HT2 Labs, including HT2 Ltd and HT2 Inc. (“HT2”) operates several websites including ht2labs.com, curatr3.com, learninglocker.net and related sub-domains of each of these domains. It is HT2’s policy to respect your privacy regarding any information we may collect while operating our websites.
Like most website operators, HT2 collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. HT2’s purpose in collecting non-personally identifying information is to better understand how HT2’s visitors use its website.
We may collect statistics about the behavior of visitors to its websites. For instance, HT2 may monitor the experiences run through the curatr3.com site or use anonymous data gathered by the Enterprise Learning Locker service to help identify future product needs. HT2 may display this information publicly or provide it to others.
HT2 also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on blogs. Some of this data may be shared with employees, contractors, affiliated organisations by using HT2’s websites, you consent to the transfer of such information to them.
Visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.
If you are a registered user of an HT2 website and have supplied your email address, HT2 may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with HT2 and our products. We primarily use our various product blogs to communicate this type of information, so we expect to keep this type of email to a minimum.
If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.
HT2 only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information, except that blog commenter IP addresses and email addresses are visible and disclosed to the administrators of the blog where the comment was left.
If HT2, or substantially all of its assets, were acquired, or in the unlikely event that HT2 goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of HT2 may continue to use your personal information as set forth in this policy.
If you have an Enterprise Learning Locker account, you should also check your LRS’s dashboard for alerts to these changes.
If you have a Curatr3 account, please keep an eye out for messages on your dashboard or on update notices.
HT2 complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.
HT2 collects non personally identifiable information and personally identifying information such as username and email address. In each case, HT2 collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with HT2. HT2 does not disclose personally-identifying information other than as described below. Depending on services requested information data collected could also extend to job title, employer, as well as financial payment information.
This information is only disclosed to our employees both in the UK and the US as well as partners and contractors on a need to know basis.
Use and disclosure of information is on a need to know basis only to process information on behalf of HT2 or to provide and maintain services the user has expressly requested and are available on our website or on the basis of their agreement with us.
Most data is collected with the express consent of the individual, typically obtained by our customers before disclosure of information. In other cases users will be provided with an opt-out/ opt-in choice before we collect or share their data and only on basis that such data is used for purpose originally intended and as authorised by individual via the opt-in.
Data is also collected and retained to satisfy our legal obligations and for the enforcement of agreements until we cease to provide services to the user.
Accountability for onwards transfer
HT2 discloses personal data to its employees as well as to partners and contractors on a need to know basis as well as when required as part of a lawful request by public authorities. Onwards transfer of data shall be pursuant to the EU-US Privacy Shield; in case of a data breach HT2 could potentially be liable.
HT2 takes reasonable and appropriate measures to protect from data loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into “due account” the risks involved in the processing and the nature of the personal data.
Data integrity and purpose limitation
HT2 limits the personal data it collects to information that is relevant for the purposes of processing. HT2 does not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorised by the individual. To the extent necessary for those purposes, HT2 takes reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current.
HT2 takes reasonable and appropriate measures to retain personal data only for as long as it has a legitimate legal or business need to do so, such as customer service, compliance with legal or contractual retention obligations, retention for audit purposes, security and fraud prevention, preservation of legal rights or other reasonable purposes consistent with the purpose of the collection of the information. HT2 will adhere to this for as long as it retains personal data transferred in reliance upon the Privacy Shield.
HT2 acknowledges that EU individuals have the right to access the personal information/data that we maintain about them. An individual who seeks to access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to HT2 at email@example.com. We provide means for the individual to request the correction, amendment, or deletion of that information where it is inaccurate, or has been processed in violation of the principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. In cases where we are acting as a processor for data from our customers, it may be necessary for us to direct an individual to our customer to provide the requested access.
HT2 requires that an individual provide reasonable verification of their identity before we provide access to personal data.
RECOURSE, ENFORCEMENT AND LIABILITY
HT2 has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the independent recourse mechanism of the EU data protection authorities (DPAs). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, you can submit a complaint directly to your local DPA. See: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm for more information and to file a complaint.
In the case of human resources data, HT2 has agreed to cooperate with a panel of European Data Protection Authorities created for that purpose.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
HT2 is required by the Privacy Shield program to respond promptly to inquiries and requests for information from the Department of Commerce. HT2 is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”).
PUBLIC RECORD AND PUBLICLY AVAILABLE INFORMATION
In accordance with Privacy Shield, in cases where HT2 discloses public records or publicly available information from the EU without combining that information with non-public information, our general policies on Notice, Choice, and Accountability for Onward Transfer may not apply.
To ask questions about our privacy practices or our business in general you may contact us at:
Oxford OX2 9NH
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