- Types of Information We Collect
- How We Collect Information
- How We Use Your Information
- How We Respond to “Do Not Track” Signals
- Communications with You
- Information Sharing with Third Parties
- Site Not Directed to Children
- Protection of Personally Identifiable Information
- Updating Your Information
- Notice of Privacy Rights of California Residents
- TYPES OF INFORMATION WE COLLECT
We may collect personally identifiable information and non-personally identifiable information about you. Personally identifiable information refers to your name and contact information, and any other information that is maintained in a manner that links the information to your name, contact information or other information that would identify you as the individual to whom the information relates. Personally identifiable information may include, but is not limited to, your first and last name, employer name and address, title, email address, home address, date of birth, telephone number, photo or audio/video recording, or professional biography. We also may collect information about your gender, dietary restrictions, username and password, participation in events and activities, billing information, transaction history, account profile, preferences, User Content (defined below), information that you provide relating to other members or participants, and other non-public information that you may provide or that we may collect from others about you.
Non-personally identifiable information refers to information that does not personally identify you as the individual to whom the information relates, such as information that is aggregated by HES or a third party, or information that is not linked to your name or contact information or other information that would identify you as the individual to whom the information relates.
We also may automatically collect certain information about your computer or device hardware and software and your use of the Sites. This may include information such as your IP address(es), usage statistics, browsing and navigational history when accessing or using the Sites, content you access, view, click on or search for when using the Sites and the length of time for which you view same, general geographic location such as the city from which your computer or device is connecting to the Internet, precise geographic location of your device if you are using a mobile app, webpages requested and visited, timestamps, cursor navigation, sites you visit prior to and after accessing the Sites, type of computer or device from which you access the Sites, type of operating system you use on your computer (e.g., Microsoft Windows or Mac OS) or device (e.g., iOS or Android) to access the Sites, the type of browser you use (e.g., Firefox, Chrome, Internet Explorer, Safari), the domain name of your internet service provider, as well as other information regarding your activities.
In addition, we may collect information regarding your Internet location if and when you see HES ads and whether you click on such ads, and information regarding your age, gender, zip code, occupation, preferences, interests, favorites, survey responses, connections, and other public or non-public information about you that we may acquire through the collection methods described below.
To the extent that any of the above information is maintained, used or shared by HES in a manner that associates it with your name, contact information or other personally identifiable information, it will be treated as personally identifiable information; otherwise, such information will be treated as non-personally identifiable information.
- HOW WE COLLECT INFORMATION
We may collect information about you during your online and offline interactions with HES and the Sites, such as when you:
- Access, use or browse the Sites;
- Register for a HES account, modify your account information, or create or modify your account profile;
- Sign up to receive HES announcements, emails or newsletters;
- Register for an event or program offered by HES;
- Contact, communicate with or otherwise interact with other members, participants at a program or Activity (defined below) offered by HES or its sponsor, or users of the Sites;
- Contact, communicate with or otherwise interact with HES or our personnel via the Sites, email, fax, telephone, or by other means whether online or offline;
- Order or request products, literature, services or other information from HES by online or offline means;
- Submit, post or transmit any User Content (defined below);
- Apply for a job at HES; or
- Register, enroll or participate in any surveys, questionnaires, promotions, or any other services or activities online or offline sponsored by HES or offered in connection with HES or the Sites (“Activities”).
We also may obtain information from third parties such as the owners or operators of the websites or applications where our advertisements appear (some of which may partner with HES or an advertising network used by HES), our service providers, affiliates, suppliers, vendors, distributors, other users of the Sites, Activities partners and sponsors, and other sources (e.g., offline records or publicly available information). Non-personally identifiable information also may be obtained by these other sources from inferences based upon the websites you visit; third party data; information you share on other websites, social media platforms and applications; or demographics derived from profiles or accounts that you create. We may combine personally identifiable information we collect with information that we obtain from these sources. We will treat any such combined information as personally identifiable information.
HES may automatically receive and record non-personally identifiable information on our server logs from your browser as well as through other analysis of the Sites. We also may collect information using cookies, web beacons, pixels, gifs, tags or similar collection technologies (together, “Cookies”), or through third parties using similar technologies.
- “Demographics and Interest Reporting” to analyze information regarding the interests and demographics of users of the Sites. We use such non-personally identifiable information in the same manner as we use other non-personally identifiable information as described below.
- “Remarketing with Google Analytics” to place ads on other sites directed to people who have accessed the Sites.
- “Google Display Network Impression Reporting” to report how people’s interactions with our ads relate to their visits to the Sites.
- Integrated services that require Google Analytics to collect data via advertising cookies and identifiers.
- HOW WE USE YOUR INFORMATION
We may use the information we collect about you for the following purposes:
- To process and respond to your requests and inquiries and provide services to you;
- To process your registration and attendance at events or programs, communicate with you about events or programs, and send communications between users of the Sites and participants in events, programs or Activities;
- To alert you to new developments, features, terms, products, services or promotions, or other Activities and to plan and administer same;
- To send you announcements, promotions, and newsletters, and to personalize same;
- To monitor and analyze information regarding your browsing and viewing preferences and to diagnose problems with the Sites;
- To carry out internal operations and to analyze our users’ demographics, interests and purchasing practices;
- To administer and process payments;
- To process your payments for events, programs and Activities;
- For administration and improvement of the Sites and to enhance the user experience and HES’s services;
- To promote, develop, deliver, and improve our services, products, content, and advertising;
- To send important notices about transactions and changes to our terms, conditions, and policies;
- For the purposes for which you provided the information;
- For fraud prevention, legal compliance, and other public and security related purposes;
- To alert you to other useful information regarding any of the foregoing or HES via email, direct mail, telephone, fax, text or other means
In addition to the uses discussed above, HES may use non-personally identifiable information in its de-identified or aggregated form without restriction. These uses may include, without limitation, analysis of website trends and how the Sites are used; improving navigation of the Sites; analysis of the performance of the Sites and diagnosis of problems; analysis and developing advertisements and advertising campaigns; and providing you with special offers and promotions and determining the effectiveness of same.
HES also may use your non-personally identifiable information to present you with targeted content and advertisements (including on third party websites and applications). Such targeted content and advertisements may include marketing for the Sites, products or services of HES or its business and advertising partners, and Activities. Your non-personally identifiable information also may be used to optimize and determine the effectiveness of content and advertisements, and to analyze interactions with content and advertisements.
Some of HES’s third party partners may participate in the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising or the Network Advertising Initiative Consumer Opt-Out, which programs allow consumers to opt-out of targeted advertising based on web activity tracking. For more information regarding the foregoing, please visit www.aboutads.info/choices/ and www.networkadvertising.org/choices/#completed. Please note that even if HES’s third party partners participate in the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising or the Network Advertising Initiative Consumer Opt-Out, if you opt out of targeted advertising based on web activity tracking, you still may receive standard advertisements from us and targeted advertisements from third parties after clicking the link and following the instructions provided therein. You may need to re-click the links and follow the instructions provided again if you delete Cookies or use a different computer, device or browser.
- HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
HES does not alter the practices detailed herein based upon your selection of the “Do Not Track” setting or other “opt out” setting or feature that may be offered by your browser; however, HES reserves the right to do so in the future without notice to you.
- COMMUNICATIONS WITH YOU
By accessing, using or browsing the Sites or interacting with HES, you authorize HES to transmit email or postal mail to you, text you, fax you, or telephone you. If we send any emails to promote our services, unsubscribe instructions will be included in each such promotional email from HES to the extent required by law. Please note that unsubscribe requests may take up to ten (10) business days to become effective. You may not opt out of receiving communications regarding your dealings with HES, the Sites or technical information about the Sites, or events or programs in which you register or participate.
- INFORMATION SHARING WITH THIRD PARTIES
HES may disclose the information it collects to third parties, including, but not limited to, (i) other participants for informational and networking purposes; (ii) event sponsors; (iii) vendors engaged by HES to manage, administer or execute an Activity; and (iv) agents, vendors, software licensors, merchants, advertisers, consultants and affiliates that work on behalf of HES to perform one or more of HES’s functions;
HES may request that participants sign a Confidentiality Pledge to commit to not publicly attribute discussions from any event, program or Activity to a specific member or organization, but HES takes no responsibility for participants’ compliance with such a pledge or for any disclosures of information learned at HES events or programs, or through HES, with or without attribution or alteration.
HES does not share your personally identifiable information with third parties for their direct marketing purposes.
Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified or aggregated form with event sponsors, advertisers, business partners or other third parties, to analyze participation in our programs, the Site’s usage or demographics, or improve our content or services, improve our user experience, or for similar purposes. When sharing non-personally identifiable in such a manner we will ask our contracting parties to agree to keep the data in its de-identified form.
The Sites also may contain plugins for social media platforms, such as LinkedIn and Twitter. HES is not responsible for the privacy practices of such social media platforms and recommends reviewing the privacy policies with respect to the plugins for these platforms prior to clicking on such plugins.
From time to time, portions of the Sites may include features that enable you to send information, materials, emails, and other types of messages or notices to HES or to others users of the Sites, create a profile in connection with your account accessible to other users of the Sites or the public, submit reviews, opinions, biographical information and other content that others may be able to access or view, or to make other information, materials or submissions available on or through the Sites (“User Content”). Although we are under no obligation to do so, we have the right to review, remove or modify all User Content, for any purpose, including without limitation to enforce any terms and/or policies of HES in our sole discretion. Some User Content is open to other users of the Sites or the public and may be indexable by search engines, and may be collected and used by others. Please use your discretion when deciding whether and what to transmit, submit or post through the Sites and whom to contact and message.
- SITES NOT DIRECTED TO CHILDREN
HES does not knowingly collect information from any person under age 18. If you are under age 18, you are not permitted to use the Sites or to submit any personally identifiable information to HES or the Sites. If you provide information to HES or the Sites, you represent that you are 18 years of age or older.
- PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION
HES uses reasonable administrative, physical and electronic security measures to protect against the loss, misuse and alteration of personally identifiable information. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of HES to intercept or access transmissions or private communications unlawfully. While we strive to protect personally identifiable information, neither HES nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk.
By using the Sites, or by submitting your personally identifiable information to HES online or offline, you expressly consent to the storage and processing of your personally identifiable information in the United States or other jurisdictions, in accordance with applicable laws in those jurisdictions.
- UPDATING YOUR INFORMATION
You are responsible for keeping your information current. You may update your information or cancel your account online through access to your account or by contacting us at email@example.com. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to HES’s internal reporting, processing, retention policies and legal obligations.
- YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident who has provided personally identifiable information to HES, you may be entitled by law to request certain information regarding disclosures of personally identifiable information that may have been made by HES to third parties for the third parties’ direct marketing purposes during the immediately preceding calendar year (“Disclosure Request”). To make such a Disclosure Request, please send an email to firstname.lastname@example.org. In the Disclosure Request, specify that you seek your “California Customer Choice Privacy Notice.” Please allow thirty (30) days for a response. HES is not required to respond to more than one Disclosure Request per customer each year, or to respond to requests made by means other than through the contact information designated above for such purposes.
However, because HES has adopted a policy of not sharing your personally identifiable information with third parties for their direct marketing purposes if you request that we do not do so, HES is not obligated by law to provide you with the requested information.
Last revised: October 10, 2018
HES takes reasonable steps to ensure that the Personal Data it processes is (i) relevant for the purposes for which the Personal Data is to be used; (ii) reliable for its intended use; and (iii) accurate, complete, and current.
HES keeps your Personal Data in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the Personal Data is processed.
If you are a data subject under the GDPR, you have the following rights regarding your Personal Data:
- Right of Access – the right to be informed of and request access to the Personal Data we process about you;
- Right to Rectification – the right to request that we amend or update your Personal Data where it is inaccurate or incomplete;
- Right to Withdraw Consent – the right to withdraw any consent at any time;
- Right to Erasure – the right to request that we delete your Personal Data;
- Right to Restrict Processing – the right to request that we temporarily or permanently stop processing all or some of your Personal Data;
- Right to Object –
- the right to object to us processing your Personal Data on grounds relating to your particular situation;
- the right to object to your Personal Data being processed for direct marketing purposes;
- Right to Data Portability – the right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service; and
- Right Not to Be Subject to Automated Decision-making – the right to not be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
Please contact HES at email@example.com if you would like to exercise any of these rights or have any questions about how we process your Personal Data. You are free to lodge a complaint with the relevant and applicable supervisory authority, should you feel that we have processed your Personal Data in way that is against applicable law.
Last revised: October 10, 2018
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