Last Updated: January 1, 2022
What Role Does HRA Serve in Data Protection?
PART I: HRA AS A DATA PROCESSOR
PART II: HRA AS A DATA CONTROLLER
Information We Collect
HRA may collect information about you from various sources. Specifically, we may obtain information about you:
1. On our Sites (e.g., when you request information, establish an account, or submit content to our Sites);
2. When you call us, email us, or communicate with us through social media; and
3. From our affiliates or subsidiaries, service providers, business partners, and other third parties.
The types of personal information we may obtain includes:
1. Contact details (e.g., name, postal address, email address, and telephone number);
2. Username and password for the account you may establish on our Sites;
3. Photographs, videos, comments, and other content you submit to us;
4. Information you provide by interacting with us through social media; and
5. Other details that you may submit to us or that may be included in the information provided to us by third parties.
Automatic Data Collection
As is true of most websites, we gather certain information automatically. We may combine this automatically collected log information with other information that you provide us or that we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality and to analyze trends in the aggregate and to administer our Sites. The information we may collect by automated means includes:
1. Information about the devices our visitors use to access the Internet (such as the IP address and the device, browser and operating system type);
2. URLs that refer visitors to our Sites;
3. Dates and times of visits to our Sites; and/or clickstream data
4. Internet service provider;
5. Referring/exit pages;
6. The files viewed on our Sites (e.g., HTML pages, graphics, etc.)
8. Information on actions taken on our Sites (such as page views and site navigation patterns);
9. A general geographic location (such as country and city) from which a visitor accesses our Sites or mobile applications; and
10. Search terms that visitors use to reach our Sites.
1. Essential Cookies – These cookies are essential to provide you with our services and to enable you to use some of the features. For example, they help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
2. Functionality Cookies – These cookies allow our Sites to remember choices you make when you use our services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Sites or services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Sites.
3. Analytics and Performance Cookies – These cookies are used to collect information about traffic to our Sites and how users use our services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Sites, websites that referred them to our Site, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information. We use this information to help operate our Sites and services more efficiently, to gather broad demographic information and to monitor the level of activity on our Sites.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Sites and services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: https://policies.google.com/privacy
You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available via this link:
4. Targeted and Advertising Cookies – These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show ads which may be relevant to your interests while you are on third party websites.
5. Social Media Cookies – These cookies are used when you share information using a social media sharing button or “like” button on the website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.
How We Use the Information We Collect When Acting as a Data Controller
When you use or communicate with us through the Site, we may use the information we obtain about you to:
1. Register you on our Sites and manage and maintain your accounts on our Sites;
2. Provide products or services you request;
3. Understand your needs and interests and tailor our products and services to suit your personal interests and the manner in which visitors use our Sites, products, and services;
4. Communicate with you about products, services, based on the general geographic location transmitted by your mobile device;
5. Maintain a record of general transactions on our Sites;
6. Respond to your questions and comments and provide customer support;
7. Communicate with you through email, website, mobile applications and social media about our products, services, offers, events and promotions, and offer you products and services we believe may be of interest to you;
8. Enable you to communicate with us through our blogs, social networks, and other interactive media;
9. Operate, evaluate, and improve our business and the products and services we offer;
10. Analyze and enhance our marketing communications, and strategies (including by identifying when emails sent to you have been received and read);
11. Analyze performance of our services and technology and to analyze trends and statistics regarding visitors’ use of our Sites, mobile applications, and social media assets, and the transactions visitors conduct on our Sites;
12. Protect against fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
14. Comply with applicable legal requirements and industry standards and our policies.
Information We Share
Your Rights When HRA is Your Data Controller
HRA will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. The user account will remain active until responsible contracting company has either disabled the account or termination of service contract with HRA.
How We Protect Personal Information
We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide on our Sites and HCM Cloud Platform against accidental unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Other personal information (not including payment card information) may be transferred unencrypted and involve (i) transmissions over various networks and (ii) changes to conform and adapt to technical requirements of connecting networks or devices. However, HRA will use commercially reasonable efforts, like secure socket layer (SSL), to encrypt information such as your login credentials during transmission. Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.
Linked Websites and Social Networks
Our Sites may provide links to third-party sites for your convenience and information. HRA does not control linked websites, and we do not endorse or make any representations about third-party websites. Linked sites may have their own privacy policies, which you should review if you visit those sites. We are not responsible for the content of any sites not affiliated with HRA, any use of those sites, or those sites’ privacy practices. We may also provide social media features on our Sites that enable you to share HRA information with your social networks and to interact with HRA on various social media websites. This includes social media features, such as the Facebook Like button and widgets, such as the Share this button or interactive mini-programs that run on our Site. Your use of these features may result in the collection or sharing of information about you. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. We encourage you to review the privacy policies and settings on the social media websites with which you interact to help you understand those website’s privacy practices.
HRA does not knowingly collect Personal Information or direct its Sites to children under the age of 16. If we learn that a user of our Site is under 16 years old, we will promptly delete any personal information that the individual has provided to us.
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