's directed emails.
When you initiate a response by clicking on a link within an e-mail message,
you may be re-directed to an internet link that records the status of your reply.
- Service Providers
If ICC employs or works with any service providers such as consultants, temporary workers, third party software developers or outsourcers to complete
a business process or provide a service on our behalf, we shall take the necessary
steps to insure that all client information is protected in the same manner as
which ICC protects information internally. If ICC employs service providers, we may
need to share your personally identifiable information as covered under Federal,
State and local privacy legislation. All service providers are strictly prohibited and will
be contractually prohibited from using Client's information whether or not it is identified
as "personally identifiable information" for purposes other than to act on ICC's or
the Client’s behalf.
- Service Alerts and Critical Notices
Although we respect and honor our client's privacy
preferences, we reserve the right to contact you to inform you of specific
changes that may impact your ability to use ICC's systems, programs or for other
critical non-marketing purposes, such as ICC bulletins which are published from time
-to-time. ICC may also contact you to respond to your specific requests or to clarify
the document preparation order that was transmitted to ICC.
- Changes to Our Privacy Policies
If ICC plans to make any significant change to
any of ICC's privacy policies or information usages practices, especially with respect
to how ICC deals with legislative issues involving the use of personally identifiable
information, ICC will post those changes to ICC's website as soon as practical before
they take effect. ICC may also highlight the change by placing an icon next to our
current policy indicating a "new" or "modified version of the privacy policy document
may exist.
- Change of Company Control
While no change of control is anticipated at this time.
ICC reserves the right to transfer nonpublic personal information as a condition of a
sale, merger, transfer, exchange or other disposition (whether of assets, stock or
otherwise) of all or a portion of ICC's business. All legislated privacy protections will
contractually survive any and all change of control issues in order to protect your information.
ICC will further provide its clients with the opportunity to opt out of further
use of client's information following any change of control.
- Legal Disclosure of ICC or Client Information
In some cases ICC may need to
disclose certain nonpublic personal information to comply with a legal process, such
as a court order, subpoena, search warrant, administrative summons or other law
enforcement request. Unless otherwise specifically prohibited, ICC will endeavor to
inform you of its plan to respond to an official information request in time to challenge
the request in a judicial or administrative proceeding.
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| Web Technologies |
| Here is how and why we use some common Web technologies to help manage our Web sites: |
- Cookies
A "cookie" is a small piece of information that our websites may automatically
provide to your browser while you are at our sites. ICC websites may supply
your browser with cookies that contain a unique identifier used to better navigate our
web pages or maintain certain information necessary to communicate information
backward and forward between the pages. This cookie is not linked to the personally
identifiable information that you provide us elsewhere on the site. Cookies are not
currently used or supported by ICC.
- Web Site Usage Data
ICC's website may tracks usage data, for example, your IP
address or domain name, browser type and version, which pages you view, which
page, if any, linked you to our site and which link, if any, you follow off of our site for
security purposes. We do not currently use this information for any other purpose.
ICC does not share any usage or tracking information with any third-party and does
not track your website addresses once you leave our site.
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ICC protects personally identifiable information from loss, misuse, or unauthorized alteration.
We employ industry recognized security safeguards to help protect the personally identifiable
information you provide us from loss, misuse, or unauthorized alteration. Whenever
we prompt you to transmit sensitive information, such loan information, to us through our
Web site, we support the encrypted transmission of that data.
We work to protect personally identifiable information stored on our sites' servers from unauthorized
access using industry standard computer security products such as firewalls, as
well as carefully developed security procedures and practices. All ICC employees must
review and sign a written statement with these practices, which include limiting access to
sensitive information to only those employees who require the information and enforcing
strict password protocols for all employees. In addition, a username and password are required
for you to enter, use, view or print loan information. ICC reserves the right to use
both internal and external resources to review the adequacy of our security measures on a
regular basis.
ICC provides various ways for you to obtain information about our information policies, procedures and privacy protections.
Questions regarding ICC's privacy statement, our online privacy policy, our information
practices or other aspects of privacy on our Web sites should be directed to us at http://
www.iccdocs.com or by writing to us Interactive Computer Corporation Customer Service
Department, 1500 Sunkist Street, Suite “H;” Anaheim, CA 92806 or by calling ICC's toll-free
hotline at (800) 437-3627.
Reviewed: June 1, 2008 |
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