HHS TECHNOLOGY GROUP PRIVACY POLICY

This Privacy Policy (hereinafter – Policy) is effective as of May 1, 2018. Please note that this Policy will be updated in accordance with Company procedures to reflect HHS Technology Group changes of personal data management or changes in applicable laws.

This Policy includes all you need to know about how HHS Technology Group and/or its affiliates (“HHS”; “we”) protect the personal data we process and control relating to you (“your personal data”; “your data”) and the rights you have with regard to the processing of your personal data.

Further information on HHS (and, if relevant, its representatives) can be found here. Any HHS entity located outside the USA will for the purposes of compliance with data privacy laws be represented by HHS Technology Group, LLC.

Below, we first give a general description of how HHS protects your personal data. Further below, we include specific information concerning the following:

How do we use personal data when you visit HHS’s website?

How do we use cookies (and other tracking technologies)?

How do we use personal data for marketing purposes? 

  1. HOW DOES HHS PROTECT YOUR PERSONAL DATA?

HHS attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with HHS, your personal data is in good hands.

HHS protects your personal data in accordance with applicable laws and our privacy policy. In addition, HHS maintains the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.

The following sections provide further details as to how HHS processes your personal data:

  • Which categories of personal data do we collect and how do we process such personal data?
  • For which purposes and on which legal basis do we use your personal data?
  • Will we share your personal data with third parties?
  • What about sensitive data?
  • What about data security?
  • Where will your personal data be processed?
  • How long will your personal data be retained by HHS?
  • Which rights do you have with respect to the processing of your personal data?

 

Which categories of personal data do we collect and how do we process such personal data?

We collect personal data of our employees, potential employees, clients, suppliers, business contacts, shareholders and website users. If the data we collect is not listed in this Policy, we will provide individuals (when required by law) with appropriate notice of which other data will be collected and how it will be used.

Specifically, the personal data we collect includes the categories of personal data described in the sections “How do we use personal data when you visit HHS’s website?”, “How do we use cookies (and other tracking technologies)?” and “How do we use personal data for marketing purposes?”, as well as any other categories of personal data referred to in this Policy or in other statements you have received.

Except for certain information that is required by law, your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this Policy, and you may not be able to use all the benefits which require the use of such personal data.

If you provide us with personal data of another person (for instance, a referral), you are responsible for ensuring that such person is made aware of the information contained in this Policy and that the person has given you his/her consent for sharing the information with HHS.

The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or to leave us a message on our website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors.

For which purposes and on which legal basis do we use your personal data?

HHS uses your personal data only where required for specific purposes. Please see the table below for (i) a list of the purposes for which HHS uses your personal data and (ii) an overview of the legal basis for each such purpose.

Purpose Legal basis
Managing our contractual and/or employment relationship with you. Necessary for the performance of a contract to which you are a party.
Recruitment. Justified on the basis of our legitimate interests for ensuring that we recruit the appropriate employees.
Facilitating communication with you (including in case of emergencies, and to provide you with requested information). Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.
Operating and managing our business operations. Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Complying with legal requirements. Necessary for the compliance with a legal obligation to which we are subject.
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use). Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.
Improving the security and functioning of our website and information. Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our information are secure.
Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal data for marketing purposes?” below). Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.

 

Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy reviews and (iv) the rights you have in relation to the processing activity. Please contact us if you wish to obtain further information on this approach.

We will process your personal data for the purposes mentioned above based on your consent, to the extent such consent is mandatory under applicable laws.

We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

Will we share your personal data with third parties?

We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and HHS’s internal policies.

Unless you are otherwise notified, we do not anticipate any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA. Any transfers of your personal data, will take place in accordance with the appropriate international data transfer mechanisms and standards.

What about sensitive data?

We do not generally seek to collect sensitive data (also known as special categories) through our site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for consent.

The term “sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

What about data security?

We maintain organizational, physical and technical security arrangements for all the personal data we hold. We have relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.

We adopt best practice security measures to protect your personal data. This includes, but is not limited to, holding to the highest and strictest information security standards. These standards define the requirements for an Information Security Management, and confirm that HHS’s processes and security controls provide an effective framework for protecting our clients’ and our own information. We perform regular testing, to be sure of our technical defenses, and give you that confidence as well.

Regarding your use of our website, you should understand that the open nature of the internet is such that information and personal data flows over networks connecting you to our systems without security measures and may be accessed and used by people other than those for whom the data are intended.

Where will your personal data be processed?

As a global organization with offices and operations in different international locations, personal data we collect may be transferred or be accessible internationally throughout HHS’s global business and between its entities and affiliates.

Any such transfers throughout HHS’s global business take place in accordance with the applicable data privacy laws and in accordance with HHS’s Security Policy (SP).

Our SP reflects the standards contained in the US and European data privacy laws (including the General Data Protection Regulation). Having the Security Policy means that all our affiliated entities have to comply with the same internal rules and procedures. It also means that your rights (see “Which rights do you have with respect to the processing of your personal data?”) stay the same no matter where your data are processed by HHS.

Further information on HHS (and, if relevant, its representatives) can be found here. Any HHS entity located outside the USA will for the purposes of compliance with data privacy laws be represented by HHS Technology Group, LLC.

How long will your personal data be retained by us?

We will retain your personal data only for as long as is necessary. We maintain specific records management and retention procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:

We retain your data as long as we have an ongoing relationship with you (in particular, if you are a(n) employee/client/vendor/contractor of HHS).

We will only keep the data while your engagement with HHS is active or for as long as needed to provide services to you.

We retain your data for as long as needed in order to comply with our legal and contractual obligations.

Which rights do you have with respect to the processing of your personal data?

You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.

Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.

Object to the processing of your personal data: this right entitles you to request that HHS no longer processes your personal data.

Request the removal of your personal data: this right entitles you to request the removal of your personal data, including where such personal data would no longer be necessary to achieve the purposes.

Request the restriction of the processing of your personal data: this right entitles you to request that HHS only processes your personal data in limited circumstances, including with your consent.

Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to HHS, or request HHS to transmit such personal data to another data controller.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting HHS’s Privacy Officer . Please note that this will not affect HHS’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to HHS first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against HHS with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).

Contact us to exercise any of your rights.

  1. HOW DO WE USE PERSONAL DATA WHEN YOU VISIT HHS’S WEBSITE?

In addition to the information set out above, the following sections describe how we use personal data when you visit HHS’s website:

  • Which personal data do we gather?
  • Do we include (links to) websites and programs of third parties?
  • How do we use personal data that we collect from our websites?

 

Which personal data do we gather?

HHS collects personal data at its website in two ways: (1) directly (for example, when you provide personal data to contact us); and (2) indirectly (for example, through our website’s technology).

We may collect and process the following personal data:

Personal data that you provide by filling in forms on our website. This may include registering to use the website, subscribing to services, newsletters and alerts, requesting a white paper or further information. Pages that collect this type of personal data may provide further information as to why your personal data are needed and how it will be used. It is completely up to you whether you want to provide it.

If you contact us, we may keep a record of that correspondence.

We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

Any postings, comments or other content that you upload to an HHS website.

Our website collects personal data about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.

Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookies section below for more information.

Do we include (links to) websites and programs of third parties?

Our website may include:

Links to and from the sites of our partner networks, advertisers and affiliates.

Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.

We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.

How do we use personal data that we collect from our website?

We use personal data for the purposes described in the section “For which purposes and on which legal basis do we use your personal data?” above, as well as to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected. For example:

To fulfill your requests for white papers, articles, newsletters or other content.

For surveys or research questionnaires.

To personalize your experience on our website.

To contact you for marketing purposes where you have agreed.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the Cookies section below for more information.

  1. HOW DO WE USE COOKIES (AND OTHER TRACKING TECHNOLOGIES)?

In addition to the information set out above, this section describes how we use cookies and other tracking technologies.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.

Please see our Cookies policy for more details. By using our website, you agree that we can place cookies and other similar technologies on your device as explained in our Cookies policy. 

  1. HOW DO WE USE PERSONAL DATA FOR MARKETING PURPOSES?

In addition to the information set out above, the following sections describe how we use personal data for marketing purposes:

  • What are the sources of marketing data?
  • Do we send targeted e-mails?
  • Do we maintain Customer Relationship Management (CRM) databases?
  • Do we combine and analyze personal data?
  • Do we share personal data with third parties?
  • What are your rights regarding marketing communications?

 

What are the sources of marketing data?

The bulk of the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company.

Do we send targeted e-mails?

We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from HHS, we will also use a cookie to log what pages you view and what content you download from our website.

Targeted e-mails from HHS may include additional data privacy information, as required by applicable laws.

Do we maintain Customer Relationship Management (CRM) databases?

Like most companies, HHS uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of users of our website, and other business information included by professionals at HHS based on their personal interactions with you. If you wish to be excluded from our CRM databases, please contact us.

Do we combine and analyze personal data?

We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our website and information collected when you sign-up or log on to our site or connect to our site using your social media credentials (such as LinkedIn). We combine this data to better assess your experience with HHS and to perform the other activities described throughout this Privacy Policy.

Do we share personal data with third parties?

We do not share your personal data with third parties aside from those mentioned in the section “Will we share your personal data with third parties?” above.

What are your rights regarding marketing communications?

You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship management (CRM) databases at any time by contacting us. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.

  1. CONTACT US

Please click here to contact the HHS’s Privacy Officer if:

You have a general question about how HHS protects your personal data.

You wish to exercise your rights in relation to your personal data rights (as set out in the sections “Which rights do you have with respect to the processing of your personal data?” and “Your rights regarding marketing communications”).