Privacy policy
Last updated: October 14, 2023
Introduction. The purpose of this Privacy Policy is to describe how HR Participants, LLC. and its affiliated companies (“HRP” or “we” or “us”) collects, uses, and shares information about you generally, including through HRP’s online interfaces (e.g., websites and online portals) owned and controlled by us, including www.hrparticipants.com collectively referred to herein as the “Site”; all such data “Personal Data”).
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
You acknowledge that your continued use of the Site after we publish our changes to this Privacy Policy means that the collection, use, and sharing of your Personal Data is subject to the updated Privacy Policy.
Data this Privacy Policy Covers. This Privacy Policy covers Personal Data, including through our Site. Some of our Site’s functionality can be used without revealing any Personal Data, though for some features, Personal Data is required. In order to access certain features on our Site, you may need to submit or we may collect Personal Data. Personal Data does not include information that is anonymized.
Personal Data We Collect Related to Your Use of Our Website. We may track, collect, and aggregate information from your use of the Site, through the use of cookies or otherwise, indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect your IP address and standard log information, such as your browser type and operating system.
Personal Data We Collect Provided Directly by You or by Third Parties. We collect Personal Data that you provide to us when you register for an account, update or change information on your account, use our services, send email messages, and / or participate in other services on our Site. During registration and later on our platform, we may collect Personal Data such as your real name, alias, email address, phone number, postal address, current or past job history, unique personal identifier, online identifier, Internet Protocol address, account name, payment account information, Social Security number, or other similar information. We may also create Personal Data about you, such as records of your interactions with us, our clients, our other participants, or from third parties that provide us with it or access to it.
How We Use Your Personal Data. We may use your Personal Data for various purposes, subject to applicable law, including to:
Allow you to access and use the Site and to provide or facilitate your participation in certain information, products, or services that you request from us;
Operate, manage, and communicate with you via our Site;
Notify you of changes to our Site or services;
Monitor, improve, and develop our services;
Facilitate communications or transactions with you;
Share it with other parties as necessary in order for us to facilitate your participation in our services (e.g., cloud service providers, payment processors, etc.).
From time to time, we may use your email address to send you information and keep you informed of products and services in which you might be interested. You may at any time elect to stop receiving such emails. Your contact information may also be used to reach you regarding issues concerning your use of the Site, including changes to this Privacy Policy.
How We May Share Personal Data. We may, for legitimate business purposes, disclose your Personal Data to other parties, including:
Your appointed representatives;
Other HRP entities;
Professional advisors to HRP, such as accountants, auditors, and lawyers, and
Other parties as necessary in order for us to provide you with our services (e.g., cloud service providers, payment processors, etc.).
We may disclose your personal data to a third party if we believe in good faith that such disclosure is necessary or desirable (i) to comply with lawful requests, subpoenas, search warrants, or orders by public authorities, including to meet national security or law enforcement requirements, (ii) to address a violation of the law, (iii) to protect the rights, property, or safety of HRP, its users or the public, or (iv) to allow HRP to exercise its legal rights or respond to a legal claim.
If we engage a third party to process your Personal Data, that party will (i) only process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.
For Residents of the European Economic Area (EEA) and United Kingdom (UK) Only:
This Privacy Notice for EEA and UK Residents supplements and should be read in conjunction with the information contained in HRP’s Privacy Policy and applies solely to Site visitors, users of or participants in our services, and others who reside in the EEA. HRP is the data controller with respect to your Personal Data (“Controller”). The Controller is the entity that determines how and why Personal Data are processed. HRP retains your Personal Data until either it is no longer necessary for the purpose for which it was collected, you withdraw consent to process your data, or no other legal basis for processing exists. You can contact HRP via email at compliance@hrparticipants.com or data@hrparticipants.com.
Legal Basis for Data Processing. As explained above, we use your Personal Data in various ways depending on your use of the Site and/or participation in HRP’s services. We may process your Personal Data in reliance upon one or more of the following legal bases, depending on the circumstances: (1) with your consent; (2) as necessary to perform our agreement to provide services; (3) where required by applicable law; (4) where necessary to protect the vital interests of any individuals; or (5) where we have a legitimate interest.
Transfers of Personal Data. Personal Data we collect may be transferred to, and stored and processed in, the United States or any other country in which we, our affiliates, or third parties with whom we engage in order to provide our services maintain facilities. We will ensure that transfers of Personal Data to a third country or an international organization are subject to appropriate safeguard as described in Article 46 of the General Data Protection Regulation.
Right to Access and Correct Personal Data. You can access your Personal Data and confirm that it remains correct and current by emailing data@hrparticipants.com. You have the right to request access to your Personal Data and to receive a copy of your Personal Data, as well as certain information about our processing activities with respect to your Personal Data. You have the right to request correction or completion of your Personal Data if it is inaccurate or incomplete. You have the right to restrict our processing if you contest the accuracy of the data we hold about you, for as long as it takes to verify its accuracy. If you are a current HRP client or a current member of our participant panel and would like a copy of your Personal Data, please log in to the Site and click on the ‘Personal Data’ link at the bottom of the page and follow the instructions (if you are not a current HRP client or a current member of HRP’s participant panel and would like a copy of your Personal Data, please send an email to: data@hrparticipants.com).
Right to Request Data Erasure. You have the right to have your data erased from our Site if (i) the data is no longer necessary for the purpose for which it was collected, (ii) you withdraw consent and no other legal basis for processing exists, or (iii) you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing. Your Personal Data will generally be erased from the Site without undue delay and will be anonymized in order to be able, if necessary, to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms and Conditions or agreements, or fulfill your request to “unsubscribe” from further messages from us. If you would like to request the erasure of your Personal Data from our Site, please contact: data@hrparticipants.com.
Right to Withdraw Consent. Where we process your Personal Data on the basis of your consent, you have the right to withdraw consent. If you would like to withdraw your consent to the processing of your Personal Data, please send an email to: data@hrparticipants.com.
Right to Lodge Complaint. You have the right to lodge a complaint with the appropriate relevant data protection supervisory authority in your EEA country of residence.
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For Residents of the State of California Only:
This Privacy Notice for California Residents supplements the information contained in HRP’s Privacy Policy and applies solely to Site visitors, users of or participants in our services, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA will have the same meaning when used in this notice.
Information We Collect. Our Site collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). HRP’s may have collected the following categories of personal information from its consumers within the last twelve (12) months:
Identifiers
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, address, telephone number, employment, employment history, Social Security number, and bank account number. Some personal information included in this category may overlap with other categories.
Commercial Information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Professional or employment-related information.
Current or past job history.
HRP obtains the categories of personal information listed above from the following categories of sources:
Public websites,
Information collected directly from consumers through use or participation in HRP’s services,
Subscription databases and information vendors.
Personal information does not include:
Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Use of Personal Information. In addition to the stated uses set forth above, we may use, or disclose the personal information we collect for any purpose described to you when collecting your personal information or as otherwise set forth in the CCPA.
Sharing of Personal Information. HRP may disclose your personal information to third parties for purposes consistent with the business purpose for which it was collected.
Your Rights and Choices Related to Personal Information. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights. You have the right to request that HRP disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
sharing for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights for Personal Information. You have the right to request that HRP delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses with that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Emailing us at compliance@hrparticipants.com
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Request Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.