Privacy Policy

HBR Consulting LLC on behalf of itself and its affiliated entities including HBR Managed Services LLC (collectively, “HBR” or “we” or “our” or “us”) is committed to protecting your data privacy and this Privacy Statement (“Privacy Statement”) sets forth the terms and conditions with respect to how HBR processes personal information on individuals (“you”) that access or use any of our websites or otherwise engage with us, and on other third parties.  This Privacy Statement describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information.  For purposes of this Privacy Statement, each publicly available website that HBR owns, licenses, or operates shall be referred to individually, or collectively, as the “Site”.

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. By accessing or using the SITE or otherwise providing us with personal information, you are consenting to the terms of this Privacy Statement.

1. Scope

This Privacy Statement describes how HBR processes personal information in our role as a “data controller” (i.e., when HBR determines the purposes for which and the means by which personal information is processed). In the event HBR is providing managed services or is otherwise processing personal information on behalf of another entity, such processing will be governed by the HBR Data Processing Addendum (or a similar data processing agreement) and not this Privacy Statement.

For purposes of this Privacy Statement, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device, and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized data that is not attributable to a particular individual, household, or device or otherwise subject to a data protection law, statute, or regulation. HBR may anonymize and aggregate personal information, and such data is not subject to this Privacy Statement, and HBR may use such data for any purpose.

2. The Types and Categories of Personal Information We Collect

HBR collects personal information in order to provide our Site, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Statement. When you do not provide personal information to HBR, we may not be able to provide you our services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:

Personal Information
Category
Description/Examples

Personal Identifiers

Identifiers, such as your name, alias, business address, email address, account number, telephone number, customer identification number.

Online Identifiers (For more information, see “Technical Data” below)

Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.

Commercial Information

Records of the services you purchased , obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our services.

Business Contact Data

Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.

Marketing and Communications Data

Information with respect to your marketing preferences and your subscriptions to our publications and alerts.

Internet and Electronic Network Data

Data pertaining to your access or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites.

Your Feedback

Information you provide about the Site or our services, which may include data gathered from any HBR surveys or reviews submitted by you.

Geolocation Data

Information about the general city, state, or region in which a user of the Site is located.

Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below)

If you apply for a job with HBR, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.

Inferences

Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.

3. Technical Data

When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, and your experience on the Site and other websites, including the following:

Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Site. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged. For more information, see our Cookie Policy. For the avoidance of doubt, our Cookie Policy is hereby incorporated into, and forms an integral part of, this Privacy Statement.

4. Sources of Information

We collect the personal information identified herein directly from when you engage with us directly, through automated means when you are using the Site, and from third parties. More specifically, we collect personal information from the following sources:

First Party / Direct Collection. We collect personal information directly from you when you use our services or otherwise directly engage with us (e.g., account registration, completing purchases, signing-up for subscriptions, when you visit our offices or premises or otherwise contact us).

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references.

5. How We Use your Information / Purpose of Collection

We may use the personal information we collect about you in order to provide the Site, comply with our legal obligations, and promote our business interests, including to (i) provide, operate, maintain, improve, and promote our services, (ii) enable you to access and use the Site, (iii) process and complete transactions, and send you related information, including purchase confirmations and invoices, (iv) send transactional messages (e.g., responses to your comments, questions, and requests) and provide customer service and support for our services, (v) furnish technical notices, updates, security alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about our services, features, surveys, newsletters, offers, promotions, contests, and events), (vii) process and deliver contest or sweepstakes entries and rewards, (viii) monitor and analyze trends, usage, and activities in connection with our services to promote our business interests (e.g., marketing), (ix) investigate and prevent fraudulent transactions, unauthorized access to or use of the Site or our services, and other illegal activities, and (x) personalize the Site and our advertising, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, HBR may collect and use your personal information for any other purpose for which we obtain your consent. For the avoidance of doubt, you hereby agree that HBR may contact you via any means, including SMS/text message and email, to furnish you information regarding a product order, shipping status, warranty-related information, and similar data and information pertaining to a commercial transaction.

6. Sharing Information / Third-Party Disclosures

We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.

Affiliates and Corporate Group Sharing. We may share personal information to and among our affiliates and subsidiaries who act for HBR or on behalf of our parent company and these recipients may use your personal information in accordance with the terms and conditions of this Privacy Statement (e.g., marketing, surveys) or with their own data privacy representations to which you agree or are provided notice. In addition to the foregoing, HBR may leverage computer networks and systems of our affiliates and subsidiaries and your personal information may be transmitted or retained thereon.

Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions, and performing analyses to improve the quality of the Site and our services.

Payment Card Transactions. HBR does not have access to your credit card information and does not store or disclose your full credit card information. Any personal or financial information you provide to a third party online payment system is subject to the third party’s privacy terms, and not this Privacy Statement.

Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials.

Business Restructuring. Circumstances may arise where for strategic or other business reasons HBR decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of HBR’s assets.

Disclosure for Other Reasons. We may disclose personal information (i) if required by law, government order, or legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, HBR may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.

In the event that you facilitate a transaction with HBR, or request information from or otherwise engage with us, and such activities require HBR to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct HBR to intentionally disclose your personal information to the service provider or third party, provided HBR has determined, in its reasonable judgment, that either (i) the service provider or third party will not sell the personal information or (ii) disclosing the personal information is required or permitted by law.

7. Social Media

We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on one of these platforms for customer support or otherwise, we may contact you via the social media’s direct message tools. Those communications are governed by this Privacy Statement as well as the policies and terms of the relevant social media platform. The information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

8. Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, the Site may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Statement does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Site. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

9. Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to facilitate transactions you have requested, or to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Statement.

HBR is based in the United States and the personal information that we collect and process is retained and stored in the United States. Please be aware that the United States may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States, your personal information may be accessible by, or otherwise made available to, government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations applicable in the United States. By continuing to provide us such information, you hereby consent to your personal information being transferred to, and stored in, the United States.

10. Security

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE OR US OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access the Site or our services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

11. No Data Collected from Children

The Site is not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under sixteen (16) years of age without verified consent from their parents or guardians. If you are under the age of sixteen (16), you are prohibited from accessing or using the Site or with providing us with your personal information, unless you provide us written and verifiable authorization from your parent or legal guardian permitting you to do so.

12. Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to HBR if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. If you provide personal information (including personal information concerning a third party) to HBR, you expressly represent and warrant to HBR that you have the full right and authority to provide HBR with such personal information (including personal information concerning a third party) and that HBR’s use and processing of such personal information AS SET FORTH HEREIN will not violate any PERSON’S rights or privileges, including rights to privacy. You hereby agree to fully and completely indemnify HBR for any claims, harm, or damages that may arise from your provision of personal information (including personal information concerning a third party) to HBR.

13. Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. You must directly notify HBR of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.

14. Email Marketing and Your Rights

You have the right to opt-out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify HBR, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.

15. California Privacy Rights

Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents have additional data privacy rights, including (i) the right to be notified about what personal information is collected about you, and our intended use and purpose for collecting your personal information, (ii) the right to know and access personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the categories of personal information we have collected, used, disclosed, or sold about you, the categories of sources from which the personal information is collected, the business or commercial purpose for which your personal information was collected, used, disclosed, or sold, and the categories of third parties with whom we have shared your personal information, (iii) the right to request HBR to transfer, to the extent feasible, personal information in certain forms and formats, (iv) the right to request that we delete/erase your personal information under certain circumstances, and (v) the right not to be subject to discrimination for asserting your rights under the CCPA. The personal information we collect from you, the purposes for which it is used, the source of such personal information, and the parties to whom we share your personal information is set forth in this Privacy Statement. To exercise any of the CCPA’s data privacy rights set forth herein, please contact us in accordance with the “Contact Us” section listed below.

Privacy Request Process. If you (or your authorized agent) makes any request related to your personal information under the CCPA, HBR will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. HBR will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email or other means and match at least two or three pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein. None of the CCPA’s rights are absolute and are subject to legal and regulatory exceptions and exemptions.

Opt-Out Rights / Do Not Sell My Personal Information. In some circumstances, California residents have the right to opt-out of the sale of their personal information to third parties for profit or other valuable consideration. However, HBR does not sell your personal information to third parties for profit or other valuable consideration and therefore this opt-out right is not applicable to HBR.

16. Nevada Privacy Rights

HBR does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.

17. Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

18. Persons with Disabilities

HBR strives to ensure that every person has access to information related to the Site and our services, including this Privacy Statement. Please contact us if you would like this Privacy Statement provided in an alternative format, and we will seek to meet your needs.

19. Employment Applications and Talent Management

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and, information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Statement.

20. Events and Video Teleconferencing

HBR hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.

21. Changes to the Policy

We reserve the right to amend this Privacy Statement at any time. We will notify you if this Privacy Statement is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Statement to determine whether any amendments have been made hereto. Your use of the Site, and continued use of the Site, after any amendments are made to this Privacy Statement signifies your consent to this Privacy Statement and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Statement; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Statement to determine whether any amendments have been made hereto. 

22. Contact Us

If you have questions regarding this Privacy Statement or our handling of your personal information, would like to request more information from us regarding our privacy practices, or would like to exercise a data privacy right, please contact us at the following: (email) privacy@hbrconsulting.com (Subject Line: Privacy Request), (telephone) 1-800-832-7599, or (mail) 425 South Financial Place, Suite 2250, Chicago, IL 60605.