Hotshot Inc. (referred to as “Hotshot”, “we” or “us”) takes your privacy seriously and seeks to comply with all applicable privacy laws including, where relevant, the General Data Protection Regulation (“GDPR”). We want you to be familiar with how we collect, use and process your Personal Information (defined below) and your rights to seek the return and/or changes to any of your Personal Information that we hold.
1. PERSONAL INFORMATION
Personal Information We May Collect, As Provided by You
“Personal Information” is information that identifies you as an individual, which may include:
- Email address
- School status
- Your viewing of content and other usage information
How We May Collect Personal Information
We may collect Personal Information in a variety of ways, including:
- Offline: We may collect Personal Information from you offline, such as when you contact customer service.
How We May Use Personal Information
We may use Personal Information:
- To respond to your inquiries and fulfill your requests, such as to send you e-mails or other communications about the Services.
- To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
- To send you marketing communications that we believe may be of interest to you, unless you elect not to receive them.
- To personalize your experience on the Services by presenting information tailored to you.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, assessment of the effectiveness of your learning or the Services, developing new products, enhancing, improving or modifying the Services, assessing your performance, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we reasonably believe to be necessary: (a) to comply with applicable laws, such as accounting regulations; (b) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) to enforce our terms and conditions and/or reasonably protect damage to our operations or ensure the safety of any third party; and (d) to respond to civil subpoenas or inquiries.
We will only collect and process such Personal Information as is required for the uses set out above. If a user receives any certifications or accreditations from completing a Hotshot course (“Certification”), such Certifications will be retained by Hotshot and made available to you, transferred to a new client account or deleted, upon your request.
How Personal Information May Be Disclosed
Your Personal Information may be disclosed (but in all cases only so far as reasonably necessary):
- If your subscription is provided in whole or in part by your employer, school, or other third party, we may share with them information about your access to and use of your subscription. When providing this information, we may reveal limited amounts of your Personal Data, such as your name and usage information.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence or otherwise to comply with legal process; (b) to respond to legitimate requests from public and government authorities including public and government authorities outside your country of residence; and (c) to enforce our terms and conditions as reasonably necessary in order to protect our operations, prevent damage to property, other third parties, or ensure personal safety.
2. OTHER INFORMATION
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Browser and device information
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you
- Aggregated information
We and our third-party service providers may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type, screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies: We and our third-party providers may use Flash LSOs, Flash Cookies, and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Services or our online content.
- IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is done automatically by many websites, applications and other services. We use IP Addresses for many purposes, including, without limitation, calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
- From you: Information such as your location, as well as other information, such as your preferred means of communication, practice area, your performance and responses to quizzes and surveys, and organization, is collected when you voluntarily provide this information.
- By aggregating information: Aggregated Personal Information does not alone personally identify you or any other user of the Services, (for example, we may aggregate Personal Information to calculate the percentage of our users in a particular region).
How We May Use and Disclose Other Information
In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). Any such combination shall not reduce or remove Hotshot’s obligations with respect to Personal Information.
3. THIRD-PARTY SERVICES
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, including our third-party providers, or other organizations or services that you may use to access the Services, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to such other organizations.
We have implemented organizational, technical and administrative measures to protect Personal Information within our organization. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us as soon as possible in accordance with the “Contacting Us” section below.
5. CHOICES AND ACCESS
Your Choices Regarding Our Use and Disclosure of Your Personal Information
We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:
- Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out of receiving these marketing-related emails by sending an email to email@example.com or follow the unsubscribe instructions included in each marketing-related email.
- Receiving telephone calls or postal mail from us: If you no longer want to receive marketing-related telephone calls or postal mail from us on a going-forward basis, you may opt out of receiving these marketing communications by sending an email to firstname.lastname@example.org and specifying the contact information used and form of marketing from which you are opting out.
- Hotshot retaining, for you, your Certification data: If you no longer want us to retain your Certifications, please notify us by sending an email to email@example.com and specifying the contact information originally used to access the Service.
We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt out from receiving administrative messages.
How you can access or change your Personal Information – Portability
If you would like to review, correct, update, suppress, or delete, subject to the terms herein, any of your Personal Information that is retained by Hotshot, you may contact us by emailing: firstname.lastname@example.org
In your request, please make clear what Personal Information you would like to have changed or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us.
For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
Upon termination of your subscription with Hotshot you may request access to the Personal Information we hold about you which will be delivered in the format in which Hotshot maintains this data. Such Personal Information may be used by you for any purposes subject to any restrictions in the Agreement between Hotshot and you or the organization which paid for your access to the Services
6. RETENTION PERIOD
7. USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of eighteen (18), and these individuals are prohibited from providing Personal Information through the Services.
8. CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.
9. SENSITIVE INFORMATION
We ask that you not send us, and therefore you must not disclose, any sensitive Personal Information (e.g., gender, sexual orientation, social security numbers, birthdates, account numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise to us.
11. CONTACTING US