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INFORMATION COLLECTION
HALIGHT may collect various types of personal information, including:
- Full name, email address, employment company name and proof of employment
- Personal and business contact information (such as name, billing and shipping address, phone number, email address, and social media/messaging account ID)
- HALIGHT Account ID
- Profile picture
- Social media postings and information
- Depending on the service we are providing, we may also need to collect more sensitive personal information (such as location, government-issued identification, photographs, audio/video recordings, images, and biometrics) directly from you
If customer representative submits any personal information about other people to us or to our service providers, customer representative affirms authority to do so and to permit us to use their personal information in accordance with this Privacy Notice.
Additional information may be collected for the purpose of distributing contents or sweepstake winnings. Contest specific rules are addressed in a separate document.
Other Information We May Collect
HALIGHT may also collect other information from user app, browser, or device that does not reveal real world identity, for example:
- Browser and device information
- App or device usage data
- Information collected through cookies, pixel tags, and similar technologies
- IP address
- Location data
- Aggregated, anonymized, or de-identified information
- Demographic information and other information provided by you (i.e., language, occupation, postal code or zip code).
We and our third-party service providers may collect this information in a variety of ways, including:
- Through your browser or device: Most browsers and devices collect certain information automatically, for example, type and version of operating system, screen resolution, device manufacturer and model, language, Internet browser type and version, and the name and version of the HALIGHT Services (such as the app) you are using. We use this information, for example, to make sure that the HALIGHT Services function properly, analyze the performance of our products, and improve and maintain the HALIGHT Services.
- Through your use of a HALIGHT app: When downloading and using an HALIGHT app, we and our service providers may track and collect usage data, such as the date and time the HALIGHT app on a device accesses our servers and what information and files have been downloaded to the HALIGHT app.
- Through cookies and similar technologies: We use cookies to make our web sites operate, work more efficiently, and provide analytic information. Technologies similar to cookies are also used in connection with some HALIGHT Services, such as pixel tags, web beacons, clear GIFs, JavaScript, and local storage.
- IP Address: IP addresses are automatically transmitted as part of any Internet communication, and collecting IP addresses is a common practice; many web sites, applications and other HALIGHT Services collect IP addresses automatically. We use IP addresses for purposes such as communicating with your device, calculating usage levels of the HALIGHT Services, helping diagnose server problems, security, and administering the HALIGHT Services.
Some classes of users, may be permitted to delete accounts and all information collected on them.
User profiles designated as subscriber employees could not be deleted at user requests as their employers may need to retain records of their training (for example confirm that an employee completed compliance training)
HALIGHT might utilize third parties to track end user data for analyzing aggregate user trends and to improve the quality of the subscription solution
The HALIGHT Learning Management System is not negatively impacted by browser do not track signals.
2. NOTICE
We provide access to our Privacy Notice by:
- Linking to it throughout our websites
- Incorporating it into our contracts, agreements, and other documents as necessary or appropriate
3. INFORMATION USE AND DISCLOSURE
How We May Use and Disclose Personal Information
We may use personal information:
- To provide HALIGHT Services.
- To respond to inquiries and fulfill requests, such as to send technical documents or whitepapers.
- To allow users to participate in surveys, sweepstakes, contests, and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain more information about how we use and disclose your personal information, so we suggest that you read these rules carefully.
- To allow user to send messages to a friend or post comments through the HALIGHT Services. By using this functionality
- To complete and fulfill purchase, for example, to process payments through third party vendors, have your order delivered, provide related customer service, and establish and manage HALIGHT accounts.
- For our business purposes, such as data analysis, audits, crime/fraud monitoring and prevention, security, developing new products, testing, enhancing, improving or modifying our HALIGHT Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
- Perform accounting, auditing, billing, reconciliation, and collection activities. To send administrative information and service notifications, for example, information regarding the HALIGHT Services and changes to our terms, conditions, and policies.
- Perform other activities consistent with this Notice.
Personal information may be shared or disclosed:
- To our authorized service providers and suppliers who provide services to us such as web site hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and other similar services.
- To third parties to permit them to send you marketing communications, as permitted under applicable law and in accordance with your communication preferences.
- To third party sponsors of sweepstakes, contests, and similar promotions.
User Information collected is used to for analytics purposes, for advertising or promotional purposes, for sending newsletters, for complying with law enforcement or regulatory demands, and for managing the business.
Information may be shared with third party hosting company, a credit card processer, law enforcement, a court or an advisor.
4. THIRD-PARTY SERVICES
This Privacy Notice does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not HALIGHT service providers, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service to which the HALIGHT Services link – the inclusion of a link on the HALIGHT Services does not imply endorsement of the linked site or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) – including any personal information you disclose to other organizations through or in connection with the HALIGHT Services or our Social Media Pages. For example, we may use and direct you to a third party payment service to process payments made through the HALIGHT Services. If you wish to make such a payment, your personal information may be collected by such third party and not by us, and will be subject to the third-party’s privacy policy, rather than this Privacy Notice.
When we share personal information with an HALIGHT service provider, we require that they first contractually agree to comply with reasonable and appropriate privacy and security standards.
5. SECURITY
The HALIGHT Services are designed to provide reasonable and appropriate organizational, technical, and administrative measures to protect personal information within our organization against unauthorized or unlawful access, alteration, disclosure, or destruction. Users of HALIGHT Services must also do their part in protecting the data, systems, networks, and service they are utilizing.
Customer specific data identified as classified (such as user profile information) will be encrypted in transit and at rest.
6. RETENTION PERIOD
We will retain personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
HALIGHT shall maintain Subscriber’s Content and data stored to the Software Platform for thirty (30) days immediately following the expiration or termination of the Agreement, at which time such Content and data will be expunged. Subscriber shall have the right to request a copy of the Content and data stored in the Software Platform within the thirty (30) day period immediately following any expiration or termination of this Agreement. In any such case, a copy of Content will be provided in its original format, and a copy of the user information, training records, and completion records will be provided in a text-readable format. All data will be made available via a secure file transfer mechanism at no additional charge.
7. Data Storage Location
All information collected, will be stored in the US.
8. Communicating Privacy Policy
The Privacy Policy will be posted on the HALIGHT web site. The last updated date will be posted on the web site, communicated updates to the privacy policy. Questions about privacy and confidentiality policy can be directed to:
Privacy Officer
HALIGHT
1-844-425-4448
13360 Sylvestre Dr.
Windsor, ON, N8N 2L9