Higher Logic, LLC (“Higher Logic”) is committed to protecting your privacy. We are an industry leader in cloud-based engagement platforms. We offer an expanded suite of engagement capabilities, including online and mobile communities, and marketing automation services.
(i) your visit to our Website www.higherlogic.com (where you can learn more about the Higher Logic’s products and services, and request information and content), hug.higherlogic.com (where Higher Logic Subscribers can engage and network with other community managers within the Higher Logic User Group), support.higherlogic.com (where Higher Logic Subscribers receive help and support), academy.higherlogic.com (where Higher Logic Subscribers may take e-learning courses), http://community.informz.net, our Subscribers’ 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 Subscribers who have registered to use the Higher Logic online community platform (pursuant to which our Subscribers 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 Subscriber and the Subscriber’s own privacy policies. We are not responsible for the privacy policies or privacy practices of Subscribers or other entities.
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).
The following table describes (1) the categories of Personal Data we collect, (2) examples of the types of information that fall within each category of Personal Data collected, (3) how we use each category of Personal Data, and (4) how we disclose Personal Information.
|Categories of Personal Information||Examples||Sources of Personal Information||Use of Personal Information||Disclosure Of Personal Information|
|Identification Information||Your name, email address, postal address, telephone number, and your company name, size, and job title.||We collect Identification Information from you voluntarily when you interact with our products, services, and customer service.
We may also receive information about you from publicly available and third-party databases or services that provide information about business people and companies, or from entities from whom we have purchased information.
|We use Identification Information to (1) 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; (2) respond directly to your information requests (including registrations or other specific requests) or other inquiries; and (3) facilitate your engagement in the Higher Logic User Group. For EU Data Subjects, these uses are necessary for the performance of the contract between you and us.
We also use Identification Information to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.
|We disclose Identification Information to (1) service providers who provide certain services to us to assist us in meeting business operation needs, including:
|Employment Information||Your employment and education history as well as any other information you submit through your resume and/or application for employment.||We collect Employment Information from applicants, employees, and contractors through job applications and other job application interactions.||We use Employment Information to assess candidates for employment, for tax reporting purposes, financial reporting matters, and for HR and legal purposes to manage our business.||We may disclose Employment Information to service providers who provide certain services to us to assist us in meeting business operation needs, including, for example, HR vendors and cloud management services.|
|Interaction Information||Your name and contact information and 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 collect Interaction Information when you interact with our products, services, and customer service, when you create a profile in the Higher Logic User Group on our Website hug.higherlogic.com or our Apps, and from information that is provided, posted or uploaded by users to the Higher Logic User Group.||We use Interaction Information to (1) 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; (2) respond directly to your information requests (including registrations or other specific requests) or other inquiries; and (3) facilitate your engagement in the Higher Logic User Group. For EU Data Subjects, these uses are necessary for the performance of the contract between you and us.
We also use Identification Information to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.
|We disclose Interaction Information to (1) service providers who provide certain services to us to assist us in meeting business operation needs, including:
|Automatically-Collected Data||When you visit the Websites we may collect your IP address, browser type/settings, search terms used, and the data and time of your visit, ISP, site usage data, referring/exit pages, clicks, and ads viewed, among other things.||We collect Automatically-Collected Data through cookies, web beacons and other technologies (“Tracking Technologies”).||We use Automatically-Collected Data for system administration, technology management, including optimizing our websites and applications, information security and cybersecurity purposes, including detecting threats, for recordkeeping purposes, to better understand our customers and prospective customers and to enhance our services, for online targeting and advertising purposes, and for our everyday business purposes.||We may disclose Automatically-Collected Data Information to (1) service providers who provide certain services to us to assist us in meeting business operation needs, including:
Other Disclosures. We may also disclose Personal Data: (1) if you request or authorize (2) to comply with law, including responding to a warrant or subpoena or other government requests, (3) to protect the rights, property, or safety of us or others, (4) to investigate fraud, (5) for law enforcement purposes, (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 or as part of the diligence process.
Service Data. In providing our services to Subscribers through the Platforms, we also process on behalf of Subscribers information, including Personal Data, that Subscribers upload to, integrate with or otherwise submit to our services. Our Subscribers decide what data to submit (this typically includes information about their customers, prospects, employees, consultants or independent contractors, suppliers and other individuals or entities). We only collect such information under the direction of Subscribers and have no direct relationship with the individuals whose Personal Data we process.
Our use of information collected through the Platforms on behalf of our Subscribers is limited to the purpose of providing the service for which the Subscriber has engaged Higher Logic and is governed by our contract with that Subscribers and the Subscriber’s own privacy policies.
How You Can Access and Change Information
Higher Logic acknowledges that you may 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 Subscribers. An individual who seeks to access, correct, amend, or delete inaccurate data should direct his query to the Higher Logic Subscriber (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 Subscribers for Personal Data that we process through the Higher Logic Platform, as described under the “Higher Logic Platform” section above.
Consent. 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. With your permission, we may also use information you provide to us as a testimonial posted on the Websites.
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 rely on our EU-U.S. and Swiss-U.S. Privacy Shield certification to transfer Personal Data that we receive from the EU and Switzerland to Company in the U.S. (for more information, please read the “Privacy Shield” section below).
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 Subscribers for as long as needed to provide services to our Subscriber and pursuant to our contract with that Subscriber.
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||Purpose|
|Strictly Necessary||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.
|Preferences||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 Subscribers’ 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.|
|Analytics||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 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.
In their use of our services, Subscribers’ may enable various integrations which may set additional cookies. These cookies are set and controlled by Subscribers 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 Subscriber’s own privacy and cookie policies.
III. Other Technologies
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 ChoicesOn 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.
If you do not wish to receive marketing materials, brochures, push notifications, or emails from Higher Logic, you may inform us of your preference by calling Higher Logic at the contact information below, submitting a contact form electronically through the Websites and unsubscribing 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.
Inapplicability of Privacy Policies of Any Linked Websites or Other Entities
California Privacy Rights
I. California Consumer Privacy Act (“CCPA”)
To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the Personal Data we collect:
- The right to know what Personal Data we have collected and how we have used and disclosed that Personal Data;
- The right to request deletion of your Personal Information;
- The right to be free from discrimination relating to the exercise of any of your privacy rights.
We will acknowledge any request to know or to delete within 10 days of receipt, and aim to respond to such requests with 45 days. If we need more than 45 days to respond to your request to know or delete, we will inform you accordingly.
Higher Logic does not sell your Personal Data. However, we may share your Personal Data (including your contact information and your browsing activity) with social media platforms, including Facebook, that will use that information to serve targeted advertisements on the social media platforms and third-party websites. We do not control and are not responsible for the social media platform’s processing of your Personal Data. You can opt out of such marketing through Facebook here and you can contact us with any additional questions by e-mailing [email protected].
Verification: in order to protect your Personal Data from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal Data. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Data for verification. If we cannot verify your identity, we will not provide or delete your Personal Data.
Authorized Agents: you may submit a request to know or a request to delete your Personal Data through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.
II. Do Not Track
III. Shine The Light Law
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
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
Email: [email protected]
Last updated December 18, 2019