Privacy Policy
Last Updated: June 1, 2024
Introduction
This Privacy Policy (“Policy”) describes how we at HRP Group and its subsidiaries (“HRP Group,” “we,” or “us”) collect, maintain, use and disclose personally identifiable information (“PII”) about you through your use of our website (www.hrpgroup.com) or any other online platform that links to this Policy (collectively referred to as the “Site”).
This Policy does not apply to information contained in our Investor Portal, however, which is accessible only to current and prospective investors who have created an account with us. (See Login - Juniper Square.) The Investor Portal, which is hosted by Juniper Square, has a separate privacy policy and is not subject to this Policy. This Policy also does not apply to any PII we collect regarding job applicants or employees. We provide a separate Privacy Notice to job applicants and employees.
For purposes of this Policy, we define “PII” about you broadly, to include not only information such as your name or email address, but also any other information that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
Please be sure to read this Privacy Policy before using the Site, as you are deemed to consent to the collection, use and disclosure of information in accordance with this Privacy Policy when you use the Site. HRP Group reserves the right to revise this Privacy Policy at any time at our sole discretion. If we modify the Privacy Policy in a material way, we will post a notice on the Site’s landing page to let you know that the Policy has been so modified. Your use of the Site following such modification (or following any nonmaterial change) constitutes your acceptance of the revised Privacy Policy then in effect.
How Does HRP Group Collect your PII and What Types of PII Does It Collect?
HRP Group collects PII about you when you actively provide it to us, such as by filling out our “Get In Touch” form on the Site. Currently, the Site does not invite you to provide PII through any other forms or channels and thus for many Site users, the only PII we will collect is your name and email address as well as browsing history.
As noted above, if you are an investor, we will collect certain financial information about you, but not through the Site. If you are a business partner, we will collect from you the PII we need to keep in contact with you. We also may collect PII about you from other sources, such as the Internet, including social media websites or other forms of media; and other organizations or individuals as permitted under applicable law.
Listed below are the types of PII that we might collect about you from the sources noted above. Each type of information listed below is PII only if the information identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. As noted, we collect only a very small subset of these types of PII through the Site.
Identifiers such as: your name, Internet Protocol (IP) address, email address, or other similar identifiers.
“Customer Records” information (some of which may be identifiers or professional/employment-related information as well), such as your name, signature, address, telephone number, driver's license or state identification card number, bank account number, credit card number, debit card number, or any other financial information.
Commercial information, such as records of investments made or considered, products or services purchased or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity, such as browsing history, search history, information on your interaction with our Site or an advertisement. This may include hardware and browser information of your computer or other online device.
Geolocation data, such as the physical location of the device you use to connect with us online.
Sensitive personal information, such as financial account information if you create an investment account with us.
Sensory data, such as audio, electronic, visual, or similar information.
Professional or employment-related information, such as your current or past job history.
Personal characteristics that are related to classifications legally protected from discrimination, such as race, national origin, ethnicity, marital status, age and gender.
Inferences drawn from other PII, such as a summary we might make based on your apparent preferences, characteristics, predispositions, or behavior.
Our Business Purposes for Collecting PII; How We Use the Information
We may use the PII we collect from you for a variety of purposes permitted by law, including:
To communicate with you, including in response to your inquiries and to fulfill your requests;
To provide you with information about our products and services;
To improve the content of the Site, including to customize the Site to your preferences;
For our data analysis, product development, and marketing and research purposes;
To prevent fraud, including by confirming your identity;
To maintain and upgrade the security of any data or information collected;
For risk management and compliance purposes, including to comply with law enforcement and other legal processes;
For any other purpose you may agree to at or before the time the personal information is collected from you.
When We May Disclose Personally Identifiable Information
We may disclose the PII that we collect as follows:
To our service providers, whom we engage to assist us with technology support, operational support and other forms of assistance, and whom we bind by contract to protect the confidentiality and security of the PII we share with them;
In the event of a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our company or its assets, to the proposed or actual acquiring party or assignee;
With respect to PII about your Internet or other similar network activity, to our business partners for purposes of cross-context behavioral advertising, unless you opt out of such sharing. This enables us to deliver digital advertising that is likely to be relevant to you, as described further in the “Online Tracking” section below.
As we believe to be appropriate: (i) when required by applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce the terms and conditions for use of the Site, including this Policy; (v) to protect and defend our rights and property; (vi) to protect the interests of HRP Group or others; and (vii) to permit us to pursue available remedies or limit the damages that we may sustain.
For any other purpose you may agree to at or before the time the PII is shared.
Absent your consent, we will not sell your PII or provide your PII to third parties for their use for their own direct marketing purposes.
Online Tracking Information Collection, Use and Sharing
When you use the Site, we may automatically collect from the device you use to connect to the Site information such as your Internet protocol (“IP”) address, the URL of the website you just came from, and the browser version your computer is currently using. This Site may also collect information from your computer through cookies or similar tracking technologies. Cookies are small bits of information that are stored on your device’s web browser and allow a website to distinguish your device from other devices accessing that website. To learn more about cookies, please visit http://www.allaboutcookies.org.
Specifically, we use Cloudfare’s tracking technologies (see Cloudflare Cookies · Cloudflare Fundamentals docs) to enhance the functionality of the Site, and we also use Google Analytics (http://www.google.com/analytics/) to monitor the use of the Site. Google Analytics uses cookies to collect information about Site visitors in order to provide analytics services based on a user’s visits to sites across the Internet and across other mobile applications. For further information about the collection and use of data through Google Analytics, see http://www.google.com/policies/privacy/partners/. Google offers the ability to opt out from tracking through Google Analytics cookies; to learn about this, visit: http://tools.google.com/dlpage/gaoptout.
Some web browsers may transmit “Do-Not-Track” signals to the websites with which the user communicates. Our Site currently does not respond to Do-Not-Track signals because we do not track our users over time and across third-party websites.
Data Retention; Security
We will retain PII about you for the period necessary to fulfill the purposes outlined in this Policy. We endeavor to use reasonable organizational, technical, and administrative measures to protect the PII we maintain within our organization. However, any device or application connected to the Internet is susceptible to a security breach, despite the level of administrative, technical, and physical safeguards employed. By using our Site, you accept this risk.
Updates to your PII
If you would like to update PII that you have provided to us, you may contact us through one of the means listed in the “How to Contact Us” section at the end of this Policy.
VIII. Site Use Limitations and International Data Transfers
Our Site is not directed to users under the age of 13 and we do not knowingly collect PII online from any person we know to be under the age of 13.
Our Site is designed for users from, and are controlled and operated by us from, the United States. By using our Site, you consent to the transfer of your information to the United States, which may have different data protection rules than those of the country in which you are located.
IX. Links to Other Websites
Our Site may provide links to third-party websites. When you click on one of these links, you will be accessing content that is not subject to this Policy. We are not responsible for the information-collection practices of the other websites that you visit, and advise you to review their privacy policies before you provide them with any PII.
X. California Residents’ Privacy Rights
If you are a resident of California, you have certain privacy rights under the California Consumer Privacy Act (“CCPA”). We honor those rights, as described below, and we are prohibited by law from discriminating against you for exercising any of those rights.
Right to Know
If you are a California resident, you have the right to know what PII we have collected about you, why we collected it, and the categories of third parties (excluding service providers) with whom we have shared the PII during the past 12 months. (See below on “How to Submit a Request.”) you may request that we provide a description of the categories of PII we have collected (a “Categories Request”) or a request for access to the specific pieces of PII we have collected (a “Specific Pieces Request.”)
If you make a Categories Request, and you do not have any type of account with us, we will need you to provide us with at least two data elements specific to you, such as your cell phone number or mother’s maiden name (depending on the data elements we already maintain about you), so that we can verify your identity. After we confirm that your request is a verifiable consumer request, we will disclose to you:
The categories of PII we collected about you.
The categories of sources for the PII we collected about you (e.g., health care providers, social media websites, government records available to the public, etc.).
Our business or commercial purpose for collecting that PII.
The categories of third parties other than service providers (if any) with whom we shared the PII.
If you make a Specific Pieces Request, we need to be sure we have verified your identity with great certainty to safeguard your privacy. In order for to verify your identity, if you do not have any type of account with us, you will need to provide to us at least three data elements specific to you, together with a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. After we confirm that your request is a verifiable consumer request, we will disclose to you the specific pieces of PII we collected about you that you requested.
Right to Request Correction or Deletion
You have the right to request that we correct any inaccuracies in the PII that we maintain about you. You also have the right to request that we delete any of your PII that we maintain. However, we are not obligated to comply with your request for deletion if we have a legal basis to retain the PII. We will not correct or delete any PII pursuant to your request unless we are able to verify that you are the individual to whom that PII pertains.
If you make a request for us to correct or delete PII, we may need you to provide us with at least two data elements specific to you so that we can verify your identity. Once we receive and confirm that your request is a verifiable request (see below on “How to Submit a Request”), we will inform you whether we have corrected or deleted (and have directed our service providers to correct or delete) your PII, or if we are declining to grant your request to correct or delete due to a legal basis for us to do so.
How to Submit a Request
To request access to or deletion of your PII as described above, please submit a verifiable consumer request to us by either:
Calling us at our Privacy Rights toll-free number: (877) 201-2557
Submitting the request through our interactive webform, at: https://hrpgroup.com/contact
You may make a request on your own behalf, and if you are the parent or guardian of a minor child, you also may make a request related to your child’s PII. If you wish to designate an authorized agent to make a request on your behalf, please provide us with a signed declaration stating that your intent is to permit that individual to act on your behalf and include such individual’s full name, address, email address, and phone number. That way we will be sure you have fully authorized us to act in accordance with the requests of that individual.
As indicated above, in order to protect your PII from unauthorized disclosure or deletion at the request of someone other than you or your legal representative, HRP Group requires identification verification before granting any request to provide copies of, know more about, or delete your PII. We take special precautions to help ensure this. We cannot respond to your request or provide you with PII if we cannot verify your identity or authority to make the request and confirm that the PII relates to you. We will only use PII collected in connection with a verifiable consumer request to verify the requestor's identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.
XI. How to Contact Us
If you have any questions regarding this Policy, please send an email to hrpinfo@hilcoglobal.com, call us at 877.201.2557, or write to us at:
HRP Group
Attention: Corporate Affairs
111 South Wacker Dr Suite 3000
Chicago IL 60606
Get in Touch
For media inquiries, please contact:
hrpgrouppress@hilcoglobal.com
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