1.Introduction
This Digital Channels Privacy and Cookie Notice ("Notice") applies to the HFL Group of companies, which means HFLLtd, Canada-India-UAE and each entity in which HFL Ltd, Canada-UAE-India, directly or indirectly, has a majorityholding or owns or controls the majority of voting rights and the partners, value providers, Technical and VocationalEducation and Training organizations (TVET), and Registered Training Organizations (RTO). The HFL company that iscommunicating with you or to which you are providing goods or services (referred to as "HFL" or “we”, “us”, “our”),is responsible for the processing of your personal data and other information related to you (such as cookies) andcontrols how it is used, in accordance with this Notice.
At HFL, respecting your data protection rights is a top priority. This Notice explains how we use personal data and other information about you, how we process such data, and what rights you have regarding your personal data.
2.Who is responsible for the processing of your personal data?
HFL Ltd and its subsidiary companies, partners, value providers, TVETs, and RTOs are responsible for your personaldata. For applicable privacy and data protection laws, the primary controller of your data is the HFL subsidiarycompany, which is communicating with you. Other subsidiary companies of HFL, partners, value providers, TVETs,and RTOs may also receive and process your personal data, either in the capacity of controller or processor and thisNotice applies equally to them.
3.The types of information we collect and use?
We collect and use personal data that concerns you in connection with use of our digital channels and all HFL,partners, value providers, TVETs, and RTOs services. We may collect the following categories of personal data andother information related to you (such as cookies):
•Identification data and business contact information, you share with us such as first name, last name,job/position/title, business email address, business address, telephone number, mobile telephone number, telefaxnumber, private telephone number, gender, date of birth, login credentials.
•Additional information you provide to us in the course of your use of the platform, register for HUMI, avail anaccount and providing the service requested such as interests in HFL products, subscription preferences, personalpreferences, profile information (cv), posts on digital channels, texts, comments, opinions, images, videos, voices,credit card and other payment information.
• Electronic identification data and information collected by the communications systems, ICTSP (Information andCommunications Technology Systems and Processes) applications and website browser such as informationtechnology usage (system access, ICTSP and internet usage), device identifier (mobile device ID, IP address, browsertype, browser settings, time and URL accessed, cookies), registration and login credentials, login data and log files,analytics ID, searches, website registration and sound recordings (e.g. voice mail/phone recordings, MS Teams /WebEx / other online-platform and Face to Face engagement recordings).
In case you would like to be provided with information about a specific personal data processing activity, you can request that by furnishing your valid HUMI number and submitting a request at www.houseforlearning.com/privacy. 4.Why we use your personal data?We may use your personal data and other information as described above for the following purposes:
•to understand your interests and preferences in relation to the HFL digital channels;
•to register an account, grant you access to and authenticate you on HFL's digital channels;
•to subscribe and in the course of the subscription to follow comments, posts, articles, authors, news, and updatesabout HFL products and services;
• in the course of creation of and publishing media and press releases, to create brochures, news, media assets (suchas text, images, audios, videos), newsletters etc.
•in order to create articles that will be published on HFL’s internal and external digital channels;
•to provide you the possibility to create your profile on HFL digital channels for example to create posts, makecomments, follow posts and discussions and sign-up for newsletters etc.
• to allow you making posts, comments, upload content, participate in quizzes and publishing opinions on HFL digitalchannels;
•in the course of sharing job adds on HFL’s digital channels;
•to provide customer support and process, evaluate and respond to requests and inquiries;
•to collect your image and your personal data in the course of an event to show impressions of an event; and
•to create lists of contact persons for specific topics.
We only collect the personal data from you that we need for the above purposes. For statistical purposes, improvement of our services and testing of our ICTSP systems and processes, we use as much as reasonably possible anonymized data. This means that these data can no longer (in)directly identify you or single you out as an individual.
We offer certain digital channels where you can post information on the site which will then be available to other visitors of the site. Examples are discussion forums and comments on blogs. When you post, basic information identifying you as the poster will be made available to other visitors together with your posted information. This information includes your name or alias, and where relevant, may include other information such as your country or the name of the company or organization you work for. You have control over this data in your user profile and can control what will be shown in your posts.
We may also display statistical, reputational, and other similar information related to your user account. Examples are the number of forum posts you have posted or a rating showing how useful other visitors have rated your posts. For details, please see the help pages for each service.
5.What happens if you do not provide us with the information we had asked you for or if you ask us to stopprocessing your information
Where it concerns processing operations related to HFL digital channels (as described above), HFL will not be able to adequately establish, conduct or terminate a business relationship with you or your company and generally perform the purposes described above without certain personal data. Although we cannot obligate you to share your personal data with us, please note that this then may have consequences which could affect the use of the platform in a negative manner, such as not being able to provide the requested service, take requested pre-contractual measures to enter into a contract with you or to establish and continue the business.
6.The legal basis we rely on
We use your personal data and other information related to you for the purposes described in this notice based onone of the following legal bases, as applicable:
•We may process your personal data for the fulfilment of contractual obligations resulting from contracts with youor your company, or as part of pre-contractual measures we take;
•We will ask your consent for the activities described in this privacy notice when required by applicable law, forexample when we process your data for carrying out analytics by the use of first- and third-party cookies; or
•In some cases, we rely on our legitimate interests to process your personal data insofar as this is not overriddenby your own privacy interests. Such interests may include:
•Better understand users’ behavior to further improve our offerings
•Purposes of ensuring network and information security (for example to prevent malicious use such as hacking anddenial of service attacks)
•Offering a personalized service and communications
•Analytics and profiling for business intelligence
•Allowing interaction on products and services offered by HFL
You may obtain a copy of our assessment of why we may process your personal data for these interests by furnishing your valid HUMI number and submitting a request at www.houseforlearning.com/privacy.
7.Parties we share your personal data within Canada (CA), and outside Canada being - USA (Northern America—the northern region of the North American continent (including Canada), the United States, Greenland, Saint-Pierre and Miquelon, and Bermuda. Central America—the countries south of the United States and northof Colombia. Caribbean. South America—all the countries south of Panama), EU, EEA, EFTA, Schengen,Eastern Europe and Northern Asia, Southeast Asia, East Asia, Central Asia, South Asia, and SouthwestAsia (also known as the Middle East), North Africa, West Africa, Central Africa, East Africa, Southern Africa,and the “Sixth Region“, which constitutes the African Diaspora, Antarctic Peninsula, East Antarctica, SouthPole, West Antarctica, and the Ross Sea, or outside the country where the HFL company that controls yourdata is located)
HFL data privacy governance process complies with the requirements of: -
•Canada’s PIPEDA (Personal Information Protection and Electronic Documents Act) of 2020;
•USA’s Data Protection Laws and Regulations 2020;
•The California Online Privacy Protection Act | USA (CalOPPA) of 2004
•California Consumer Privacy Act | USA (CCPA) of 2020
•Indian (IN’s) Personal Data Protection Bill 2019;
•Singapore’s (SG’s) PDPA (Personal Data Protection Act)
•European Union (EU’s) GDPR (General Data Protection Regulation);
•European Union’s ePrivacy Directive & Regulation (ePrivacy)
•Russia’s Data Protection Law
•China’s (CN’s) Personal Data Protection Law (First Draft released on 13 October 2020)
•Australia’s (AU’s) The Federal Privacy Act 1988 (Cth) (Privacy Act) and its Australian Privacy Principles (APPs)
•Philippines Data Privacy Act of 2012
•South Africa’s Protection of Personal Information Act (POPI ) of 2014
•Senegal’s Data Protection Act
•Germany’s Bundesdatenschutzgesetz (BDSG)
•Argentina’s National Directorate of Personal Data Protection (PDP) of 2017•Brazil’s Lei Geral de Proteção de Dados Pessoais (LGPD) of 2020
•Chile’s data protection law, Law No. 19,628 on Privacy Protection (“Data Privacy Act”) of 1999
•Egypt’s Personal Data Protection Law No. 151/2020 (PDPL) of 2020
•Israel’s The Protection of Privacy Regulations (Data Security), 2017 (the Data Security Regulations)
•Japan’s Act on the Protection of Personal Information (“APPI”) of 2003
•New Zealand’s The Privacy Act 2020
•Nigeria’s Data Privacy and Data Protection Law of 2022
•South Korea’s The Personal Information Protection Act (PIPA) of 2011
•Switzerland's Data Protection Act "Datenschutzgesetz" (DSG) of 2020
•Thailand’s Personal Data Protection Act (PDPA) of 2019
•Turkey's Law on Personal Data Protection (LPDP) of 2016
We only share your personal data with other HFL affiliates or third parties as necessary for the purposes described in the table below. In certain services we offer, your group membership and user profile may be visible to other users in the same group and such user data is also visible to you. Where we share your personal data with an affiliate or third party so that it is transferred to or becomes accessible from outside Canada (“CA”) and the North American continent ("NA") or outside the country where the HFL company that controls your data is located, we always put adequate safeguards in place to protect your personal data. Examples of these safeguards are an adequacy decision of the regional or / and country commission, Standard Contractual Clauses (latest versions available on public websites in English language), Privacy Shield certification, and the Binding HFL Corporate Rules. We have taken
additional measures for the transfer of data from within to outside the CA, USA, UAE, IN, and outside the country where the HFL company that controls your data is located to protect your personal data. If you would like an overview of the safeguards, which are in place, please furnish your valid HUMI number and submit a request at www.houseforlearning.com/privacyRecipient category Recipient location Purpose HFL affiliates and subsidiaries See the list of HFL subsidiaries The purposes described in this privacy notice HFL business partners, distributors, and agents CA/NA/SA/EU/EEA/ETFA/Schengen/EU & NA/IMEA/APAC and non-CA/ (global) The purposes described in this privacy notice Service providers such as ICTSP services and independent agents working on HFL’s behalf CA/NA/SA/EU/EEA/ETFA/Schengen/EU & NA/IMEA/APAC and non-CA/ (global) The purposes described in this privacy notice Potential or actual acquirers of HFL businesses or assets CA/NA/SA/EU/EEA/ETFA/Schengen/EU & NA/IMEA/APAC and non-CA/ (global) For the evaluation of the business or assets in question or for the purposes described in this privacy notice Recipients as required by applicable law or legal process, to law enforcement or government authorities, etc. CA/NA/SA/EU/EEA/ETFA/Schengen/EU & NA/IMEA/APAC and non-CA/ (global) Where required by applicable law or a legitimate request by government authorities, or a valid legal requirement
8.How long we keep your personal dataBased on mandatory legislation, HFL must keep certain personal data for a minimum period of time. We only keepyour personal data for as long as necessary for the purposes described in this privacy notice. After this time, we willsecurely delete your personal data, unless we are required to keep it in order to meet legal or regulatory obligations,or to resolve potential disputes. Note, HFL will to the extent necessary delete posts, articles, press releases or destroybrochures, where your image was used; and will remove it from all databases to avoid further usage. At the sametime, applicable data protection laws require that we do not keep personal data in an identifiable form for any longerthan is necessary for the purpose for which the personal data is being processed. Through the setting up of ICTSPapplications and policies we ensure that our keeping of your personal data is deleted when we no longer need it.For more information regarding specific retention periods that apply to your personal data, please furnish your validHUMI number and submit a request at www.houseforlearning.com/privacy.9.Your data privacy rightsDepending on the jurisdiction in which you are located and in which your personal data is processed, you may havethe following rights:Data privacy rights What it means The right to access your data You are entitled to ask HFL for an overview of or to obtain a copy of the personal data we hold about you. The right to have your data corrected You may request immediate correction of inaccurate or incomplete personal data we hold about you. The right to have your data erased You may request personal data to be erased when it is no longer needed, where applicable law obliges us to delete the data or the processing of it is unlawful. The right to restrict data processing You have the right to restrict the processing of your personal data in specific circumstances. The right to data portability You have the right to receive your personal data in a structured, machine-readable format for your own purposes, or to request us to transfer it to a third party. The right to object to data processing You have the right to object to our processing of your personal data where we rely on our legitimate interests as the basis for our processing, where your data protection rights outweigh our reasoning for legitimate interests. The right to withdraw consent Where HFL has asked for your consent to process personal data, you may withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Please note that the rights described above are not absolute, and that your request cannot always be met entirely. For example, sometimes we cannot delete or restrict the processing of your personal data as we may have legal obligations or contractual obligations to keep certain such personal data. You may furnish your valid HUMI number and submit a request to enforce your data privacy rights at www.houseforlearning.com/privacy
10.Contact and further informationIf you want to access your personal data, make use of any of your other rights mentioned above or if you have any questions or concerns about how HFL processes your personal data, please contact us at hfl.ceo@icloud.com, or furnish your valid HUMI number and submit your complaint at http://www.houseforlearning.com/privacy. Should you not be satisfied with our response or believe we are processing your personal data against the law, you may also have the right to file a complaint with the Data Privacy Authority in your country of residence or work, or seek a remedy through the courts where you believe an infringement of data privacy laws may have taken place.11.LinksThe external sites linked to from the HFL web sites are developed by people over whom HFL exercises no control. These other sites may place their own cookies on your computer, collect data or solicit personal information. Please refer to the privacy notice on each site for more information.12.Cookie PolicyA cookie is a small text file that a website stores on your computer or mobile device when you visit the site. We use cookies to improve the quality of our service and to better understand how people use our websites. We do this by storing user preferences in cookies and by tracking user trends and patterns of how people navigate our sites. We use cookies to distinguish visitors from each other by assigning a random anonymous identifier to each visitor. We may collect information about your browsing habits on our website (such as pages visited, links clicked on, length of time spent on certain pages etc.).
Cookies specific to the HFL website
HFL’s website uses both "first party" cookies (cookies set by the HFL website) and "third party" cookies (cookies set by a third-party website that is providing a service for the HFL website). We use first party cookies for keeping the website running, improving user experience, creating a profile of your interest to provide you tailored information according to your expressed interests storing preferences, tracking user trends and patterns with the help of web statistics providers and for storing data needed throughout your visit on the site (for example, contents of your shopping cart). We use third party cookies for analytics purposes.
Our website may use cookies of the following kinds:
•Strictly necessary cookies: Used for purposes such as to route the information over the network and detecttransmission errors, control of electronic communication channels and traffic load, etc. These cookies are necessaryfor the website to function and cannot be switched off in our systems.
•Functional cookies: Used for purposes such as to remember your settings and preferences, history of your visit onthe site, user authentication (logging in), increase the security, allow social networks users to share contents andwhen needed to play back video or audio content. These cookies are necessary to provide specific functionalities toyou as a part of the services you have requested on the HFL digital channels.
•Social plug-in tracking cookies: Used by third party social network sites for purposes such as analytics when weembed content from their website on ours.
•First- and third-party analytics cookies: Used for HFL's purposes such as to measure the traffic, performance andusage patterns of our website, test improvements of the website, detect search engine keywords that lead to awebpage or to track down website navigation issues. In the case of third-party analytics cookies, the data isanonymized.
In general, cookie data are stored for the duration of up to 24 months. For more information regarding specific retention periods that apply to cookies, please furnish your valid HUMI number and submit a request at www.houseforlearning.com/privacyWe may provide links to third party integrations. Third party integrations are websites or platforms that synchronize with our Site to provide you with additional functionality, tools, or services such as a direction, collecting resumes, sharing documents or videos, or sending announcements. You acknowledge and agree we are not responsible for the availability of such sites or resources and do not endorse and are not responsible or liable for any content, advertising, goods, services, or other materials on, available through, or provided by such sites or resources. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of any of your personal information that you provide or is collected by such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites. How to manage cookies You can set your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features or services on our sites may not function properly without cookies. Date of publication: 16 December 2022