PRIVACY POLICY

• Your Privacy is not for sale
• We limit the collection and use of personal information

The following documentation explains how and why HiraEdu., its affiliates, advertising, and other third-party partners, collectively referred to as “we” for the purposes of this documentation, collect and use personal, identifiable, and other information (“User Information”) about users through use of our website, HiraEdu, our applications, and other online services (“Services”).

1. Data Protection Principles

The Company is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General Provisions

1. This policy applies to all personal data processed by the Company.
2. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
3. This policy shall be reviewed at least annually, or sooner if needs dictate.

3. Lawful, Fair and Transparent Processing

1. To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner.

4. Lawful Purposes

1. All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
2. The Company shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.

5. Data Minimisation

1. The Company shall ensure that personal data is adequate, relevant and limited to what is necessary, in relation to the purposes for which it is processed.

6. Accuracy

1. The Company shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Information Collected by the Company

1. Information We Collect Automatically
   1. When users visit one of our Services, we may automatically collect information about them such as IP address, mobile device identifier or other unique identifier, browser and computer type, access time, originating web page, next URL, web page(s) accessed during a user’s visit, and interaction with content and/or advertising on the Services (“Usage Data”).
   2. When users share our articles on social media platforms, we may also receive Usage Data and User Information shared with the platform.
   3. We also use third-party pixel tags which are small graphic files which allow ourselves and our partners to get Usage Data on users.
   4. We and our third-party advertising, affiliate, and analytics partners also use cookies to keep a record of the information stated above in users’ local browser cache. This helps us collect Usage Data upon subsequent visits, linking previous activity with current and future visits.
2. Information Users Provide
   1. When users subscribe to our newsletter, we collect and save the email address associated. When comments are submitted, we receive the poster’s profile information through our partner, Disqus. When users apply for a job in the Careers section of our website, or send a message through our Contact section, we receive the user’s name, email, website, and other information disclosed in the comment.
3. Information We Get From Others
   We may get User Information about users from third-party (advertising, affiliate, and advertising) partners in the following circumstances:
   1. When users signup at our affiliate partners to purchase something, or participate in a campaign
   2. From our advertising partners about users’ activity on our website
   3. When users utilize a third-party partner’s system to log into our website

8. How long is information stored?

The data collected from users may be used in the following ways:

1. Our third-party advertising partner may use Usage Data to show users advertisements that may be more suited to them.
2. We use users’ information in an aggregate, (i.e. non-personally identifiable) form to identify viewership trends on our website. We also use it to improve the interface and content of the website.
3. We use users’ email addresses to send a daily email summarizing the news we cover.

9. How long is information stored?

1. Email addresses and submissions made through the ‘Contact’ and ‘Careers’ sections of our website are kept for the same duration as we are in operation.
2. We ask our analytics partner, Google Analytics, to remove personally-identifiable information after a period of 36 months in which there has been no interaction from the user. After this occurrence the only information that is kept is done so in an aggregate form, devoid of any personal identifiers.

10. How We Share Your Information

1. No user information is sold to any third-party.
2. We may share the information we have about you with our third-party (advertising, affiliate, and analytics) partners, including when you connect with third-party apps and widgets. This information is shared to improve functionality or make advertisement possible on the website.
3. We share user email addresses with a third-party partner to send users our daily newsletter.
4. We reserve the right, and terms of customer usage of the website expressly authorize the company, to share User Information in the following circumstances:
   1. In response to subpoenas, warrants, court orders, or legal processes.
   2. To establish, protect, or exercise our legal rights or defend against legal claims.
   3. If we believe it is necessary to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property.
   4. If we believe it is necessary to investigate, prevent, or act regarding significant abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of information).
   5. To protect and defend our legal rights or property, our services or their users, or any other party, and to protect the health and safety of our users or the public.
   6. To our parent company, subsidiaries, joint ventures, or other companies under common control with us, and as such, are responsible under the same Privacy Policy herein.

11. Security

We have implemented commercially-reasonable security measures to help protect your Personal Information from loss, misuse, or unauthorized access or disclosure; however, as no data transmission over the Internet can be guaranteed to be 100% secure, whilst we strive to protect your User Information, we cannot guarantee its security. Usage of the Site and provision of information is done at your own initiative and risk with strict adherence to the spirit and principles of General Data Protection Regulation.

12. Contact

If you have any questions about this Privacy Policy, please feel free to contact us by email at [email protected].