Electronic Bill Payment and Presentment Consumer Information Privacy Principles

Introduction
The Housing Opportunities Commission of Montgomery County (HOC) is committed to treating and using personal financial information about you responsibly. These Privacy Principles explain what personal information we collect, why we collect it, how we protect personal information, and how and why in certain cases we may share such information with select other parties. These principles are effective September 1, 2011, and may be amended from time to time.

HOC’s Electronic Bill Payment and Presentment Consumer Information Privacy Principles (“EBPP”) apply to personal information collected or used when you use our online bill payment system.

We Collect Information As Needed to Identify You and Serve You as a Resident
We collect information from and about you in order to identify you as a resident of HOC, establish and manage customer accounts, complete customer transactions, and to comply with legal and regulatory requirements.

Information we receive from you:

Contact Information (such as name, address, e-mail address, and telephone number). We use contact information, for example, to identify you, and to contact you about your accounts.

Account Information (such as bank account numbers, bank routing numbers, and credit card numbers). We use the account information you provide us in order to complete your payment requests.

Policies and Procedures
HOC’s EBPP service utilizes advanced technology and information management techniques to implement security, audit and control programs designed to protect the confidentiality and security of the information we collect. HOC limits employee access to resident information provided on our EBPP site to those employees we believe have a legitimate business need for the information.

We May Share Information With Other Companies
It is our policy not to sell, rent or otherwise provide resident information collected on HOC’s EBPP site to outside companies so they can market their products or services.

The section below describes the types of third parties with whom, and the situations when, we may share customer information outside HOC:

· HOC will share personally identifiable information that you provide us on our EBPP site with third parties that help us process the transactions you request;

· When we respond to your service requests;

· When we suspect fraud or for risk management purposes;

· When we are required by a federal, state, or local law or regulation to do so;

· When we receive a subpoena or are ordered by a court to do so;

· As otherwise permitted by federal or state law.

Under no circumstances, will HOC disclose bank account numbers, credit card numbers or access codes provided to us via our EBPP website to third parties for telemarketing or direct marketing purposes.

Former Residents
We do not disclose information about former residents to outside companies except as may be required by law. Some examples of when we may share information about former residents, such as when we receive a subpoena, are listed above.

State Privacy Laws
We will also comply with state privacy laws..

Online Information Policies
We respect the privacy of our residents and are committed to protecting their information on our websites with the same care we utilize for our own transactions.