Healthy Place To Work Privacy & Security Notice

At Healthy Place To Work Institute, Inc. (“HPTW”, “we”, and/or “us”) we take security and privacy seriously. HPTW is committed to protecting the privacy of the individuals (“visitors,” “users,” and/or “you”) who visit our website and subpages located at https://www.Healthyplacetowork.com (the “Site”) or use our products and services.

Scope

This Privacy & Security Notice describes HPTW’s privacy practices in connection with:

Your use of the Site
The HPTW products and services accessed by HPTW’s customers, partners or end users (hereafter, the “Product”)

This Privacy & Security Notice does not cover HPTW’s privacy practices for:

HPTW employees, contractors, or job applicants
Children and/or Minors. Our Site is neither designed nor intended for any visitors under 18 years of age. If you have any reason to believe that a visitor to our Site is under 18 years old, please contact us, at privacy@Healthyplacetowork.com and we will endeavor to delete the information from our databases.

What is Personal Information?

For purposes of this Privacy & Security Notice, personal information means information collected by HPTW relating to an identified or identifiable natural person and includes similar terms as defined by various jurisdictions.

Links to Third-party Websites

For your convenience, the Site may contain links to third-party websites and/or information. When you access those links, you leave HPTW’s Site and are redirected to a third-party website. HPTW does not control third-party websites, and the privacy practices of third parties might differ from HPTW’s privacy practices. We do not endorse or make any representations about third-party websites. When you share personal information with third-party websites, the third-party processing is not covered by this Privacy & Security Notice. We encourage you to review the privacy policy of any website or company before sharing personal information.

HPTW’s Privacy Practices Affecting Users of Our Site

Sources of Personal Information We Collect From Site Visitors:

HPTW collects personal information from individuals who access our Site, including:

Directly from a website visitor
From service providers or other third parties; and
Automatically from a web visitor’s visit or activity on our site

Information Collected Directly From Website Visitors Including Job Applicants

HPTW collects personal information when you visit our Site and when you choose to provide personal information. For example, we collect information when you contact us via our Site, provide your email, phone number or other similar contact information, such as the information that you provide when you sign up for a webinar.

What We Collect

The personal information collected from a visitor to our Site may include:

Name
Company
Job Title
Address
Phone Number
Email Address

The personal information collected from an applicant or employee of HPTW includes, but is not limited to:

Personal Identifiers (Name, Address, Age, Date of Birth, Social Security Number);
Professional or Employment-related Information (Employment Record, Salary);
Education Information; and
Personal/Professional Contact Information

If you register to attend a HPTW sponsored Event, we may require certain data in some instances, including:

Emergency contact
Dietary preferences
Health and safety information
Billing information (such as billing name, billing address, and credit card number)

Information Provided by Third Parties or Publicly Available Sources

We may receive information about you from other sources and combine that information with the information we collect directly. Examples of information we may receive from other sources include: purchased business contact information and from publicly accessible websites, such as your company’s website, professional network services, or press releases.

Business contact information may include:

First name
Last name
Business email
Telephone number
Company name
Job level
Functional role
Business street address
Online identifier
Employment history

We use this data for our internal customer analytics, to identify prospective customer marketing opportunities, and to improve the relevance of our Site content and our advertising.

Information Collected by Cookies

Like many websites, HPTW uses cookies and similar tracking technologies (including for analytics, functionality, advertising, and other purposes).

You can set your Internet browser or operating system settings to stop accepting new cookies, to receive notice when you receive a new cookie, to disable existing cookies, to omit images (which will disable pixel tags) or adjust your tracking preferences. Note that the opt-out will apply only to the browser that you are using when you elect to opt out of advertising cookies. Without cookies or pixel tags though, you may not be able to take full advantage of our sites’ features.

Information Collected for Analytics

Our Site may record information concerning how often you use the application, the events that occur within the application, aggregated usage, performance data, your IP address. We do not link the information we store within the analytics software to any personal information you submit within the Site.

If you use certain systems provided by HPTW, we will collect data from you to enable multifactor authentication, such as mobile number, email address, or unique verification identifier.

Information Collected Directly From Social Media Features

Our website may host various blogs, forums, wikis, and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal information or other information that you contribute to any Social Media Application can be read, collected, and used by other users of that Social Media Application over whom we have little or no control. Therefore, we are not responsible for any other user’s use, misuse, or misappropriation of any personal information or other information that you contribute to any Social Media Application.

Other Information

If HPTW collects any other personal information from you, we will explain which personal information is collected and the purpose for its collection.

Why We Use Your Personal Information

Our purposes of processing personal information include:

To fulfill the purpose(s) for which the information was collected or provided, including to communicate with you and respond to your inquiries and requests;
To improve our site, products and services, through testing, research, analysis and product development;
To market, advertise, and promote our products and services, such as to make suggestions and recommendations to you about products or services that may be of interest to you;
To provide training related to the products and services, such as making available training materials or events (whether in-person or online) for which we may use your personal information to provide notices and information regarding such training and events;
For security, audit, internal investigation, and fraud prevention purposes, such as to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity, and availability of your personal information; to allow only the appropriate use of your personal information; to identify any fraudulent, harmful, unauthorized, unethical or illegal activity;
To manage litigation, such as in connection with establishing, exercising, or defending our legal rights where it is necessary for our legitimate interests or the legitimate interests of others;
To improve the content and format of our Site by using cookies and other similar technologies, such as to measure the preferences of our Site visitors, analyze trends, administer the Site, analyze use of the Site, and to gather demographic information about visitors to the Site;
For other purposes for you have provided consent;
To aggregate or deidentify your personal information so that the information can no longer be linked to you or your device and use and share such data for any business purpose in accordance with applicable law; and
To comply with all applicable legal obligations, such as to comply with subpoenas and other court orders to process data where we have determined there is a legal requirement to do so.

Disclosure of Your Personal Information

Please note, HPTW does not sell or share personal information to third parties. The term “sell” as defined by applicable laws, means disclosure of personal information to third parties for monetary or other valuable consideration.

Please review each of the sections below to learn more about how we may disclose your personal information.

Affiliates, Licensees, and Subsidiaries: We might disclose your personal information with our affiliates, licensees, and subsidiaries in order to deliver a product or service or to complete a task requested by you.
Third-Party Suppliers or Service Providers: We might engage with third parties (suppliers and/or service providers) in order to deliver a product or service, perform certain functions such as enhancing or delivering the Product, or complete a task requested by you.

We have contracts with our Third-Party Suppliers or Service Providers to perform certain functions on our behalf, and only at our direction. Our third parties are bound by confidentiality agreements and other data protection terms designed to ensure the Third-Party Suppliers or Service Providers only use your personal information to the extent necessary to provide these contracted services in accordance with our instructions (and for the purposes we disclose).

In addition, HPTW might disclose personal information if we in good faith believe that it is necessary:

To protect or defend our rights and property;
To protect against misuse or unauthorized use of our website;
To protect the personal safety or property of our users or the public (among other things, this means that, if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions); and
To comply with the law or with legal obligations, such as with law enforcement officials, government authorities or other third parties in response to a lawful request for information by a competent authority, if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process, including to meet national security or law enforcement requirements.

Choosing Not to Share Your Personal Information

You may choose not to provide personal information. If you choose not to provide personal information (or ask us to delete it), we may not be able to provide you with our Site, the Site functionality may be limited, or we may not be able to otherwise fulfill requests you submit to us. We will tell you what information you must provide for us to fulfill your request by designating it as required at the time of collection or through other appropriate means.

Site Security

HPTW utilizes physical, technical, and administrative controls and procedures designed to safeguard the information we collect, prevent unauthorized access or disclosure, to maintain data accuracy of your personal information, and to restrict the processing of your personal information as set forth in this Privacy & Security Notice.

We utilize a variety of physical and logical access controls, firewalls, anti-virus, and backup systems. We use encrypted sessions when collecting or transferring sensitive data through our Site.

We limit access to your personal information and data to those persons who have a specific business purpose for maintaining and processing such information. Our employees who have been granted access to your personal information are made aware of their responsibilities to protect the confidentiality, integrity, and availability of that information and have been provided training and instruction on how to do so.

HPTW’s Privacy Practices Affecting Users of Our Product

We generally market and sell our Product to businesses, not consumers. Our commitments regarding the personal information we collect, use, and disclose about the end users of the Product are largely driven by our contracts with business customers. The information provided below is intended to help our business customers understand our privacy practices. If you are an end user of one of our products or services, you are encouraged to contact your employer with questions about how your personal information is being collected, used, and disclosed.

Information We Collect

In most instances, HPTW customers are the controllers of the personal information they collect, create, communicate, and store in our Product. The types of personal information that can be stored in our Product may include, but is not limited to:

End User Names
Company Names
Job Titles
Business Addresses
Email Addresses
Any personal information provided to us by Users of our Product, and which is required for us to execute our agreements with our Customers.

Use of Information We Collect

When we act as a processor, the personal information we collect is used to deliver our products and services to Customers. Any personal information we use is done in accordance with our contracts with our Customers.

Because our business clients are data controllers, it is primarily them who must undertake efforts regarding how information is collected and processed in accordance with data-protection laws. Therefore, if you have questions or concerns about the processing of your information as an end user, you should contact your employer directly or refer to its separate privacy policies.

HPTW does not give anyone access to the personal information maintained in the Product unless:

It is permitted to do so in its contract with the Customer.
The Customer instructs HPTW to do so;
The Customer consents (e.g., subprocessors used by HPTW);
If HPTW is legally obligated to do so; or
If HPTW has a legitimate interest (as defined under GDPR and other applicable laws) to do so.

Data Retention

HPTW will only retain personal information for the length of time necessary to fulfill the purpose(s) for which the information was collected or as required or permitted by applicable laws, (including the resolution of disputes) and in accordance with our customer contracts.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require your personal information, we will either delete or deidentify it or, if this is not possible, we will securely store it in accordance with this policy and cease use of the personal information until deletion is possible. If we deidentify your personal information (so that it is no longer associated with you), we may retain this information for longer periods. To support our research and enable historical comparisons, we retain deidentified data indefinitely.

Disclosure of Personal Information

We do not sell your personal information to third parties. We may, however, share your information with:

Affiliates, Licensees, and Subsidiaries: We might share personal information with our affiliates, licensees, and subsidiaries in order to deliver a product or service or to complete a task requested by our customer.
Third Party Suppliers or Service Providers: We might engage with third parties (suppliers and/or service providers) in order to deliver a product or service, perform certain functions such as enhancing the Product, or complete a task requested by our customer.

We have contracts with our Third-Party Suppliers or Service Providers to perform certain functions on our behalf, and only at our direction. Our third parties are bound by confidentiality agreements, only have access to personal information to the extent necessary to provide these contracted services, and are only permitted to process personal information in accordance with our instructions (and for the purposes we disclose).

In addition, HPTW might disclose personal information if we in good faith believe that it is necessary:

To comply with the law or with a legal process
To protect or defend our rights and property
To protect against misuse or unauthorized use of our website
To protect the personal safety or property of our users or the public (among other things, this means that, if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).
In connection with, or during negotiations for, an acquisition, merger, asset sale, or other similar business transfer that involves all or substantially all of our assets or functions where personal information is transferred or shared as part of the business assets (provided that such party agrees to use or disclose of personal information consistent with our Privacy & Security Notice or gains your consent for other uses of disclosures).

We will not cross-reference your personal information with that of any other customer or entity. HPTW does not support “back door” access to any of its products, services, or operations (including our data stores) by any government or third party. HPTW does not share its encryption keys or provide the ability to break our encryption keys with any government or third party.

Protecting Your Information

HPTW has many dedicated policies, practices, and protocols to protect our IT infrastructure, networks, devices, and data from unauthorized access, collection, retention, and use of sensitive, confidential, and/or proprietary customer or user data, including personal information. These policies, practices, and protocols include, but are not limited to:

Product Security

Engineering and development access to the components that comprise the Product is restricted using methods including, but not limited to, Single Sign-On, two factor authentication, network segmentation, and IP restriction. Access to servers and services inside the primary Product boundary is controlled using centralized accounts, two-factor authentication, and bastion hosts. We employ separation of duties between developers and operations staff to limit access to the Product environment to those with a legitimate business need. The Product is protected by a web application gateway and an outbound firewall with IdP. Data is encrypted in transit and at rest using encryption that meets the current NIST standard.

Access Provisioning and Review

We have a policy and process for creating new accounts, adding and removing permissions from existing accounts, and deprovisioning access upon separation. Required approvals are collected from supervisors and application / group owners to ensure that requests are reviewed for appropriateness by multiple leaders before permissions are granted. In addition, we conduct a quarterly two- phase access review that engages both supervisors and group owners. HPTW employee permissions related to the Product that grant access to customer data are included in this access provisioning and review process. The Product provides customers with real-time information about the user accounts they have created and gives them the ability to change or revoke access at any time.

Customers are responsible for managing access to the platform by creating and revoking user accounts.

Endpoint Security

Our employee endpoints (laptops and mobile devices) are connected to endpoint management software. In order to sign on to any HPTW SSO protected resource (including the Product), an employee must be using a device registered in our endpoint management software that meets our compliance policy. The compliance policy is designed to ensure that a device meets our standards for minimum operating system version, hard drive encryption, secure boot/anti- rooting, firewall enablement, anti-virus, etc. Users and administrators are notified when a device is out of compliance. Non-compliant devices are automatically blocked from accessing company resources once the compliance grace period expires.

Vulnerability Management

Our employee endpoints (laptops and mobile devices) as well as servers in the Product environment are connected to vulnerability management software. We actively scan for vulnerabilities and have a vulnerability management policy and procedure designed to limit the number of known vulnerabilities and number of exposed devices, according to the severity of the vulnerability. We have periodic vulnerability management meetings to review current remediation status, plan future remediations, manage exceptions and accepted risk, and review aged vulnerabilities as time passes and the technical landscape evolves. On laptops and mobile devices, we automatically update critical software (operating systems, browsers, productivity software). Inside the Product environment, we periodically update minor versions of operating systems, databases, and other critical software through our change management process following validation in pre-production environments.

Backup and Disaster Recovery

The Product environment is periodically backed up. All persistent data is backed up with at least a 24 hour recovery point objective. Data that changes frequently is backed up more frequently (up to and including continuous backup). Backups are persisted to geo-redundant online storage at least every 24 hours to protect against the catastrophic failure of a given data center. The majority of our infrastructure is implemented using infrastructure as code. We have documentation and code allowing us to build a new Product environment in the event of a major disaster. We test our disaster recovery procedure annually.

Data Classification, Handling, and Labeling

We have a data classification, handling, and labeling policy. Data is classified according to its risk. Employees receive training on the policy and its practical implementation. We have a detailed list of all data artifacts related to or produced by the Product that explains their classification in detail.

Global Laws and Regulations

We commit to comply with all applicable laws and regulations including, but not limited to, the following outlined below.

General Data Protection Regulation (GDPR)

The GDPR is a comprehensive data-protection law that regulates the processing of personal data of European Union (EU) residents and provides individuals rights to empower individuals by giving them more control over their personal data. The GDPR enshrines major principles such as privacy by design,privacy by default, and implementation of strong technical and organizational measures designed to protect personal data.

The GDPR is not limited to the EU. It applies to all organizations that target, collect, or use the personal data of any EU resident and mandates organizations to:

Know what data they hold and have appropriate rights to use the data.
Be accountable and able to answer questions about what type of data they hold, and in some cases, delete data they no longer need.
Notify supervisory authorities of data breaches.
Use vendors that comply with the principles of the GDPR
Offer European Essential Guarantees by challenging governments’ requests to access personal data.

HPTW is committed to compliance with the GDPR and all applicable laws. We have enhanced process to prepare to address the rights of people in the EU and we are prepared to answer questions from our customers as well as our employees.

California Residents – California Privacy Notice

The California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) provide certain privacy-related rights to California residents. Learn more about HPTW privacy practices and compliance with the CCPA and CPRA.

International Transfers of Personal Information

HPTW operates globally and, as such, may process personal data worldwide to provide customer support; in connection with HPTW sub-processors, a list of which is available below and their own sub-processors, where applicable; and in connection with HPTW professional services.

Strict data protection laws govern he transfer of personal data from the European Economic Area (EEA), United Kingdom, and Switzerland, to countries deemed by the European Commission as not offering an equivalent standard of protection, including the United States.

To address this requirement for our customers with operations in the EEA, the United Kingdom, and Switzerland, HPTW has incorporated the European Commissions approved standard contractual clauses, also referred to as the “SCCs,” into our customer contracts.

HPTW has started using the new SCCs, which were adopted on June 4, 2021, for all new agreements, order forms, and other customer and supplier transaction documents. If you require an amendment to include the new SCCs, please reach out to privacy@Healthyplacetowork.com.

Data Privacy Framework

Compliance and Certification: HPTW complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. HPTW has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. HPTW has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit the Data Privacy Framework website.

Inquiries and Complaints: You may lodge a complaint with a data protection authority, such as the supervisory authority of your usual place of residence. A full list of EEA data protection authorities is available here.

Swiss Federal Data Protection and Information Commissioner (FDPIC)
Federal Data Protection and Information Commissioner
 Feldeggweg 1
 CH - 3003 Bern
Tel. 058 462 43 95

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, HPTW commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF.

If you believe HPTW maintains your personal data in one of the services within the scope of our Data Privacy Framework certification, you may direct any inquiries or complaints concerning our Data Privacy Framework compliance to privacy@Healthyplacetowork.com. HPTW will respond within forty-five (45) days. If HPTW does not resolve your complaint, you may have the possibility to engage in binding arbitration through the Data Privacy Framework Panel. For more information on this option, please see Annex I of the EU-U.S. Data Privacy Framework Principles.

Third parties who may receive personal data: HPTW uses a limited number of Third-Party Suppliers or Service Providers to assist us in providing our services to customers. These Third-Party Suppliers or Service Providers offer various services, including data storage services. These Third-Party Suppliers or Service Providers may access, process, or store personal data in the course of providing their services. HPTW maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Data Privacy Framework obligations, including the onward transfer provisions, and HPTW remains responsible and liable if they fail to meet those obligations and we are responsible for the event giving rise to damage.

U.S. Federal Trade Commission enforcement: HPTW’s commitments under the Data Privacy Framework are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Compelled disclosure: HPTW may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. HPTW maintains transparency reports accordingly.

Data Processing

As part of providing the Product to you, we currently engage the following sub-processors:

Name

Website

Details

Microsoft Azure

https://azure.microsoft.com/

Provides the hosting environment and software development tools for the Product.

AWS

https://aws.amazon.com/

Provides the hosting environment for the public Healthy Place To Work website: https://www.Healthyplacetowork.com

HTEC Group

https://htecgroup.com/

Provides software engineering and operational support services for the Product.

Data Subject Rights

In accordance with applicable law and depending on your location, you may be entitled to exercise some or all the following rights regarding our collection, use, and sharing of your personal information:

Access the personal information we maintain about you;
Update or correct any inaccurate or incomplete personal information about you;
Request that we delete your personal information;
Object to or restrict the processing of your personal information;
Receive the personal information you have previously provided to HPTW, in a machine-readable format, allowing you to transfer that personal information to another company at your discretion;
Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you; and
File a complaint directly with your governmental representative (such as your Supervisory Authority) about how we process your personal information.
Dispute resolution

Exercising Your Rights

To protect your privacy and security, we take reasonable steps to verify your identity before granting access to your personal information. Please follow the instructions below based on your relationship with HPTW and provide the requested information to allow us to adequately address your request. We will respond to your request within a reasonable timeframe and as otherwise required by applicable law in your location.

If you are not a California resident and would like to request access to your personal information or request erasure (right to be forgotten) of personal information previously provided, please contact privacy@Healthyplacetowork.com.

If you have a question or request concerning personal information held by HPTW, including your personal information collected through the use of the Product please email privacy@Healthyplacetowork.com. To protect your privacy and security, we may take reasonable steps to verify your identity before responding to your request. We will respond to your request within a reasonable timeframe and as otherwise required by applicable law in your location.

Updates To Our Global Privacy & Security Notice

HPTW reserves the right to update or change portions of this statement at any time and without prior notice. If we change or update this statement in a material way, we will process new personal information received under this Global Privacy & Security Notice according to the terms of this Notice, unless you consent otherwise.