HOUSING AND CREDIT COUNSELING, INC.
INTERNET PRIVACY & USAGE POLICY

Housing and Credit Counseling, Inc. doing business as Housing and Credit Counseling, Inc. and HCCI (“HCCI”)
is committed to maintaining the integrity and privacy of your personal information. This privacy policy and usage
statement is intended to explain our information collection and dissemination practices in connection with the
HCCI family of websites located at www.hcci-ks.org (the “Sites”).

Agreement

By using this website, you agree to our Internet Privacy and Usage Policy and to the use of the information we
receive and collect as stated herein and in ways we may notify you of in the future. By providing any personal
information to this site, you acknowledge that you fully understand and consent to the collection and processing
of such information. We reserve the right at our discretion to modify this Internet Privacy and Usage Policy at
any time. Your continued use of this site following the posting of changes to these terms means you accept
these changes.

Description of Services

HCCI provides you with access to a variety of resources including educational materials, press releases,
financial calculators, monthly statements and deposit receipts which will be collectively referred to as
"Services". The Services, including any update and additions, are subject to this policy. We do not lend money.

Personal Use Limitation

The Services are for your personal use. You may not modify, copy, distribute, transmit, display, reproduce,
publish, license, or sell any information obtained from Services. Permission to use the Educational materials
from the Services is granted, provided that (1) use of such Educational Materials is for informational or personal
use only, and (2) no modifications of any Educational Materials are made. Accredited educational institutions
may download and reproduce Educational Materials for use in the classroom.

Personal Information We Collect

In order to monitor the Sites’ performance, provide you with a better experience when visiting the Sites and for
statistical and routine system maintenance purposes, HCCI may automatically collect information from you
through the use of cookies. Cookies are text files containing small amounts of information which are
downloaded to your device when you visit a website. Cookies are then sent back to the originating website on
each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a
website to recognize your device, facilitate and improve your interaction with our Sites and our services.

We also collect information, including personal information, provided by visitors as a result of their interactions
with our Sites or that is shared through our Sites. “Personal information” is data that reasonably can be used to
identify an individual. We may collect and process the following data about you:
➢ Information that you provide to us by completing forms or surveys on our Sites, including information
provided at the time of registering to participate in counseling or attend our conferences or events, or
subscribing to newsletters, updates, and other communications, such as contact details, name, email
address, mailing address, and phone number.
➢ Information that you share through our Sites by using our services including any personal information in
the data that you share.
➢ Information about your interaction with our Sites and services, including home server domain name, IP
address, repository ID, geographic location, account activity, license information, and type of computer,
operating system, and web browser used to access our Sites.
➢ Information you provide to us when you contact us for customer or technical support.
➢ Information that you provide to us when carrying out transactions through our Sites including payment
details such as credit card information and billing address.
➢ Information we receive from third party search engines relating to your search activity.
➢ Details of your visits to our Sites including, but not limited to, traffic data, location data, weblogs and
other communication data and the pages and resources that you access, including the date of access.
➢ Information you provide to us when you register for events, request information or materials, and
participate in promotions, contests or giveaways.
➢ Information you provide when you submit questions or comments to us.

Collection of Personal Data from Children

HCCI does not attempt to collect personal information from children. Personal information sent to HCCI, such
as an email, which appears to be from a child, will be deleted. HCCI cannot always determine if a visitor to its
Sites or the sender of an e-mail is a child but will exert our best efforts to do so.

How We Use Personal Information

Data collected by HCCI will be used by HCCI for purposes consistent with the way in which it was collected or
submitted, such as to:
➢ Create and maintain your account.
➢ Process, fulfill, and follow-up on your attendance at events or conferences.
➢ Process your account registration.
➢ Answer your questions.
➢ Send you newsletters, updates, and other communications that you have requested.
➢ Send you information about our services and resources.

Disclosure of Personal Information to Third Parties

HCCI will not sell, share, rent or disclose to third parties any personally identifying information, such as names,
mailing address, email addresses, telephone numbers, and other personal information which you voluntarily
provide to us, unless we secure your permission to do so, except to:
➢ Provide the services you have requested.
➢ Comply with applicable laws or valid legal processes.
➢ Protect HCCI’s intellectual property and other legal rights.

Personal information that you provide voluntarily is only available to our employees managing this information
and to contracted service providers for the purposes of providing services relating to our communications with
you. Names, mailing addresses, e-mail addresses, and telephone numbers provided by users may be added to
HCCI’s databases and used for future communications regarding Site updates, new products and services,
upcoming events, and other matters.

We may, from time to time, send you newsletters, updates and other communications regarding our services and
events. HCCI works with third-party vendors to provide users with its newsletter and communications services.
While these vendors will have access to your personally identifiable information in order to provide email
services, they are required to maintain the privacy of all information in their control. You may opt out of
receiving any HCCI newsletters, updates, or other emails by clicking “unsubscribe” at the bottom of each email
and following the subsequent instructions.

Request for Services

If you submit a request for service, your information will be captured in our database and provided to one of our
employees to contact you.

Bankruptcy Services

The Executive Office of the US Trustee does require HCCI to submit client information in order to generate a
pre-filing or pre-discharge certificate associated with bankruptcy services. The information provided may
include client name, bankruptcy case number, bankruptcy district and division, and the date and time services
are provided.

Log Files

As is true of most Web sites, we gather certain information automatically and store it in log files. This
information includes internet protocol (IP) addresses, browser type, internet service provider (ISP),
referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which
does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the
site and to gather demographic information about our user base as a whole. On rare occasion, unexpected
software errors occur, and our servers log data related to those software errors into a log file. It is possible that
the data recorded in those log files may contain customer specific information. However, that data is kept in a
secured location that is only accessible to engineers that require access to such log files. We do not use this data
for any purposes other than for debugging and diagnosing software problems. We do not link this
automatically-collected data to personally identifiable information.

Safeguard Information

We safeguard information by regularly reviewing our security standards and procedures to help prevent
unauthorized access to personal information. The information that we receive from you is important in meeting
your needs and providing consistent service quality. We will permit only authorized employees who are trained
in the proper handling of customer information to have access to your information. We regularly test our
technology and employ multiple defenses to protect the confidentiality of information about you.

Legal Disclaimer

We reserve the right to disclose your personally identifiable information as required by law and when we
believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order,
or legal processes.

Registration for HCCI Sites

Registration is not required to access our Sites.

Personal Information Shared in Public Forums

HCCI may provide bulletin boards, blogs, or chat rooms on its Sites. Any personal information you choose to
submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to
send you unsolicited messages. HCCI is not responsible for the personal information you choose to submit in
these forums.

Access to and Ability to Correct Personal Information and Opt-Out Right

Users may modify, correct, change, update, obtain a summary of their personal records, or request their
personal records to be removed from our database by contacting us via the mailing address, email or telephone
number listed below. In response to such a request, HCCI will send personal records only to the email or
mailing address on file for the username associated with it.

You may opt out of having your personal information collected by HCCI by not completing online forms,
signing up for services, or creating an account. To opt out after submitting personal information, Users must
contact us at hcci@hcci-ks.org.

You may request that HCCI remove from its database any personally identifiable information you had
previously provided. However, even after you submit a request to delete your information or deactivate your
account, copies of your information including but not limited to name and email address may be retained by us
as backup copies for legal and compliance reasons following HCCI’s Record Retention Policy guidelines.

Links to Third-Party Websites

Our Sites may contain links to other websites. HCCI does not endorse, and is not responsible for, the privacy
practices or the content of such other websites. We do not review or control such websites and suggest that you
review the privacy policies of these websites before accessing.

Downloads

HCCI cannot and does not guarantee or warrant that files available for downloading through the site will be free
of infection, viruses, worms, or other code that manifest contaminating or destructive qualities. You assume
total responsibility and risk for your use of the site and the Internet.

Security and Protection of Personal Information

All personal information you provide to us through our Sites is stored on secure servers operated by us or our
third-party providers. Any payment transactions will be encrypted using Secure Socket Layer (SSL) technology.
In addition, HCCI and its business partners enter into confidentiality agreements which require that care and
precautions be taken to guard against loss, misuse, or disclosure of your personal information. Where we have
given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you
are responsible for keeping this password confidential. We ask that you not share your password with anyone.
Although we will do our best to protect your personal information, we cannot guarantee the security of your
data. Any transmission is at your own risk. Once we have received your information, we will employ reasonable
procedures and security features to guard against unauthorized access.

Unlawful or Prohibited Use

You may not attempt to gain unauthorized access to any Services, other accounts, computer systems or
networks connected to any HCCI server or to any of the Services, through hacking, password mining or any
other means. You may not obtain or attempt to obtain any materials or information through any means not
intentionally made available through the Services.

Disclaimer

HCCI does not warrant the completeness, timeliness, or accuracy of the Services available on this website. In no
event will HCCI be liable to any party for any direct, indirect, special, or other damages for any use of or
reliance upon the information found at this web site, or on any linked web site, including, without limitation,
lost profits, business interruption, loss of programs or other data, even if HCCI expressly advised of the
possibility of such damages.

Amendments to Policy

HCCI reserves the right to change this Policy at any time, without notice, by posting the new or revised Privacy
Policy on the Sites.


Approved 6/12/18

How to Contact Us

Questions, comments and requests regarding this Policy are welcomed and should be addressed to
hcci@hcci-ks.org or mailed to the following address:

Housing and Credit Counseling, Inc.
1195 SW Buchanan Street, Suite 100
Topeka, KS 66604
Telephone: 800-383-0217