PRIVACY POLICY

Last Updated: October 2020

HiPER Solutions, LLC Privacy Policy

This Privacy Policy applies to the HiPER Solutions website, located at www.hipersolutions.com and www.thehsg.com (the “Site”) operated by HiPER Solutions, LLC (“HiPER Solutions,” “we,” “us,” or “our”). This Privacy Policy is intended to inform you about the kind of information, including Personal Information and Anonymous Information (as each is defined below) that we may collect from you when you provide us such information in connection with your interest in the products and services offered by HiPER Solutions and how we use that information and for what purpose. It also informs you about the ways in which you can control how HiPER Solutions uses your information and how we protect such information. 

Any and all information collected in connection with any HiPER Solutions product or service, including without limitation, the HiPER Solutions Subscription, will be governed by the written agreement entered into between you and HiPER Solutions for the use of such product or service.

PERSONAL AND ANONYMOUS INFORMATION

“Personal Information” means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular customer or household. 

“Anonymous Information” means data that is not associated with or linked to your Personal Information as this type of information is not collected at the time of the data capture; Anonymous Information does not, by itself, permit the identification of individual persons. 

“De-Identified Information” means data that has been stripped of information that could potentially relate to, describe, or reasonably be linked to a specific customer or household directly or indirectly.

PROTECTING YOUR PRIVACY AND CONSENT

  • HiPER Solutions, while being considered a “non-covered entity,” understands the importance of consumer privacy and strives to adhere to the requirements set forth in the California Consumer Privacy Act (CCPA) of 2018. As such HiPER Solutions feels it appropriate to notify all consumers, not just California residents, of their general rights and choices under the CCPA, specifically:

Your Rights and Choices:

You may request HiPER Solutions to disclose certain information to you about our collection and use of your personal information over the last 12 months. Once HiPER Solutions has received and confirmed your verifiable consumer request (see Exercising Access, Data Portability, and Detention Rights) we will disclose to you:

  • The categories of personal information we collect about you

  • The categories of sources for personal information we collected about you

  • Our business or commercial purpose for collecting or selling that personal information

  • The categories of third parties with whom we share that personal information

  • The specific pieces of personal information we collected about you (also called data portability request)

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    • Sales, identifying the personal information categories that each category of recipient purchased; and,

    • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

HiPER Solutions INFORMATION COLLECTION

Information collected by HiPER Solutions Assessment Questionnaires:

HiPER Solutions collects the following Personal Information from both Individuals and Organizations who have engaged HiPER Solutions for assessment services:

Category

Identifiers

Usage

Geolocation Data

Examples

A real name, alias, postal address, email address, unique personal identifier, online identifier, Internet Protocol Address, email address, account name, Month and Year of birth, employment information such as organization title and organization name

Information of the User’s interaction with the solution (such as assessment answers and metadata associated with the answering of the questions)

Physical location, generally


Information collected by HiPER Solutions Websites

HiPER Solutions websites gather information in two ways: (1) indirectly (for example, through our site's technology), and (2) directly (for example, when you, the site visitor, voluntarily provide information on various pages).

Indirect Collection

HiPER Solutions indirectly collects a variety of information through your interaction with and use of HiPER Solutions websites. This information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, content information based on your individual interests, demographic information, geographic or geo-location information, statistical and aggregated information ("Other Information").

Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users in a particular zip code.

If HiPER Solutions combines Other Information with Personal Information, we will treat the combined information as Personal Information.

The private individual data collected upon completion of the Executive Insight assessment is considered to be owned by the individual, with HiPER Solutions obtaining permission to utilize for business purposes, such as in a Team Dynamic review, and is governed by privacy frameworks and laws such as CCPA and GDPR. The customer data collected upon completion of the Team Insights assessment is considered to be owned by the customer corporation and is governed by the subscription agreement with said customer organization.

Tracking Data and Third Party Analytics Providers

Website traffic volume and patterns, such as the number of visitors to a given website or page on a daily basis is typically referred to as Tracking Data. This type of indirectly collected information is gathered through various means, such as an IP address, which is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers, the computers that "serve up" Web pages, automatically identify your computer by its IP address. When you visit any HiPER Solutions Websites, our servers log your computer's IP address.

To obtain these Tracking Data, HiPER Solutions uses third party analytics providers ("Third Party Analytics Providers"). The Third Party Analytics Providers use cookies to help us analyze how users use HiPER Solutions websites. The information generated by the cookie about your use of HiPER Solutions websites, including your IP address, will be transmitted to and stored by Third Party Analytics Providers' servers. On behalf of HiPER Solutions, the Third Party Analytics Providers will use this information for the purpose of evaluating your use of HiPER Solutions websites, compiling reports on website activity, and providing other services relating to website activity. The Third Party Analytics Providers will not associate your IP address with any other data held by them. This processing is necessary for the purpose of HiPER Solutions’ legitimate interests in accordance with Art. 6 (1) 1 lit. f) GDPR, in particular, to ensure the proper functioning of our website.

For the abovementioned purpose HiPER Solutions uses the following Third Party Analytics Providers: Google Analytics. Google Analytics is a service from Google, Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA; hereinafter "Google") using cookies which are saved on your computer. The information generated by the cookie is transferred to and stored on a Google server (generally) located in the USA. Google uses this information on our behalf in order to analyze the use of our websites. The IP address transferred from your browser through Google Analytics is not merged with other data by Google for profiling purposes.

You can prevent Google Analytics' collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available here.

Further information can be found in the Google Analytics Terms of Service.

Cookies for advertising

We may use third-party advertising companies to serve ads on our behalf. These companies may use cookies and action tags to measure advertising effectiveness. You can still decide whether you want to accept these cookies by way of consent. You may adjust your browser settings to prevent the reception of third-party cookies, or to provide notification whenever such third-party cookies are sent to you. If you do not accept these cookies, we will not be able to show you personalized content and ads.

Information Collected Directly

HiPER Solutions also collects Personal Information and other information that users voluntarily provide. It is entirely your decision to provide the requested information and all customers are notified at the time of collection what is being collected and what HiPER Solutions will use that information for.

USE OF PERSONAL INFORMATION

Disclosure of your information

We will share your Personal Information with third parties only in the ways that are described in this Privacy Policy. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Information with certain third parties without further notice to you, as set forth below.

HiPER Solutions may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share an answer in an assessment, we will utilize that information to provide you assessment results. If you provide your personal information to purchase an assessment we will use that information to deliver the assessment to you and link your answers to you as an individual (or in the case of organizational assessments we will link anonymous answers to the organization’s team assessment). HiPER Solutions may also save some personal information, such as name and email address, to facilitate new product orders.

  • To provide, support, personalize, and develop our products and services.

  • To create, maintain, customize, and secure your account with us.

  • To provide you with support and respond to your inquiries, including to investigate and address your concerns and monitor and improve our services.

Additional 3rd Party Service Providers:

HiPER Solutions engages with certain trusted third parties to perform functions and provide services to us, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationship, database storage and management, and direct marketing campaigns. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.

Affiliates
To provide the Site and various services to you, we may use the efforts of our affiliates, and any subsidiaries, joint ventures, or other companies, existing or formed in the future, under a common control (collectively, “Affiliates”). We may share some or all of your Personal Information with our Affiliates in which case we will require our Affiliates to honor this Privacy Policy.

Business Transfers
As we develop our business, we might sell or buy businesses or assets. In the event we are acquired by or merged with a third party, we reserve the right to transfer or assign the information we have collected from our users as a part of such merger, acquisition, sale, or other change of control. In an event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors’ rights generally, your Personal Information may be transferred by the trustee. If HiPER Solutions or any of its Affiliates is acquired by or merged with a third party, that third party will possess the Personal Information in HiPER Solutions’ or its Affiliate’s possession and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

Anonymous and De-Identified Information
We may create Anonymous and De-Identified Information records from Personal Information by excluding information (such as your name) that would otherwise make such data personally identifiable to you or collecting information in such a way we are not aware of your identity. We reserve the right to use and disclose Anonymous Information at our discretion.

Sales of Personal Information:

In the preceding twelve (12) months, HiPER Solutions has sold the following categories of Personal Information:

Category Type Sale Information

Category A: Identifiers [None]

Category B: California Consumer Records [None] Personal Information Categories

Category C: Protected classification characteristics [None] under California or Federal Law

Category D: Commercial Information [None]

Other Disclosures
Regardless of any choices you make regarding your Personal Information (as described below), we may disclose your Personal Information (i) to respond to subpoenas, warrants, court orders, lawful requests or legal process, (ii) to establish or exercise our legal rights or defend against legal claims or protect other users, (iii) in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or as otherwise required by law, or (iv) to investigate, prevent, or take action regarding any violation of this Privacy Policy or the Terms.

EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS

To exercise the access, data portability, and deletion rights described in our privacy policy, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child (Note: HiPER Solutions does not collect data on minors).

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

HiPER Solutions provides assessment and consulting services to individuals and organizations. A verifiable request is made by a current or prior customer of HiPER Solutions and provides information that can verify an individual’s identity in accordance with HiPER Solutions records to include prior registered email, month and year of birth, approximate date of HiPER Solutions service delivery, and legal name.  We will only use this personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

HiPER Solutions Non-Discrimination Provision

HiPER Solutions will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services once paid for

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties

  • Provide you a different level or quality of goods or services

  • Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

SECURITY

We follow generally accepted industry security standards to protect the Personal Information submitted to us; however, as no amount of security is failsafe customers by accepting this Privacy Policy you acknowledge that Personal Information is shared at your own risk.

CHILDREN

HiPER Solutions does not knowingly collect or maintain Personal Information from or about children under the age of thirteen (13) and the Site is not intended to be used by persons under thirteen (13). If you are under the age of thirteen (13), please do not use the Site at any time nor in any manner. If you find that we have personal information about anyone below thirteen (13) years of age on our website, please inform us at help@thehsg.com.

THIRD PARTY TOOLS, PROMOTIONS, AND LINKS

Please be aware that the terms of our Privacy Policy do not apply to third party websites, products, services, or content or to links provided for the foregoing on our Site. Third party providers of such third party websites, products, services, or content, may collect (via tracking technologies like cookies or web beacons) and use anonymous information regarding your interaction with the third party website, product, service, or content that they deliver and with which you interact. Your browsing and interaction on any third-party website or service, including those that have a link on our Site, are subject to that third party’s own rules and policies.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is reviewed yearly and may be amended by us from time to time. If we make material changes to this Privacy Policy, we will notify you by posting the revised Privacy Policy on our Site or notifying you at the email address we have on file (as specified in your contact information). Your continued use of the Site after such notification of changes as described above will constitute your agreement to such changes. If you object to any change, your sole recourse shall be to immediately cease using the Site and contact us at help@thehsg.com to request deletion of your Personal Information.

QUESTIONS AND ADDITIONAL INFORMATION

Please feel free to contact us at help@thehsg.com if you have any questions this Privacy Policy or HiPER Solutions’ privacy practices.

© 2020, HiPER Solutions LLC, All Rights Reserved.