Privacy Notice
The HR Trust is committed to protecting and processing your personal information responsibly. We value the data you share with us and treat it with respect.
This Privacy Notice describes how The HR Trust collects, uses, and shares your personal information. Additionally, it outlines how you can access and control your personal information.
The HR Trust collects personal information related to your profession, similar to the information you would find on a business card or in a business email signature block. We store this information in our database, and make it available to our customers, who use this information to conduct their own business-to-business (B2B) sales, marketing, and recruiting activities.
This Privacy Notice outlines our practices with respect to processing personal data of Contacts, End Users and Visitors (“Data”). Please read it carefully so that you understand how we collect, use, and process your Data, and how you may opt-out of our Data use, or otherwise access, rectify, and/or erase your Data.
If you do not agree with this Privacy Notice or any part of it, you should not access this website or use our Services.
- Our approach
The HR Trust is committed to providing its innovative services while respecting the privacy of everyone involved and complying with any applicable privacy and data protection laws.
We are committed to providing our Licensees and End Users with the most useful and accurate Data possible in our database and have implemented internal measures for accuracy and relevancy purposes.
The HR Trust only collects Data to the extent necessary and does not collect sensitive data related to health, religious beliefs, political opinions, or ethnicity.
Types of information we collect from or about you
We collect and process Data:Data about Contacts
We process business-related Data about Contacts. This Data is limited to what you would normally find on a business card or in a business email signature block, or to what is necessary to contact an individual with a business social network profile or to verify the authenticity of such a profile.Our database relies on data retrieved or derived from information from the following sources:
- Our email composing features: Where The HR Trust End Users provide us access to their email account for the purposes of using our email composing features, we obtain Data using Google’s or Microsoft’s APIs.
- Our affiliates and group members: We receive Data from affiliates, i.e. subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership or in the same corporate group.
- Publicly available sources: Our proprietary algorithm scans publicly available sources and retrieves public information to understand standard corporate email patterns (e.g. [email protected]). We use this Data only after we have verified it in accordance with our internal processes.
- Business social network profiles: When an End User uses our browser extension while using LinkedIn, we read the minimum Data presented on the LinkedIn profile pages that the End User is browsing for providing the Service( e.g. name, position, company, contact details if public)
- Third parties (for information about companies): We rely on business partners to collect company information about and maintain a verified list of existing companies. We use this information to ensure that the Data we process relates to business details obtained from the above is only added to the HR Trust B2B Database if it relates to business details (as opposed to personal contact details).
Information we collect about and from End Users
Data we process about End Users
We collect Data directly from End Users where they interact with us. For example, this is the case when End Users create an account, use our Services, contact us via our website or support channels. The Data includes:
- name
- professional email address
- professional phone number
- professional mailing address
- location
- user activity
- referred friend’s professional email address and name (only if you use our referral service)
- any other information you provide us voluntarily when you communicate with us.
We do not sell any Data or information shared with us by our paying Licensees, End Users, or customers.
Data our Payment Partner collects
For End Users and Licensees that pay for the Services by credit cards, our service provider processes your payment information, while The HR Trust does not have direct access to it. We have an agreement with the service provider to ensure that your payment information is processed in a secure and confidential way.Information we process about End Users and Visitors alike
If you are an End User using our Services as an authorized user of a HR Trust Licensee or a Visitor that visits our website or Service, we automatically collect information sent to us by your computer, mobile phone, or other access devices. This information includes: - Your device information (for example, the type of browser and operating system your device uses, your language preference, your domain name, and the time you accessed the website)
- Your mobile network information
- Your IP address
- Alerts for troubleshooting errors and bugs
Where you are not logged into your account, this information is unidentified to you and we are not aware of the identity of the user from which this information is collected.
We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.
Additional restrictions
Notwithstanding anything else in this Privacy Notice, if you provide The HR Trust access to your email account, for the purpose of using our email composing features, the following types of your Google data or Microsoft data will be subject to these additional restrictions:The HR Trust will only use access to read, write, modify, or control email message bodies, metadata, headers, and settings to enable End Users to compose and process emails and will not transfer this data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger or acquisition. We will not use this data for serving advertisements, selling data, or any other purpose except as set hereinabove or as otherwise permitted in line with Customer-/End User-specific consent.
The HR Trust’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
How we share your information
We may share information with third parties in the ways and for the purposes described above.
- With our End Users and Licensees (Contacts only): We share Contacts stored in our Database with our End Users and Licensees, for the purpose of providing our Services and allowing access to authentic, current, and up to date business contact information.
- Within The HR Trust or our Payment Partner: We may share your information within The HR Trust. To the extent permitted by law and taking into account the protection of your rights and freedoms with respect to the processing of your Data, and the consent you have given (if any), your Data will only be accessible by a limited and defined number of recipients within The HR Trsut (such as employees) or our Payment Partner.Please be assured that such access to your Data will be strictly on a “need to know” basis and will be subject to our internal privacy policy and an obligation of confidentiality.
- With our service providers: Your Data will generally not be disclosed to recipients outside The HR Trsut or our Payment Partner. In some cases, however, The HR Trust uses third-party sub-processors acting on its behalf under contracts that will include strict data protection obligations.In particular, we will provide your Data to service providers or suppliers as part of our normal business operations. Such service providers include (i) hosting services providers, (ii) data analytics providers, (iii) payment processors, and (iv) security services providers.When you are joining The HR Trust or fan page on Facebook, Facebook and We are acting as joint controllers. The same goes when you are visiting our LinkedIn Page.
- Facebook Inc., headquartered at 1 Hacker Way, Menlo Park, CA 94025, United States of America.
- LinkedIn Corporation is headquartered at 1000 W. Maude Avenue, Sunnyvale, CA 94085 USA.Please note that when it comes to connecting your CRM, Google, or Microsoft accounts to our Service (via Google connect, Office 365 Login, etc.) The HR Trust acts as an independent controller.
- In connection with a business transaction: We may share Data while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.
- With other third parties and with public authorities: In certain circumstances, we may also share and disclose such your information, if we believe in good faith that such disclosure is necessary or required: (i) to comply with a law, regulation, governmental or securities exchange requirement, court order, judicial proceeding, or legal process, such as a subpoena or a search warrant; (ii) to address a violation of the law; (iii) to investigate fraud or criminal activity, and to protect our rights or those of our affiliates, vendors and users, or as part of legal proceedings affecting or may affect us or our affiliates, vendors or users; and (iv) to allow The HR Trust to exercise its legal rights or respond to a legal claim.How long do we keep your Data?
The HR Trust has implemented a retention policy, setting retention periods taking into account the type of information that is collected and the purpose for which it was collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
We only keep your Data for the time necessary for the purposes described above. - Contacts: We retain your Data for the duration necessary to provide our Services and, thereafter in archives, to comply with our legal obligations, resolve disputes and enforce our policies.
- The HR Trust End Users: We retain your Data for the duration of your active account on The HR Trust. We may keep your Data for 3 years following the last activity in your account in order to comply with our legal and contractual obligations or to protect ourselves from any potential disputes (as required by laws applicable to record-keeping and to have proof and evidence concerning our relationship, should any legal issues arise following the termination of your account), all in accordance with our Data Retention Policy.Lastly, we retain Data in our suppression list for the duration necessary to provide our Services, which includes ensuring that any Contacts who are public figures or who have exercised their right to opt-out remain excluded from our Database.Once the retention period has passed, Lusha takes the appropriate and adequate measures to dispose of all and any Data in a secure and lawful manner.
How to opt-out or access, rectify, and/or erase your Data
The HR Trust allows you to access your Data, edit or obtain Data collected about you by contacting our Privacy Team.Note that we maintain a suppression list which may include personal data, for the sole purpose of ensuring that opt-out requests are respected and that your contact information no longer appears in our Database in the future if you have opted-out.
For any request relating to your Data, contact us. In particular, you may request:
- Information and access to a copy of your Data: you may obtain confirmation as to whether or not your Data is processed by The HR Trust. As applicable you may get more information on the Data we hold and how your Data is processed, and get a copy of your Data.
- Rectification of your Data: you may rectify your Data if it is inaccurate or incorrect or out-of-date. You may also have incomplete Data completed.
- Erasure of your Data: you may request the erasure of your Data, e.g. if you object to the processing of your Data. However, we may have legal or legitimate reasons for retaining the Data depending on the context. Upon complying with your request, we shall also inform the customers that purchased your data.
- Limitation of processing: you may request a limitation of your Data, e.g. in case of issue or audit. We will mark your Data to limit their future processing.
You may also object to the processing of your Data for certain purposes. - To stop receiving marketing communications from us: you may demand that we stop any direct marketing to you, at any time.
- For other purposes: you may object to the processing of your Data where such processing is based on legitimate interest as described above. Please describe the reasons relating to your particular situation to justify your request. If applicable, we will stop the processing unless we have compelling legitimate grounds.Before completing your request, we will need to verify your identity. We will send you a link to verify your email address and may request additional information solely for the purpose of verifying your identity. Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.If you have given us your consent, you may withdraw that consent at any time for future processing. This will not affect the lawfulness of the processing prior to the withdrawal of consent.
Minors
The products and services of The HR Trust are not targeted to or intended for children under the age of 18. In the event that we become aware that a Contact or End User is under the age of 18, we will discard such information. If you have any reasons to believe that a minor has shared any information with us, please contact us at [email protected]
How do we safeguard and transfer your Data?
We will take all steps reasonably necessary to ensure your information is treated securely and in accordance with this Privacy Notice.
Once we receive your information, we take all appropriate technical and organizational measures, reasonable precautions, and follow industry best practices to safeguard your information against loss, theft, unauthorized use, access, or modification.
Changes to this policy
The HR Trust may modify this Privacy Notice from time to time, to reflect eventual changes in the way we process Data. If we make material changes to this policy (such as a change in our processing purposes, a change in the identity of the controller, or even a change regarding the way you can exercise your rights in relation to our processing activities), we will notify you, as appropriate, depending on the substance of the change, by email or by means of a notice on our website’s homepage, prior to the changes becoming effective.
Contact us
Should you have any queries regarding this Privacy Notice or about how The HR TRust uses your data that are not answered here, please contact us via our email which is [email protected]
Complaints
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint. Please email the details of your complaint to: