Last Updated: 25 April 2024
 

The Handa Group is a business unit within the Hofflander and Associates group of companies, based in Edina, Minnesota, USA operating as The Handa Group ("Hofflander and Associates", “The Handa Group", ” “Company”, “we”, “us”, “our”) is committed to protecting and respecting your privacy.
 

This General Privacy Policy describes our privacy practices in relation to the information we collect from you when you visit our website or when you access or use any applications or features made available by us on or through or in connection with this Website or our services that link to this General Privacy Policy (collectively, the “Website”).
 

Hofflander and Associates may supplement this Privacy Notice with other privacy notices if you register for specific services.

• If you are receiving The Handa Group virtual coaching services, you will also want to review The Handa Group Participant Privacy Notice.

• If you are working with The Handa Group Recruitment Solutions seeking an interim or permanent staffing placement, you will also want to review The Handa Group Recruitment Solutions Candidate Privacy Information Statement.

• If you are receiving The Handa Group Career Transition services through your employer, you will want to review The Handa Group Candidate Privacy Notice.  
   

Our contact details as the Data Controller of your personal data

Hofflander and Associates, DBA: The Handa Group is the Data Controller of your personal data.
 

What categories of personal data does The Handa Group collect and use?

Personal data includes any information relating to an identified or identifiable natural person. It does not include data that cannot be linked to an individual (such as anonymous data).
 

We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us:

 

a. Identity Data includes your name.

b. Contact Data includes your email address and telephone number.

c. Professional Data includes your job title and other job or career information that you choose to provide to us.

d. Marketing Communications Data includes your preferences on content type, frequency of communications and preferred language.

e. Profile Data includes information about you, provided by you on our electronic portals or platforms including services or products ordered by you, your system preferences, your user-generated content (for example, your coaching program) and your feedback including survey responses.

f. Usage Data includes information about how you use our website, systems, products and services.

g. Technical Data includes technical information collected when you access our electronic portal or platform, and includes your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
 

Why do we process your personal data and on what legal basis?

We process personal data from you only where we have a legal basis for doing so. Our legal basis for collecting and using your personal data will vary depending on the personal data concerned and the specific context in which we collect it. Please note that some of the information below may not apply to you depending on your relationship with us and/or the legislation of your home country.

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PURPOSES OF THE PROCESSING | TYPE OF PERSONAL DATA | LEGAL BASIS TO PROCESS YOUR PERSONAL DATA

To provide you with our services and to attempt to establish or strengthen a business relationship with you.

a) Identity Data b) Contact Data c) Professional Data d) Profile Data
 

- Performing a contract or taking steps prior to entering a contract in respect of the contract with or related to you - Consent where we are required under the law to obtain consent to provide you with our services - Fulfilment of our legitimate interests to provide our products and services
 

To keep you informed about our services, via email, messaging, phone, social media or any other channel. This includes information such as events or newsletters that may be of interest to you.
 

a) Identity Data b) Contact Data c) Marketing Communications Data

To keep you informed about our services, via email, messaging, phone, social media or any other channel. This includes information such as events or newsletters that may be of interest to you. a) Identity Data b) Contact Data c) Marketing Communications Data d) Social Media Data if applicable - Consent where we are required under the law to obtain consent for marketing - Performing a contract or taking steps prior to entering a contract in respect of the contract with or related to you - Fulfilment of our legitimate interests to promote our products and services where we are not obliged to obtain consent by law
 

To respond to your request or questions or to provide information when you contact us or make a request to us.
 

a) Identity Data b) Contact Data c) Profile Data

Fulfilment of our legitimate interests to respond to you

- To allow you to participate in interactive features of the Website, when you choose to do so; - To further develop and improve the Website and systems to better serve you; - To best tailor content, the Website and resources according to your preferences, to improve them and to present it in the most effective manner for you.

a) Identity Data b) Contact Data c) Professional Data d Profile Data e) Usage Data f) Technical Data

Fulfilment of our legitimate interests to administer our websites and provide you with relevant information about our products and services
 

Where necessary, to comply with any legal obligation.

Personal data as strictly necessary.

Compliance with a legal or regulatory obligation

To investigate or respond to incidents and complaints and/or to comply with investigations carried out by the police, government or regulators.

Personal data as strictly necessary.

- Compliance with a legal or regulatory obligation - Performance of a task carried out in the public interest.
 

How do we get your personal data, and do you have to give them to us?

We use different methods to collect data from and about you, including through:

 

1. Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   register for our products or services;

   1. create an account on our Website;

   2. subscribe to our service or publications;

   3. request marketing to be sent to you;

   4. enter a competition, promotion or survey; or

   5. give us feedback or contact us.
       

The provision of your personal data is voluntary for you. You may choose not to provide your personal information to us; however, this may limit your ability to use the website, receive our services or to interact with us.
 

How long do we keep your personal data for?

We keep your personal data only as long as necessary to provide you with The Handa Group services and for legitimate and essential business purposes, such as carrying out The Handa Group services, complying with our legal obligations, and resolving disputes. The retention periods of your personal data depend on the respective purpose the data are processed for and the relevant jurisdiction. In some circumstances, we may anonymize your personal data so that it can no longer be associated with you, and use this indefinitely, without further notice.

 

What marketing communications do we send?

Communication with Individuals

We will only send marketing communications to you, as an individual, if you have consented to us doing so.

To receive marketing or promotional communications, you can opt in by checking the relevant box located on the form on which we collect your data.
 

Communication with Businesses

We process your data within the scope of an existing business relationship with you or your company because:

• We have a contract with you (or are considering entering into a contract with you). In this case, the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship; or

• It is in our legitimate interests for the conduct of our business activities (for example, to communicate with you in a ‘business to business’ capacity in order to promote our products and services that we believe will be of interest to you or your company). In that regard, we may also obtain contact information from public sources, including content made public on social media platforms, to make initial contact with a relevant individual at a client or other company; or

• You consented to receive our marketing communications via email as an individual at our clients/companies.
  In this case, we will send you marketing communications to develop or maintain a business relationship in accordance with applicable electronic and marketing communications laws. These communications may include web beacons, cookies and similar technologies that allow us to know whether you open, read or delete the message, and links you may click on.
  We will usually offer you a check box on the forms we use to collect your personal data. If you agree to receive the communications, you must click on the box.
   

How to unsubscribe?

In any case, where we send marketing communications to you via email, you may opt out of receiving any further marketing communications by clicking on the ‘unsubscribe’ or ‘opt-out’ function at the bottom of the marketing email. You can also exercise your opt-out right at any time by filling out the applicable form in the section “Getting in touch with us” below.
 

Please note that it may take up to 30 days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a month after you make your request. Your opt-out will not affect transactional/service emails from us, such as password reset emails or notifications of updates to our terms. You will still receive these as part of your services.
 

Do we use artificial intelligence?

Yes, we do use artificial intelligence tools for business processes and as part of providing our services. However, these tools are only used to support our staff, not to make decisions on their own. This means that we do not use automated processing to make decisions that have any legal effect or similarly significant effect on you.
 

Do we share your data with third parties?

We share personal data with a carefully selected list of trusted business partners to provide our services, and to fulfil our contractual obligation to our customers for the purposes set out above.
 

The table below outlines the category of third parties we may need to share your personal data with, and business purpose for doing so. We will obtain your consent to any disclosure of your personal data where required by law.
 

RECIPIENT REASON FOR SHARING
 

Service Providers

To enable third parties to provide services to you on behalf of The Handa Group as necessary:
• administrative and operational work in support of our relationship with you,
• IT providers to host or support our IT systems.

• Corporate Transaction Partners and related professional advisors
 

In connection with the sale, assignment or other transfer of all or part of our business.
 

Government authorities or law enforcement

If we in good faith believe we are compelled by any applicable law, regulation, legal process or government authority, or where necessary to exercise, establish or defend legal rights, including to enforce our agreements and policies.

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Do we transfer or store your data outside of your home country?

For the purposes described above, we may have to transfer personal data outside of your country of residence to office in a jurisdiction that does not have an adequacy decision from the outside of the United States. We will always ensure that there is a legal basis for this transfer and that we have appropriate safeguards in place so that personal data is treated in a manner that is consistent with and respects the United States and other applicable laws and regulations on data protection.
 

What are your rights regarding your personal data?

Under applicable data protection laws, you may have some of the following rights:

• Right to be informed about collection or disclosure of your personal data

• You have the right to be informed of the categories of personal data that we collect about you as well as the categories of sources from which the personal data was collected.

• You also have the right to be informed of the business or commercial purposes for which we use and disclose your personal data as well as the categories of third parties with whom we share that personal data, as mentioned in this Privacy Notice.

• Right to access and obtain a copy of your personal data

You have the right to request to have access to the personal data that we collected about you and obtain a copy of them under certain circumstances.

 

• Right to correct your personal data

If you can demonstrate that the personal data we hold about you is not correct, you can ask that this information is updated or otherwise corrected.

 

• Right to be forgotten or to delete personal data

In certain circumstances, you have the right to have your personal data deleted. You may make such a request at any time, and we will evaluate if your request should be granted. However, this right is subject to any legal obligations we may have to retain data. For situations where, in accordance with the law, we determine that your request to have your personal data deleted must be granted, we will do so within the time limit set by the applicable data protection laws.

 

• Right to restrict or object to the processing of your personal data

In certain circumstances, you have the right to obtain restriction of the processing of your personal data, or to object to certain processing thereof on grounds relating to your situation.

 

• Right to data portability

This only applies to the information you have given us. You have the right to ask that we transfer the information you gave us from one organization to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering a contract and the processing is automated.

 

• Right to opt out from marketing communications and newsletters

Where we send marketing to you, you may opt out by using the ‘unsubscribe’ function or submitting the applicable form in the section “Getting in touch with us” below.

 

• Right to withdraw consent

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

• Right to lodge a complaint

You have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your personal data has arisen.

You are not required to pay for exercising your rights.

If you want to exercise any of your rights, please fill out the applicable form in the section “Getting in touch with us” below.
 

Data Security

We maintain commercially reasonable security safeguards designed to protect the personal data we collect against unauthorized use, disclosure, alteration or destruction. Although we aim to protect the security and integrity of the personal data we collect, we cannot guarantee or warrant that any information, during transmission through the Internet or while stored on our system or otherwise in any case, is 100% secure from intrusion by others. If you have reason to believe that your interaction with us is not secure or that data has been compromised, please immediately notify us of the problem by contacting us using the contact information below.

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Children’s privacy

Our Website is designed and intended for adults. By accessing and/or using our Website, you represent that you are a legal adult. If you are not a legal adult, you must have your parent or legal guardian access and use the Website for you. If you want to purchase any goods or services that may be offered on our Website, such purchase(s) must be made by your parent or legal guardian on your behalf. 
 

Residents of the United States

Please see our California Privacy Notice at Collection, and California & Other US State Privacy Rights sections.

 

How do we handle changes to this Privacy Notice?

The terms of this Privacy Notice may change from time to time. We shall publish any material changes to this Privacy Notice through appropriate notices either on this Website or contacting you using other communication channels.

 

Getting in touch with us

If you have questions about data protection or if you wish to contact us, or to exercise any of your rights related to your personal data contact us via our CONTACT US page on thttps://www.thehandagroup.com