HiHaHo Privacy Policy

This privacy policy document has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in European and United States privacy law and information security, is information that can be used on its own, or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

This Privacy Policy is in effect as of September 1, 2014.

HiHaHo Privacy Policy was screened and adjusted in view of the EU General Data Protection Regulation (GDPR) to be enforced from May 25th, 2018.
For more info, see:
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679&from=EN

 

What personal information do we collect from the people that visit our website or blog?

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, Company name or other details to help you with your experience.

When do we collect information?

We collect information from you when you register on our site, place an order, subscribe to a newsletter or by watching a HiHaHo interactive video or when entering information on our site.

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

  • To personalize user’s experience and to allow us to most adequately deliver the appropriate services to the users of HiHaHo.
  • To improve our website in order to better serve you.
  • To allow us to better serve you in responding to your customer service requests.
  • To send periodic emails regarding your order or services.

 

How do we protect visitor information?

Our website is scanned on a regular basis for security holes and vulnerabilities in order to make your visit to our site as safe as possible.

Your personal information is contained behind secured networks and is only accessible by a limited number of people who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user places an order, enters, submits, or accesses their information, to maintain the safety of your personal information.

All transactions are processed through a gateway provider and are not stored or processed on our servers, to expedite future orders, and to automate the billing process.

Do we use cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow it), that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

HiHaHo’s cookie policy is fully in line with the applicable legal framework as formulated in the Dutch ‘Telecommunicatiewet’ (Telecommunication Law), the current EU Directive on Privacy and Electronic Communications (Directive 2002/58/EC), and The EU General Data Protection Regulation (GDPR). Furthermore, as far as possible during the ongoing political deliberations about the final draft of it, HiHaHo is preparing itself for the implementation of the EU ePrivacy Regulation (to be published Fall 2019, as a replacement of the EU Directive 2002/58/EC).

HiHaHo makes use of ‘functional’ and ‘analytical’ cookies, for the use of them no explicit permission is required. The functional cookies are: FirstTimeReferer in the domain .hihaho.com (referring to first visit); hipid in the domain player.hihaho.com (referring to webservers the user is connected with); session_hihaho (to keep the user logged in). The analytical cookies are all in the domain .hihaho.com, being identifiable as _ga, _gat, _gat_UA-xxxx-x, and _gid. For further information see https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.

Can users disable cookies in their browser?

If you disable all cookies, the HiHaHo website and all HiHaHo services will become unusable. These services include the viewing, creating, editing, publishing and posting of embedding of a HiHaHo interactive video and/or viewing the viewing details of a HiHaHo interactive video.

If you only disable so called third party cookies, there will be no effect on the HiHaHo website and HiHaHo services.

Third Party Disclosure

We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties, unless we provide you with advance notice. This does not include website hosting partners and other parties that assist us in operating our website, conducting our business, or serve you, as long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third party links

Possibly, at our discretion, we may include or offer third party products or services on our website. Once you have used a link you will leave the HiHaHo-website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Links to third party content from HiHaHo interactive videos

HiHaHo interactive videos are the result of the HiHaHo website and HiHaHo services. These interactive videos can contain (embedded) links to third party content (websites, images, documents, videos etc). Once you use an external link you will leave the HiHaHo-website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites.

Links to third party Learning Management Systems (LMS) from HiHaHo interactive videos

HiHaHo interactive videos are designed to communicate with Learning Management Systems using standards like SCORM and xAPI. Information about how long you watched the HiHaHo interactive video and which interactions/links you used and/or the results of quizzes, will be sent to an LMS only if the author/owner of the HiHaHo interactive video has set these options as a property of HiHaHo interactive video.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. For more info, see: https://support.google.com/adwordspolicy/answer/6008942?hl=en&rd=1
HiHaHo works with Google Analytics as a web analytics service that tracks and reports website traffic. Google analytics is used to track the website activity of the users such as session duration, pages per session, bounce rate etc., along with the information on the source of the traffic. For further information we refer to the Terms of Service of Google Analytics, and in particular to its section on ‘privacy’.

The General Data Protection Regulation (GDPR) (EU) 2016/679

  1. Starting from May 25, the GDPR will be enforced in all European countries. The personal information of persons who use the HiHaHo website, including the HiHaHo Video Enrichment application, are treated conform the GDPR. Furthermore, HiHaHo warrants the users’ rights as formulated in the GDPR.
    According to the GDPR we specifically agree to the following, as far as not yet mentioned elsewhere in this document:
    A. With respect to the rights of individual users (consumers):
    – Individual users of HiHaHo have the right to claim access to their own personal data.
    – Individual users of HiHaHo are the right to have their personal data adjusted, corrected, supplemented, and/or deleted.
    – Individual users of HiHaHo have the right of data portability, i.e. they may ask HiHaHo to make their own personal data available for transferring to another supplier.
    – Individual users of HiHaHo have ‘the right to be forgotten.’
    – Individual users of HiHaHo have the right to have the data processing restricted with respect to their own personal data.
    – Individual users of HiHaHo have the right not to be subject to a decision, which may include a measure, evaluating personal aspects relating to him or her which is based solely on automated processing and which produces legal effects concerning him or her or similarly significantly affects him or her, such as automatic refusal of an online credit application or e-recruiting practices without any human intervention.
    – Individual users of HiHaHo have the right to forward objections against the processing of their own personal data.
    Users of HiHaHo, who want to effectuate their rights, are expected to do so by a written, signed request, addressed by mail to the HiHaHo Office. HiHaHo will provide the requested data and/or realize the requested adjustments, within two weeks after having received the request to that effect.
    B. With respect to the rights of persons who use the HiHaHo Video Enrichment application under the auspices, or on behalf of an organization or company, which formally is considered the application’s licensee (for instance as an employer or a training agency), the above rights can only be effectuated based on the licensee’s written consent.
    C. With respect to end-users (viewers) of HiHaHo Enriched Interactive Videos who are enlisted as such by an organization or company, which formally is considered the application’s licensee (for instance as an employer or a training agency), the assignment and enforcement of their rights shall be executed under the full responsibility of the licensee concerned.

California Online Privacy Protection Act

CalOPPA is the first state law in the USA to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world), that operates websites collecting personally identifiable information from California consumers, to post a conspicuous privacy policy on its website stating exactly what information is collected and with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/#sthash.uHz7bD7K.dpbs

According to CalOPPA we agree to the following:

Users can visit our site anonymously

Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.

Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above.

How does our site handle ‘do not track’ signals?

We don’t honor ‘do not track’ signals, because it is part of the HiHaHo service to track views and interaction on HiHaHo interactive videos (being) viewed.

Does our site allow third party behavioral tracking?

We do allow third party behavioral tracking such as Google Analytics.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email within 3 business days.

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

  • Send information, respond to inquiries and/or other requests or questions.
  • Process orders and to send information and updates pertaining to orders.
  • We may also send you additional information related our services.
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

 

To be in accordance with CAN-SPAM, we agree to the following:

  • NOT use false or misleading subjects or email addresses
  • Identify the message as an advertisement in some reasonable way
  • Include the real address of our business or site headquarters
  • Monitor third party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly
  • Allow users to unsubscribe by using the link at the bottom of each email
  • If at any time you would like to unsubscribe from receiving emails in the future, you can follow the instructions at the bottom of each email.

 

Law and Jurisdiction

This Privacy Policy will be governed by and construed in accordance with the laws of The Netherlands, and any disputes relating to this Privacy Policy will be subject to the exclusive jurisdiction of the courts of The Netherlands.

Contacting Us

HiHaHo.com is operated by HiHaHo, a trade name of Icademy BV, Kloekhorststraat 29, 9401 BB Assen, The Netherlands (Europe), registration Number at the Dutch Chamber of Commerce: 01166414.

If you have any questions or comments about this Privacy Policy as outlined above, you can contact us at:

HiHaHo
Kloekhorststraat 29
Assen, 9401 BB
The Netherlands (Europe)
Phone: +31(0)592-377285

Email:

Version: 1.6

Last revised: September 2, 2019

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