Privacy Policy

PRIVACY DISCLOSURE

This Notice at Collection and Privacy Policy (“Privacy Disclosure”) explains how Highspring LLC, its parents, affiliates, and subsidiaries (“Company”, “us”, “our”, or “we”) collect, use, process, disclose, sell, share, and/or retain personal information as a controller (“Information Practices”) subject to applicable privacy laws.

This privacy policy will inform you of our information gathering and dissemination practices when you visit our websites using this privacy policy (the domains of which are listed here). This policy also covers information we collect about you offline, from third parties, or when you visit one of our locations or in person or contact us by phone. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

In the United States, certain states provide specific rights to their residents, as listed below. While we will attempt to respond to a request from any U.S. resident, we reserve the right to deny requests if allowed under applicable law. Unless you are a California resident, certain rights that may be available in your state may not be applicable to you while you are operating in your commercial or employment capacity.

If you are not a resident of the United States, please also refer to the sections below or click on the hyperlinks that will provide additional information and rights you may have with respect to your personal information. In case of conflict between the main body of this policy and the region-specific addendum, the latter shall take precedence:

• To see our General Data Protection Regulation (GDPR) Addendum click here.
• To see privacy information for individuals located in Canada click here.
• To see privacy information for individuals located in the Philippines click here.

The terms used in this Privacy Disclosure shall have the same or similar meaning as those terms in each of the applicable laws or the closest approximation of such terms.

NOTICE AT COLLECTION

The following notice identifies the categories of personal information to be collected from you and the purposes for which the personal information will be used, including whether that information is sold or shared for the purposes of cross-context behavioral advertising (e.g., targeted advertising).

General Personal Information

We do not collect biometric information, commercial information, or sensory and surveillance data.

Sensitive Personal Information

We do not collect any other sensitive data, other than those categories listed above.

Retention Periods

The period for which we retain information depends on the purposes for which we collect or use that information. We will delete or de-identify information when it is no longer needed to fulfill the purposes listed for each category above unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.

Notice of Sale and/or Share

Our use of tracking technologies may be considered a sale or sharing with third parties for cross-context behavioral advertising (e.g., targeted advertising) under applicable state law. You can opt-out of being tracked by these third parties by clicking the “Your Privacy Choices” link and selecting your preferences. Please note that this link provides opt-out rights under all applicable state laws, also known as “opt-out rights” or “personal data use opt-out.”

Please review our Privacy Policy below.

PRIVACY POLICY

The purpose of this privacy policy is to provide you with a comprehensive description of our online and offline practices regarding our Information Practices.

The following table includes disclosures for the preceding 12 months of: categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we shared the personal information during that period.

General Personal Information

We do not collect: biometric information, sensory surveillance data, professional or employment-related information, education information, or profile data.

We may also disclose your personal information:

• to comply with any court order, law, or legal process, including to respond to any government, regulatory, or law enforcement request;
• to enforce or apply our agreements, including providing our products and services; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Sensitive Personal Information

Unless otherwise allowed by applicable state law, we will only collect certain types of sensitive personal information with your consent. We do not use or disclose the below sensitive personal information for purposes other than those business purposes specifically enumerated below. As a result, we do not offer a right to limit our use or disclosure of these categories of sensitive personal information.

Social Security Number (and Foreign Equivalent) Protection Policy

Social Security numbers (and their respective foreign equivalents) are classified as “Restricted” or “Sensitive Personal” information under our policies. As such, Social Security numbers may only be accessed by and disclosed to our associates and others with a legitimate business purpose in accordance with applicable laws and regulations. Social Security numbers, whether in paper or electronic form, are subject to physical, electronic, and procedural safeguards. These restrictions apply to all Social Security numbers collected or retained by us.

Data Collection

The categories identified as collected in the tables above were collected from the following categories of sources:

• You, directly. For example, we collect information from you when you fill out a form on our website, provide us your resume, or provide us your information at a job fair.
• Third parties, such as our affiliates and distributors, or through certain job websites such as LinkedIn and Monster.com.
• Through automatic data collection, such as device information collected through tracking technologies or data analytics collected on our website.

We may also create and disclose aggregated information about our users and (depending on the jurisdiction) de-identified or otherwise anonymized data or information that does not identify an individual.

Communications

You may decide how you want us to contact you, whether by mail, email, text message, or by phone and you can update your communication preferences at any time by contacting us. If you are communicating with us via text message, normal messaging rates apply, and the frequency of messages may vary. Mobile carriers are not liable for delayed or undelivered messages. Absent consent, no mobile information will be shared with third parties/affiliates for marketing/promotional purposes. You may opt-out of text messaging at any time by replying to any message with “STOP” or contacting us at privacy@highspring.com. This will end the communications from that phone number. You may continue to receive service-related and other non-marketing text messages from other phone numbers managed by Company, and you may opt out of those in a similar fashion. You may opt-out of other marketing-related emails by following the opt-out or unsubscribe instructions (typically at the bottom of the email in question), or by contacting us at privacy@highspring.com . You may continue to receive service-related and other non-marketing emails.

What We Sell to Third Parties or Share with Third Parties for Cross-Context Behavioral Advertising and Right to Opt-Out

Non-essential tracking technologies and functionality is turned on by default in the US and turned off by default in all non-US jurisdictions when you visit our website. If you opt-in to tracking or are in the US, we may have sold to or shared personal information with third parties for cross-context behavioral advertising (e.g., targeted advertising) in the preceding 12 months as disclosed in the table below.

The purpose of the notice of Right to Opt-Out is to inform you that you have the right to direct us to stop selling or sharing your personal information, which is called the “Right to Opt-Out.”

You may exercise your Right to Opt-Out by: (1) clicking “Privacy Preferences” to use the interactive form, or (2) submitting your request through an opt-out preference signal (described further below in the section titled “Opt-Out Preference Signals”).

Once you make an opt-out request, we will comply within 15 business days.

We do not sell or share other personal information, including sensitive information, as described in the tables above.We do not sell or share your sensitive personal information. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

Information Security

• We have implemented reasonable and appropriate organizational, physical, and technical security measures designed to secure your personal information from accidental loss or destruction and from unauthorized or unlawful access, use, fraudulent misuse, unlawful destruction, alteration, contamination, and disclosure. Some of these measures include data encryption at rest and in transit with the latest acceptable encryption ciphers. Acceptable use and security training is developed, communicated, and shared with those that may come in contact with data in the course of conducting authorized processing activities.

We store your information on servers located in the United States.

Cookies and Other Technologies

We use first- and third-party cookies and other various technologies to help us provide information to you more effectively. A cookie is a unit of data stored on the user’s hard drive that helps us remember you and your preferences.

You can refuse to use cookies by turning them off in your browser. You do not need cookies turned on to use our websites. However, a drawback to this is that you will be limited in some areas of our sites and may notice some impact on overall functionality.

Third-Party Links

This website may contain links to other third-party websites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Children Under the Age of 14

Our website is not intended for children under 14 years of age. No one under age 14 may provide any information to or on the website. We do not knowingly collect personal information from children under 14. If you are under 14, do not use or provide any information to or on this website or through any of its features. If we learn we have collected or received personal information from a child under 14 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 14, please contact us in one of the ways provided in the Contact Information section, below.

Notice of Financial Incentive

The purpose of this notice of financial incentive is to explain to you the material terms of a financial incentive or price or service difference that we are offering so that you may make an informed decision on whether to participate.

We conduct raffles during job fairs or other in-person events to collect information from individuals with the incentive that these individuals may win a prize. Participation in these raffles is completely voluntary, and you may participate if you are at an event and inform us of your intended participation. However, you may only participate if you provide us with your contact details upon our request. If you decide later on you do not want to participate, you may withdraw at any time by communicating with us at the applicable job fair or event. We value all visitors and potential customers, and your involvement helps us estimate the level of interest individuals like yourself have in our products and services.

U.S. State Privacy Rights

Certain states provide specific rights to their residents. A description of these rights as it relates to our Information Practices and how you can exercise those rights is outlined below. While we will attempt to respond to a request from any U.S. resident, we reserve the right to deny requests if allowed under applicable law.

Your Right to Know

Certain states provide the right to request our disclosure of any of the following:

• the categories of personal information we have collected about you
• the categories of sources from which the personal information is collected
• the business or commercial purpose for collecting, selling, or sharing with third parties for cross context behavioral advertising (e.g., targeted advertising)
• the categories of third parties to whom we disclose personal information
• the specific pieces of personal information we have collected about you

You can do this through a verified consumer request. That process is described below in the section, “How to Exercise Your Rights.”

Your Right to Request Correction of Inaccurate Personal Information

Certain states provide you the right to request correction of inaccurate personal information maintained by us. We may request documentation from you to determine the accuracy of the information. If you provide us with documentation either upon our request or through your own initiative, that documentation will only be used for the purpose of correcting your personal information and complying with our recordkeeping requirements.

As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under applicable law or if we determine that the contested information is more likely than not accurate, based on the totality of circumstances. You can submit a correction request through a verified consumer request. That process is described below in the section, ” How to Exercise Your Rights.”

Your Right to Request Deletion of Your Personal Information

Certain states provide the right to request that we delete any of your personal information, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section, “How to Exercise Your Rights.”

There may be scenarios where we deny your deletion request. If that occurs, we will provide you with an explanation as to why we could not delete all or some of your personal information.

How to Exercise Your Rights

You may exercise your rights, as applicable, by submitting a verified consumer request to know information (and to receive your personal information in a portable format), to correct information, or for deletion.

The response to a request to know will provide the personal information we have collected and maintained about you, in a portable format, unless an exception under applicable state law applies. Please note that, depending on the applicable state law, we may not be required to provide personal information to you if you make multiple requests in a certain time period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Once we receive your verifiable consumer request, we will confirm receipt of the request within 10 business days, or as allowed under applicable law, describing our verification process. We will respond to your request within 45 calendar days, or as allowed under applicable law, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.

Requests to Know or Delete for Child Under the Age of 13: We do not knowingly collect information of minors under the age of 13.

Using an Authorized Agent to Submit a Request

California: Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf, may make a verifiable consumer request related to your personal information, to opt-out of sale or sharing, or to limit the use or disclosure of your sensitive personal information. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly by submitting a verified consumer request according to the procedures in the section “How to Exercise Your Rights,” and directly confirm with us that you provided the authorized agent permission to submit the request. To submit authorized agent documentation, contact us at privacy@highspring.com.

Other States: If you use an authorized agent, you may provide a power of attorney executed pursuant to applicable state law. If a power of attorney is not submitted, you may be required to provide commercially reasonable identification of your identity and evidence of your authorized agent’s authority to act on your behalf. For example, you may need to provide the authorized agent signed permission to submit a request, verify your identity directly by submitting a verified consumer request according to the procedures in the section “How to Exercise Your Rights,” and directly confirm with us that you provided the authorized agent permission to submit the request, by contacting us at privacy@highspring.com.

Opt-Out Preference Signals/Universal Opt-Out Mechanism

Our use of tracking technologies may be considered a sale or share for targeted advertising under applicable state law. You can opt-out of being tracked by these third parties by clicking the “Privacy Preferences” link at the bottom of our website and selecting your preferences, or by broadcasting an Opt-Out Preference Signal/Universal Opt-Out Mechanism, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us. Because the signal is browser-specific, you will need to broadcast subsequent signals if you are accessing our website through different online devices (e.g., computers, smartphones, tablets).

Supplemental U.S. State Privacy Rights

In addition to the privacy rights listed above, certain states provide supplemental privacy rights to residents of those states.

Right to Opt-Out of Certain Profiling

You have the right to opt-out of our use of profiling when used to make decisions that produce a legal or similarly significant effect concerning you or your interactions with us. Currently, we do not engage in such profiling.

Right to Request a List of Specific Third Parties to Whom Your Data Was Disclosed

You may have the right to request that we provide you with a list of specific third parties to whom we have shared or disclosed personal information.

Right to Appeal

You have the right to appeal our refusal to take action on, or respond to, a verified consumer request. Upon receipt of our denial or refusal to take action on, or to respond to, a verified consumer request, a consumer has 90 days to submit a request to appeal our decision by mail. We will timely inform you in writing of any action taken or not taken in response. We will also include a written explanation of the reasons for our decision.

Changes to this Privacy Policy

The terms of this policy may change, so please check it from time to time. We reserve the right to amend this privacy policy at our discretion and at any time. This version was last updated on June 25, 2024. We keep our privacy policy under regular review, and we will place any updates on this web page. When we make changes to this privacy policy, we will post the updated notice on our websites and update the notice’s effective date. Your continued use of our website(s) following the posting of changes constitutes your acceptance of such changes.

• If experiencing any difficulties accessing our website content, please reach
• out to hr@highspring.com for further assistance and/or alternative arrangements.

Contacting Us

If there are any questions regarding this privacy policy, you may contact us via e-mail at privacy@highspring.com or mail at the below address:

• Phone: 844-880-8226

Additional Phone: 615-324-8226

Email: privacy@highspring.com

Postal Address:
Highspring Global Headquarters 
5501 Virginia Way #120 
Brentwood, TN 37027

Attn: Director/Head of Security, Compliance & Risk

Supplemental GDPR Privacy Rights

Effective Date: June 1, 2020 | Last Revised on: February, 15, 2025| Last Reviewed on: February 15, 2024

Aggregate and Special Categories of Personal Information

We collect, use, and share Aggregated Data (as defined in the GDPR) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your personal information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.

We do not collect Special Categories (as defined in the GDPR) of personal information about you unless there is a clear reason for doing so i.e., conducting criminal background checks for employment purposes. We will only collect and store special categories of personal information with your consent or other valid justification.

How We Use Your Personal Information

Information Use

We are the sole owner of the information collected about you. We will not sell, swap, or rent this information.

The legal basis that we rely on for processing your information will depend upon the circumstances in which it is being collected and used, but will in most cases fall into one of the following categories:

• where you have provided your consent to allow us to use your data in a certain way;
• where the processing is necessary to carry out for the performance of a contract with you;
• where the processing is necessary in order for us to comply with a legal obligation; or
• where it is in our legitimate interests to perform our functions, for example, sending you administrative communications where our legitimate interest is to provide services to you.

We use Internet Protocol addresses to analyze trends, administer our websites, track user movement, and gather broad demographic information for aggregate use. Internet Protocol addresses are not linked to personally identifiable information.

Depending on your relationship with us or where you give us your consent, we will also use your personal information in order to send you marketing communications in connection with marketing activities, products, and services. You may decide how you want us to contact you, whether by mail, email, text message, or by phone and you can update your communication preferences at any time by contacting us. If you are communicating with us via text message, normal messaging rates apply, and the frequency of messages may vary. Mobile carriers are not liable for delayed or undelivered messages. Absent consent, no mobile information will be shared with third parties/affiliates for marketing/promotional purposes. You may opt-out of text messaging at any time by replying to any message with “STOP” or contacting us at privacy@highspring.com. This will end the communications from that phone number. You may continue to receive service-related and other non-marketing text messages from other phone numbers managed by Company, and you may opt out of those in a similar fashion. You may opt-out of other marketing-related emails by following the opt-out or unsubscribe instructions (typically at the bottom of the email in question), or by contacting us at privacy@highspring.com. You may continue to receive service-related and other non-marketing emails.

We may also carry out analysis of the personal information we collect directly or indirectly from you (including from your interactions with our websites and request of certain services), third party sources, and publicly available information to create a profile of your interests, characteristics, and preferences. This is for the purposes of sending you promotional messages, marketing, advertising, and other information that we believe may interest you. Please let us know if you would prefer us not to process your data in this way by contacting us at privacy@highspring.com.

Information Disclosure, Sharing, & Transfer

Within the Highspring Network

We may share information within the Highspring corporate family of companies that (of which all share common ownership or control) to help us maintain websites, communicate with you, provide our products and services, and conduct further data processing.

Service Providers and Business Partners

We may share your information with certain outside vendors and service providers in order to ensure the adequate performance of our services or the provision of our products to you. Service providers may help us with:

• information processing;
• fulfilling customer orders;
• delivering products to you;
• managing and enhancing customer data;
• reviewing and assessing employment backgrounds and qualifications;
• providing customer service, advertising, or payment services;
• assessing your interest in our products and services (to the extent necessary to provide said services); and
• conducting research or satisfaction surveys.

Legal Requirements

Notwithstanding the foregoing, we will consider, and may release, personally identifiable information to third parties: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena, or court order; or (2) in special cases, such as a physical threat to you or others.

With Your Consent

We may share your personal information other than as described in this policy if we notify you and you consent to the sharing.

International Information Transfers

Given that the Internet is a global environment, using it to collect and process personal information necessarily involves the transmission of data on an international basis. This means for instance that data you pass to us may be processed outside the European Economic Area (EEA). In such cases where such transfer occurs, we endeavor to maintain an adequate level of protection in accordance with General Data Protection Regulation (“GDPR”), including, where appropriate, requiring contractual commitments between companies transferring personal information, as these clauses bind the parties and require them to protect the privacy and security of the data.

Information Retention

We will retain your personal information for the period necessary to fulfill purposes outlined in this policy, unless a longer retention period is required or permitted by law, or you provide consent for a longer retention period. For example, we may ask you if you would like us to retain your information for future employment opportunities.

Information Security and Access

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Third-Party Links

This website may contain links to other sites, not owned, associated, or managed by us. Please be aware that while we try our best to only link to reputable websites, we are not responsible for the privacy practices of such other sites. Users are encouraged that, when they leave our site, they should read the privacy statements of each website that collects personally identifiable information.

Children Under 16

We do not collect personal information on individuals under 16 without parental consent. If we become aware that a child under 16 has provided us with personal information, we will take steps to require that consent is given or authorized by the holder of parental responsibility over the child. If you become aware that a child under the age of 16 has provided us with Personal Information without parental consent, please contact us at privacy@highspring.com.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please email us at privacy@highspring.com. You have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal information. Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you have the right to make an objection to our processing. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
• Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to draw up a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Updating Personal Information

You can help us keep our records up to date by telling us when your contact details and other personal information change. You can also change your mind at any time about how we contact you or ask us to stop contacting you altogether.

• Please contact us to make changes at privacy@highspring.com or via mail to Highspring UK Limited, Hamilton House, Mabledon Place, London, WC1H 988

Contacting Us

If you have any questions or comments about this notice, the ways in which we collect, use, disclose, and store your personal information, our privacy policies and practices, your choices, and rights regarding your personal information, or wish to exercise your rights under the GDPR, please let us know by contacting us:

• Phone: 844-880-8226

Additional Phone: 615-324-8226

Email: privacy@highspring.com

Postal Address:

Highspring Global Headquarters 
5501 Virginia Way #120 
Brentwood, TN 37027

Attn: Director/Head of Security, Compliance & Risk

You also have the right to lodge a complaint at any time with your member state data protection authority for data protection issues. We would, however, appreciate the opportunity to handle your concerns before you contact your member state authority, so please contact us in the first instance.

Supplemental Canadian Privacy Rights

Effective Date: June 1, 2020 | Last Revised on: February 15,  2025 | Last Reviewed on: February 15, 2025

The below addendum applies to the following legal entities:

• This addendum applies to the following legal entities:
• Highspring Canada Holdings Inc.
• Highspring Ontario, Inc.
• Highspring Talent Solutions Toronto, Inc.
• Highspring Global Technology Solutions, Inc.
• Highspring Canada GP, Inc.
• Highspring Partners, Inc.
• Highspring Canada M LP
• Highspring Canada V LP
• Highspring Talent Solutions Calgary, Inc.

Information Collection, Use, Disclosure, & Transfer

In most instances the legal basis for collecting, using, or disclosing your information will be with your knowledge and consent, which may be explicitly provided by you or implied based on the circumstances. However, depending upon the particular circumstances (including and not limited to the province in which you are located), circumstances may arise where we do not need your explicit consent.

These include:

• Where we collect, use, or disclose your information for a particular purpose and give you sufficient notice and a reasonable opportunity to object or decline such collection, use, or disclosure within a reasonable time;
• Where legal, medical, or security reasons make it impossible or impractical to seek your consent, such as when collecting information for the detection and prevention of fraud or for law enforcement;
• Where the collection, use, or disclosure of your information would be obvious, you have voluntarily provided your information, or we have a binding contract with you;
• Where the collection, use, or disclosure if otherwise permitted or required by law.

Aside from the entities to whom we disclose your information, as discussed above, our employees (including salespeople, HR professionals, and IT resources), contractors, and agents who have a legitimate reason to access or use your information will also have access to your information that we have collected. A copy of the respective policy is available upon request. We also maintain contractual and other safeguards with any third party that handles your personal information on our behalf.

International Transfers

We may transfer information we collect outside of any respective province in Canada, including to our third-party service providers. While located outside of the initial region of collection, your information will be subject to the laws of the foreign jurisdiction, including access by local law enforcement. If you have any questions about the transfer of information outside Canada, please contact our Privacy Officer (see contact details below).

Information Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law, or you provide consent for a longer retention period. For example, we may ask you if you would like us to retain your information for future employment opportunities.

Information Security

We have implemented reasonable and appropriate organizational, physical, and technical security measures designed to secure your personal information from accidental loss or destruction and from unauthorized or unlawful access, use, fraudulent misuse, unlawful destruction, alteration, contamination, and disclosure. Some of these measures include data encryption at rest and in transit with the latest acceptable encryption ciphers. Acceptable use and security training is developed, communicated, and shared with those that may come in contact with data in the course of conducting authorized processing activities.

We store your information on servers located in the United States.

Your Rights

You may have the following rights depending on the particular province in which you are located. Some of the rights you may have include:

• Request access to your personal information. This may enable you to receive a copy of the personal information we hold about you, to check that we are lawfully processing it, and to whom we are disclosing your information. Under certain circumstances, we may not be able to give you access to information, such as if such disclosure could reasonably be expected to threaten the life or security of someone else or it would reveal personal information of someone else.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request deletion of your personal information. Please note that we will not always be able to accommodate this request.
• Refusing to consent to the collection of your personal information. However, doing so could limit our ability to offer you services or sell you products. If you refuse such consent, we will not deny you products or services unless they cannot be provided without such collection. Thus, consenting to our use of your personal information for secondary purposes (such as marketing) is not required.
• Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complaints

You may file a complaint with our Privacy Officer (see below) if you believe that we are not complying with our obligations to protect personal information. We will confirm receipt of your complaint, contact you for more information as needed, conduct a confidential investigation, and share its conclusions with you. If your complaint is justified, we will take appropriate measures to correct the situation. If you are unsatisfied with our internal review of your complaint, you can contact the following organizations responsible for the protection of personal information: the Office of the Privacy Commissioner of Canada (federal), Québec’s Commission d’accès à l’information, the Office of the Information and Privacy Commissioner for British Columbia or the Office of the Information and Privacy Commissioner of Alberta.

Making a Request

To exercise any of the above rights, you must issue your request to us in writing. You can make a request using the applicable methods in the “Contact Information” section below.

Contacting Us

If you have any questions or comments about this notice, the ways in which we collect, use, disclose, and store your personal information, our privacy policies and practices, your choices, and rights regarding your personal information, or wish to exercise your rights under Canadian law, please do not hesitate to contact our Privacy Officer:

Phone: 844-880-8226
Additional Phone: 615-324-8226
Email: privacy@highspring.com

Postal Address:

Highspring Global Headquarters 
5501 Virginia Way #120 
Brentwood, TN 37027

Attn: Director/Head of Security, Compliance & Risk

We sincerely hope that we can address your concerns, but should you not be satisfied with our response, you also have the right to make a complaint to the Office of the Privacy Commissioner of Canada, at 1-800-282-1376 (toll-free) or to any respective provincial privacy commission.

Supplemental Philippines Privacy Rights

Children Under the Age of 18

Our website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information to or on this website or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us in one of the ways provided in the Contact Information section, below.

Data Retention and Disposal

We keep your personal data until the purpose for why it was collected is achieved or expires. Our retention and disposal schedule is one (1) year from the date of said reckoning periods.

However, it may be necessary for us to keep your personal data for a longer period for legitimate business purposes, legal, regulatory, accounting and reporting obligations.

Rights As A Data Subject

If you are using our services in Philippines, the following additional terms shall apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.

To the extent that the relevant laws, rules, and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages, and data portability.

Domains

• highspring.com
• vaco.com