- The type of information we collect
- How IHRDC collects your information, including tracking and cookies
- How IHRDC uses your personal information
- How you can correct or update the information IHRDC has
- Rights to object or restrict processing of Personal Information
- Who we may share information with
- How we handle Do Not Track requests
- Linked sites and services
- Data security
- Retention of your information
- Notice of privacy rights to California residents
- Notice of privacy rights to residents of the European Union Area
- How to contact us
1. The type of information we collect
IHRDC may collect information that you provide to IHRDC in connection with your use of the IHRDC Services when you:
- Register your account with IHRDC as a user of the IHRDC Services (“Customers”)
- Make changes to your user profile information
- Send email messages, forms, or other information to IHRDC or other users using the IHRDC Services, or
- Install, use or otherwise interact with the IHRDC Services.
This information may include your first and last name, your address, email address, telephone number, your location, and any additional information you provide to IHRDC during the account registration process or via the IHRDC Services.
IHRDC may also collect certain technical information about your use of the IHRDC Services. This technical information may include technical information about your device(s), browser type and version, geo-location information, computer and connection information, statistics on page views, traffic to and from the IHRDC Services, ad data, Wi-Fi connection information, internet protocol (“IP”) address, and standard web log information.
Additionally, when expressing an interest in obtaining additional information about the IHRDC Services or registering to use the IHRDC Services, we require you to provide us with personal contact information, such as your name, company name, address, phone number, and email address (“Required Information”). Although we use third party service providers to process payments, when purchasing access to the IHRDC Services, we may require you to provide our payment processing service providers with financial and billing information, such as billing name and address, credit card number, and the number of employees within your company that will be using the IHRDC Services (“Financial Information”). We may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information about Customers are referred to collectively as “Customer Data.”
2. How IHRDC Collects Your Information; Tracking and Cookies
When you register for an account with IHRDC, we may ask you to provide us with certain information in order to create your account, and to provide you with our IHRDC Services. This information is collected by us when you fill out forms that may be provided to you through the IHRDC Services.
If Cookies are used, they may be used to collect information about you and your use of the IHRDC Services, such as your browser type, preferences, data relating to content that has been displayed to you or that you have clicked on, and the date and time of your use. Cookies may also be used in order to further features and processes on the IHRDC Services, provide authentication and security for your transactions using the IHRDC Services, store your preferences, facilitate relevant advertising, and help us learn more about how users engage with the IHRDC Services.
We sometimes use service providers to help us provide certain products and services or to integrate other features. These third-party providers may collect information when you view or use them, including information about you and your device or browser. They may do this using Cookies or similar technologies. These third-party providers also may use these technologies to help share information with us, like how you use their website or application. To learn more about the information they collect or receive, review their privacy policies.
As part of using our IHRDC Services, IHRDC’s Customers may submit to IHRDC electronic data or information (“Submitted Data”) that constitutes personal information of other individuals. Such data may include an individual’s name, email address, phone number or any other data that the Customer chooses to submit to us. IHRDC generally has no direct relationship with the individuals to whom Submitted Data may pertain. IHRDC processes Submitted Data on behalf of our Customers and any uses of Customer Data by IHRDC are done so pursuant to our Terms of IHRDC Services or a separate agreement in place between IHRDC and the applicable Customer, which governs our treatment of Submitted Data.
3. How IHRDC Uses Your Information
IHRDC may use your information to:
- Provide access to the IHRDC Services to communicate with you
- Personalize, customize, measure, and improve IHRDC’s products, services, content, and advertising
- Prevent, detect, and investigate potentially prohibited or illegal activities or a breach of the applicable agreement(s) between you and IHRDC
- Analyze the accuracy, effectiveness, usability, or popularity of the IHRDC Services
- Generate and review reports and data about IHRDC’s user base and IHRDC Services usage patterns
- Compile aggregate data for internal and external business purposes
- Resolve disputes and troubleshoot problems; and
- Contact you with information, including promotional, marketing, and advertising information and recommendations that IHRDC believes may be of interest to you.
Consistent with applicable laws, including United States CAN-SPAM laws, if you do not wish to receive commercial emails, you may unsubscribe following the instructions on any email. We may still send you administrative notices, however.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. In particular, you acknowledge that IHRDC is not responsible for any loss of any passwords or login information which you receive for access to IHRDC Services which results from your failure to keep that information secure.
4. Correcting and Updating Your Information
Customers may update or change their account information through their account settings accessible using the Customer account page included in the IHRDC Services. Access to your IHRDC account page will require your IHRDC Services username and password. To update your Financial Information or to delete your account information, please email [email protected].
You can access or change your profile and contact information or delete your account through the IHRDC settings page. If you choose to delete or deactivate your account, you can no longer retrieve content or reactivate your account.
You have the right to request access to any Personal Information which IHRDC may have about you by contacting [email protected]. The information will be provided in a machine-readable format. You may also ask that we transfer the Personal Information to a third party, which we will do if technically feasible.
You also have the right to review, add and update your Personal Information. You may also request the deletion of your Personal Information where:
- the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed,
- you withdraw consent to IHRDC’s possession of the information on which the processing is based and where there is no other legal ground for IHRDC’s retention of the information,
- you object to IHRDC’s possession of the information and there is no overriding legitimate basis for the retention,
- the personal information has been unlawfully obtained or processed, or
- the personal information has to be erased for compliance with a legal obligation in the European Union or other law to which IHRDC is subject.
When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
If your individual personal information has been submitted to us by a Customer as Submitted Data and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please first inquire with the Customer (or his/her organization) directly.
5. Consent to Commercial Electronic Messages
If you provide us with an email address, you expressly consent to receiving Commercial Electronic Messages from IHRDC about your use of the Website, the IHRDC Services and our Products. If you have any questions about IHRDC’s Commercial Electronic Messages, you can contact IHRDC at:
IHRDC, 535 Boylston Street, Boston, MA 02116
Attention: Chief Information Security Officer or by emailing [email protected]
In addition, you may opt out of receiving Commercial Electronic Messages at any time by emailing [email protected].
6. Rights to Object or Restrict Processing of Personal Information
If IHRDC has your Personal Information as a result of your relationship with one of IHRDC’s customers, you should first contact that customer before contacting IHRDC. You may, however, at any time revoke your consent to the collection, processing and use of your Personal Information by emailing [email protected]. Upon receipt of your request, IHRDC will delete your personal data provided IHRDC may retain any data which is required for billing and accounting purposes or which is subject to legal retention requirements. In addition, if you discover any errors in data, you may contact us by emailing [email protected] and we will correct it. You can always opt not to disclose information to us, but keep in mind some information may be needed to take advantage of product features or may be required by your relationship with one of IHRDC’s customers.
7. Right to be informed of appropriate safeguards where Personal Information is Transferred to a Third Country or to an International Organization
IHRDC enters into agreements with its customers regarding the safeguards that have been put in place to protect your Personal Information for transfer outside of Switzerland or the European Economic Area. For transfers to countries without an adequacy decision by Switzerland or the European Commission, IHRDC puts appropriate safeguards through contractual obligations.
8. Who We May Share Information With
IHRDC may disclose the information we collect from you to the following third parties:
Users of the IHRDC Services; Public Information. When you share information with us via the IHRDC Services, IHRDC may share your information to other users, in accordance with the privacy settings you have chosen for your account or that are applicable to that information. To the extent you share any information to a public audience or via a publicly accessible portion of the IHRDC Services such as an online customer community or forum, that information may be available to anyone who has access to that customer community or forum.
Credit Card Processing IHRDC Services. When you make a payment to IHRDC through our payment page, we may collect credit card information from you in order to properly process your payment. We do not store your credit card information on our servers and no one at IHRDC can access your credit card information. All credit card information that you share with us is maintained by a third-party payment processing merchant. We use industry standard encryption techniques and methods to protect all information sent to the payment processing merchants servers. Once your information reaches the payment processing merchant it resides on their server that is protected both physical and electronically.
IHRDC’s IHRDC Services Providers. IHRDC may share your information with third-party contractors, agents, collaborators, or service providers who provide certain services to IHRDC or on IHRDC’s behalf, such as operating and supporting the IHRDC Services. IHRDC may also request your information from a previous service provider, which we need to provide our services to you. Alternatively, IHRDC may pass on your information to a service provider that IHRDC customers have chosen to replace IHRDC.
Companies that Acquire IHRDC’s Business or Assets. If IHRDC becomes involved in a merger, acquisition, sale of assets, securities offering, bankruptcy, reorganization, or dissolution or if the ownership of all or substantially all of IHRDC’s business relating to the IHRDC Services otherwise changes, IHRDC may provide your information to a third party or parties in connection with the applicable transaction.
IHRDC’s Affiliates. IHRDC may share some or all of your information with IHRDC’s parent company, subsidiaries and corporate affiliates, joint ventures or other companies under common control with IHRDC.
IHRDC Customers. If IHRDC has received your information as part of Submitted Data, IHRDC may share that information, or any modifications or revisions to that information with that Customer.
Switching IHRDC Services Providers. IHRDC may request your information from your previous service provider, which we need to provide our services to you. Alternatively, IHRDC may pass on your information to a service provider that you have chosen to replace IHRDC.
Aggregate Information. IHRDC may share information relating to our visitors and users with affiliated or unaffiliated third parties on an aggregate basis, however this information will not identify you personally.
Legal Requirements. IHRDC may share your information with law enforcement, governmental agencies, or authorized third parties, in response to a request relating to a criminal investigation or alleged illegal activity or any other activity that may expose IHRDC, you, or any other IHRDC user to legal liability, or to protect IHRDC’s rights or property, or during emergencies when safety is at risk. IHRDC may also share your information in response to court orders, subpoenas, or other legal or regulatory requests, and IHRDC may provide access to your information to IHRDC’s legal counsel and other consultants in connection with actual or potential litigation. IHRDC shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless IHRDC proves that it is not responsible for the event giving rise to the damage.
9. How We Handle “Do Not Track” Requests
10. Linked Sites and IHRDC Services
IHRDC’s website or mobile application may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
11. Data Security
IHRDC takes reasonable measures to protect the information you provide to IHRDC or submit through the IHRDC Services against misuse, loss, theft, unauthorized use, disclosure, or modification. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk and your information may be disclosed to third parties in unforeseeable situations or situations that are not preventable even when commercially reasonably protections are employed, such as in the case that IHRDC or if the IHRDC Services are subject to a hacking or other attack. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
12. Retention of Your Information
13. Notice of Privacy Rights to California Residents
Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, information related to the personal information disclosed by IHRDC to third parties for direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing IHRDC at [email protected].
14. Notice of Privacy Rights to Residents of the European Economic Area
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at [email protected].
IHRDC’s Amsterdam office has been appointed as IHRDC’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. IHRDC’s Amsterdam office can be contacted in addition to [email protected] only on matters related to the processing of personal data. To make such an inquiry, please contact IHRDC’s Amsterdam office via our online form https://www.ihrdc.com/AboutIHRDC/PrivacyCenter/privacy-contact.asp or by telephone at: +31 299 373480.
Alternatively, IHRDC’s Amsterdam office can be contacted at:
IHRDC / Amsterdam
Jan Nieuwenhuizenplein 12
1135 WV Edam, The Netherlands
15. How to Contact Us
IHRDC / Headquarters
Attn: Chief Information Security Officer
535 Boylston Street
Boston, MA 02116 USA
In compliance with the Privacy Shield Principles, IHRDC commits to resolve complaints about our collection or use of your personal information. EU or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact IHRDC at [email protected] or via postal mail at:
IHRDC / Headquarters
Attn: Chief Information Security Officer
535 Boylston Street
Boston, MA 02116 USA
IHRDC has committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning personal data and human resources data transferred from the EU. IHRDC has committed to cooperate with the panel established by the Swiss data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning personal data from Switzerland with respect to personal data IHRDC receives under circumstances other than in the context of an employment relationship. IHRDC’s use of personal information is also subject to the investigatory and enforcement powers of the US Federal Trade Commission (“FTC”).
IHRDC has chosen the EU Data Protection Authorities through The United States Council for International Business, acting as a trusted third party on behalf of the EU and Swiss Data Protection Authorities, to serve as an Independent Recourse Mechanism (“IRM”) for dispute resolution arising from collection, use, and retention of personal information transferred from EU member countries or Switzerland to IHRDC.
This resource mechanism is available free of charge. The U.S. Department of Commerce agrees to cooperate with the EU DPA and the Swiss DPA to receive, review and undertake best efforts to facilitate resolution of the complaint and respond to the DPA within 90 days.
IHRDC also commits to binding arbitration at the request of the individual to address any complaint that has not been resolved by other recourse or enforcement mechanism.
Effective January 6, 2020