Effective Date: 10th April 2023
High Trail, Inc. (“the Company”, “we”, “our” or “us”) is committed to protecting the privacy and security of your personal information.
This Privacy Policy describes how the Company may use and disclose information that we may collect about you through our websites. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.
This Privacy Policy covers:
1. Information We Collect About You
2. How We Collect Your Personal Information
3. How We Use Your Personal Information
4. Sharing Your Personal Information
5. Data Security
6. Your Rights in Relation to Your Personal Information
7. Other Important Information
8. California Information Sharing Disclosure
1. Information We Collect About You
For the purposes of this Privacy Policy (“Policy”), “personal information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, regardless of whether it is held in paper, electronic or any other format.
We collect, maintain, and use different types of personal information in the context of our relationship or potential relationship with you. The following provides examples of the type of information that we collect from you and how we use the information.
| Context | Categories of Information | Primary Purpose for Collection and Use of Information |
|---|---|---|
| Contact Information and other Identifiers | We collect items such as name, title, work and/or personal email address, and telephone numbers (including your mobile number). We may also collect other identifiers such as account name, date of birth, Social Security number, driver’s license number, photograph, passport number, unique personal identifier, online identifier, account name, or other similar identifiers. | We have an interest in communicating with our clients concerning normal business administration such as projects, services, and billing, and to communicate with applicants and potential applicants regarding general questions and the application process, including reminders about interviews and documentation we may need to collect. We may use your personal information to respond to your requests for information relating to our services, staffing and employment opportunities; to communicate with you, including sending messages about products or service-related issues. We may disclose your personal information to the third parties to whom you direct. |
| Cookies and First Party Tracking | We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. | We have an interest in making our website operate efficiently. |
| Cookies and Third Party Tracking | We may participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. | We have a legitimate interest in engaging in behavior-based advertising. |
| Email Interaction | If you receive email from us, we use certain tools to capture data related to when you open or interact with our messages. | We have an interest in understanding how you interact with our communications to you. |
| Feedback / Support | If you provide us with feedback or contact us for support, we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. | We have an interest in receiving, and acting upon, your feedback or issues. |
| Mailing List | When you sign up for one of our mailing lists we collect your name, email address or postal address. | We share information about our services with individuals that consent to receive such information. We have an interest in sharing information about our services. |
| Website Interactions | We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. | We have an interest in understanding how you interact with our website to better improve it. We also have an interest in detecting and preventing fraud. We may use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information. |
| Web Logs | We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. | We have an interest in monitoring our networks and the visitors to our websites. |
2. How We Collect Your Personal Information
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, online job sites, or other publicly available sources. If you provide us with a mobile phone number, you agree to receive text messages from the Company. Text messages will be sent to keep you updated on information relevant to the provision of our services, which may include reminders.
3. How We Use Your Personal Information
In addition to the purposes and uses described above, we use your personal information for the following purposes:
• To communicate with you and provide services to you, your business or employer;
• To conduct analytics;
• To respond to inquiries related to services, employment opportunities, or other requests;
• To send marketing and promotional materials, including information relating to our services;
• To comply with laws or regulations to which the Company is subject;
• To manage and comply with our contractual obligations and agreements;
• To detect and prevent fraud or crime;
• To enforce, exercise, or defend legal claims;
• To investigate potential misconduct or conduct internal audits; and
• For internal administrative and human resources purposes, as well as to manage our relationships.
• To maintain commercial insurance policies and coverages
• To operate and develop our Site
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. Our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our general interest in conducting our business. Note that this Privacy Policy may be updated to notify you of additional purposes for which we process your personal information. If High Trail makes any substantial or material changes to this Policy, we will provide notice on the Site. You are encouraged to review this Policy periodically for updates and changes. Changes will be effective immediately upon posting to the Site.
4. Sharing Your Personal Information
In addition to the specific situations discussed elsewhere in this policy, we share your personal information in the following situations:
• Affiliates and Business Transfers. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control) in the course of our normal business operations. If another company acquires, or plans to acquire, any part of our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
• Legal or Regulatory Requests and Investigations. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws or regulations. We may also need to share your personal information with tax authorities, courts, regulators, the police and other governmental authorities where we are required or permitted to do so by law.
• Other Disclosures with Your Consent. We may ask to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy.
• Protection of the Company or Others. We may share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
• Third-Party Service Providers. We may share your information with service providers. Among other things, service providers may help us to administer our website, provide technical support, and assist in the fulfillment of services.
5. Data Security
We maintain reasonable physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to help protect your personal information against loss, unauthorized access or disclosure, modification, or destruction. While we use reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any privacy or security event relating to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
6. Your Rights in Relation to Your Personal Information
You can make the following choices regarding your personal information:
• Notification of Employment Opportunities. You may choose to provide us with your email address for the purpose of allowing us to send employment or candidate opportunities to you. You can stop receiving these emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive these emails, we may still send you service-related communications.
• Request access to your personal information. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. There may be instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information we hold about you.
• Request deletion of your personal information. You may request that we delete your personal information. There may be instances where applicable law or regulatory requirements allow or require us to refuse a deletion request. For example, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
• Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
• Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
• Right to Request Correction. You have the right, subject to certain limitations, to request that we correct any inaccurate personal information we maintain about you. Upon receipt of a verifiable consumer request, and as required by the CCPA, we will take appropriate steps to respond to your request.
• Right to Non-Discrimination for the Exercise of Privacy Rights. We will not discriminate against you for exercising any of your rights under the CCPA.
• Verifiable Requests. We reserve the right only to respond to verifiable consumer requests to Know, Delete, or Correct. A verifiable consumer request is one made by any individual who is:
o the consumer who is the subject of the request,
o a consumer on behalf of the consumer’s minor child, or
o the authorized agent of the consumer.
To verify your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information which we will only use to verify your identity, and for security or fraud-prevention purposes. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond.
If you would like to exercise any of the above rights (to the extent these rights are provided to you by law), you may:
1. Call us at 203 663 3990; or
2. Email us at info@hightrail.com.
Note that, as required by law, we may require you to prove your identity. We may conduct an identity verification by phone call, email, online portal, or in person. Depending on your request, we will ask for information such as your name, title, phone number, email address, or recent job information.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require that you verify that you provided the authorized agent permission to make a request on your behalf, as well as verify your own identity directly with us.
If you are an authorized agent, you may submit a request on behalf of an individual by calling 203 663 3990, or submitting the request to info@hightrail.com.
7. Other Important Information
The following additional information relates to our privacy practices:
• Changes To This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
• Accessibility. High Trail, Inc. is dedicated to supporting our guests, regardless of physical or cognitive ability. If you need to access this Privacy Policy in an alternative format, please contact info@hightrail.com.
• Minors. This site is not intended for use by children under the age of 13, and we do not knowingly collect or use any personal information from such children. We do not sell or share Personal Information of California residents, as those terms are defined by the CCPA, nor do we have actual knowledge that we have sold or shared the Personal Information of minors under the age of 16.
• Information for California Residents. California law indicates that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). You can find a list of the categories of information that we collect and share below. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.
• Contact Information. If you have any questions about this Privacy Policy, please contact us at: info@hightrail.com.
• Effective Date. This policy is effective as of April 11, 2023.
• Last Revised: April 11, 2023
8. California Information Sharing Disclosure
California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). We do not “sell” your personal information. The table below indicates the categories of personal information we collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself.
| Categories of Personal Information We Collect | To Whom We Disclose Personal Information for a Business Purpose |
|---|---|
| Identifiers – this may include real name, alias, unique personal identifier, online identifier, email address, account name, or other similar identifiers. | • Affiliates or subsidiaries • Clients and customers • Business partners • Data analytics providers • Internet service providers • Operating systems and platforms • Other Service Providers • Government entities, as may be required to comply with law or prevent illegal activity |
| Internet or other electronic network activity information – – this may include real name, alias, unique personal identifier, online identifier, email address, account name, or other similar identifiers. | • Affiliates or subsidiaries • Business partners • Data analytics providers • Internet service providers • Operating systems and platforms • Professional services organizations, this may include auditors and law firms • Social networks • Other Service Providers • Government entities, as may be required to comply with law or prevent illegal activity |
| Professional or employment-related information | • Affiliates or subsidiaries • Clients and customers • Business partners • Data analytics providers • Internet service providers • Operating systems and platforms • Professional services organizations, this may include auditors and law firms • Other Service Providers • Government entities, as may be required to comply with law or prevent illegal activity |