Privacy Policy

Privacy Policy

Welcome to HCM Defender. HCM Defender is the first of its kind industry utility in the HCM space. The HCM Defender system is provided as a service to any HCM whose application for access has been approved by HCM Defender. Its mission is to help its members (service suppliers and HCMs) with tools, resources, and information to help lower security risks and drive down cost.

HCM Defender is designed to provide services to everyone in the industry in a non- biased manner. The goal is that greater collaboration between members and industry suppliers creating a community sharing experiences and support to make the industry safer.

In Part I of this HCM Defender’s Privacy Policy we outline handling of Personal Information which we collect online through www.HCMDefender.com (the “Website”).

In Part II of HCM Defender’s Privacy Policy we outline handling of Personal Information which we collect other than through the HCM Defender Website.

“Personal Information” is any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you. Personal Information includes “sensitive Personal Information” and “pseudonymized Personal Information” but excludes anonymous information or information that has had the identity of an individual permanently removed.

Your use of the HCM Defender Website and/or provision of your Personal Information or sensitive Personal Information to HCM Defender constitutes your consent to the use, storage, processing and transfer of that information in accordance with this Privacy Policy.

Except as otherwise expressly stated, the data controller is HCM Defender, LLC with an office at 3856 S. Boulevard, Ste. 110, Edmond, OK 73013 USA. HCM Defender is an organization based in the United States.

Questions

If you have any questions or complaints regarding this Privacy Policy, please contact us at info@HCMdefender.com. If you have any questions about the HCM Defender Website, please contact us at info@HCMdefender.com, or send a letter to:

HCM Defender, LLC

3856 S. Boulevard, Ste. 110 Edmond, OK 73013 USA

Changes to this Privacy Policy

We will update this Privacy Policy from time to time, so please check back periodically.

If at any point we decide to use Personal Information in a manner that is materially different from that stated at the time it was collected, we will endeavor to notify you of such changes (e.g., we will post a revised Privacy Policy with a new effective date, display the word “Updated” next to the Privacy Policy link on each page on the HCM Defender Website, or otherwise) prior to implementing them.

Part 1 – HCM Defender Website Privacy Policy

Throughout the Website, there are forms for visitors to request information and services. We use Personal Information from these forms to provide the services, promotional materials, or memberships that you request.

Forms on the Website that request financial information do so in order to bill you for services ordered. Unique identifiers (such as your email) are collected from Website visitors to verify the user’s identity for access to restricted content or features on the HCM Defender Websites.

This Privacy Policy discloses HCM Defender’s privacy practices and contains detailed information about the following:

What information do we collect?
What are “cookies” and how does HCM Defender use them? Do we share information with third parties?
How do we use the information we collect?
How can you review and modify your Personal Information? What is the opt-out policy for the Website?
Your California privacy rights
Your European privacy rights
What types of security procedures are in place to protect against the loss, misuse or alteration of your information?
How does the Website use bulletin boards, discussion lists, and moderated chats?

1) What information do we collect?

The Website collects the following Personal Information about site visitors:

a) Site Use Information

HCM Defender collects technical information relating to each time a visitor comes to the Website, including IP address, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform type (e.g. Internet Explorer browser on a Windows platform).

We may also collect information about your visit, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

This information is primarily collected for statistical analysis. Gathering this technical information helps us to learn what browsers we need to support and helps us determine what sections of the Website are most popular and how many visitors come to our site. You do not have to register with the Website before we can collect this information.

b) Information Provided to HCM Defender

You may provide Personal Information to us, including but not limited to email, the application portal and/or the member portal, which may include your name, home and/or work email address, postal address, phone number and/or fax number, your employer and job title, demographic information about you including birth year, certification designation, etc., and if you are making a purchase, your credit card information. Such information is only required to join as a Member or to take advantage of optional services provided through HCM Defender.

HCM Defender collects Personal Information in the following ways from different parts of the Website:

Membership Applications: You are sharing Personal Information with us when you join or renew your membership in HCM Defender through the Website. HCM Defender members will have HCM Defender membership log-in credentials which enable members to take advantage of restricted content and features on the Website.

Other Registration: When registering for specific services we may ask for the same type of Personal Information. For example, if you subscribe to an e-mail newsletter, we will ask you to provide your e-mail address.

Online Purchases: When you make a membership purchase using the HCM Defender e-commerce page or when you subscribe to a HCM Defender publication through the Website, we may also ask for the same type of Personal Information. The number and variety of useful services on the Website that may require the collection of Personal Information about you will continue to grow and evolve.

2) What are “cookies” and how does HCM Defender use them?

A cookie is a small text file containing a unique identification number that is transferred from a website to the hard drive of your computer. This unique number identifies your web browser to HCM Defender whenever you visit the Website. HCM Defender uses the following types of cookies:

These cookies are essential for our website to perform basic functions. These include cookies that are required to allow users to authenticate and perform account related functions and provide personalized member services.
These cookies are used to store preferences set by users.
We use these cookies to help identify and prevent potential security risks.
We use performance cookies to collect information on how users interact with our Site and the content utilized on our Site. We use these details to improve how our services and Sites.

The use of cookies is an industry standard, and cookies are currently used on most major websites. Most web browsers are initially set up to accept cookies. If you prefer, you can reset your browser to notify you when you have received a cookie. You can also set your browser to refuse to accept cookies altogether.

While HCM Defender does not require you to use cookies, keep in mind that certain services will not function properly if you set your browser to refuse all cookies. By using our Website without changing your browser or device settings to disable cookies, you agree to the use of cookies as described above. You may see a “cookie banner” on our Website and may be asked to accept cookies in accordance with this policy. When you consent to this banner, we will assume that you consent to our use of cookies as described above for all future visits unless you contact us and notify us otherwise.

3) Do we share information with third parties?

Personal Information collected through the Website is generally collected and maintained solely by HCM Defender or its contracted vendors.

We may share Personal Information in the following ways:

a) Information You Give Us

Personal Information provided when you register for services. When you provide Personal Information through the Website (whether to register for a service or request information or otherwise) HCM Defender may share such Personal Information internally and with its contracted vendors and service providers as necessary to the complete the transaction you request.
Information provided when joining or renewing membership in HCM Defender. If you join or renew your HCM Defender membership through the Website, you provide Personal Information about you on the membership application. HCM Defender will share such Personal Information internally and with its contracted vendors and service providers as necessary to complete the transaction requested by
HCM Defender does not sell does not sell or otherwise provide information to third parties, such as e-mail addresses, personal information, mailing/information lists, etc.) derived from any part of its Website except as directed by you to process a specific transaction.
Sensitive Personal Information. HCM Defender does not share with third parties, sensitive Personal Information such as usernames, passcodes, credit card information, or other Sensitive PII except as necessary to complete transactions requested by you, to process services requests, or to comply with legal obligations, and under strict confidentiality and security protections; nor does HCM Defender publish such sensitive Personal Information.
We may disclose or transfer your Personal Information to a third-party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control or we may disclose your Personal Information if we believe that disclosure is reasonably necessary to comply with applicable law or regulation, respond to a legal process or law enforcement or governmental request, enforce our terms and conditions or other rights (including investigations of potential violations of our rights), detect, prevent, or address fraud or security issues, or to protect against harm to the rights, property, or safety of our company, our users, or the public.

b) Site Use Information

We disclose to third-party analytics provider(s) aggregate statistics (i.e., impressions and click-throughs on a Website activity).

In addition, we may share aggregate website statistics with the media or other third parties. We do not disclose Personal Information to these sponsors/advertisers or other third parties as part of this process, only information in an aggregate form.

4) How do we use the information we collect?

We use your Personal Information according to the terms of the Privacy Policy in effect at the time of our use. We will only process your Personal Information, including sharing it with third parties, where (1) you have provided your consent which can be withdrawn at any time, (2) the processing is necessary for the performance of a contract to which you are a party (including your membership agreement with us), (3) we are required by law, (4) processing is required to protect your vital interests or those of another person, or (5) processing is necessary for the purposes of our legitimate commercial interests, provided your interests and fundamental rights do not override those interests.

We use Personal Information for the following purposes:

a) Information You Give Us

We use the Personal Information you give us:

To carry out our obligations arising from your membership and/or any other agreement entered into between you and us
To update and renew your membership as required
To provide you with the information and services you request from us
To arrange and deliver conferences, events and programming relevant to your job and subjects of interest
To respond to your questions and provide related membership or customer services
To improve the HCM Defender website
To send you HCM Defender publications, information about member benefits and special offers, and other information that HCM Defender believes is relevant and useful to its members, where you have not opted out of receiving such information; we may automatically process your information to determine which products and services may be of most use to you. You may object to such processing by contacting us at info@HCMdefender.com
To send you third party information that HCM Defender believes is relevant and useful to you, where you have given your consent
To notify you about changes to your membership or related services or to ask you to provide feedback
To enable you to partake in a prize draw, competition or complete a survey
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
To comply with all applicable laws or legal processes, including providing information on individual users to the appropriate governmental authorities where required by law enforcement or judicial authorities
In matters involving a danger to personal or public safety, or to protect the rights, property or safety of HCM Defender, our Members or others, HCM Defender may voluntarily provide information to appropriate governmental authorities

b) Site Use Information

As mentioned above, HCM Defender uses the aggregate, anonymous data collected to understand site analytics such as the number of impressions or views and the number of “click throughs” on topic of interest.

HCM Defender also uses this aggregate, anonymous data to perform statistical analyses of the collective characteristics and behavior of visitors to the Website; to measure user interests regarding specific areas of the Website; and to analyze how and where best to use our resources.

Without such data, we would not know which parts of the Website are the most popular, and we would not be able to change and update the content and services appropriately.

c) Exceptions

On occasion HCM Defender collects Personal Information through the Website with the intent to afford a greater degree of privacy for such information than is otherwise set forth in this privacy policy.

In those relatively rare situations where HCM Defender does so it will clearly disclose to you at the time it collects such information, what degree of privacy will be afforded to the Personal Information collected at such time; and HCM Defender will follow a process to assure that the specifically disclosed degree of privacy is in fact afforded to such information.

For example, HCM Defender may collect survey information through a survey where HCM Defender’s use of any Personal Information from that survey is more limited than the general HCM Defender Privacy Policy would otherwise allow; in such a case, HCM Defender will disclose the stricter privacy policy governing that survey information at the time such Personal Information is collected from the survey respondent.

5) How can you review and modify your Personal Information?

Each HCM Defender account is intended to be used by an individual. Multiple logins for an individual are prohibited, except as allowed by HCM Defender. Each user is responsible for keeping personal profile data with HCM Defender up to date and accurate. Furnishing false data on the application form, including fraudulent use of credit card numbers, is grounds for immediate termination from the program and may subject the offender to civil or criminal liability.

Alternatively, you have the following options for modifying or causing to be deleted Personal Information or demographic information previously provided by you to HCM Defender.

HCM Defender

You can send an e-mail to: info@HCMdefender.com
You can send mail to the following postal address: HCM Defender, LLC 3856 S. Boulevard, Ste. 110, Edmond, OK 73013 USA.

6) What types of communications will HCM Defender send me?

We may use your information to contact you about membership benefits as well as other potential products and services. You have the right to opt-out of such messages. HCM Defender provides Members with the opportunity to opt-out of receiving such communications from us and our partners. If you no longer wish to receive specific communications or services, you have the following options:

HCM Defender

You can send an e-mail to: info@HCMdefender.com
You can send mail to the following postal address: HCM Defender, LLC 3856 S. Boulevard, Ste. 110, Edmond, OK 73013 USA.
Instructions for opting out of any e-mail newsletter you receive are included with each e-mail.

We may use your information to investigate, respond to and/or resolve legal, security or technical issues and complaints and as necessary for security purposes or to investigate possible fraud, violations of law or violations of this Policy or our Terms of Use. We may use your information to contact you about these security, legal and other service-related issues. Please be aware that you cannot opt-out of receiving such messages from us.

We may also use your personal information to provide you with notice regarding a security incident or data breach, by: (a) sending a message to the email address you provide (as applicable); (b) posting to a publicly facing page of our website; (c) through major statewide media; and/or (d) telephonic means, including calls and/or text messages, even if sent via automated means including automated dialers (standard text and data messaging rates may apply from your carrier). Notices sent by e-mail will be effective when we send the email, notices we provide by posting will be effective upon posting, and notices we provide through telephonic means will be effective when transmitted or dialed. You consent to receiving electronic communications from us relating to any security incident or data breach. It is your responsibility to keep your email address and any other contact information you provide to us current so that we may provide these communications to you.

7) Your California Privacy Rights

For California Residents Only. HCM Defender may disclose your Personal Information to our subsidiaries or other third parties who may use that information to market directly to you. As a California resident, you have the right to opt-out of having your Personal Information licensed to such third parties. We will not share your information after we have received your notification that you are opting out. If you wish to opt-out, you have the following options:

HCM Defender

You can send an e-mail to: info@HCMdefender.com
You can send mail to the following postal address: HCM Defender, LLC 3856 S. Boulevard, Ste. 110, Edmond, OK 73013 USA.

8) Your European Privacy Rights

For European or United Kingdom Residents Only. If you are based in the EU or the UK, in certain circumstances, you may request the following in relation to your Personal Information.

Request access to your Personal Information. You may have the right to request access to any Personal Information we hold about you as well as related information, including the purposes for processing the Personal Information, the recipients or categories of recipients with whom the Personal Information has been shared, where possible, the period for which the Personal Information will be stored, the source of the Personal Information, and the existence of any automated decision making.

Request correction of your Personal Information. You may have the right to obtain without undue delay the rectification of any inaccurate Personal Information we hold about you.

Request erasure of your Personal Information. You may have the right to request that Personal Information held about you is deleted.

Request restriction of processing your Personal Information. You may have the right to prevent or restrict processing of your Personal Information.

Request transfer of your Personal Information. You may have the right to request transfer of Personal Information directly to a third party where this is technically feasible.

Where you believe that we have not complied with our obligations under this Privacy Policy, or under European or UK data protection laws, you have the right to make a complaint to an EU or UK Data Protection Authority, such as the UK Information Commissioner’s Office.

We may decline to process requests if we cannot verify the requestor’s identity, if we believe the request will jeopardize the privacy of others, if we believe the change would violate any law or legal requirement or cause the information to be incorrect, or for a similar legitimate purpose. In any case, where we provide information access, deletion or correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information. If we modify or delete some or all of your Personal Information, we will retain your personal data if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce obligations or fulfill any other requests from you (for example, to opt-out of further messages or for a copy of your data).

We will not discriminate against you for exercising any of your rights under applicable law. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If you wish to exercise your European or UK data subject rights, you have the following options:

HCM Defender

You can send an e-mail to: info@HCMdefender.com
You can send mail to the following postal address: HCM Defender, LLC 3856 S. Boulevard, Ste. 110, Edmond, OK 73013 USA.

9) What kinds of security procedures are in place to protect against the loss, misuse or alteration of your information?

The Website has security measures equal to or better than those reasonably expected in the industry, such as firewalls, in place to protect against the loss, misuse and alteration of your Personal Information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we take reasonable precautions to prevent such unfortunate occurrences. Certain particularly sensitive information, such as your credit card number, collected for a commercial transaction is encrypted prior to transmission.

You are ultimately responsible for the security of your HCM Defender login credentials. Users will not disclose account information or cause account information to be put at risk. You may not share your HCM Defender login credentials with colleagues or friends so they can access content or features that are restricted to HCM Defender Members only. Users shall not attempt to circumvent user authentication or security mechanisms of any host, network, or account. You should log out of your browser at the end of each computer session to ensure that others cannot access your Personal Information and correspondence, especially if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe. Any compromise or suspected compromise of an account shall be immediately reported to the HCM Defender.

10) How does HCM Defender use bulletin boards, discussion lists, and moderated chats?

The Website may make internal uncensored bulletin boards, discussion lists, and moderated chats available to its members. These message boards are for the posting of timely topical information by users. As such, HCM Defender does not control the content of the message board available to the members.

Any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your Personal Information. Although users may post messages that will appear on the message boards anonymously, HCM

Defender does retain a record of who posts all notes.

11) Do third parties collect information from the Website?

Please keep in mind that the Website may contain links to other websites or apps. Some content or applications on or in the Website may be served by third-parties, including content providers, application providers, analytics companies, your mobile device manufacturer, and your mobile service provider. These other sites and companies may place their own cookies or other files on your computer, collect data or solicit personal information from you. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services. They may use this information to provide you with interest-based (behavioral) targeted content.

We do not control these third parties’ privacy practices or tracking technologies. If you have any questions about targeted content, you should contact the responsible provider directly. You are responsible for reviewing the privacy statements and policies of those other websites you choose to link to or from the Website, so that you can understand how those websites collect, use and store your information. We are not responsible for the privacy statements, policies or content of these other companies and websites or apps, including websites you link to or from the Website.

Part II – HCM Defender Privacy Policy for Information Collected Other Than Through the HCM Defender Website

If you submit Personal Information to HCM Defender through any channel other than the Website, the same privacy rules set forth at Part I above for the HCM Defender Website will be applied to such Personal Information you submit through channels other than the Website (including without limitation your opt-out rights at Part I, Section 6 above), except as follows:

The “cookies” and other tracking devices used by the Website and described in Part I above do not apply to Personal Information gathered through channels other than the Website.

Hardcopy Personal Information provided to HCM Defender which is not converted to electronic media and hosted by HCM Defender will be subject to different security procedures than will stored electronic Personal Information. HCM Defender has security measures equal to or better than those reasonably expected in the industry, in place to protect against the loss, misuse and alteration of your hardcopy Personal Information under our control.

When HCM Defender collects Personal Information through channels other than the Website it may in some instances apply a different privacy policy to such information; but where it does so it shall conspicuously disclose to you at the time of collection what privacy policy will apply to such information. For example, HCM Defender may collect survey information through a survey where HCM Defender’s use of any Personal Information from that survey is more limited than the general HCM Defender Privacy Policy would otherwise allow; in such a case HCM Defender will disclose the stricter privacy policy governing that survey information at the time such Personal Information is collected from the survey respondent.