1. Introduction and Purpose.

The purpose of this Privacy Policy is to let you know how the Halight family of companies, including Halight Inc. (collectively, “Halight”), respects your privacy by providing an explanation of how we collect, use, share, and store your personal information. We hope this explanation will help you make an informed decision as to whether to use or continue using our websites, mobile apps, and/or learning management systems. All of our privacy related practices have been designed to comply with or exceed applicable privacy legislation, including the Canada Personal Information Protection and Electronic Documents Act, the EU's General Data Protection Regulation, California's Consumer Privacy Act, and other privacy legislation.

We may update this Privacy Policy from time to time and encourage you to refer back to it regularly. This Privacy Policy is current as of the “last revised” date which appears at the top.

2. Who does this Privacy Policy apply to?

At Halight, we create engaging, immersive software solutions provided via website and app (collectively, the “Halight Platform”) for our clients to train and empower retail employees and others who may be involved with the promotion or other use of the customers' products and services. If you have participated in or plan to participate in training through one of our learning management systems, you are referred to in this Privacy Policy as an “LMS User.” All persons using the Halight Platform or interacting with Halight other than LMS Users (for example, an employee of a client working with us to contract for, develop, launch, and/or maintain a learning management system for your employer) are referred to herein as “Client Users.” Note that the same person may qualify as a Client User in some circumstances (for example, an employee of a client who negotiates a contract with us) and an LMS User (such as when the same client employee later creates an LMS User account and participates in a training program).

LMS Users and Client Users are collectively referred to herein as “Users” and individually addressed as “you.” Unless a particular provision in this Privacy Policy is expressly limited to either LMS Users or Client Users, it applies to all Users.

3. Notice

We provide access to this Privacy Policy by:

  • Linking to it through the Halight Platform; and
  • Incorporating it into our contracts, agreements, and other documents as necessary or appropriate.

4. Who controls your personal information?

Any information provided to or gathered by Halight is controlled by:

13360 Sylvestre Dr. Windsor, Ontario CANADA N8N 2L9

5. How do we collect personal information?

Halight may collect information about you through various means, including:

  • When you enter or upload information to the Halight Platform. Whether you are an LMS User or a Client User, we mostly collect personal information about you directly from you. We collect information from you when you voluntarily register with Halight and/or submit your personal information to us over one of our websites, applications, learning management systems, or other part of the Halight Platform, such as when you are registering your account (each, a “User Account”). For LMS Users, the Halight Platform tracks your engagement with our learning management systems and the results of that engagement.
  • When you provide information outside of the Halight Platform. There are circumstances when you provide information outside of the Halight Platform, including when you enter into a written agreement with Halight, such as a Client agreement, when you meet us at a trade show or other event and give us your contact information or sign up to receive emails, or when you visit our offices. Halight makes no effort to segregate information collected through the Halight Platform from information collected elsewhere. Accordingly, information collected on the Halight Platform may be combined with information collected through other avenues.
  • When you communicate with us. We collect information from your communications, such as when you email us, contact our customer service, or communicate via social media.
  • Through your browser or device. Most browsers (e.g., Google Chrome, Microsoft Edge) and devices (e.g., your computer, mobile phone or tablet) collect certain information from you automatically and pass it on to Halight, such as your IP address, type and version of operating system, screen resolution, and so forth.
  • From third parties. Halight may use third party services for advertising and analytics for the Halight Platform. These third parties may place cookies on the devices of LMS Users, use web beacons, gather IP addresses, and log data to collect traffic and activity data in order to deliver relevant metrics.
  • Through cookies, tracking tools and other automated technologies. As discussed in more depth in Section 5, Halight and its third party service providers may use cookies and similar technologies to make the Halight Platform operate, work more efficiently, and provide analytic information.

6. How do we use cookies and similar technologies to collect information?

“Cookies” are text files that are placed on your computer by websites that you visit or certain emails that you open. A cookie acts as a string of information that a website stores on a User's device, and that the User's browser provides to the website each time the user submits a query to the website. The purpose of a Cookie is to identify the User as a unique User of the website. Technologies similar to cookies are also used in connect with some parts of the Halight Platform, such as pixel tags, web beacons, clear GIFs, JavaScript, and local storage.

Halight uses functional cookies, some of which may be placed by third parties, to customize your experience on the Halight Platform. Cookies allow us to:

  • Authenticate and identify you on the Halight Platform so we can provide you the services you request;
  • Keep track of information you have provided;
  • Store your preferences; and/or
  • Measure your use of the Halight Platform so that we can improve it and tailor it to your interests.

We may also use Google cookies and tools, such as Google Analytics, on the Halight Platform to collect usage data and analyze how users use the Halight Platform. For more information about how to opt out of this practice, visit the Google Analytics Opt-Out Add On page.

You can change your cookie settings in your browser and use preferences or settings on your device to manage your privacy controls. However, if you disable cookies or other tools, some of the features of the Halight Platform may not function correctly. For more information, see https://www.allaboutcookies.org/; and to learn more about targeted advertising, including how to revoke consent and disable tools and how to opt out of third- party cookies and collection of mobile device IDs, see below and the links here and here.

7. What personal information do we collect?

We limit the personal information that we collect about you to that which is necessary for our purposes as outlined in this Privacy Policy. The specific amount and type of information we gather depends upon your use of the Halight Platform and, in some cases, what type of information you choose to disclose. We may collect the following information from you:

Personal Information

  • Your full name and email address;
  • Employment information, such as your company name and proof of employment (see Note below);
  • Personal and/or business contact information, such as billing and shipping address, phone number, and social media/messaging account handle;
  • Your User Account identification and login credentials;
  • Any profile picture provided by you;
  • Any social media postings and related information shared by you; and
  • For LMS Users, dependent upon the nature of the training program you participate in, you may be required to provide additional information such as photographs, audio/video recordings, images, and biometric information.

Note: for LMS Users, some clients require a copy of your paystub and/or government-issued identification as proof of employment with a particular retailer. It is up to you, as the LMS User, to redact all unnecessary and sensitive personal information, such as social security number and salary, from the proof submitted and in accordance with the instructions provided through the Halight Platform.

If you are a Client User and submit personal information about third parties to us or our service providers, you represent and warrant that you have the ability to submit said personal information and permit its use and disclosure consistent with this Privacy Policy.

Additional information may be collected for the purpose of distributing contest or sweepstakes winnings. Contest specific rules are addressed in a different document.

Information You Make Public

The Halight Platform may contain features that allow you to upload, post, transmit, display, perform or distribute content, including personal information about yourself. For example, you may choose to include personal information within a public-facing profile on one of our leaderboards, which is available and accessible to other participants on the Halight Platform. Any information that you choose to disclose by means of such features becomes public information over which Halight is unable to exercise control. You should take caution when deciding to disclose personal information by means of such features.

Device/Internet Connection Information

When you use the Halight Platform, we automatically gather information made available by your web browser, internet service provider, and device, depending on your settings for each. This information does not reveal real world identity. For example, we may collect:

  • browser and device information;
  • Halight Platform usage data;
  • IP address;
  • Geolocation data; and
  • Aggregated, anonymized, or de-identified data.

Information Provided by Third Parties

Halight may receive information about you if you have provided it to a Third Party and we subsequently acquire the information from the Third Party, such as from one of our clients. Such information may include information related to your employment or sales activity.

Other Information

From time to time, we may obtain other information from you, such as when you request assistance through from our customer service department, and when you voluntarily subscribe to a newsletter. For example, if you earn more than $600 in rewards or prizes during a given year, we will ask you for an IRS W-9 form. You will always be asked to provide such other information voluntarily, and we will not collect it without your permission.

8. How do we use personal information?

We use the information we've gathered from you, including through cookies and web beacons, for the following business and commercial purposes:

  • Fulfilling our legal obligations and complying with applicable law;
  • Operating our learning management systems and other parts of the Halight Platform;
  • Personalizing your User experience;
  • Allowing Users to participate in surveys, sweepstakes, contests, and similar promotions and to administer these activities;
  • Communicating with you and allowing Users to communicate with each other;
  • Establishing, maintaining, and managing our client relationships;
  • Meeting our contractual commitments;
  • Responding to your requests;
  • Completing and fulfilling rewards, prizes and any purchases (including purchase through redemption of LMS rewards) earned or made through the Halight Platform;
  • Preparing User instructions, technical documents, and whitepapers
  • Verifying User identity and preventing fraud;
  • Understanding User preferences;
  • Improving the Halight platform and related systems, products and services, including your and your employer's experience with them;
  • Accurate record keeping and accounting, including billing, auditing, reconciliation, and collection activities;
  • Employee training;
  • Planning, administering, managing and evaluating Halight's operations;
  • Conducting quality improvement and research activities, such as surveys; and
  • Developing new products and services, testing, and identifying usage trends.

If the personal information we require is collected for a reason other than as outlined in this Privacy Policy or if a new purpose arises, we will seek your further consent.

9. What personal information do we disclose to others and why?

Except under the following circumstances, Halight will keep your personal information private and will not share it with third parties. We may share your personal information with others for the following reasons:

To Satisfy Our Obligations to Our Clients

Through the Halight Platform, Halight provides training, education, games, and promotional opportunities for LMS Users engaged in the sale of products and services of our participating clients. Thus, when you complete a training program or participate in a promotional opportunity through the Halight Platform, we may transfer information about you and your completion thereof back to the affiliated client to demonstrate fulfillment of our contractual obligations.

To Fulfill Your Rewards

For LMS Users, we may transfer your information to third parties, including our fulfillment and shipping service providers, when necessary to provide a reward or prize that you earned through us. For example, if you redeem rewards in the form of a gift card or coupon code, we will transfer your necessary personal information to our fulfillment provider so that they can send your gift card or coupon code to you.

To Advertise to Others

We may share your reviews and comments about Halight to advertise and market our products and services. If you want us to stop using the personal data you have provided in these ways, please contact us [email protected]

To Our Affiliated Companies

Affiliated companies are different than third parties or clients, they are businesses that have common ownership with us. We may disclose, transfer, and sell your information to our affiliated companies at our discretion, in which event, your information shall be treated by the affiliated companies in accordance with this Privacy Policy. Should Halight be subject to an acquisition, merger, sale or other change of control or business entity status, we reserve the right to transfer or assign your information as part of that acquisition, merger or sale.

To Our Third-Party Service Providers

We may disclose your personal information as needed to our third-party service providers who provide services to us such as website hosting, data analysis, reward fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and similar services.

To Comply with Legal Process and Prevent Harm

We may disclose your information to respond to subpoenas, court orders, and other legal processes. In rare circumstances, we may disclose personal information when we believe it is necessary in order to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals.

To Collect Unpaid Accounts

If you are a Client User and the associated client fails to pay any balance owed in consideration of services rendered by Halight, we may, as permitted by law, report information about the client (including any unpaid balance) and your personal information as contact for the client, to collection agencies and others in conjunction with our efforts to collect the unpaid balance.

10. Do we sell personal information?

Halight does not sell, and has not sold during the last 12 months, personal information gathered through the Halight Platform.

11. How long do we keep personal information?

We will retain personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law or a valid court order.

12. Where do we store personal information?

Halight stores personal information in the United States. If you are visiting the Halight Platform from a location outside of the United States, your connection will be through and to servers maintained by Amazon Web Services, which are located in the United States. By using the Halight Platform, you authorize and specifically consent to the transfer of personal information to the United States and its storage and use as specified above when you provide such information to us.

13. What security measures do we take?

We understand that the security of your information is important. Halight has implemented and maintains reasonable and appropriate security procedures and practices to protect against the unauthorized access, use, modification, destruction, or disclosure of your information.

You should note that the security of your personal information also depends on you. Please do not communicate any information to us through unsecured channels, such as when you are on a public device. Where we have provided you or you have chosen a password, access code, or similar security feature, you must keep the password, access code or security feature confidential. Please do not share your password with anyone. If you believe your password or account has been compromised, please contact us immediately at [email protected]

Please note that the transmission of information via the Internet or other means of communication is not completely secure. Although we take reasonable measures to secure your information, we cannot guarantee the security of your information transmitted to our Website or through other means of communication. Any transmission of information is at your own risk.

14. How can you ensure your personal information is up to date?

We rely on you to let us know of any changes to your personal information that may be relevant to your relationship with us. This way we can keep our records accurate and up to date, which helps us to protect your privacy.

15. What are your rights with regard to your personal information?

When you (or someone you have authorized) provides us with your personal information, you are consenting to Halight's use and disclosure of that personal information for the purposes outlined in this Privacy Policy. In many circumstances, particularly when the personal information is sensitive, we also employ other methods to further ensure consent, such as just-in-time notifications. For example, when you access our learning management systems a notice about consent will appear at the outset.

You may access all information we've collected about you for purposes of correcting, amending, transferring, or deleting such information. Access can be obtained by contacting [email protected] To protect your privacy and security, we may take reasonable steps to help verify your identity before granting access or making corrections.

You can change your consent preferences or withdraw your consent for the collection, use and disclosure of any or all of your personal information, at any time (see contact information below). It is important to note however, that when you change or withdraw your consent, it will not have a retroactive effect; it may have implications to you, such as not being able to access a learning management system and it will not affect the collection, use and disclosure of personal information where such collection use and disclosure is permitted or required by law without consent.

Process for Making a Request

To make a privacy request regarding your personal information, please contact us at either [email protected] with your name and either your email address or physical address associated with your use of the Halight Platform. If you are making a privacy request through an authorized agent, please also provide the agent's name and email address and statement of authorization. If we need additional information to verify your identity or process your request, we will promptly respond to you. Under certain privacy laws, consumers have specific additional privacy rights, as outlined below.

California Residents

California consumers have the following rights under California privacy laws:

  • Right to access and correct your personal information;
  • Right to request disclosure of the categories of information collected about you, the categories of sources from which the information is collected, the business or commercial purpose for collecting or selling information, the categories of third parties with whom we share your information, and specific pieces of information we have collected about you;
  • Right to opt out of certain privacy practices, including any sale of information;
  • Right to request deletion of personal information collected about you; and
  • Right to no discriminatory treatment (and Company will not discriminate against you, for example by charging you a different price, for exercising your rights).

In addition, under California's “Shine the Light” law, California residents who provide information to the Website may request certain information regarding our disclosure of your information to third parties for their direct marketing purposes.

Nevada Residents

Nevada consumers have the right to request that Halight not sell their personal information for monetary consideration to certain other parties. This right applies even if their personal information is not currently being sold. If you wish to make a request, please contact us.

European Economic Area Residents

Residents of the European Economic Area have the right to access information we hold about you and to ask that your information be corrected, updated, or erased, and the right to object to, or request that we restrict, certain processing of your information. You also have the right to lodge a complaint with the data privacy authority where you live, see e.g., this website.

Canada Residents

We encourage you to let us try any resolve any privacy concerns that you may have. However, residents of Canada may also have the right to complain about any violation of your privacy rights to Office of the Privacy Commissioner of Canada who can be reached at:

30 Victoria Street Gatineau, QC, K1A 1H3

Tel: (819) 994-54443 or (800) 282-1376

Halight Platform: https://www.priv.gc.ca/en/contact-the-opc/

Limitation on Rights of Certain LMS Users

If you are an LMS User, we may be legally required to retain some or all of your personal information at the request of your employer (for example, if you complete employee training through the LMS Platform and your employer is required by law to retain a record of the same). If we are unable to complete your privacy request as a result of such limitation, we will explain the reason and legal basis in our response.

16. What do we do to protect the privacy of children?

Halight will never knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because we do not collect such information, we have no such information to use or to disclose to Third Parties. We have designed this policy in order to comply with the Children’s Online Privacy Protection Act (COPPA).

17. Do we respond to Do Not Track signals?

DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked. The Halight Platform does not currently respond to DNT requests.

18. Are third party websites covered by this Privacy Policy?

When we collect your personal information, we do so principally on behalf of the customer who has directed us to provide you with a learning and training opportunity. As such all of the personal information that we collect is also available to them. In other words, our collection, is their collection. Thus, it is important to refer not only to our Privacy Policy but their privacy policy as well, to fully understand how your personal information is collected, used and disclosed.

19. How can you contact us??

We are committed to providing you with understandable and easily available information about our privacy policies and procedures. We encourage you to contact us with any questions you might have. You can reach our Privacy Officer as follows:

  • By telephone at: 1-844-427-4742
  • By email at: [email protected]
  • Or send us a letter to:
    Halight Inc.
    13360 Sylvestre Dr.
    Tecumseh, Ontario
    CANADA N8N 2L9
    Attention: Privacy Officer