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01.  About Us

This website https://www.hrsg.ca/, along with its subdomains, is operated by Human Resource Systems Group Ltd. (“HRSG”). HRSG is located at 6 Antares Drive, Phase II, Suite 100, Ottawa, Ontario K2E 8A9.

HRSG values the privacy of the individuals who use the HRSG website and/or the HRSG services or who otherwise deal with HRSG. This Privacy Policy demonstrates our commitment to your privacy and describes the personal information we collect and how we use that personal information. For example, we use your personal information to answer your inquiries, to authenticate you when you sign into HRSG’s online services, to prevent loss and fraud, to analyze our business operations and website and service performance, and to carry on our business relationships with your employer. (For the purposes of this Privacy Policy, employer is also intended to include contracting relationships where you have been retained as an individual contractor by an organization to provide services to that organization.) By accessing or using the HRSG website and/or the HRSG online services, or by otherwise dealing with HRSG, you consent to the collection, use, transfer, and other processing of your personal information as described in this Privacy Policy.

In this Privacy Policy, the terms "we", "our" and "us" mean HRSG.

02.  Effective Date and Scope

This Privacy Policy is effective as of December 15, 2021.

03.  Personal Information We Collect

Personal Information is information that identifies you or that could be combined by us or our service providers and affiliates with other information to identify you. We collect and process some or all of the following categories of personal information from you during your use of the website or our online services or in conducting any business relationship with you or your employer:

  1. Personal Information you provide when filling out our forms. This personal information includes your name, personal or business e-mail address, your work and/or home telephone number, your personal or work cellphone number, your work function or title, and other similar information when associated with you. We collect personal information from you when you create an account, make a purchase, apply to a job opening, communicate with us using our web forms to make a request or ask a question, submit a product review, take a survey, or otherwise submit personal information to us.
  2. Details of your visit to the website or our online services. Personal information may also include information about whether you have opened our promotional e-mails or how you have used our website or online services, if we can associate that personal information with you. We may also collect personal information automatically when you visit our website or online services, such as information about your browser settings and other information collected through cookies. For more information on cookies, see the “Cookies” section below.
  3. Personal Information collected via our online services. In order to provide our online services, we need to collect the following personal information. We collect account login information for all of our online services (“Account Information”). Account Information consists of a first and last name, a profile picture, a preferred language, a business email address, a city and province/state of residence, and a company name. We also collect basic employment related information about you, such as your employee identification number, hire date and job title. For our Career Planning online service, we collect the following types of personal information in order to provide that service: education history, employment history, continuing education courses completed, professional certifications, knowledge assessments, competency/proficiency assessments, language assessments, career goals, desired career pathways, goal-related comments. We also collect and generate other account-related information, such as your account types, account status, login attempts, and the last IP address used by you to log into our online services. Account Information, Career Planning-related personal information, and basic employment-related information may be submitted to us by you or by an organization for which you work as an employee or contractor. Generally, this personal information will be provided to us by the person who your organization has designated as the administrator for your organization’s use of our online services. However, other people in your organization who are users of our online services may also provide personal information about you through their use of the online services. For example, your manager may provide comments about you in a goal. When Account Information, Career Planning-related personal information, and/or basic employment-related person information is submitted to us about you by an organization, it is that organization’s obligation to obtain your consent for such disclosures.
  4. Assessment and Survey Data. We collect certain personal information related to your creation of or taking of surveys or assessments through our online services. This information includes your answers, your name, your job position, comments, and scores.
  5. Activity Information. We may also collect information related to your activity when creating surveys, assessments, and goals. For example, the name of the creator, as well as the dates of creation or closing of such surveys, assessments, and/or goals. Personal information from your account, provided by you or by your organization’s administrator, may be used to automatically populate other sections of our online services. For example, your manager’s name and your name and profile picture are automatically populated when providing you with requested career path information.
  6. Making Purchases Through the Website. Our website allows users to sign up for online training courses in respect to our online services and to pay for these training courses. Our third-party payment processor will request credit card and other identifying information to process a credit card transaction when you purchase an online training course offered by us through our website. HRSG does not receive any of the payment information that you submit when paying for our online training courses and all such information is collected and stored by our payment processor (see our list of sub-processors below). Personal information collected from you by our payment processor is processed in accordance with our payment processor’s privacy policy and the terms of this Privacy Policy do not apply to personal information that is collected from you by our payment processor. We will also ask you for contact information, such as an email address, so that you can access any online training courses that you have purchased.
  7. Personalized Offers and Web Analytics. We also automatically collect information when you visit our website in order to customize your experience. For example, we collect information about what site referred you to our website, your browser type, operating system type and version, language, and your Internet Protocol ("IP") address. We also collect information about how you browse through our website and online services, including logging the pages you visit and the amount of time you spend on certain pages. We use this information for several technical purposes to ensure that our pages load correctly in your browser, as well as to personalize our offers to you. We also use this information to improve our website and/or online services. For example:
  1. we use IP addresses to correct pages for your geographical location;
  2. we log the frequency of visits to certain pages on our website and/or online services and how visitors navigate through our website and/or online services to detect problems, improve our website and/or online services, and learn about what products and services are of interest to our customers; and
  3. we track whether certain types of promotional e-mails were opened by you and whether you sought information about a particular product or service in order to make inferences about other products and services you might be interested in.

 

04.  Personal Information from Other Sources

We receive personal information about you from other sources. For example, we receive information and data from third party sources and service providers:

  • In order to enrich our leads;
  • In order to provide webinars to registrants;
  • When you purchase services through our website we may receive information from our payment processor about whether the payment credentials you submitted have been accepted or declined.
  • When you have allowed a promotional or marketing company to share your information with us.

 

05.  How We Use Personal Information

We use your information to provide products and services, manage our business operations, manage our business relationship with your employer, communicate with you, analyze how people use our website and/or online services, and as required by law or security, specifically for the following purposes:

  • to register for an account for our online services;
  • to authenticate you when you log into your account for our online services, to provide customer support, and to operate and maintain the online services. For example, we use the name and picture you provide in your Account Information to identify you to other users of the online services;
  • to fulfill your requests for products and/or services or information about our products and/or services;
  • to communicate with you about your requests, including where you have requested a demo of our products and/or services;
  • to recommend or to offer you other products and/or services based on your inferred interests and to communicate with you and provide news or information about us;
  • to respond to comments, questions, and requests and provide customer service and support;
  • conduct business and contractual relationships that we have with various persons and companies (such as customers, suppliers, resale channels, employees and contractors);
  • to verify identities for the purposes of complying with know-your-customer laws and regulations, economic sanctions laws and regulations and other similar laws and regulations;
  • to measure website and online services use and improve website and online services content and operation;
  • to protect the security or integrity of our websites, online services, and our business and to monitor the website and online services for suspicious activity and to identify violations of our website and online services policies;
  • to send technical notices, updates, security alerts and support and administrative messages;
  • to enforce our terms and conditions and other contractual rights;
  • as required or permitted by law;
  • to prevent damage to property, bodily injury and/or death;
  • to ensure and protect the security or integrity of our users, our website and online services, the public, or other third parties;
  • in order to participate in or be the subject of any financing, sale, merger, acquisition, restructuring, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including due diligence activities in respect to any such transactions); and
  • for other purposes which we will notify you about and seek your consent.

We retain personal information provided by you or provided about you by your organization’s administrator and/or collected through your and your organization’s use of the online services for as long as an active subscription for you exists for an applicable online service or as otherwise required for the purposes for which such personal information was initially collected. We will also retain and use personal information as necessary for us to comply with our legal obligations, resolve disputes, and/or enforce our agreements. Personal information may be retained for up to sixty (60) days following the end of a subscription for the online services or as may be necessary to comply with applicable laws, resolve disputes, and/or enforce our agreements. If your account is deactivated or disabled, some of your personal information and the content you have provided will remain to allow other users to make full use of the online services. For example, where you have provided a rating or comment about another person in your organization, those comments and ratings will remain and such other person and the organization will still have the ability to access and view such comments and ratings.

For individual who are located in the European Economic Area, the United Kingdom or Switzerland, we process your personal data under the following legal bases:

  • where the processing is necessary for the purpose of legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the applicable data subject and require the protection of such personal data. Specifically, we process personal data of personnel employed by or retained as contractors by entities with whom we have the legitimate interest of entering into contracts or the legitimate interest of performing contracts (particularly, contracts entered into by us for the provision of our online services);
  • where the processing is necessary for compliance with a legal obligation applicable to us;
  • where the processing is necessary to protect the vital interest of the data subject or another natural person; and
  • where the applicable data subject has given consent to the processing of his or her personal data.

If you have consented to our use of your personal data for a specific purpose, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place. Where we are using your personal data because we or a third party (for example, your employer) have a legitimate interest to do so, you have the right to object to that use, however, in some cases, this may mean you can no longer use our website and/or online services.

06.  Cookies

Our website and online services use small pixel files (small images) and cookies (small text files) to keep track of your browser so that you will be recognized when you re-visit our website or online services or when you visit other websites where our third-party ad management providers may show you advertisements from us based on your visit to our website. Some of these advertisements may be customized to particular products and services that you viewed or they may be based on inferences about products and services that you might be interested in. This is called interest-based advertising.

Our website and online services use cookies to distinguish you from other users of our website and online services and to track user behaviour on our website and in our online services. This helps us to provide you with a good experience when you browse our website and use our online services and also allows us to improve our website and online services. By using our website and/or online services you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

The cookies and pixels We use include:

  • HubSpot: Tracks user behaviour on our website and saves information provided in forms by users.
  • Google: Provides ad targeting, reporting, analytics/measurement, optimization.
  • LinkedIn: Enables in-depth campaign reporting, allows for ads to show on LinkedIn to our website users.
  • Facebook: Enables in-depth campaign reporting, allows for ads to show on Facebook to our website users.
  • JustUno: Tracks user behavior on our on-site popup advertisements.
  • ProveSource: Tracks user behavior on our on-site popup advertisements.
  • Hotjar: Provides heatmap functionality of user behaviour.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website and/or online services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our website and online services. If you block cookies on our website and/or online services, certain functions may not operate properly.

Analytics Tools

We use analytics tools and other third-party technologies, such as Google Analytics and/or DoubleClick cookies, to collect personal and non-personal information in the form of various usage and user metrics when you use our online sites/services.

These tools and technologies collect and analyze certain types of information (which can include personal information), including cookies, IP addresses, device, and software identifiers, referring and exit URLs, onsite behaviour and usage information, feature use metrics and statistics, usage and purchase history, MAC address, mobile unique device identifier, and other similar information.

The third-party analytics companies who collect information on our website and online service may combine this with information independently collected from other websites, other online/mobile products and services relating to your activities across their network of websites as well as online/mobile products and services. This type of information (including personal information) is collected and used under the applicable analytics companies’ privacy policy and is subject to the provisions of those privacy policies (which you should read) and this Privacy Policy does not apply to the use of this type of information (including personal information) that is collected and processed by these companies.

You may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page or Google Analytics by visiting the Google Analytics opt-out page. Google has additional information available about their Remarketing Privacy Guidelines and Restrictions.

You can set preferences for how Google advertises to you using the Google Ad Preferences page and, if you want to, you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

07.  How Do We Disclose Your Personal Information to Others?

We may share your personal information with our service providers and our corporate affiliates that help us with our business operations. For additional information, please see our list of sub-processors at: https://www.hrsg.ca/dpa-subprocessors.

Service Providers. We use third-party service providers or affiliates who provide us with marketing, promotional and other business services (such as customer relationship management capabilities or payment processing) and who help us with providing our website and online services to you (such as hosting and email distribution services). If a service provider or affiliate needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your personal information.

Links to Third Party Sites. Our website and online services may include links to other websites whose privacy practices we have no control over. If you submit personal information to any of the third-party websites that are linked to from our website or online services, your personal information is governed by the privacy policies of the providers of those websites. We encourage you to carefully read the privacy policy of any website you visit.

Compliance and Enforcement: We may disclose personal information to a third party where we reasonably believe that the sharing of the personal information is necessary to (a) comply with applicable law, regulation, legal process, or governmental requests (for example, in response to subpoenas, civil investigative demands, or similar processes, or in connection with know-your customer requirements or for export and economic sanctions-related compliance); (b) enforce our agreements, policies, and/or Terms of Service; (c) protect the security of our website and/or the online services and/or to detect, prevent, or otherwise address fraud, security, or technical issues; or (d) prevent damage to property, bodily injury and/or death.

Merger or Sale. We may transfer any personal information we have about you in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our business. The foregoing disclosures of personal information include for due diligence activities in connection with a merger or sale involving all or part of our business. We may also disclose your personal information if it is necessary for us to collect a debt from you or where we have reason to believe that it is relevant to the investigation or decision to investigate a breach of the laws of Canada, a province or territory of Canada, or a foreign jurisdiction, and we are legally permitted to do so.

Other Users. We may also share your personal information with other users of our online services. You may provide content that can be shared with other users as part of the intended uses of the online services. Depending on the capabilities of the online services used by you and your organization, this may include content that you have granted permission for other users to see, like your picture for the purpose of identifying you to other users, personal logs shared with a manager or other specified employee, or your name and position associated with a job in the career path capabilities provided by the online services. Where registration is done on your behalf by an administrator designated by your organization, information about you, including your Account Information and employment details are accessible by that administrator. Your comments provided in an area accessible by both you and another user or other users will appear to that other user or those other users without you having to grant express permission.

08.  Protecting Your Personal Information

We take administrative, technical, and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft, and misuse. These measures include confidentiality agreements with employees and contractors, firewalls, Secure Sockets Layer protocol, usernames, and passwords. We take physical precautions to ensure that the computer servers on which your personal information is stored and archived are secure and that access to such servers is protected.

Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your personal information and no website or online service is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit personal information to us using our website or online services if you consider that information to be sensitive.

09.  Storage Outside of Canada

Your personal information may be used or stored by us or our service providers and our corporate affiliates outside of Canada. We require that our service providers and corporate affiliates safeguard your personal information. You acknowledge and agree that your personal information may be accessible to law enforcement and governmental agencies in Canada and the United States and other jurisdictions under lawful access regimes or court orders. For the location of the various sub-processors used by us, please see our list of sub-processors at: https://www.hrsg.ca/dpa-subprocessors. For individuals in the European Economic Area, the United Kingdom or Switzerland, we will only transfer your personal information to a jurisdiction not providing adequate protection for personal information in accordance with applicable European Economic Area, United Kingdom or Swiss law.

10.  Your Rights

If you are resident of the European Economic Area, the United Kingdom or Switzerland, you have several important rights free of charge, however, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Your requests may be limited in certain cases. For example, where fulfilling your request would reveal information about another person, or where you ask to delete information which we or your employer are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

In summary, those include rights as follows:

  • Right to Erasure. Request erasure/deletion of your personal data in certain circumstances.
  • Data Subject Access Request. You have the right to request access to your personal data and to receive a copy of the personal data we hold about you and an explanation of the purposes for which personal data is being used.
  • Data Portability. You have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit that data to a third party in certain situations. This right does not apply to paper records.
  • Correction. You have the right to request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new personal data you provide to us.
  • Right to Object. At any time, you may object to processing of personal data concerning you for direct marketing and object in certain other situations to our continued processing of your personal data.
  • Right to Restrict Processing. In circumstances where you have objected to the processing of your personal information or if you need the data to make or defend a legal claim, you can request that any further processing of your personal data be restricted. When processing is successfully restricted, your organization still has the right to store the personal data.
  • Right to Withdraw Consent to Processing. You have the right to withdraw consent to processing of your personal data at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent or the lawfulness of any processing where we are relying on a legal basis other than consent. If you withdraw your consent, we may not be able to provide certain online services to you. We will advise you if this is the case at the time we respond to your request.

Subject to the provisions below about processing done on behalf of your employer, if you would like to exercise any of the foregoing rights, please email, call, or write to us at the contact information indicated below and provide us with information confirming your identity and let us know what personal data your request pertains to.

If you are resident in California, you may have certain rights under the California Consumer Privacy Act (the “CCPA”).

For more details about the personal information we have collected about you over the last twelve (12) months, please see the “Personal information that We Collect” section above. We collect this personal information for the commercial purposes described above. We do not sell (as that term is defined in the CCPA) the personal information we collect.

Subject to applicability and certain limitations, the CCPA provides California consumers the right to request details about the categories or specific pieces of personal information we collect about them (including how we use and disclose this personal information), to delete their personal information, to opt out of any “sales” of personal information that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information below. We will verify your request using the information (including personal information) associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

For all of the rights described in this Section, in certain instances, where we are acting as a sub-processor for one of our Clients (as hereinafter defined) who is the actual data controller, we may not be able to respond to or take action in respect to a request from you in connection with your personal information or personal data without notifying and receiving consent and/or further instructions from such Client who is the actual data controller. Where the online services are made available to you through an organization (for example, your employer) (our “Client”), for your purposes, that organization is the administrator of the online services and is responsible for the accounts and/or sites over which it has control. Please direct your personal information and personal data questions to your administrator, as your use of the online services is subject to that organization's policies. We are not responsible for any Client’s privacy or security practices, and those practices may be different those described in this Privacy Policy. If you seek to access, amend, or delete inaccurate information or seek to assert any other rights with respect to your personal information or personal data, you should direct your request to the applicable Client (the data controller). The Client can remove personal information or personal data without our involvement in some cases or will request that we remove applicable personal information or personal data from the online services (subject to the provisions on data retention above). Please refer to the applicable Client’s organizational policies for more information.

11.  How to Contact Us

If you have a privacy question or concern, or wish to exercise your rights with respect to your personal data, please contact us at:

6 Antares Drive, Phase II, Suite 100

Ottawa, Ontario, Canada

K2E 8A9

Telephone: 1-866-574-7041

Email: privacy@hrsg.ca

12.  Links to Third-Party Websites and Social Network Plug-Ins

You may be able to access third-party websites through links available on our websites. These links are provided for your convenience. We do not have any control over those third-party websites and we do not provide any guarantee that the privacy practices of the hosts of those websites meet our standards. Your use of such third-party websites is at your own risk and will be governed by the privacy policies of those websites and not by this Privacy Policy. Do not transmit personal information to those websites without reading the privacy policies governing those websites.

You may create links between our website and/or online services and social networking sites. If you do so, we may be able to publish updates about our products and services to your social network account through the links that you establish. You may terminate those links at any time by modifying your social network account.

You may change the way social networking sites and our website and/or online services interact with your social networking account by modifying your privacy settings in your social networking account. You can also log-out of your social networking account before visiting our website and/or online services. For more information, please refer to your social networking site's privacy policy, which governs your use of these social network plug-in features.

13.  Changes to our Privacy Policy

We reserve the right to amend this Privacy Policy at any time. Any changes we make to our Privacy Policy in the future will be made available to you by posting the updated Privacy Policy on the website. Any updated Privacy Policy will become effective upon its posting on the website and the updated Privacy Policy shall apply to all of your personal information submitted to us including person information submitted by you to use prior to the effective date of such updated Privacy Policy.