Last Revised February 15, 2022
Any information provided to or gathered by Halight is controlled by:
13360 Sylvestre Dr. Windsor, Ontario CANADA N8N 2L9
Halight may collect information about you through various means, including:
Halight uses functional cookies, some of which may be placed by third parties, to customize your experience on the Halight Platform. Cookies allow us to:
We may also use Google cookies and tools, such as Google Analytics, on the Halight Platform to collect usage data and analyze how users use the Halight Platform. For more information about how to opt out of this practice, visit the Google Analytics Opt-Out Add On page.
You can change your cookie settings in your browser and use preferences or settings on your device to manage your privacy controls. However, if you disable cookies or other tools, some of the features of the Halight Platform may not function correctly. For more information, see https://www.allaboutcookies.org/; and to learn more about targeted advertising, including how to revoke consent and disable tools and how to opt out of third- party cookies and collection of mobile device IDs, see below and the links here and here.
Note: for LMS Users, some clients require a copy of your paystub and/or government-issued identification as proof of employment with a particular retailer. It is up to you, as the LMS User, to redact all unnecessary and sensitive personal information, such as social security number and salary, from the proof submitted and in accordance with the instructions provided through the Halight Platform.
Additional information may be collected for the purpose of distributing contest or sweepstakes winnings. Contest specific rules are addressed in a different document.
Information You Make Public
The Halight Platform may contain features that allow you to upload, post, transmit, display, perform or distribute content, including personal information about yourself. For example, you may choose to include personal information within a public-facing profile on one of our leaderboards, which is available and accessible to other participants on the Halight Platform. Any information that you choose to disclose by means of such features becomes public information over which Halight is unable to exercise control. You should take caution when deciding to disclose personal information by means of such features.
Device/Internet Connection Information
When you use the Halight Platform, we automatically gather information made available by your web browser, internet service provider, and device, depending on your settings for each. This information does not reveal real world identity. For example, we may collect:
Information Provided by Third Parties
Halight may receive information about you if you have provided it to a Third Party and we subsequently acquire the information from the Third Party, such as from one of our clients. Such information may include information related to your employment or sales activity.
From time to time, we may obtain other information from you, such as when you request assistance through from our customer service department, and when you voluntarily subscribe to a newsletter. For example, if you earn more than $600 in rewards or prizes during a given year, we will ask you for an IRS W-9 form. You will always be asked to provide such other information voluntarily, and we will not collect it without your permission.
We use the information we've gathered from you, including through cookies and web beacons, for the following business and commercial purposes:
Except under the following circumstances, Halight will keep your personal information private and will not share it with third parties. We may share your personal information with others for the following reasons:
To Satisfy Our Obligations to Our Clients
Through the Halight Platform, Halight provides training, education, games, and promotional opportunities for LMS Users engaged in the sale of products and services of our participating clients. Thus, when you complete a training program or participate in a promotional opportunity through the Halight Platform, we may transfer information about you and your completion thereof back to the affiliated client to demonstrate fulfillment of our contractual obligations.
To Fulfill Your Rewards
For LMS Users, we may transfer your information to third parties, including our fulfillment and shipping service providers, when necessary to provide a reward or prize that you earned through us. For example, if you redeem rewards in the form of a gift card or coupon code, we will transfer your necessary personal information to our fulfillment provider so that they can send your gift card or coupon code to you.
To Advertise to Others
We may share your reviews and comments about Halight to advertise and market our products and services. If you want us to stop using the personal data you have provided in these ways, please contact us [email protected]
To Our Affiliated Companies
To Our Third-Party Service Providers
We may disclose your personal information as needed to our third-party service providers who provide services to us such as website hosting, data analysis, reward fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and similar services.
To Comply with Legal Process and Prevent Harm
We may disclose your information to respond to subpoenas, court orders, and other legal processes. In rare circumstances, we may disclose personal information when we believe it is necessary in order to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals.
To Collect Unpaid Accounts
If you are a Client User and the associated client fails to pay any balance owed in consideration of services rendered by Halight, we may, as permitted by law, report information about the client (including any unpaid balance) and your personal information as contact for the client, to collection agencies and others in conjunction with our efforts to collect the unpaid balance.
Halight does not sell, and has not sold during the last 12 months, personal information gathered through the Halight Platform.
Halight stores personal information in the United States. If you are visiting the Halight Platform from a location outside of the United States, your connection will be through and to servers maintained by Amazon Web Services, which are located in the United States. By using the Halight Platform, you authorize and specifically consent to the transfer of personal information to the United States and its storage and use as specified above when you provide such information to us.
We understand that the security of your information is important. Halight has implemented and maintains reasonable and appropriate security procedures and practices to protect against the unauthorized access, use, modification, destruction, or disclosure of your information.
You should note that the security of your personal information also depends on you. Please do not communicate any information to us through unsecured channels, such as when you are on a public device. Where we have provided you or you have chosen a password, access code, or similar security feature, you must keep the password, access code or security feature confidential. Please do not share your password with anyone. If you believe your password or account has been compromised, please contact us immediately at [email protected]
Please note that the transmission of information via the Internet or other means of communication is not completely secure. Although we take reasonable measures to secure your information, we cannot guarantee the security of your information transmitted to our Website or through other means of communication. Any transmission of information is at your own risk.
We rely on you to let us know of any changes to your personal information that may be relevant to your relationship with us. This way we can keep our records accurate and up to date, which helps us to protect your privacy.
You may access all information we've collected about you for purposes of correcting, amending, transferring, or deleting such information. Access can be obtained by contacting [email protected] To protect your privacy and security, we may take reasonable steps to help verify your identity before granting access or making corrections.
You can change your consent preferences or withdraw your consent for the collection, use and disclosure of any or all of your personal information, at any time (see contact information below). It is important to note however, that when you change or withdraw your consent, it will not have a retroactive effect; it may have implications to you, such as not being able to access a learning management system and it will not affect the collection, use and disclosure of personal information where such collection use and disclosure is permitted or required by law without consent.
Process for Making a Request
To make a privacy request regarding your personal information, please contact us at either [email protected] with your name and either your email address or physical address associated with your use of the Halight Platform. If you are making a privacy request through an authorized agent, please also provide the agent's name and email address and statement of authorization. If we need additional information to verify your identity or process your request, we will promptly respond to you. Under certain privacy laws, consumers have specific additional privacy rights, as outlined below.
California consumers have the following rights under California privacy laws:
In addition, under California's “Shine the Light” law, California residents who provide information to the Website may request certain information regarding our disclosure of your information to third parties for their direct marketing purposes.
Nevada consumers have the right to request that Halight not sell their personal information for monetary consideration to certain other parties. This right applies even if their personal information is not currently being sold. If you wish to make a request, please contact us.
European Economic Area Residents
Residents of the European Economic Area have the right to access information we hold about you and to ask that your information be corrected, updated, or erased, and the right to object to, or request that we restrict, certain processing of your information. You also have the right to lodge a complaint with the data privacy authority where you live, see e.g., this website.
We encourage you to let us try any resolve any privacy concerns that you may have. However, residents of Canada may also have the right to complain about any violation of your privacy rights to Office of the Privacy Commissioner of Canada who can be reached at:
30 Victoria Street Gatineau, QC, K1A 1H3
Tel: (819) 994-54443 or (800) 282-1376
Halight Platform: https://www.priv.gc.ca/en/contact-the-opc/
Limitation on Rights of Certain LMS Users
If you are an LMS User, we may be legally required to retain some or all of your personal information at the request of your employer (for example, if you complete employee training through the LMS Platform and your employer is required by law to retain a record of the same). If we are unable to complete your privacy request as a result of such limitation, we will explain the reason and legal basis in our response.
Halight will never knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because we do not collect such information, we have no such information to use or to disclose to Third Parties. We have designed this policy in order to comply with the Children’s Online Privacy Protection Act (COPPA).
DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked. The Halight Platform does not currently respond to DNT requests.
We are committed to providing you with understandable and easily available information about our privacy policies and procedures. We encourage you to contact us with any questions you might have. You can reach our Privacy Officer as follows: