Privacy Policy
Hotshot Inc. (referred to as “Hotshot”, “we” or “us”) takes your privacy seriously and seeks to comply with all applicable privacy laws including, where relevant, the General Data Protection Regulation (“GDPR”). We want you to be familiar with how we collect, use and process your Personal Information (defined below) and your rights to seek the return and/or changes to any of your Personal Information that we hold.
1. PERSONAL INFORMATION
Personal Information We May Collect, As Provided by You
“Personal Information” is information that identifies you as an individual, which may include:
- Name
- Email address
- Position/Role
- School status
- Your viewing of content and other usage information
If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, (as defined below), you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
How We May Collect Personal Information
We may collect Personal Information in a variety of ways, including:
- Through the Services: We may collect Personal Information through the Services, such as when you register for a user account, access content, take a quiz or fill out a survey. The “Services” means: (i) videos and related materials covering legal and other professional skills provided by Hotshot; (ii) our website located at www.hotshotlegal.com, and pd.hotshotlegal.com, from which you are accessing this Privacy Policy.
- Offline: We may collect Personal Information from you offline, such as when you contact customer service.
How We May Use Personal Information
We may use Personal Information:
- To respond to your inquiries and fulfill your requests, such as to send you e-mails or other communications about the Services.
- To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
- To send you marketing communications that we believe may be of interest to you, unless you elect not to receive them.
- To personalize your experience on the Services by presenting information tailored to you.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, assessment of the effectiveness of your learning or the Services, developing new products, enhancing, improving or modifying the Services, assessing your performance, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we reasonably believe to be necessary: (a) to comply with applicable laws, such as accounting regulations; (b) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) to enforce our terms and conditions and/or reasonably protect damage to our operations or ensure the safety of any third party; and (d) to respond to civil subpoenas or inquiries.
We will only collect and process such Personal Information as is required for the uses set out above. If a user receives any certifications or accreditations from completing a Hotshot course (“Certification”), such Certifications will be retained by Hotshot and made available to you, transferred to a new client account or deleted, upon your request.
How Personal Information May Be Disclosed
Your Personal Information may be disclosed (but in all cases only so far as reasonably necessary):
- To our third-party service providers who provide services such as data analysis, acting as content intermediaries, authentication, information technology and related infrastructure provision, video provider, educator, customer service, email delivery, auditing, legal, accounting, and other similar services, provided that, at all times, any such third party is required to hold your Personal Information in accordance with terms at least as restrictive as those set out in this privacy policy.
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) provided that, at all times, any such third party is required to hold your Personal Information strictly in accordance with the terms of this privacy policy.
- If your subscription is provided in whole or in part by your employer, school, or other third party, we may share with them information about your access to and use of your subscription. When providing this information, we may reveal limited amounts of your Personal Data, such as your name and usage information.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence or otherwise to comply with legal process; (b) to respond to legitimate requests from public and government authorities including public and government authorities outside your country of residence; and (c) to enforce our terms and conditions as reasonably necessary in order to protect our operations, prevent damage to property, other third parties, or ensure personal safety.
2. OTHER INFORMATION
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Browser and device information
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you
- Aggregated information
We and our third-party service providers may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type, screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
- Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Services, as well as for online tracking purposes. We can recognize your computer to assist your use of the Services. We also gather statistical information about the usage of the Services in order to continually improve the design and functionality, understand how the Services are used and to assist us with resolving questions regarding the Services. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies in online advertising to track responses to our advertisements and we may use cookies or other files to track your use of other websites. If you do not want information collected through the use of cookies, you can decline cookies; however, if you do not accept these cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer and you may need to log in every time you visit the applicable Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies: We and our third-party providers may use Flash LSOs, Flash Cookies, and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Services or our online content.
- IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is done automatically by many websites, applications and other services. We use IP Addresses for many purposes, including, without limitation, calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
- From you: Information such as your location, as well as other information, such as your preferred means of communication, practice area, your performance and responses to quizzes and surveys, and organization, is collected when you voluntarily provide this information.
- By aggregating information: Aggregated Personal Information does not alone personally identify you or any other user of the Services, (for example, we may aggregate Personal Information to calculate the percentage of our users in a particular region).
How We May Use and Disclose Other Information
Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we will only collect, store, and process such information in accordance with this privacy policy as if it was Personal Information as set out above.
In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). Any such combination shall not reduce or remove Hotshot’s obligations with respect to Personal Information.
3. THIRD-PARTY SERVICES
This Privacy Policy does not address in whole, and we are not responsible for, the privacy, information or other practices of any third parties, including any third-party operating any site or service to which the Services link. The inclusion of a link on or to the Services does not imply our endorsement of the linked site or service.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, including our third-party providers, or other organizations or services that you may use to access the Services, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to such other organizations.
4. SECURITY
We have implemented organizational, technical and administrative measures to protect Personal Information within our organization. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us as soon as possible in accordance with the “Contacting Us” section below.
If we become aware of any use or inadvertent disclosure of your Personal Information, outside of the terms of this privacy policy, which has a significant risk of causing harm or damage to you, then we will notify you (and any applicable regulator) as soon as reasonably possible. Where any such notification is possible, we shall notify you of the details of the breach and any consequences of which we are aware.
5. CHOICES AND ACCESS
Your Choices Regarding Our Use and Disclosure of Your Personal Information
We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:
- Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out of receiving these marketing-related emails by sending an email to privacy@hotshotlegal.com or follow the unsubscribe instructions included in each marketing-related email.
- Receiving telephone calls or postal mail from us: If you no longer want to receive marketing-related telephone calls or postal mail from us on a going-forward basis, you may opt out of receiving these marketing communications by sending an email to privacy@hotshotlegal.com and specifying the contact information used and form of marketing from which you are opting out.
- Hotshot retaining, for you, your Certification data: If you no longer want us to retain your Certifications, please notify us by sending an email to privacy@hotshotlegal.com and specifying the contact information originally used to access the Service.
We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt out from receiving administrative messages.
How you can access or change your Personal Information – Portability
If you would like to review, correct, update, suppress, or delete, subject to the terms herein, any of your Personal Information that is retained by Hotshot, you may contact us by emailing: privacy@hotshotlegal.com
In your request, please make clear what Personal Information you would like to have changed or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us.
For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
Upon termination of your subscription with Hotshot you may request access to the Personal Information we hold about you which will be delivered in the format in which Hotshot maintains this data. Such Personal Information may be used by you for any purposes subject to any restrictions in the Agreement between Hotshot and you or the organization which paid for your access to the Services
6. RETENTION PERIOD
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required by law. We will not retain your Personal Information for longer than is reasonably necessary.
7. USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of eighteen (18), and these individuals are prohibited from providing Personal Information through the Services.
8. CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.
9. SENSITIVE INFORMATION
We ask that you not send us, and therefore you must not disclose, any sensitive Personal Information (e.g., gender, sexual orientation, social security numbers, birthdates, account numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise to us.
10. UPDATES TO THIS PRIVACY POLICY
We may change this Privacy Policy. Please take a look at the date at the bottom of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.
11. CONTACTING US
If you have any questions about this Privacy Policy, please contact us by email at privacy@hotshotlegal.com.
October 2018