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Privacy Policy

Introduction
We protect your privacy.
This Privacy Notice explains how we will collect, handle, store and protect information about you collected from the Web pages of any website or application with respect to which this Privacy Notice is posted or linked (collectively referred to as the “Website”), or any other mode of interacting with you relating to HighPerfPeople communications, such as online or offline newsletters, that reference this Privacy Notice (“Communication”). By using the Website, or continuing to receive Communications, you agree to the use of such information in accordance with this Privacy Notice.

This Privacy Notice also contains information about when we share your Personal Information with other members of HighPerfPeople and other third parties (for example, our customers or service providers).

Information collection
Personal Information refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, or household.

We may collect Personal Information when you interact with the Website or because you give it to us (for example, in a form on our Website).  Depending on the specific Communication you are receiving, or the Web page of the Website you are using, such information may consist of: your name; current job title; company name; e-mail address; country of residence; telephone and fax number(s); physical address(es);  gender; date of birth; marital status; employment and education details (such as learning history, work experience and skills); geolocation; certificate or license number; account number; photograph, video or audio recording identifiable to an individual; your postings on any blogs, forums, wikis and any other social media applications that we provide; your IP address; your browser type and language; your access times; complaint details; correspondence with you; the newsletters you subscribe to; information relevant to providing services to you; and any other information that you voluntarily provide to us. We may also collect or obtain Personal Information from you because of the way you interact with us or others.

We do not usually seek to collect ‘sensitive’ or ‘special categories’ of Personal Information (e.g., data relating to race or ethnic origin, religious or philosophical beliefs, trade union membership, political opinions, medical or health conditions, or information specifying the sex life or sexual orientation of an individual) through your use of this Website. The types of ‘special categories’ of Personal Information that we collect may vary depending on how you use this Website. In some rare circumstances, we might gather special categories of Personal Information about you because you volunteer that data to us, or we are required to gather that data as a result of legal requirements imposed on us.  We will, where necessary, obtain your explicit consent to collect and use such information.

Log information, cookies and web beacons
When you access the Website, we may collect standard Internet log information including your IP address, browser type and language, access times and referring website addresses. To ensure that the Website, and Communications are well managed and to facilitate improved navigation, we or our service provider(s) may also use cookies (small text files stored in a user’s browser) or web beacons (electronic images that allow us to count users who have accessed particular content and to access certain cookies) to collect aggregate data. Additional information on how we may use cookies and other tracking technologies and how you can control these can be found in our Cookie Notice.

Information use
Use of Personal Information collected via our Website
We may use your Personal Information collected:
to verify your identity each time you log in to the Website;
to manage your account and improve our Website;
to manage and promote collaboration and communication;
to provide and document training and qualifications;
to tailor the content of our Website to provide you with a more personalized experience; and
to manage our relationship with you and respond to any request you submit through our Website.
Use of Personal Information for other activities that form part of the operation of our business
In addition to the purposes connected to the operation of our Website, we may use your Personal Information for the purposes of, or in connection with:
applicable legal or regulatory requirements;
requests and communications from competent authorities; and
protecting our rights.

Access to the Website may be subject to review, monitoring and recording at any time to help us confirm compliance with applicable Terms of Use and that only authorized parties are accessing the Website.

Legal basis for processing information
We are required by law to set out in this Privacy Notice the legal grounds on which we rely in order to process your Personal Information.
We use your Personal Information for the purposes outlined above because of: (a) our legitimate interests in the effective delivery of our Website related services offered to you; (b) our legitimate interests in the effective and lawful operation of our Website so long as such interests are not outweighed by your interests; (c) the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency.
To the extent that we process any sensitive Personal Information relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) the processing is necessary for the establishment, exercise or defense of legal claims or (iii) you have made the data manifestly public.
Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you. If you do not want to continue receiving any marketing materials from us, you can  unsubscribe from the Communication.

Disclosure of information to third parties
In connection with one or more of the purposes outlined in the “Information use” section above, we may disclose details about you to: other members of HighPerfPeople for legitimate business-related purposes; third parties that we provide services to or from.
In relation to Communications, we may also share your Personal Information with service providers in connection with the delivery of such Communications.
We may also need to disclose your Personal Information if required to do so by law, by a regulator or during legal proceedings.
Please note that some of the recipients of your Personal Information referenced above may be based in countries without data protection laws similar to those in effect in your area of residence. In such cases, we will ensure that there are adequate safeguards in place to protect your Personal Information that comply with our legal obligations. For example, the adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of Personal Information to third countries.
Further details of the transfers described above, and the adequate safeguards used by us in respect of such transfers, are also available from us. For such information, please contact us by using the “Contact information” section below.
Under applicable law, you may be entitled to request information concerning whether your Personal Information has been disclosed to nonaffiliated third parties for their direct marketing purposes. We do not share your personal information with nonaffiliated third parties for such purposes.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.

Selling of information
We do not sell your personal information.
Blogs, forums, wikis and other social media
The Website may host various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively referred to as “Social Media Applications”). Any personal information or other information that you contribute to any Social Media Application can be read, collected and used by other users of that Social Media Application over whom we have little or no control. Therefore, we are not responsible for any other user’s use, misuse or misappropriation of any personal information or other information that you contribute to any Social Media Application.

Privacy practices of third parties
This Privacy Notice addresses only the use and disclosure of information we collect through your interaction with the Website. Other websites or applications that may be accessible through links from the Website have their own privacy notices and personal information collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy notices provided by these other parties prior to providing them with information.

Do not track
“Do Not Track” is a preference you can set in your web browser to let websites and applications you visit know that you do not want them collecting information about you. The Website does not currently respond to a “Do Not Track” or similar signal.

Information retention
We will hold your Personal Information on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law; (iii) the end of the period in which litigation or investigations might arise in respect of the services.

Your rights
Under applicable law, you may have various rights in relation to your Personal Information. In particular, you may have a right to:
obtain confirmation that we are processing your Personal Information and request a copy of the Personal Information we hold about you;
ask that we update the Personal Information we hold about you, or ask that we correct such Personal Information that you think is incorrect or incomplete;
ask that we delete Personal Information that we hold about you, or restrict the way in which we use such Personal Information; and
object to our processing of your Personal Information.
Where applicable, if you decide that you no longer wish to have your third party social network site account (e.g., LinkedIn, Facebook, or Twitter) linked to your profile on the Website, please change the settings in your third-party social network site account.

If you are unsatisfied with the way in which we have handled your Personal Information or any privacy query or request that you have raised to us, you have a right to complain to the data protection authority in your jurisdiction. For such information, please contact us by using the “Contact information” section below.

Verification of Personal Information requests
For certain personal information requests, we must first verify your identity before processing your request. To do so, we may ask you to provide us with your full name, contact information, and relationship to HighPerfPeople. Depending on your request, we may ask you to provide additional information. Once we receive this information, we will then review it and determine whether we are able to match it to the information HighPerfPeople maintains about you to verify your identity.

Third party requests
If you are submitting a personal information request on behalf of someone other than yourself, please contact us by using the “Contact information” section below and include proof that you are authorized to make the request. This may be in the form of a written authorization signed by the person whom you are acting on behalf of or a valid power of attorney.

Changes to this Privacy Notice
We may modify or amend this Privacy Notice from time to time.
To let you know when we make changes to this Privacy Notice, we will amend the revision date at the top of this page. The new modified or amended Privacy Notice will apply from that revision date. Therefore, we encourage you to periodically review this Privacy Notice to be informed about how we are protecting your information.