Higher Logic, LLC (“Higher Logic”) is committed to protecting your privacy. We are an industry leader in cloud-based engagement platforms. We offer our Clients an expanded suite of engagement capabilities, including online and mobile communities, and marketing automation services.
(i) your use of the websites www.higherlogic.com (where you can learn more about the Higher Logic’s products and services, and request for information and content), hug.higherlogic.com (where Higher Logic clients can engage and network with other community managers within the Higher Logic User Group), support.higherlogic.com (where Higher Logic clients receive help and support), academy.higherlogic.com (where Higher Logic clients may take e-learning courses), http://community.informz.net, our Clients’ community for the Informz product, http://www.realmagnet.com and http://www.informz.com (where you can find information on our email marketing and marketing automation products and services) (each a “Website” and, collectively, the “Websites”);
(ii) your use of our mobile applications Higher Logic User Group for members of Higher Logic’s Users Group and Higher Logic Super Forum, used for Higher Logic’s annual customer event (together, the “Apps”);
(iii) events you may attend to (for example, trade shows).
Our use of information on behalf of Clients who have registered to use the Higher Logic online community platform (pursuant to which our Clients offer access to a website for their employees, customers and other authorized individuals), and the Real Magnet and Informz platforms (each a “Platform” and, collectively, the “Platforms”) is governed by our contract with that Client and the Client’s own privacy policies. We are not responsible for the privacy policies or privacy practices of Clients or other third parties.
Our Collection of Your Personal Data
Higher Logic collects and uses information that, alone or in combination with other information, could be used to identify you (“Personal Data”) in order to deliver our products and services, process applications to join programs, inform you of various opportunities, and provide support, as described below (please also see the “How We Use Information” section below).
Personal Data That You Voluntarily Provide To Us. Higher Logic primarily collects Personal Data provided to us by individuals when they interact with our products, services, and customer service. For example, you may voluntarily provide us with Personal Data when you sign up to participate in our blogs, sign up for a seminar, ask to download content (such as a white paper or a brochure), submit a web form, call or email us directly, request a demonstration of our products or services, or submit your business card.
The types of Personal Data that we collect vary based on the services offered on the Websites and Apps, but generally include your name, address, telephone number, company name, job title, e-mail address, and other information that you voluntarily submit to us.
Moreover, when you create a profile in the Higher Logic User Group on our Website hug.higherlogic.com or our Apps, we will collect the information that you elect to upload to your profile, such as a biography, your education and job history, company information. We also collect information that is provided, posted or uploaded by users to the Higher Logic User Group. We do not control the content that users post to our user group. You should carefully consider whether you wish to submit Personal Data and whether you wish to make your profile available to other users, and you should tailor any content you submit appropriately. You should also review any additional terms and conditions that may govern your use of our services.
Information Received from Other Sources. We may receive information about you from publicly available and third-party databases or services that provide information about business people and companies, or from third parties from whom we have purchased information (including an individual’s name, job title, business contact information, and information about the business where the individual works), and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. We will obtain your consent before contacting you if required by the law of the country in which you are located.
Automatically Collected Data. As you interact on our Websites, we may collect information about your computer or device and visits to one or more of our Websites (“Automatically Collected Data”) through cookies, web beacons and other technologies, Internet Protocol (IP) address tracking/URL tracking, and other tools (collectively, “Tracking Technologies”). The types of Automatically Collected Data collected on our Websites through the use of these and other tools that we may add from time to time may include: the search terms you used, new or returning user information, browser information, computer or device type, operating system, internet service provider, website usage, referring/exit pages, platform type, date/time stamp, number of clicks, and ads viewed. Please see the “Tracking Technologies” section below to learn more about how we use Tracking Technologies.
Service Data. In providing our services to Client through the Platforms, we process on behalf of Clients information, including Personal Data, that Clients upload to, integrate with or otherwise submit to our services. Our Clients decide what data to submit (this typically includes information about their customers, prospects, employees, consultants or independent contractors, suppliers and other individuals or third parties). We only collect such information under the direction of Clients, and have no direct relationship with the individuals whose Personal Data we process.
How We Use Information
Provide our products and services and respond to requests. We use the Personal Data we collect from you (unless otherwise restricted by law) to:
- Provide you support or other services you have ordered from us, as well as product updates, product patches and fixes and other similar operational communications. For EU Data Subjects, such use is necessary for the performance of the contract between you and us.
- Respond directly to your information requests (including registrations or other specific requests) or other inquiries. For EU Data Subjects, such use is necessary to respond to or implement your request prior to entering into a contract with us.
- Facilitate your engagement in the Higher Logic User Group. For EU Data Subjects, such use is necessary for the performance of the contract between you and us.
Marketing. We also use your contact information to contact you by email or by phone regarding information that we think may be of interest to you. If you do not wish to receive marketing materials, brochures, or emails from Higher Logic, you may inform us of your preference by sending a letter or calling Higher Logic at the contact information below. You may also submit a contact form electronically through the Websites and unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails.
We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
Where required by the applicable law (for example, if you are an EU Data Subject), we will send you marketing information or notifications only with your consent, which was given at the time you provided us with the Personal Data. In such case, if you do not provide us with your consent to the processing of your Personal Data for this purpose, we will not send you this information, (please refer to the “EU Data Subjects” section below for information on your rights). For California residents, please consult the “Your Privacy Rights” section below for additional considerations.
With your permission, we may also use information you provide to us as a testimonial posted on the Websites.
Correspondence. If you correspond with Higher Logic via e-mail, the postal service, our web forms, or other form of communication, we may retain the correspondence and the information it contains. We may use the information for business purposes, including responding to your inquiry, notifying you of Higher Logic-related opportunities, and other marketing purposes (please read the Marketing section above for more information on our marketing practices and how to opt out or unsubscribe).
URL and IP Address. Higher Logic collects information about users’ IP addresses, including users’ utilization of our Websites, to help us design our Websites to better suit our Website users’ needs. We may use information about your IP address to help diagnose problems with our server, administer our Websites, analyze trends, track visitor movements, and gather information that assists us in identifying visitor preferences. We also may use your IP address to enhance our security and investigate an actual or potential security incident. For EU Data Subjects, this use of your information is necessary for our legitimate interests in understanding how the Websites and our Services are being used by you, to improve your experience on it and ensuring network and information security. For more information about what we mean by legitimate interests, and when we may process Personal Data for our legitimate interests, please see the “EU Data Subjects” section below.
Service Data. Our use of information collected through the Platforms on behalf of our Clients is limited to the purpose of providing the service for which the Client has engaged Higher Logic and is governed by our contract with that Clients and the Clients’ own privacy policies.
Disclosure Of Information
Higher Logic discloses Personal Data that we collect (described above) in accordance with the terms set forth in this section.
We share your Personal Data with third parties who provide certain services to us to assist us in meeting business operation needs. These parties are authorized to process your Personal Data, on our behalf and pursuant to our instructions, only as necessary to provide these services to us. We share your Personal Data with the following service providers:
- Providers of payment processing and accounting, as necessary to process payment from our Clients
- Learning management systems that integrate with our platform
- Customer service providers
- Providers helping us fulfill subscription services (such as Salesforce)
- Providers of research and analytics services, including Google Analytics
- Providers of cloud computing infrastructure services
We may also disclose Personal Data to third parties in the following circumstances: (1) if you request or authorize (when required by the law, we will inform you in advance of the third parties to which we may provide your data and the purpose for doing so, and we will obtain your prior consent for such use); (2) the information is provided (a) to comply with the law (for example, to comply with a search warrant, subpoena or other legal process), (b) to enforce an agreement we have with you, (c) to protect our rights, property or safety, or the rights, property or safety of our employees or others, (d) to investigate fraud, or (e) to respond to a government request or to lawful requests by public authorities, including to meet national security or law enforcement requirements; (3) to address emergencies or acts of God; (4) to address disputes, claims, or to persons holding a legal or beneficial interest; (5) if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, in which case your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
How You Can Access and Change Information
Higher Logic acknowledges that you have the right to access your Personal Data. Our Websites and Apps allow you to access, correct, amend, or delete inaccurate data. In case you request us to remove data, we will respond within a reasonable timeframe.
Upon request, Higher Logic will provide you with information about whether we hold any of your Personal Data. You may access, update or correct your Personal Data or remove it from our system by making a request to us at the contact information provided below. Requests typically receive a response within thirty (30) days. If access cannot be provided within that time frame, we will provide the requesting party with an estimated date by which the information will be provided. If for some reason access is denied, we will provide an explanation of why access has been denied.
Higher Logic has no direct relationship with the individuals whose personal data it processes on behalf of clients. An individual who seeks to access, correct, amend, or delete inaccurate data should direct his query to the Higher Logic Client (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
If you are an EU Data Subject, please see the “EU Data Subject” section below for information on your rights in relation to the Personal Data we hold about you.
EU Data Subjects
Scope. This section applies if you are an individual located in the European Union (“EU”) (“EU Data Subject”). For these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland.
Data Controller. Higher Logic, LLC is the data controller for the processing of your Personal Data, but we act as data processor on behalf of Clients for Personal Data that we process through the Higher Logic Platform, as described under the “Higher Logic Platform” section above.
Your Rights. Subject to applicable law, you have the following rights in relation to your Personal Data:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
- Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
- Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
- If we are processing your Personal Data for direct marketing.
- Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, that affect you, unless such processing is necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent to such processing.
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
You may exercise your rights by contacting us as indicated under “Contact Us” section below.
Data Transfers. We have entered into Model Contractual Clauses for the transfer of Personal Data collected in the European Economic Area and Switzerland with certain service providers, customers and other parties. Please contact us as described under the “Contact Us” section below to obtain a copy of the Model Contractual Clauses we use.
Our Security Measures to Protect Your Personal Data
We are committed to taking reasonable efforts to secure the information that you choose to provide us, and we use a variety of security technologies and procedures to help protect against unauthorized access to or alteration, disclosure, or destruction of Personal Data. We restrict access to Personal Data to our employees, contractors and service providers (described in the “Disclosure of Information” section above) who need to know the information in order to operate, develop, or improve our services.
We retain your Personal Data for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. We retain Personal Data collected through the Platforms we process on behalf of our Clients for as long as needed to provide services to our Client and pursuant to our contract with that Client.
I. What Are Cookies
Cookies are pieces of data sent to your browser when you visit a website and stored on your computer’s hard drive. Cookies may store user preferences and other information. For example, cookies can store your session information for easy log-in to a website or platform, or your language or user interface customization preferences or may allow websites to record your browsing activities (for example, number of page views, number of visitors, and time spent on each page).
We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for a set period of time or until you delete it.
We classify cookies in the following categories:
|Categories of Use
These cookies allow to link the actions of a user during a browser session in order to allow navigation around web pages, access to secure areas of the Websites or Platforms and help make the services available through our Websites and Platforms work. Without these cookies, basic functions of the Websites and Platforms would not work.
For example, on the www.higherlogic.com and hug.higherlogic.com Websites we use a cookie called “ASP.NET”, a session cookie used to track a visitor’s identity during a particular session, and a cookie named “HLAuthToken” which contains credentials to authenticate a user).
On the Platforms, we use session cookies for authentication and authorization purposes and to track a visitor’s identity during a particular session.
Because these cookies are strictly necessary to deliver our services, users cannot refuse them.
You can block or delete these cookies by changing the browser settings as explained below
These cookies are used to store choices you make and your preferences regarding our services (such as your user name, language or the region you are in, enable user interface customization). These cookies allow us to provide enhanced, more personal features (such as enabling customer support for users, for example offering live support chat). These cookies are not essential for using our services. However, without these cookies, certain functionality may become unavailable or may not function properly.
On the Platforms, we use user interface customization cookies to store Clients’ preferences such as grid preferences (columns, sort order, etc.) or to enable certain functions, such as to prepopulate the input of the RSS feed dialog.
You can block or delete these cookies by changing the browser settings as explained below.
These cookies allow us to recognize and count the number of visitors and to see how visitors move around the Websites and Platforms when they are using it. This helps us to improve the way our the Websites and Platforms work, for example by making sure visitors are finding what they need easily. The information collected through these cookies include anonymous traffic statistics, like number of page views, number of visitors, and time spent on each page.
We use Analytics cookies from HubSpot, Inc. on the www.higherlogic.com and hug.higherlogic.com Websites to analyze and evaluate the use of our sites and improve our services and features. Learn more about Hubspot’s privacy practices here. If a user is logged in to HubSpot, the application also sets the additional authentication cookies listed here.
On the Real Magnet and Informz Platforms, we use Higher Logic’s Analytics cookies to track visits across pages on the Platforms and landing pages (for example, on Real Magnet we use tracking cookies named _rm_tk, _rm_ts and _rm_lprq; on the Informz Platform, we use tracking cookies named _sp_id, _sp_ses).
You can block or delete these cookies by changing the browser settings as explained below.
You can also prevent your data from being collected by Google Analytics on the Websites by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
III. Other Technologies
In their use of our services, Clients’ may enable various integrations which may set additional cookies. These cookies are set and controlled by Clients for various purposes such as website usage tracking and analytics and enabling social media features. Higher Logic does not control the placement of such cookies. Use of these cookies is governed by Client’s own privacy and cookie policies.
Higher Logic may use a tracking technique that employs embedded URLs to allow use of the Websites without cookies. Embedded URLs allow limited information to follow you as you navigate the Websites, but are not associated with Personal Data and are not used beyond the session.
Higher Logic and its service providers may use embedded pixel technologies (or pixel tags) for the purposes of identifying unique user visits (as opposed to aggregate hits) and for advertising purposes. In addition, embedded pixels or other technologies may be used in e-mails and our online display advertising to provide information on when the e-mail or ad was opened to track marketing campaign responsiveness; information collected using these technologies may be associated with the recipient's e-mail address.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the Apps, the events that occur within the Apps, aggregated usage, performance data, and where the Apps was downloaded from. We do not link the information we store within the analytics software to any Personal Data you submit within the Apps.
IV. Your Choices
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
Please note that if you reject cookies or disable cookies, your use of certain features or functions on our Website or Platforms or service may be limited.
To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org and/or or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org, and follow the opt-out instructions there. If you access the Websites on your mobile device, you may not be able to control tracking technologies through the settings. If you wish to not have your information used for the purpose of serving you targeted ads, you may opt-out by visiting the Network Advertising Initiative’s online resources available here and following the opt-out instructions there, or if located in the European Union, visit the European Interactive Digital Advertising Alliance’s Your Online Choices opt-out tool here. By opting out of targeted advertisements you will no longer see advertisements on our Websites from third-party partners that participate in the Digital Advertising Alliance; however, you may still continue to see other non-targeted advertisements on our Websites.
Inapplicability of Privacy Policies of Any Linked Websites or Other Third Parties
California Privacy Rights
The Websites and Apps are not intended for use by or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13.
Conditions of Use
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Higher Logic, including its U.S. subsidiaries Higher Logic, International Inc., Informz, LLC, Kavi, Inc., Real Magnet, LLC, and Socious, LLC, participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Frameworks, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov]
Higher Logic is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third-party acting as an agent on its behalf. Higher Logic complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Higher Logic is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Address: 1919 North Lynn Street, Suite 500 Arlington VA 22209
Last updated July 30, 2018