Last updated: Dec 27, 2017
The meaning of Personal Information
Personal Information has the same meaning as Personal Information. Personal Information is defined in data privacy laws applicable in your country. It includes any information relating to an identified or identifiable natural person. This means any individual who can be identified directly or indirectly by reference to an identifier such as name, identification number, location data, online identifiers (for example, IP addresses - if they can be used to identify you) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Put simply, this includes data which either by itself or with other data held by us or available to us, can be used to identify you.
Personal Information also includes special categories of Personal Information. This is data about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation (as relevant).
Important notice about international transfers
Due to the global nature of our business, your Personal Information will be stored and transferred to parties located in other countries, including outside the European Economic Area. These other countries will either have different data protection laws than your country of residence or they will not have data protection laws. They may not be deemed by the European Commission as providing adequate protection for Personal Information.
In particular, we store your Personal Information on servers in Hong Kong and Singapore. These countries are not deemed by the European Commission to have adequate protections for Personal Information. However, we store all data on Amazon Web Services servers which use the highest level of data security technology. We will use of European Model Clause contracts, where required under applicable law. You can find out what these are online at the following address: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm. If you have any questions or wish to be provided with a copy please contact us (details below). Please note commercially sensitive information may be removed/blanked out from copies supplied to you.
The categories of Personal Information we may collect
Personal Information collected from you include the following:
Personal Information about other persons
The purposes for which we use and process Personal Information
We use and otherwise process Personal Information only for specific and limited purposes. We ask only for data that is adequate, relevant and not excessive for those purposes. When we ask you for Personal Information, we endeavor to tell you the purposes for which we will process that data where appropriate.
This may include the following:
The legal basis for our use and other processing of your Personal Information under applicable data privacy laws
We have described above the purposes for which we may use and otherwise process your Personal Information in connection with the Website or for our business purposes. We are required by law to indicate to you the legal basis for this use and other processing. This will include (as relevant):
Your consent may also be a lawful reason for processing your Personal Information in certain cases. This means your freely given, specific, informed and unambiguous consent. For instance, where we seek your consent in order to send you direct marketing communication (see below). You should be aware that you are entitled under applicable data privacy law to withdraw your consent, where that has been given, at any time. You should be aware that if you do this and if there is no alternative lawful reason for us to rely on to justify the relevant use or other processing on your Personal Information, this may affect our ability to for instance provide you with information about our products and services.
In summary, we need certain categories of Personal Information because that is necessary in order to administer any contract with you (where relevant). Certain other Personal Information is processed for our legitimate interests in cases where this does not result in prejudice to you. Certain other Personal Information is processed based on a consent.
Keeping you informed and direct marketing
With your consent, where relevant we will keep your name, address and contact details (including telephone numbers and email addresses) in our databases and may from time to time use that information to make you aware of our own related products and services as well as updates on developments in our industry sector generally which may be of interest to you. We may contact you in writing, by telephone, fax or email for this. If at any time you decide that you do not want your contact details used for these purposes, please tell us (see "Contact us" below).
Data anonymization and use of aggregated information
We may convert your Personal Information into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from that data. We may use this aggregated data to conduct market research and analysis, including to produce statistical research and reports. For example, we may produce reports on which of our product offerings attract the fewest or the highest number of enquiries from brokers and intermediaries and other persons visiting our Website. We may share aggregated data in several ways, including for the same reasons as we might share Personal Information (see "Disclosure of your Personal Information to third parties" below).
In particular, we use technology to collect anonymous information about the use of this Website. For example:
We use this anonymous data to improve the content and functionality of this Website and consider areas and subjects which are attracting interest so that we can focus our e-mail updates (for those that wish to receive such communications). This allows us to better understand our Website visitors' interest areas generally and therefore to improve our Website and products and services we offer.
Disclosure of your Personal Information to third parties
We may disclose your Personal Information to third parties, including but not limited to as follows:
Security of Personal Information
We endeavour to use appropriate technical and physical security measures to protect Personal Information which is transmitted, stored or otherwise processed by us, from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access, in connection with our Website. These measures include computer safeguards and secured files and facilities. Our service providers are also selected carefully and required to use appropriate protective measures. In certain areas, HA uses industry-standard SSL-encryption to protect data transmissions. Most current browsers support the level of security needed to use these areas.
In particular, we endeavour to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including as appropriate: (a) pseudonymisation (such as where data is separated from direct identifiers so that linkage to an identity is not possible without additional information that is held separately) and encryption, (b) ensuring the ongoing confidentiality, integrity, availability and resilience of systems and services used to process your Personal Information, (c) ensuring the ability to restore the availability and access to Personal Information in a timely manner in the event of a physical or technical incident; and (d) ensuring a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational security measures.
Your HA account information is password-protected for your privacy and security. While we strive to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third parties from intercepting this information. You should not assume or expect that any communication that you transmit to us (such as personally identifiable or other data, questions or answers, comments, or suggestions) is confidential. We strongly recommend that you do not disclose your password to anyone. HA will never ask you for your password in any unsolicited communication. HA, any third parties providing services in connection with the Site, and their respective internet service providers shall not be liable or responsible if any information about you is intercepted and used by an unintended recipient.
Retention period or criteria used to determine the retention period
We keep your Personal Information for as long as it is necessary to do so to fulfil the purposes for which it was collected as described above.
The criteria we use to determine data retention periods for Personal Information includes the following: (i) Retention in case of queries. We will retain it for a reasonable period after the relationship between us has ceased (up to 6 months) in case of queries from you; (ii) Retention in case of claims. We will retain it for the period in which you might legally bring claims against us (in Germany this means we will retain it for 10 years) if and to the extent we have entered into any contract with you; (iii) Retention in accordance with legal and regulatory requirements. We will consider whether we need to retain it after the period described in (ii) because of a legal or regulatory requirement.
If you would like further information about our data retention practices please contact us (see "Contact Us" below).
Your rights under data privacy laws
You have various rights under data privacy laws in your country. These may include (as relevant): the right to request access to the Personal Information we hold about you; the right to rectification including to require us to correct inaccurate Personal Information; the right to request restriction of processing concerning you or to object to processing of your Personal Information, the right to request the erasure of your Personal Information where it is no longer necessary for us to retain it; the right to data portability including to obtain Personal Information in a commonly used machine readable format in certain circumstances such as where our processing of it is based on a consent; the right object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual; and the right to withdraw your consent to any processing for which you have previously given that consent. Please be aware that some of these rights will only become relevant when changes to data privacy laws come into force in May 2018.
Please see "Contact Us" if you wish to exercise any of these rights (as relevant).
Links to Other Websites
Updated and changes to this Website Privacy Statement
We are continually improving our methods of communication and adding new functionality and features to this Website and to our existing services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data practices will change from time to time. We encourage you to check this page frequently.
If you wish to exercise your data privacy related rights against us please e-mail: firstname.lastname@example.org
Be sure to include your email address and telephone number with your correspondence.
Alternatively, write to
Harrison Assessments International, Ltd.
Unit 3105, Level 31, Metroplaza Tower 1, 223 Hing Fong Road, Kwai Fong, New Territories, Hong Kong
Phone: (852) 35896541
For other contact details please see our website.