PRIVACY POLICY

Introduction

 

This privacy policy (“Privacy Policy”) describes how HAVI Group, LP (“HAVI” or “we”) processes personally identifiable information (“Personal Data”) via the website www.Thehighcarefactor.com (the “Website”). The Privacy Policy does not explain the practices for processing Personal Data on other sites that may be linked via the Website but are operated by third parties.

In relation to the Website, we process your Personal Data to provide you the Website and the services offered on the Website, give you access to HAVI content, and answer your queries. To a certain extent, we also collect data to learn more about how you use the Website and to improve the Website.

To learn more about how HAVI processes your Personal Data and about HAVI’s use of cookies, please read the full version of the Privacy Policy below as well as the cookie-related information (the “Cookie Policy ”).

Contacts

 

1. HAVI is responsible for the processing of your Personal Data

 

HAVI Group, LP, located at 3500 Lacey Road, Suite 600, Downers Grove, IL 60515, United States of America is responsible for the processing of your Personal Data.

 
2. HAVI’s data protection/privacy contact

 

You can contact our data protection/privacy contact at HAVI-DPC@havi.com if you have any questions in relation to the processing of your Personal Data by HAVI.

 

3. Which of your Personal Data is processed by HAVI and for what purposes?

 

Personal Data means any information relating to an identified or identifiable natural person. Depending on the applicable jurisdiction, Personal Data may include some or all of the following: name, email address, postal address, IP address, browser type, and previously visited websites.

HAVI processes your Personal Data in connection with the Website for the following purposes:

 

(a) When you visit www.thehighcarefactor.com

 

You can visit the Website even if you have deactivated the use of cookies in your browser settings or by setting opt-out cookies, if applicable. However, please note that not all functions might be available if the use of cookies is disabled. If you disable cookies, we will still receive basic information (such as last URL visited) when you navigate to the Website. For details concerning our use of cookies, please see the Cookie Policy.

Personal Data that we process

When you visit the Website, we process Personal Data as reflected in the Cookie Policy.

Why we process this Personal Data

We use technologies such as cookies to process this Personal Data to improve your user experience and the safety on the Website as well as to provide you with information that we believe may fit your interests.

(b) When you contact us

You may contact us via our contact form or the chatbox to obtain further information about our products and services, to arrange a meeting with a HAVI representative, or for general inquiries.

Personal Data that we process

When you use our contact form, you have to provide the following Personal Data about you: first name, last name, email address, inquiry type (i.e. what topic your inquiry relates to). On a voluntary basis you may also provide your telephone number and include a message to HAVI. Please do not provide us with additional information if you do not want HAVI to process it in connection with your inquiry.

Why we process this Personal Data

We process this Personal Data to provide you with a response to your inquiry from the most suitable contact person for your request and business, as well as to subsequently address you directly.

 

 

4.How we share your Personal Data

 

There are also circumstances where we will transfer and/or disclose to third parties Personal Data. Those circumstances are as follows:

  • Subsidiaries and Affiliates: HAVI will transfer Personal Data to its subsidiaries and corporate affiliates.

  • Consultants and Service Providers: HAVI may disclose Personal Data to third party consultants and service providers (such as providers of hosting, technology outsourcing and support services) to the extent that they require access to our databases, or the information contained in our databases, to service HAVI and the Website.

  • Security: HAVI reserves the right to release Personal Data in response to a subpoena or otherwise when we believe that the law requires us to do so or when we believe it is necessary to resolve disputes or to protect and/or enforce the rights, property interests, or safety of HAVI, our users or others.

  • Reorganization or Sale: In the event that HAVI or any of its business units is merged with or becomes part of another organization, or in the event that HAVI is sold, goes bankrupt, is in receivership, or it sells all or substantially all of its assets, the information you provide may be one of the transferred assets.

5.California privacy rights

 

We collect Personal Data (including identifiers, Internet activity information and professional information) when you use the Website and provide it to us through the Website.

We do not rent, sell, or share personal information (as defined by California Civil Code §1798.83) about you that we collect on the Website with other people or unaffiliated companies for their direct marketing purposes, unless we have your permission. We have not sold Personal Data, but we disclose Personal Data we collect (i.e., identifiers, Internet activity information, and professional information) for our business purposes as described in Section 4. The Website does not respond to web browser “do not track” signals at this time.

As a data subject located in California, you may have the following rights regarding your Personal Data in certain circumstances and subject to the associated preconditions as set forth under California law:

  • Right of access: You may ask us to provide you with a copy of the types of Personal Data and the Personal Data we have collected about you during the prior 12 months, and information about where we obtain Personal Data, why we collect Personal Data and what, how and with whom Personal Data is shared with others.

  • Right to deletion: In some circumstances, you may ask us to delete or remove your Personal Data, but this right is limited.

 

You may exercise the above rights by contacting us as described in Section 10 of this Privacy Policy. We may take steps to verify your identity and request before responding to your request. We will not discriminate against you if you decide to exercise your California privacy rights.

6.Further information for the EU

The following additional information and rights only apply to users who visit the Website from the EU/EEA.

(a)Why we are permitted to process your Personal Data

 

The legal permission for our processing of your Personal Data is as follows:

  • Website visit/cookies: We process your Personal Data that we collect via strictly necessary and functionality cookies based on our legitimate interest to provide you with a functioning, safe and user-friendly Website. We only process Personal Data that we collect via performance and targeting cookies based on your consent. Please see the Cookie Policy  to learn how to withdraw consent for specific cookies.

  • Contact us/chatbox: We process the listed Personal Data to respond to your inquiry, so for contract performance.

  • Data transfers: We share your Personal Data with the listed third parties listed in section 4 (e.g. vendors) if this is necessary to provide you with the Website services, so for contract performance. Sharing your data with third parties to improve the functionality of the Website is based on our legitimate interest to provide a secure and user-friendly Website.

We share your Personal Data with our affiliates if this is necessary to perform or prepare for the performance of a contract with you or for our legitimate interests to facilitate internal processes.

 

We will inform you separately if we share your Personal Data with authorities or possible purchasers based on our legal obligations.

 

(b)How long we retain your Personal Data

 

HAVI’s practices for retaining Personal Data of EU data subjects are as follows:

Website visit: Please see the Cookie Policy for details about cookie retention 

Contact us/Chatbox: We retain the listed Personal Data until we have answered your inquiry to your satisfaction. If you have provided further consent, we retain the Personal Data to contact you consistent with the purposes for which you have consented, until you withdraw your consent. Beyond that, we only store your Personal Data for as long and insofar as this is necessary or appropriate for the fulfillment of legal retention periods or for any legal disputes.

(c)Third country data transfers

Sharing your Personal Data with the recipients listed in this Privacy Policy may involve transfers to recipients outside the European Union/the European Economic Area. In cases of such transfers, we use the legal standards required under EU data protection laws, such as the EU standard contractual clauses as a safeguard to establish an adequate data protection level in the third country. You may ask to receive details concerning the safeguard by contacting us as described in sections 2 and 10 .

(d)Google Analytics

 

The Website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”). Google Analytics uses cookies to help a website analyse how users use the website. The information generated by the cookie about your use of our Website (including your IP address) will be transmitted and stored by Google on servers in the USA.

We have activated IP anonymization on the Website; accordingly, your IP address will be truncated by Google within the member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional circumstances will a full IP address be saved to a Google server in the USA and truncated there. Google will use this information on our behalf for the purpose of evaluating your use of the Website, compiling reports on Website activity, and providing us with other services relating to the use of the Website and the internet.

You can also block the cookie’s collection of data regarding your use of Website (including your IP address) as well as the processing of this data by Google, by downloading and installing the browser add-on found via the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the browser add-on, you can manage your cookies as reflected in the Cookie Policy in order to opt-out from being tracked by Google Analytics within this Website in the future. An opt-out cookie will be stored on your device, which means that you will have to click this link again if you delete your cookies. 

You can find more information via the following link: http://www.google.com/intl/en/privacypolicy.html

 

(e)Your rights concerning your Personal Data

As a data subject located in the EU, you have the following rights regarding your Personal Data in certain circumstances and subject to the associated preconditions as set forth under the General Data Protection Regulation:

  • Right of access: You may ask us to confirm whether we are processing your Personal Data and, if so, to provide you with a copy of that Personal Data (along with certain other details).

  • Right to rectification: If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to ask for rectification or completion.

  • Right to erasure: In some circumstances, you may ask us to delete or remove your Personal Data, e.g., if we no longer need it or if you withdraw your consent (where applicable).

  • Right to restrict processing: In some circumstances, you may ask us to restrict the processing of your Personal Data, e.g.,  if you object to us processing it.

  • Right to data portability: You have the right to obtain Personal Data you have provided to us in a structured, commonly used and machine-readable format for reuse under certain circumstances.

  • Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so under appropriate circumstances, if we:

    • Rely on legitimate interests to process your Personal Data except if we can demonstrate compelling legal grounds for the processing.

  • Rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision when it is based solely on automated processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

  • Right to withdraw consent: If we rely on your consent as legal basis for processing your Personal Data, you have the right to withdraw that consent at any time.

You may exercise your rights by contacting us as described in sections 2 and 10 of this Privacy Policy.

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State where you reside, work or suspect an infringement, if you believe that the processing of Personal Data concerning you is not in compliance with GDPR requirements.

You can find more information provided by the EU Commission on your rights and associated requirements at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en

 

(f)Our EU contact details

In addition to the contact details provided in section 10 of this Privacy Policy, users from the EU/EEA may also contact our local representative in the EU at:

HAVI Logistics Business Services GmbH

Geitlingstr. 20

47228 Duisburg

Germany

Email: info.is@havi.com

Telephone: 0049 2065 695 04

 

7.How do you keep my information secure?

Although we cannot guarantee impenetrability of our servers, we have attempted to establish and implement reasonable and appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

8.Links to third party websites

Our Website may contain links to third party websites, particularly those of news and press services. Our Privacy Policy does not apply to the practices of other websites, and HAVI is not responsible for the actions and privacy policies of the third parties that operate or interact with those other websites. We encourage you to be aware of when you leave our Website and to read the privacy policies of each website that you visit, particularly before you submit any Personal Data on that website.

9.Changes and updates to the Privacy Policy

HAVI reserves the right to change the Website information and other content, features, products, policies, promotions, disclosures, and disclaimers at any time. In addition, HAVI may change its Privacy Policy as to Personal Data collected after the effective date of such change. Changes to this Privacy Policy will be described and posted on the Website and/or otherwise provided to you consistent with applicable law. At the top of the Privacy Policy, we indicate the date of the most recent update to the Privacy Policy.

10.Who do I contact if I have a privacy request or question?

If you have any requests, comments, questions or concerns regarding this Privacy Policy or HAVI’s privacy practices, please contact us. HAVI-DPC@havi.com

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