Privacy Policy - HGV Learning

Privacy Policy

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HGV Learning, Ltd. (“HGV Learning” or “we”) operates HGV Learning.com.  This Privacy Policy describes HGV Learning’s use and sharing of personally identifiable information (“PII”– your full name, email address, mailing address, telephone number, or credit card number) as well as data that can, under certain circumstances, indirectly lead to PII (“Related Data”) that Clients voluntarily provide to HGV Learning when they register.  The Term “Client” refers to a Visitor or a User.  This Privacy Policy applies to the services offered by HGV Learning, Including any HGV Learning branded URL (the “HGV Learning Website”), the HGV Learning instant messaging service, the HGV Learning application developer service and other features (for example, music and video embedded players), HGV Learning mobile services, and any other features, content, or applications offered from time to time by HGV Learning in connection with the HGV Learning Website (collectively, the “HGV Learning Services”).

The HGV Learning Services are hosted in the United Kingdom . If you are located outside the United Kingdom , you expressly agree that PII and Related Data will be transferred to the United Kingdom for the purposes set out in this Privacy Policy as a result of your using the HGV Learning Services.

The HGV Learning Website is a general audience site and does not knowingly collect PII or Related Data from children under 16 years of age.

From time to time HGV Learning may modify this Privacy Policy to reflect industry initiatives or changes in the law, our PII or Related Data collection and use practices, the features of the HGV Learning Services, or technology, and such modifications shall be effective upon posting by HGV Learning on the HGV Learning Website.  Your continued use of the HGV Learning Services after HGV Learning posts a revised Privacy Policy signifies your acceptance of the revised Privacy Policy.  It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes.  If HGV Learning materially changes its practices regarding collection or use of your PII or Related Data, your PII and Related Data will continue to be governed by the Privacy Policy under which it was collected unless you have been provided notice of, and have not objected to, the change.

COLLECTION AND SUBMISSION OF PII AND NON-PII ON HGV LEARNING

General .  HGV Learning collects your email address, first and last name, postal address, gender, and date of birth from you in order to register you as a Client (“Registration Data”).  HGV Learning cannot register you as a Client without this information.  All other information you provide during the HGV Learning registration or that you post on the HGV Learning website is voluntary.  HGV Learning may also collect PII from you if you choose to participate in HGV Learning Services activities like sweepstakes, contests, and surveys, because you want us to furnish you with products, services, newsletters, magazines, texting service or information, or in connection with content or suggestions you submit to HGV Learning for review.

In addition, HGV Learning collects other Related Data and non-PII Including IP address, aggregate user data, and browser type.  This data is used to manage and improve the HGV Learning Services, track usage, and for security purposes.

HGV Learning Clients may also choose to provide or store non-PII information and Related Data in their profiles, Including but not limited to date of birth, interests, hobbies, lifestyle choices, groups with whom they are affiliated (schools, companies), videos and/or pictures, private messages, bulletins or personal statements (collectively “Profile Information”).  The Profile Information in a Client’s profile is provided at his or her sole discretion.  Please be aware that your Profile Information, as well as any information posted to any public forum, can be accessed by the public.  Profile Information located on private profiles can be accessed by HGV Learning at all times and, in limited cases, by certain third parties authorized by HGV Learning for purposes of ensuring compliance with HGV Learning’s Terms of Use.

HGV Learning Clients can change their Registration Data and Profile Information at any time and can control how Visitors, other Clients and HGV Learning communicate with them by controlling their account settings, available within the “Edit Profile” portion of their HGV Learning profile.

HGV Learning determines the purposes of collection, use and disclosure of the Registration Data you provide and, as such, is considered the data controller of this information.  Because the Client, not HGV Learning, determines the purposes for which Profile Information is collected, used and disclosed, HGV Learning is not the data controller of Profile Information that Clients provide on their profile.

Cookies . Cookies are small bits of information that HGV Learning places on your computer. HGV Learning uses cookies to identify your Internet browser, store Users’ preferences, and determine whether you have installed the enabling software needed to access certain material on the HGV Learning Services.  Data in cookies may be read to authenticate user sessions or provide services.

Third party advertisements displayed on HGV Learning Services may also contain cookies set by Internet advertising companies or advertisers (known as “third party cookies”).   HGV Learning does not control these third party cookies and Users of the HGV Learning Services should check the privacy policy of the Internet advertising company or advertiser to see whether and how it uses cookies.  See the “Notice” section below for more information on customized advertising on HGV Learning.  A pixel tag is a tiny image inserted in a webpage and used to record the number and types of views for that page.  HGV Learning may allow third party pixel tags to be present on HGV Learning Services for purposes of advertising, providing services or data and statistics collection.

You can program your computer to warn you each time a cookie is being sent, block third party cookies or block all cookies.  However, by blocking all cookies you may not have access to certain features on the HGV Learning Services.

NOTICE: HGV LEARNING WILL PROVIDE YOU WITH NOTICE ABOUT ITS PII COLLECTION PRACTICES

When you voluntarily provide PII to HGV Learning, we will make sure you are informed about who is collecting the information, how and why the information is being collected and the types of uses HGV Learning will make of the information to the extent it is being used in a manner that differs from what is allowed pursuant to this Privacy Policy.

At the time you provide your PII, HGV Learning will notify you of your options regarding our use of your PII. Except as described in this Privacy Policy, HGV Learning will not share your PII with third parties (excluding those set out in this Privacy Policy) unless you have given HGV Learning permission to do so.

HGV Learning Services may be linked to Internet sites operated by other companies.  HGV Learning Services may also carry advertisements from other companies.  HGV Learning may transfer Related Data such as IP addresses to certain advertising partners located in your country of residence or abroad.  HGV Learning is not responsible for the privacy practices of websites or other services operated by third parties that are linked to or integrated with the HGV Learning Services or for the privacy practices of third party Internet advertising companies.  Once you leave HGV Learning Services via such a link, access a third party application (such as widgets) or click on an advertisement, you should check the applicable privacy policy of the third party or advertiser site to determine, among other things, how they will handle any PII they collect from you.

HGV Learning Services may also be linked to sites operated by companies affiliated with HGV Learning. Users who visit those Affiliated Company sites should still refer to their separate privacy policies and practices, which may differ in some respects from this Privacy Policy.

HGV Learning may use cookies and similar tools to customize the content and advertising you receive based on the Profile Information you have provided.  Profile Information you provide in structured profile fields or questions (multiple choice questions like “Marital Status,” “Education” and “Children”) (“Structured Profile Information”), information you add to open-ended profile fields and questions (essay questions like “About Me,” “Interests” and “Movies”) (“Non-Structured Profile Information”) and other non-PII and Related Data about you may also be used to customize the online ads you encounter to those we believe are aligned with your interests.  For example, based on your music interests we might display an advertisement to make sure you are advised when your favorite band is coming to town.  The information used for this feature does not provide your PII or identify you as an individual to third parties, but will involve the processing of certain Related Data such as IP addresses.  If you would like to disable this advertising customization for Non-Structured Profile Information, please contact us via our contact page message must be titled PII query.

Some of the advertisements that appear on HGV Learning Services may also be delivered to you by third party Internet advertising companies.  These companies utilize certain technologies to deliver advertisements and marketing messages and to collect non-PII information and Related Data about your visit to or use of HGV Learning Services, Including information about the ads they display, via a cookie placed on your computer that reads your IP address. To opt out of information collection by these companies, or to obtain information about the technologies they use or their own privacy policies, please visit here.

Third party applications (such as widgets) created by third party developers may also be available on the HGV Learning Services.  Third party applications are small bits of software, often with interactivity, that can be installed into Clients’ profiles or shared with other Users.  However, HGV Learning does not control the third party developers, and cannot dictate their actions.  When a Client engages with a third party application, that Client is interacting with the third party developer, not with HGV Learning.

HGV Learning encourages Clients not to provide PII to the third party’s application unless the Client knows the party with whom it is interacting.

HGV Learning and certain copyright holders have signed an agreement pursuant to which copyright holders may utilize HGV Learning’s Rights Management Tools (collectively, the “Tool”) to automatically block the upload of audio and audiovisual content for which the copyright holder has supplied content identifiers in the required format.  In addition, from time to time, HGV Learning may use the Tool to examine information (Including Profile Information located on private profiles) to detect the presence of content that matches content for which copyright holders have supplied content identifiers.  If the Tool blocks the upload of such content, and/or otherwise removes content already uploaded to the HGV Learning Website, the Client will receive a notice and may have an opportunity respond to the notice through a counter-notice.  Copyright holders may have access to certain Related Data and Profile Information when they operate the Tool, but will not have access to any PII unless the Client expressly consents to providing PII to the copyright holder in the context of a counter-notice.

CHOICE: HGV LEARNING WILL PROVIDE YOU WITH CHOICES ABOUT THE USE OF YOUR PII

Except as described in this Privacy Policy, HGV Learning will get your permission before we use the PII you provide to us in a way that is Inconsistent with the purpose for which it was submitted or share your PII with third parties that are not affiliated with HGV Learning.

USE: HGV LEARNING’S USE OF PII

HGV Learning will only use the PII you provide under this Privacy Policy in a manner that is consistent with this Privacy Policy.  If HGV Learning obtains PII from a third party, such as a business partner, our use of that information is also governed by this Privacy Policy. Clients of the public will be able to browse through any data added by you or given to HGV Learning to upload to the HGV Learning website for clients / visitors to view such items are as follows: events, music material, music videos, pictures and merchandise.

If you have consented to receive promotional materials (e.g., newsletters, magazines, text messages) or notifications from HGV Learning, HGV Learning may periodically use your email address and mobile telephone number to send you such materials related to the HGV Learning Services, as applicable.  If you want to stop receiving such materials from HGV Learning, you can inform HGV Learning via the contact page.

HGV Learning employees, agents and contractors must have a business reason to obtain access to your PII and Related Data. HGV Learning may share your PII and Related Data with those who help us manage or provide HGV Learning Services’ information activities (for example., message board administration, order fulfillment, statistical analyses, data processing), or with outside contractors, agents or sponsors who help us with the administration, judging and prize fulfillment aspects of contests, promotions and sweepstakes.   These outside contractors, agents or sponsors may temporarily store some information on their servers, but they may only use your PII to provide HGV Learning with a specific service and not for any other purpose.

HGV Learning may also provide your PII to a third party in those instances where you have chosen to receive certain information and have been notified that the fulfillment of such a request requires the sharing of your PII.  HGV Learning also may share your PII with Affiliated Companies if it has a business reason to do so.

As described in “Notice” above, HGV Learning may customize the advertising and marketing messages you receive on the HGV Learning Website, or may work with outside companies to do so.  Your Related Data, non-PII and/or Profile Information may be shared with these companies so this customization can be accomplished.  HGV Learning prohibits these companies from sharing your Related Data, non-PII and/or Profile Information with any third party or from using it for any other purpose.  Anonymous click stream, number of page views calculated by pixel tags, and aggregated demographic information may also be shared with HGV Learning’s advertisers and business partners.

There may be instances when HGV Learning may access or disclose PII, Related Data, Profile Information or non-PII without providing you a choice in order to: (i) protect or defend the legal rights or property of HGV Learning, our Affiliated Companies or their employees, agents and contractors (Including enforcement of our agreements); (ii) protect the safety and security of Users of the HGV Learning Services or clients of the public Including acting in urgent circumstances; (iii) protect against fraud or for risk management purposes; or (iv) comply with the law or legal process.  In addition, if HGV Learning sells all or part of its business or makes a sale or transfer of all or a material part of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, HGV Learning may transfer your PII to the party or parties involved in the transaction as part of that transaction.

When a Client chooses to post Profile Information that will be publicly disclosed, that Client is responsible for ensuring that such information conforms to all local data protection laws.  HGV Learning is not responsible under any data protection laws for Client posted information.

SECURITY: HGV LEARNING PROTECTS THE SECURITY OF PII

HGV Learning uses commercially reasonable administrative, technical, personnel and physical measures to safeguard PII and credit card information in its possession against loss, theft and unauthorized use, disclosure or modification.  In addition, HGV Learning uses reasonable methods to make sure that PII is accurate, up-to-date and appropriately complete.

ACCESS, REMEDIES AND COMPLIANCE: HOW TO ACCESS, CORRECT OR CHANGE YOUR PREFERENCES REGARDING YOUR PII AND HOW TO CONTACT HGV LEARNING ABOUT PRIVACY CONCERNS

Whenever possible, HGV Learning Clients may review the Registration Data we maintain about them in our records. We will take reasonable steps to correct any PII a Client informs us is Incorrect.  If you are a Client, you can view and change your Registration Data, Client preferences and Profile Information please contact HGV Learning for more information regarding view or change to PII.

If you ask HGV Learning to stop using your PII, HGV Learning will honor that request while retaining any record of your PII that is necessary to comply with the law.

If you would like to communicate with us about this Privacy Policy or HGV Learning’s collection and use of your PII please

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