Our Commitment to Your Privacy
Hult Ashridge (“Hult Ashridge”, “we”) are committed to protecting the privacy of our potential and existing customers and participants of our programs.
The Hult Ashridge privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined below) collected or submitted through our website [https://www.hultashridge.com]; through our official social media pages; through other online or offline channels; or through our online coaching platform, as further described below (collectively the “Hult Ashridge Products”). This policy describes what kind of information about you that we process within the Hult Ashridge Products, how we receive it, how it is used, how it is shared and what measures have been taken to protect your personal data. We also describe which statutory rights you have regarding your personal data.
Controller and Processor
Where we make decisions on how personal information is used in connection with our service, EF Corporate Education Limited,22 Chelsea Manor St, London is a separate controller for the processing of your personal data. This applies for example when we process Personal Data to market our services to you as representative of a company or an organization (“Customer”); to protect our own legitimate interests; if you register for a newsletter; to process contract and billing information; to manage cookies or if we are legally obliged to process data (e.g. to pass on data to an investigative authority).
Where you take part of the Hult Ashridge Products through an agreement between us and your employer (our Customer), we exclusively process your personal data as a data processor on behalf of the Customer and in accordance with the Customer's written instructions. If you have any questions about the processing we undertake on behalf of your employer, please contact your employer (i.e. our Customer) that has offered the Platform to you and is the data controller of the data provided to us.
Personal Data
“Personal Data” is information or pieces of information that could allow you to be identified. On behalf of the Customer, we process the following personal data that you have provided to the Customer or that we collect when you use the platform.
This may include:
Name and contact details (e.g. postal and email address, telephone number)
Country of residence
Job-related information: job role, gender, age, length in role, years of experience, role level, function, sector, location
Program placement details (e.g. language level, industry, occupation, gender)
Study history and results
Psychometric responses
If you take a heart rate monitoring test: Name, email address, date of birth, telephone number, height and weight, gender, fitness level, job classification, relevant medication, medical history, diary entries about day-to-day activities, biometric data, HRC reports
To provide reports to Customer: User ID, name and email address, client/org name, content ID, URL, keywords, metadata, date, time, duration, completion status of psychometrics, nano courses, quizzes, cookie, learning records
If you book accommodation with us: Passport data
Payment details
Where we process data as a separate data controller, we may collect the following Personal Data about you:
Name and contact details (e.g. postal and email address, telephone number)
Country of residence
Job-related information: job title or role, client organisation business sector, previous experience and expertise
Technical information, e.g. screen/username, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data and location data, page views and website navigation
Other information you provide during a phone-or video call or a chat, and recordings and/or transcripts of such calls or chats
How do we collect Personal Data?
We collect Personal Data in a variety of ways:
Directly from you: Information is collected directly from you, for example:
Offline: We collect Personal Data from you offline, for example when you contact customer service or sales staff, or provide information to us in writing.
Online: We collect your Personal Data through the Hult Ashridge Products, for example when you sign up for our online coaching platform. We also collect Personal Data:
Through cookies. Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. For detailed information about the cookies we use and the purposes for which we use them, please see our cookie policy.
Through your use of a mobile application. When you download and use one of our mobile applications, and to the extent allowed by your privacy settings in the application, we track and collect mobile application usage data, such as the date and time the mobile application on your device accessing our servers and what information and files have been downloaded to the mobile application based on your device number, as well as statistics on malfunctions and crashes that the users experience.
Through your device. Provided that you have enabled that function on your device, we collect the physical location of it to provide you with personalized location-based service and content. Read more about such services under “How do we use Personal Data?”
From your employer. In order to set up your Hult Ashridge Products account or take a survey, your employer may provide us with your contact and company details.
From other sources. We may receive your Personal Data from other sources, such as public databases; social media platforms, including but not limited to LinkedIn; from people with whom you are connected on social media platforms, as well as from other third parties. Furthermore, we use cookies to track members of social media networks as further explained in our cookie policy.
If you browse our sites. We may also collect information about your use of our Platform through your browser to trace activity on our sites, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the Service you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you use the Platform, along with the time of the visit and the page(s) that were visited. You can read more about collection of your IP address and other browsing data in our cookie policy.
How do we use Personal Data?
On behalf of the Customer, we process your personal data for the purposes described below:
To provide you with the information and services that you or the Customer has requested, for customer service, administrative services or as otherwise necessary to perform the contract between the Customer and us or as further described in this policy.
To book and schedule coaching, action learning and to conduct assessments.
To create a user account and give access to the Hult Ashridge Products.
To provide customer service or send service-related information, via various channels such as SMS, messenger services, chat bots or email.
To track progress and give feedback to the Customer about the services. For most part, the personal data will be anonymised before used for such purpose.
To provide psychometric testing and results.
To process reports and feedback and provide heart rate monitor services.
To book accommodation.
To manage payment for your program or your accommodation.
As a separate data controller, we process Personal data:
To manage our organisation’s relationships and interactions with the Customers and potential Customers.
For statistical purposes, system maintenance, backup, calculating usage levels, and helping diagnose server problems with the Hult Ashridge Products, for business development as well as to ensure that the Hult Ashridge Products function properly.
Where relevant, to establish, exercise or defend legal claims;
To detect, investigate or prevent information security incidents, fraud, misrepresentation, security incidents or crime;
To meet applicable legal, regulatory and compliance requirements.
To demonstrate a live class in the coaching platform to potential customers
To manage payments
If you have given your consent:
To analyse and improve our offers by identifying usage trends, determining the effectiveness of our Hult Ashridge Products and tailoring the Hult Ashridge Products experience and content based on your past activities.
To market our products and services, including special promotions based on your interests, for example through email marketing solutions such as Pardot management software which maintains mailing lists and schedules and modifies email messages based on what recipients read, click-on or forward, or through other channels such as SMS, other instant messenger services or chat bots, telephone calls with operator (so-called telemarketing) or traditional mail. All such communication will include a clear unsubscribe link or offer another opt-out function.
To provide you with personalied location-based services and content through the use of your device’s physical location.
For the transmission and communication to third-party companies or other Hult Ashridge companies for their marketing purposes, including direct marketing activities and telemarketing.
To analyze our interactions to improve our sales process and quality control.
How do we share Personal Data?
We share your Personal Data as described below and in this Privacy Policy, and as permitted by applicable law:
With the Customer: as necessary to provide access to and use of the Hult Ashridge Products according to the agreement between the Customer and us.
Third party service providers: We share Personal Data with third parties in connection with the delivery of services to you and the operation of our business, for example, providers of IT systems in order to manage customer relations; providers of software and services for digital marketing automation and analytics; for customer service, business analytics, fraud prevention and compliance services and to serve you with advertising tailored to your interests.
Business partners: We may share your Personal Data with business partners, for example if we are promoting a program or offer a service or product in conjunction with a third-party business partner or when we use local sales agents that promote the sales of our services in your country of residence. In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice.
Corporate transactions: In the event that our business is sold or integrated with another business, your Personal Data may be disclosed to our advisers, a prospective purchaser and any prospective purchaser’s advisers and will be passed to the new owners of the business.
Legal rights and obligations: We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
International Data Transfers
Hult Ashridge has business activities in several different countries, and your Personal Data may be shared with affiliates of Hult Ashridge, or other recipients as described above having a need to receive such data for the purpose of performing the Platform you have requested, or according to this policy. Such recipients may be located outside your own country, including countries outside the EEA/UK that do not ensure the same level of protection as the country where you are domiciled. Unless the European Commission has decided that a country ensures an adequate level of protection for personal data, Hult Ashridge will use contracts based on the European Commission’s standard data protection clauses for international transfers of personal data to ensure compliance with applicable law. You have a right to ask us for a copy of the standard data protection clauses (by contacting us as set out in the Contact Us section below).
On what do we base our right to collect and use Personal Data?
When we process Personal Data on behalf of the Customer, as a processor, we do so to perform the contracted services with that Customer.
For other processing, we have documented the lawful bases for our processing activities in Annex 1.
On some occasions, we process your Personal Data on the basis of your consent (for example, when you agree that we may set cookies other than those that are strictly necessary, or opt-in to receive marketing communications). Where we process data based on consent, your consent is revocable by you at any time.
The processing of some of your Personal Data is necessary in order to provide services to you pursuant to the agreement that you or your employer enters into with us. Without this information, we would not be able to provide certain services to you.
On other occasions, we process your data when we are required to do so by law (for example, if we are required by court order or any applicable law to process data).
We also process your Personal Data when it is in our, or a third party’s, legitimate interests to do so, provided that your data protection rights do not override these interests. An example is to do marketing of products or services similar to the one(s) you have already purchased from that same legal entity. Where we are not relying on consent, legal requirements or contractual necessity, we process your Personal Data for the legitimate interests as described in this Policy.
Security
We use appropriate organiational, technical and administrative measures to keep the Personal Data under our control accurate and up-to-date, as well as to protect the Personal Data against unauthorised or unlawful processing and the accidental loss, destruction or damage of the Personal Data.
How long do we store personal data?
When you have registered an account with us, we may keep your Personal Data for two (2) years after the expiry of your account, in order to be able to provide you the possibility to re-activate your account, should you or your employer decide to purchase additional courses from us, or otherwise for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been communicated.
When you represent a Customer of ours, we will keep limited parts of your Personal Data which are necessary for marketing for a maximum of 5 years after your last interaction with us, or until you withdraw your consent or object to further processing, whichever is earlier.
Sensitive Data
We do not generally seek to collect any sensitive Personal Data, unless required to be part of an assessment/program. Sensitive Personal Data is for example data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or medical condition, criminal background or trade union membership. In certain situations, this might however be necessary (for example in order to provide you with the services and products you have ordered). Where we are the controller for such processing, we will make sure that we receive your explicit consent or other legal basis for such processing and where we are processing this data on behalf of a Customer, the Customer is responsible for obtaining your consent. We will treat this information securely.
Updates To This Privacy Policy
Our Privacy Policy may change from time to time. We will not significantly reduce your rights under this Privacy Policy without informing you. We will post any Privacy Policy changes on this page and, prior to implementing such changes, we will provide a more prominent notice. Where required by law, we will seek your prior consent to any change.
Your Rights
We respect your rights to access and control your information and will respond to requests in according with applicable privacy and data protection legislation. We may ask you to verify your identity and to provide other details to help us to respond to your request.
Depending on the lawful basis for processing upon which we rely, you have a right to:
request access to your Personal Data;
request that we correct or complete Personal Data that is inaccurate or incomplete;
request that we erase your Personal Data, which we will do where required by applicable privacy and data protection legislation;
restrict our processing of your Personal Data, in certain circumstances;
request that we provide you with copies of your Personal Data in a machine-readable format or transfer it across different platform;
object to certain types of processing, including where we process your Personal Data on the basis of our legitimate interests and for direct marketing purposes; and
where we have asked for your consent to process your data, to withdraw this consent.
These rights are limited in some situations under applicable privacy and data protection legislation – for example, where we or the Customer can demonstrate that it is under a legal obligation or have other legitimate grounds to process your data.
Where Hult Ashridge is the data controller, you can exercise those rights by contacting us as set out in the “Contact Us” section below. Where Hult Ashridge is processing your data as a data processor, you must contact the Customer to assert these rights.
However, if you have unresolved concerns you also have the right to complain to your local data protection authority.
Automated Decision-Making
If you have given your consent to marketing, Hult Ashridge may collect Personal Data for the purpose of profiling in order to serve promotional information tailored to your interests, for example to analyse or predict aspects concerning that your economic situation, personal preferences, interests, behaviour, approximate location or movements. This type of profiling does not produce any legal effects on you.
Hult Ashridge may record and analyse sales calls with you with help of machine learning technology, for the purpose of quality control and to improve the sales performance. Information from such calls, for example tone and key words are also combined with other personal data we have collected in connection with our communications with you, such as meeting attendance, and meeting notes. This type of processing does not produce any legal effects on you.
Contact Us
If you would like to have a copy of the information Hult Ashridge holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact us at our address above.
If you have complaints about our handling of your Personal Data, please first contact our contact our DPO here. You also have a right to contact the supervisory authority in the country where you live.
