Hyphen cares about privacy and protecting all Personal Data handled by us.
This policy describes how and why we use your Personal Data, the lawful basis on which we use your Personal Data and what measures we take to protect it. It also provides information on how to exercise your rights in connection with our Processing of Personal Data.
This Policy provides information on how we handle Personal Data when you communicate with us, use the Services or visit our website, joinhyphen.com (together the Functions).
Applicable Law refers to the legislation applicable to the Processing of Personal Data, including the UK GDPR, supplementary national legislation, as well as practices, guidelines and recommendations issued by the Commissioner or other relevant regulatory authority.
Commissioner means the Information Commissioner's Office (the UK regulator for data protection issues).
Controller is the company/organisation that decides for what purposes and in what way personal data is to be processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.
Data Subject is the living, natural person whose Personal Data is being processed.
Personal Data is all information relating, directly or indirectly, to an identifiable natural person.
Processing means any operation or set of operations which is performed on Personal data, such as storage, modification, reading, handover and similar.
Processor is the company/organisation that processes Personal Data on behalf of the Controller and can therefore only process the Personal Data according to the instructions of the Controller and the Applicable Law.
The Services We provide a talent development platform that teaches junior talents critical business skills.
UK GDPR means the retained EU law version of the General Data Protection Regulation ((EU) 2016/679).
The definitions above shall apply in the Policy regardless of whether they are capitalised or not.
The information in this Policy covers Personal Data Processing for which Hyphen is the Controller. As a Controller we are responsible for the Processing for which we decide the purpose of ("the why") and the means of the Processing (what methods, what Personal Data and how long the Personal Data is stored). The Policy does not describe how we Process Personal Data in the role of a Processor (i.e. when we process Personal Data on behalf of our customers).
We provide a talent development platform for businesses. We therefore need to process your personal data so that we can create a user account for each individual learner and enrol you into our training program.
We have a responsibility to describe and demonstrate how we fulfil the requirements that are imposed on us when we Process your Personal Data. This section aims to give you an understanding of what type of Personal Data we Process and the lawful basis on which we Process that Personal Data.
In order for us to be able to process your Personal Data, it is required that we have so-called legal basis for each process. In our business, we process your personal data mainly on the following grounds:
Consent - Hyphen may process your personal data after you have given your consent to the Processing. Information regarding the processing is always provided in connection to the request of consent.
Performance of a contract - The Processing is necessary for the performance of a contract entered between us and the Data Subject, or to prepare for entering into an agreement with the Data Subject.
Legitimate interest - Hyphen may process Personal Data if we have assessed that a legitimate interest overrides the interest of fundamental rights and freedoms of the Data Subject, and if the processing is necessary for the purpose in question.
We will keep your Personal Data no longer than is necessary for the purpose for which it was collected. Depending on the lawful basis on which we justify the Processing, this may: a) be regulated in a contract, b) be dependent on valid consent, c) be stated in legislation or d) be based on a legitimate interest assessment (LIA). In the list below, we indicate, where possible, how long the Personal Data will be stored and the criteria used to determine the storage period.
We never store your Personal Data longer than necessary and delete Personal Data regularly. Hyphen also takes reasonable actions to keep the Personal Data up-to-date and to delete outdated and otherwise incorrect or redundant Personal Data.
The main purpose of the Processing undertaken by us is to provide, carry out and improve our services to you. There are several different reasons why we may need to collect, manage and save your data.
We mainly Process the following types of Personal Data:
We collect your Personal Data in a number of different ways. We mainly collect your Personal Data:
You are the one in control of your Personal Data and we always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.
Access (art 15) - You always have the right to receive information about the Processing of data that concerns you. We only provide information if we have been able to verify that it is you that are requesting the information.
Rectification (art 16 GDPR) - If you think that any of your Personal Data that we process is incorrect, let us know and we will fix it!
Erasure (art 17 GDPR) - Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.
Objections (art 21 GDPR) - Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don't worry - in such case, we will review our legitimate interest assessment. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data. If you object to direct marketing, we will immediately delete your personal information without making an assessment.
Restriction (art 18 GDPR) - You can also ask us to restrict our Processing of your Personal Data:
Data portability (art 20 GDPR) - We may provide you with the data that you have submitted to us or that we have received from you in connection with a contract that we have entered with you. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manager.
Withdraw consent (art 7 GDPR) - If you have given consent to one or several specific Processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future Processing of Personal Data and not for Processing that has already taken place.
If you wish to exercise any of the rights set out above, please email email@example.com.
In order to run our business, we may need help from others who will process Personal Data on our behalf, so-called Processors.
In cases where our Processors transfer Personal Data outside the UK, we have ensured that the level of protection is adequate, and in compliance with Applicable Law, by ensuring that one of the following requirements is fulfilled:
We have entered into Data Processing Agreements (DPAs) with all our Processors. Each DPA sets out, among other things, how the Processor may process the Personal Data and what security measures are required for the Processing.
We may also need to disclose your personal information to certain designated authorities in order to fulfill obligations under applicable law or legally binding judgements.
Hyphen does not sell your Personal Data to third parties and of course we do not share your Personal Data with just anyone. However, in some cases we may need to share your Personal Data with selected third parties. If so, we make sure that the transfer happens in a secure way that protects your privacy. To follow are categories of recipients with whom we may share your data.
This California Privacy Notice sets forth the disclosures and rights for California Consumers regarding their Personal Information, as required by the California Consumer Privacy Act of 2018 ("CCPA"), the California Privacy Rights Act of 2020 ("CPRA"), and any implementing regulations adopted thereunder. Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA and CPRA and the associated regulations, unless otherwise defined.
California Consumers have the right to request:
Right to Know: that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you ("Right to Know");
Right to Delete: that we delete the Personal Information we collect about you ("Right to Delete");
Right to Correct: that we correct inaccurate Personal Information we hold about you (“Right to Correct”),
Right to Opt-Out of Sharing: to opt-out from the sharing of your Personal Information and Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”),
Right to Opt-Out of Sale: to opt-out from the sale of their Personal Information and Sensitive Personal Information (“Right to Opt-Out of Sale”), and
Right to Limit The Use and Disclosure of Sensitive Personal Information: that we limit the use or disclosure of your Sensitive Personal Information to purposes set forth in the statute, including that use which is necessary and anticipated to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services (“Right to Limit The Use and Disclosure of Sensitive Personal Information”), all subject to the meanings and exceptions set forth in the CCPA and CPRA.
In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.
If you wish to exercise any of the rights set out above, please email firstname.lastname@example.org.
You may designate an authorized agent to make a request under the GDPR or CCPA on the consumer’s behalf by emailing us from the email address associated with your account, indicating: your name, the fact that you would like to indicate an authorized agent, the name of your authorized agent, and the email address of your authorized agent.
If you are an authorized representative submitting a request on a user’s behalf, please email your request to email@example.com per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.
Where possible, we will respond to a verifiable consumer request within forty-five (45) days of its receipt; however, if we require more time, we will inform you of the reason and extension period.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Hyphen has taken technical and organisational measures to ensure that your Personal Data is processed securely and protected from loss, abuse and unauthorised access. Organisational measures are measures that are implemented in work methods and routines within our organisation. Technical measures are measures implemented through technical solutions.
Organisational security measures:
Technical security measures:
If you think that we are not Processing your Personal Data correctly, even after you have notified us of this, you are always entitled to submit your complaint to the Commissioner. You can contact the Commissioner on 03031231113 or via email https://ico.org.uk/global/contact-us/email/.
More information about our obligations and your rights can be found at https://www.gov.uk/government/publications/data-protection-rights-for-data-subjects/data-protection-rights-for-data-subjects
For California Residents: If you believe our business has violated the CCPA, you may file a consumer complaint with the Office of the Attorney General.
We reserve the rights to make changes to this Policy. In the event that the change affects our obligations or your rights, we will inform you about the changes in advance so that you are given the opportunity to take a position on the updated policy.
Please contact us if you have questions about your rights or if you have any other questions about how we process your personal information: firstname.lastname@example.org. Alternatively, you can get directly in touch with our appointed Data Protection Officer, Oliver Mark Beach under email@example.com.