Heritage Global Inc. (“we” or “us”) values our relationship with you and takes your privacy seriously. The purpose of this Privacy Notice is to identify how we may process, collect, store, share and use (collectively, “use”) the data that we collect from you in connection with your use of any of our websites linking to this Privacy Notice (collectively, our “Site”). This Privacy Notice also identifies your rights with respect to your personal information, all as described in more detail below.
We may update or modify this Privacy Notice at any time, by posting the amended version including the effective date of the updated version. We will announce any material changes to this Privacy Notice by posting the amended version on our website. By accessing and/or using our Site, you accept and agree to the terms of this Privacy Notice and the use of your data and personal information as described in this Privacy Notice. If you do not agree to be bound by this Privacy Notice or any subsequent modifications, you should not access or use our Site or disclose any personal information through our Site.
This Privacy Notice was last updated March 21, 2019.
Your privacy and the security of your personal information is, and will always be, important to us. We want to transparently explain how and why we gather, store, share, and use your personal information, as well as outline the controls and choices you have around when and how you choose to share personal information.
This Privacy Notice contains the following information:
How to contact us
You can update your preferences and information, or if you have any questions or concerns about our use of your personal information, by contacting us through any of the methods listed below:
The information we collect about you and how we use it
We obtain information about you and your use of our Site when you sign up to receive communications from us or visit our Site. The information we collect can include personal information (as described below) or non-personal information, which is information that does not identify or relate to an individual.
Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We collect information through any correspondence that you provide to us whether through email, mail, phone calls, or through our Site.
We do not consider personal information to include information that can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.
When and how do we collect your information?
We collect information from you both when you provide it voluntarily and also automatically when you use our Site.
What information do we collect from you? How do we use your information?
We collect information when you sign up to receive communications from us by subscribing to our email list, including your name, email address, company name, country and interest area(s). We use this information to fulfill your request to receive communications from us.
We automatically collect your device type when you use our Site in order to optimize the display of the Site on your device.
We also collect anonymized and aggregated information through Google Analytics that may be created or derived from your usage of our Site for purposes that include data analysis and improving our Site. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners
Our legal basis for using your information as described above is a legitimate basis. In relying on legitimate interests as the reason for processing your information, we carry out a balancing exercise to make sure your rights as an individual are not impacted unnecessarily.
We consider that it is reasonable for us to process your personal information for the purposes of our legitimate interests when, on balance, (a) we process your personal information only so far as is necessary for such purpose, and your rights and freedoms do not outweigh such purposes, and (b) it can be reasonably expected for us to process your personal information in this way. In most cases, the information is being processed for your benefit as well as ours.
We have a legitimate business interest in processing your personal information where:
- We need the information to respond to your inquiries or requests (g., to add you to our email list when you have subscribed); or
- We would be unable to provide our Site without processing your information.
If we wish to process your existing information for a new purpose other than as stated above, we must inform you of that further processing and provide information surrounding your information’s use as necessary to provide the Site to you and to comply with a request to be added to our email list. In addition, if we communicate with you for marketing or other promotional purposes, via email, notifications or other messages, we do so based on your consent.
Who we may share your information with
In connection with our Site, we may share your personal information with the following types of recipients and for the following reasons:
|Categories of Recipients||Reasons for sharing|
|Service providers||We use service providers to operate our software and infrastructure, in particular providers which host, store, manage, and maintain our Site, its content and the data we process. This includes our hosting and information security service providers.|
|Data analytics providers||We will share your personal information to create general data analytics regarding usage of our Site on an aggregate basis and without personal identifiers. As noted above, we use Google Analytics, a service provided by Google, Inc., to gather information about how you and other users engage with our Site. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners.|
|Law enforcement and government authorities||We will share your personal information with third parties where required by law (including to respond to valid legal process such as a search warrant or a court order), where it is necessary in connection with our Site or where we have another legitimate interest in doing so.|
|Other legal or regulatory authorities||We will share your personal information for us to comply with our legal obligations, including assessing compliance with our regulatory requirements (e.g., using user purchases in the aggregate, including revenues generated in connection with our regulatory tax requirements).|
|Buyer or successor of our business||We will share your personal information with any buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of title.|
Most, if not all, of the third parties with whom we may share your personal information are located and store your information in the United States, although some may store your information outside of the United States.
Your rights and options regarding your personal information
You have choices about how we use your personal information to communicate with you. You can opt out from receiving future marketing communications from us at any time by:
- Using the unsubscribe function in the email you receive from us; or
- Contacting us as set forth under “How to contact us” above.
You may select a “do not track” setting on your web browser. However, these features are not yet uniform, so we do not currently respond to such features or signals. Therefore, if you select or turn on a “do not track” feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Privacy Notice.
Depending on where you live, you may have the following rights with respect to your data under certain circumstances, which may include the following:
- The right to request access to your personal information and the following information regarding our use of your personal information: The purpose of such use, The categories of your personal information that we have used, and Who we have disclosed your personal information to.
- The right to request us to erase your personal information when we no longer need such data in connection with our Site.
- The right to request us to correct any inaccurate personal information concerning you. You may also update or change your information under your account settings.
- The right to withdraw consent to our use of personal information, if we are relying on consent to use your personal information.
- The right to request us to restrict our use of your personal information (e.g., suspend our use of your personal information).
- The right to object to our use of your personal information where we are not using it to perform services you have requested from us.
- The right to receive a copy of your personal information.
- The right to lodge a complaint with the supervising authority of your country.
If you want to exercise any of the rights listed above and you are a resident of a jurisdiction providing you such rights (as of May 25, 2018, residents of the European Economic Area, and effective January 1, 2020, residents of California for the first two rights listed above), please contact us through one of the methods listed in under “How to contact us” above.
How we safeguard your personal information
We have put in place appropriate security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. While we are committed to protecting your personal information, please note that information communicated over the Internet is never 100% secure. Any transmission of personal information is at your own risk.
How long we store your personal information
We may store your personal information as long as you use our Site and for legitimate business purposes.
We may store your personal information following completion of transactions with you to the extent required to comply with our legal, accounting, or reporting requirements. Additionally, we may continue to store your personal information contained in our standard back-ups.
Upon your request, we will delete or de-identify your personal information unless we are legally required or allowed to maintain such personal information.
Links to other sites and services
Our Site is not directed to children under the age of fourteen (14) years. By using our Site, you represent that you are at least fourteen (14) years old. If you do not meet this age requirement, then you must not access or use our Site.
We do not knowingly collect information from children under the age of thirteen (13) years old. If you are under the age of thirteen (13) years old, please do not use our Site and do not provide any information to us. For more information about the Children’s Online Privacy Protection Act (“COPPA”), which applies to websites that direct their services to children under the age of thirteen (13), please visit the Federal Trade Commission’s website https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions.
If you think we have collected information from a child under the age of thirteen (13) through our Site, please contact us through one of the methods listed under “How to contact us” above. If we learn that we have collected the information of a child under the age of thirteen (13) years old, we will take reasonable steps to delete such information.
Governing law and jurisdiction
This Privacy Notice shall be construed and governed under the laws of the United States and State of California (without regard to rules governing conflicts of laws provisions). You agree that venue for all actions, arising out of or relating in any way to your use of our Site, shall be in federal or state court of competent jurisdiction located in San Diego County, California, within one (1) year after the claim arises. Each party waives any objections based on forum non conveniens and waives any objection to venue of any action instituted hereunder to the extent that an action is brought in the courts identified above.
Special notice to non-U.S. users regarding data transfers
We store your personal information in the United States or other locations outside your home country. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.
If you are located in a country outside the U.S. and submit personal information to us, you consent to the general use and disclosure of such information as provided in this Privacy Notice and to the transfer and/or storage of that information to the U.S. and other countries outside your home country.