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Effective as of July 1, 2022 HRSI (“we”, “us,” or with “our”) has developed this policy statement (“Privacy Policy”) to explain how we collect, use, process, protect and disclose personally identifiable information (“PII”) when you use the HRSI website (the “Website”) and all services made available by HRSI or through third parties on behalf of HRSI, including but not limited to the Squarespace platform, that enable you to interact with HRSI and to participate in HRSI activities and services through the Internet (collectively, including the Website, the “Services”). “You” or “user” or “your” refers to you as a user of any part of the Services. PII is information that can identify a specific individual, such as, without limitation, a name, address, phone number or email address. HRSI reserves the right to change this Privacy Policy at any time to address changes to our information collection, disclosure or use practices or changes in law. If HRSI makes changes to this Privacy Policy, HRSI will post those changes on the Website and provide notice of any material changes. By using the Services, you signify your unqualified agreement to the terms of this Privacy Policy. Please review this Privacy Policy on a periodic basis to ensure your continued agreement when you visit the Website. BY USING THE WEBSITE OR THE SERVICES, YOU ARE ACCEPTING THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, DO NOT USE THE WEBSITE OR THE SERVICES. THE TERMS OF THIS PRIVACY POLICY SHALL NOT SUPERCEDE ANY LAW, REGULATION, THE HRSI POLICIES AND PROCEDURES HANDBOOK, OR ANY OTHER WRITTEN POLICY OF HRSI THAT GOVERNS THE USE OF A SPECIFIC HRSI SERVICE, OR WRITTEN AGREEMENT THAT ANY USER OF THE WEBSITE OR SERVICES HAS ENTERED INTO WITH HRSI INDIVIDUALLY OR ON BEHALF OF AN ORGANIZATION. Why Does HRSI Collect PII? HRSI collects PII so that it may customize your experience when you use the Services, it may improve the products that it offers to you, and that it may make you aware of information about HRSI, its products, and similarly relevant products and services. What PII Does HRSI Collect? Specific examples of the types of PII HRSI may collect through the Services include: Contact Information: HRSI may request or require contact information, such as your name, job title, the organization you work for or represent, phone number, and email address when you seek access to or information from some of the Services. Demographic Information: HRSI may collect and compile demographic data (e.g., general employment or military information such as duration of employment or service, organization, service branch, title, rank and position) when you use the Services. Transactional Information: HRSI may create and maintain a database of aggregated information about transactions that occur when you use the Services (e.g., tool or feature (and related database) utilization, registration information, and activity, navigation or content selection data). Financial Information: HRSI may use credit card account information you provide to facilitate payments to HRSI or purchase HRSI Services. Note, however, that HRSI does not maintain this credit card information. Usage Information: HRSI may collect usage information, including but not limited to the Internet Protocol (IP) addresses from all users of the Services, as well as the date and time of access and the Services accessed. HRSI may also catalog the type of computer, device, browser or operating system used by the user. Location Information: The Services and/or mobile applications utilized to access the Services on a cell phone may collect certain additional information automatically, including, but not limited to, the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, available storage space, connection type (e.g. WiFi vs. cellular) and information about the way you use the application. We may also use GPS technology (or other similar technology) to determine your current location. If you do not want us to have your location information, you should not allow or turn off the location services for the mobile application and/or mobile web browser that you use to access the Services located in your account settings or in your mobile phone settings and/or within the mobile application. How Does HRSI Use PII? As detailed below, HRSI uses PII to operate the Services and to provide and/or enhance certain of its features, tools and functionality. HRSI also uses PII to provide and improve the quality of the programs, solutions and services HRSI may offer or make available and to make you aware of information about HRCI, its products, and similarly relevant products and services. Contact Information HRSI may use your contact information in connection with the provision of its services, software solutions and content and to enable you to participate in any HRSI events, programs and/or offerings available through the Services, including to: advertise its HRSI products, events, programs or services, create a personalized experience for you when using the Services, provide you with news and information, contact you regarding a survey, participate in volunteer activities including test development or committee activities assist with security or fraud prevention or response measures, and to get in touch with you with respect to transactions related to the Services, including material changes in HRSI’s policies and agreements. HRSI may (i) supplement the contact information collected from you while using the Services with information about you obtained from other sources, such as, without limitation, from HRSI’s advertisers and business partners. HRSI may (ii) engage in cross-border transfers of PII to provide or enhance our ability to provide or advertise our products, programs, events, services, or software solutions and/or the products, programs, events, services, or software solutions of others, and (iii) to otherwise tailor the Services. HRSI also may share, license, and/or sell your contact information with or to third parties including, without limitation, HRSI’s agents, contractors, vendors, advertisers or business partners, to: provide or improve our products, programs, events, services, or software solutions, allow for online registration for products, programs, events, or services, the online provision of software applications, advertise or market products and services relevant to you, and/or facilitate other internal business purposes. Demographic Information HRSI may use demographic information for marketing, administrative, management, and monitoring purposes both to continue to provide or improve the Services and to provide or improve any software solutions, programs, products, events or services HRSI may offer. In addition, HRSI may share, license, and/or sell survey results and aggregated demographic data collected through the Services with or to third parties, including, without limitation, its affiliates, advertisers, business partners, the general public, the news media, and the U.S. Government and state governments, not only as may be required by law, but also for advertising purposes, for release to third parties, and/or to participate in government programs and initiatives. No survey results or aggregated demographic data provided by HRSI to third parties will identify any particular user. Transactional Information HRSI may use transactional information for marketing, administrative, and support purposes in order to provide or improve any software solutions, programs, products, events or services HRSI may offer. In addition, HRSI may also share, license, and/or sell such transactional data for such purposes on an aggregated basis (which will not identify any particular user) with or to third parties, including, without limitation, advertisers or business partners. Financial Information HRCI may use, collect, and pass credit card or online payment information to third parties to process payments for the Services and anything available for purchase on the Website, including, without limitation, examination preparation materials, accessories, and HR Certification applications. HRCI does not store credit card information on the Website but may store unique tokens provided by third parties. Usage Information HRSI may use usage information, such as your IP address, device id, device type, connection type, browser and/or location, to help diagnose problems with our servers, analyze usage trends, track user movements on the Website, and to otherwise manage and monitor the Services. In addition, HRSI may also share, license, and/or sell such data for such purposes on an aggregated basis (which will not identify any particular user) with or to third parties, including, without limitation, advertisers or business partners. What About the Use of Cookies and Other Data Collection Techniques? HRSI or its contractors may use cookies, web beacons, tags, log-in files, and/or other similar data collection or tracking techniques (collectively, “Cookies”) to enhance and/or monitor your experience while using the Services and/or to track the efficacy of advertising campaigns. Cookies are generally pieces of information, which HRSI uses for record-keeping purposes and which the Services may transfer to us and/or your computer’s Web-browser for storage on our server(s) or your computer or mobile device.. Cookies enable HRSI to manage and/or customize your experience using the Services, including directed advertisements. Cookies also make navigating the Services in a browser easier by automatically performing certain functions, such as saving your personal preferences and by providing targeted content. HRSI never will use cookies to record passwords, credit card or other financial information. The use of Cookies is an industry standard measure, your Web browser likely is set to allow them. If you would prefer not to receive Cookies, however, you may alter the configuration of your browser to refuse cookies or surf anonymously. If you choose to have your browser refuse cookies or attempt to navigate the Services anonymously, you should understand that it is possible that some areas of the Services will not be accessible or will not function properly. Other Transfers of PII Information You Make Available to Others By using the Website or Services, submitting public queries, or making public comments in parts of the Website where that is possible, you may elect to make certain of your PII available to others, such as your name or username, and you may voluntarily enter and make available comments and other content that includes additional PII. Such publicly posted information may be accessed by users who use the Website or Services and may be accessed by commercial search engines such as Google, Yahoo!, Bing, or other browsers to the extent that such engines are permitted to access the Website or Services. Service Providers From time to time, we may establish a business relationship with other businesses that we believe to be trustworthy and have privacy practices consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, accounting, data analytics and data storage and management, assessment-related activities, Internet-based platforms, and marketing and promotions. HRSI Service Providers include but are not limited to Microsoft, the provider of customer account and relationship management applications; Credly, the provider of HRSI digital badges; HubSpot, the provider of inbound marketing, sales, and customer services for HRSI; and Squarespace, the Internet-based platform that HRSI uses to engage with HRSI potential customers. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. HRSI ensures that each Service Provider uses reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your PII from unauthorized access, use, or disclosure. Service Providers may use PII only to carry out the services that we contract from them. Business Transactions If HRSI goes through a business transaction, such as a bankruptcy event, merger, investment transaction, or acquisition by another entity involving the sale of all or a portion of its assets, the PII collected and retained by HRSI may be among the assets transferred or reviewed. If a transaction of this kind occurs and results in the transfer of your PII to a purchaser of all or a portion of the assets or ownership interests of HRSI, HRSI will notify you via e-mail and/or place a prominent notice on the Website for thirty (30) days of any such change in ownership or control and the possibility of changes being made to this Privacy Policy. Investigation and Legal Action We may use, process and disclose your PII, usage data, user interaction data and other non-personally identifiable information collected through the Services to investigate whether any use of the Website or the Services may potentially violate any policies of HRSI, agreements between users of the Services and HRSI, the rights of HRSI and any of its members or a third party, or any applicable law or regulation. This includes, but is not limited to, the investigation of allegations, reports or suspicion of conduct that could affect the validity of HRSI assessment results for one or more persons, HRSI certification application fraud, and other activities that may violate the terms of use of the Website and/or Services. The findings of any such investigation may be disclosed to interested third parties, which may include, as applicable, your employer, governmental authorities, certification and/or licensure bodies and credentialing bodies. HRSI may also disclose PII when legally required to do so in accordance with subpoenas, government requests or regulations, or legal proceedings. HRSI may also disclose PII to protect against misuse or unauthorized use of the Services or as is otherwise required to limit legal liability, protect or defend our rights, property, or interests, or protect the safety, rights or property of other end users or customers. How Does HRSI Protect PII? As is appropriate for the nature of PII collected and stored by HRSI, the Services are provided and protected by best practice and industry standard security measures or safeguards to minimize the risk of loss, misuse and alteration of the PII under HRSI’s control. With respect to any stored PII, HRSI will also use commercially reasonable efforts to preserve such PII in its original form to the extent possible and as consistent with any processing that is directed by you or necessary for HRSI to provide the Services. HRSI may store PII for a period no longer than necessary for the purpose of operating its business. Although HRSI has endeavored to ensure the Services are secure and reliable, the confidentiality, integrity, or availability of any communication, data, or material transmitted via the Internet or stored with HRSI cannot be 100% guaranteed. Accordingly, you should consider carefully whether you want to submit PII via the Internet. What About “Opting-Out” of Data Collection and Use? The collection, use, and sharing of your PII may be necessary for HRSI to provide certain products, features, programs, events, resources and services made available as part of the Services, and to operate and/or improve the Services. For example, all users who request information about products or register for an event, program or seminar, or purchase resources from HRSI on the Website must agree to HRSI’s use and collection of PII. Under other circumstances, however, you may decide on your own whether you will provide your PII or opt-out of doing so. For example, if HRSI conducts a survey on the Website, you do not have to participate unless you agree to do so. You also may opt-out of certain HRSI business practices in which your PII may be used. Specifically, users may opt-out of including the use of their PII for inclusion in: user postal mailings email communications sent by HRSI, facsimile communications sent by HRSI, and certain sharing arrangements with HRSI’s business partners. To opt-out of postal mailings, email communications, and facsimile sent by HRSI you can submit the request by email to info@HRSI.org. California Residents: Companies that collect PII from California residents and disclose such information to third parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide a mechanism by which a consumer may opt-out of having his or her information shared with third parties. HRSI has elected the second option, and you may request that your PII not be shared with third parties by sending your request, including your full name, email address and postal address, to HRSI, Attn. Privacy, 1015 15th Street NW, Washington DC 20005. California residents are also entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov. Moreover, HRSI may use certain methods and technologies to collect PII relating to your online activities over time (i.e., through more than one visit to the Website) and across third party websites or Internet-based services (i.e., through HRSI’s receipt of PII from other data sources). Any user who wishes to opt-out of such PII collection may contact us by email, phone or mail per the contact information listed in the final paragraph of this Privacy Policy. What About Correcting, Deleting, or Updating Information? Should you need to correct, modify or delete information, or when you cease to use HRSI’s services or no longer wish to be included in HRSI database, you may contact HRSI at info@HRSI.org to request to have your information corrected or removed from the HRSI database. If HRSI receives such a request or change, HRSI may require you to confirm or verify any change to your record. Please note, however, that the collection and uses of certain PII is necessary to provide all or part of the Services and you will not be able to delete such necessary information after you have entered into a contract with HRSI to provide you with services that require such information. In other instances, if you request the deletion of PII, it may render a particular HRSI solution or service in accessible to you or inoperable. What About Residents of the European Economic Area and the United Kingdom? Information about the General Data Protection Regulation (GDPR) can be found here. GDPR outlines subject access rights of individuals in relation to their personal data. If you are a resident of the European Economic Area or the United Kingdom and would like to exercise any of Your rights under GDPR, Your rights and the actions you can take are summarized below. Right to Access: You can be given access to most of the data we have about you by requesting it via an email, facsimile, or letter. You can request a complete report on what personal information we have about you and it will be provided at a reasonable interval.Right to Rectification: We strive to keep records and all data accurate. If you would like to modify an inaccurate record of Your personal data, you can request that we make the correction for you. Right to Data Portability: You can request a copy of your personal data to be transferred to a new system or platform as long as it does not create an obligation for HRSI to adopt or maintain processing systems which are technically compatible. Right to Object: You can object to our processing of your personal data in certain limited circumstances that are not related to our provision of the Services.Right to Restrict Use: You can request that we restrict the processing of your personal data in certain limited circumstances that are not related to our provision of the Services.Right to Erasure: You can request that we delete your personal data in certain extremely limited circumstances that are not related to our provision of the Services.All GDPR subject access rights requests must be sent via email to info@HRSI.org and include the specific details for your request and the basis for making the request. We will respond to all valid subject access rights requests within 30 calendar days of receiving the request; however, it may take longer to fulfill your request. If you are unsatisfied with how we handle your request, you can find the contact information for your local data protection authority here. What About Children? HRSI cares about the safety of children on its Website and encourages parents and guardians to monitor their children’s use of the internet. Although the Website is suitable for a general audience, the Website is intended for use only by users who are over 18 years of age. Accordingly, HRSI does not knowingly solicit PII from children or send them requests for personal information. If you become aware that a child has provided PII to HRSI, please contact HRSI immediately so that such PII may be deleted and that HRSI may discontinue any further services provided to such child. What About External or Third-Party Web Websites? To the extent hyperlinks or gateways are utilized to access external or third-party Websites within the Services, you should be aware that these external or third-party Websites may collect PII and are not controlled by HRSI and therefore, are not subject to this Privacy Policy. This Privacy Policy applies only to the Services as defined herein and will not apply to other websites that are not controlled or made available to HRSI stakeholders pursuant to a contract with HRSI. HRSI suggests that you check the privacy policies of other websites to determine how the proprietors of these third-party websites will collect and/or utilize your PII. What About Governing Law? This Privacy Policy is governed by and construed in accordance with the laws of the Commonwealth of Virginia, U.S.A. The use of PII also is subject to the data protection and privacy laws of countries in which the user or the PII is located. If any part of this Privacy Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision or part will be deemed suspended by a valid, enforceable provision that most closely matches the intent of the original provision or part and the remainder of this Privacy Policy shall continue in full force and effect. What About Cross-Border Transfers? The Services and the servers that host the Services are located in the United States. Backup servers for the Services and associated PII may be located in other countries. Any information you provide through the Website or Services will be transferred to the United States. By visiting and using the Services and submitting PII, you authorize this transfer of your PII to the United States and to other countries. What About Any Other Questions? If you have any questions about this Privacy Policy or the PII collection and use practices for the Services, contact HRSI at info@HRSI.org, (866) 898-4724 (U.S. Toll Free Phone Number), +1.571.551.6707 (International Phone Number), or at HRSI ATTN. Privacy, 1725 Duke Street, Suite 400, Alexandria, VA 22314.