The Hogrefe assessment system collects data generated by users of the Services that are capable of identifying users and subjects of Hogrefe assessments. User interactions in Hogrefe’s assessment system are logged with a unique identifier which links back to a separate data file that includes Personal Information. User interaction data are linked to user Personal Information in order to generate test scores and/or assessment results. Score and results information and test taker identity data are primarily available to authorized users of the Hogrefe assessment system. Personal Information may be accessed by Hogrefe when users make inquiries for assistance related to an assessment administration, for the investigation of assessment system technical problems, for investigations of suspected or reported testing irregularities, and in order to deliver Hogrefe assessments.
We may use your Personal Information for the purpose for which it was provided, including without limitation for the purposes described further below.
We will collect, use, process, store, transmit, and share your Personal Information as necessary to deliver the Services and support and monitor your use of the Services, in accordance with all applicable Hogrefe policies and any agreements entered with Hogrefe that govern the use of the Services. Some of the data we collect to provide the Services are required as account security measures and user authentication data.
From time to time, we may offer our users the opportunity to participate in surveys and other special offers. If you elect to participate in these services, you will need to provide certain Personal Information.
If you contact us by e-mail or otherwise, we will use the personal information you provide to answer your question or resolve your problem. If you do not have a user account, we do not regard any information submitted by you as a question or request as private or confidential and will use and share such information in its sole discretion, as necessary for the association’s business purposes.
Hogrefe may use your personal information to contact you in the future to tell you about products, services, and events that may be of interest to you, unless you opt-out of receiving messages of this nature.
In an ongoing effort to better understand and serve the users of the site and the services, and in the service of scientific research, Hogrefe may conduct research on its users’ demographics, interests, and behavior based on usage data and other information provided by users and third parties. This data may be de-identified, compiled and analyzed on an aggregate basis, and Hogrefe may share this de-identified data with researchers, educational institutions, business partners, publications, and other third parties. This aggregate research data will not identify you or users personally.
We may use your personal information, aggregated personal information, and other non-personally identifiable information collected through the site and services to help us improve the content and functionality of the site, to better understand our users, and to improve the services.
We may use your personal information that you provide to fulfill any orders you may place for services offered by Hogrefe.
By using the Site or Services, you may provide and upload and direct third parties to provide and upload Personal Information that you expressly direct us to share with designated third parties in order to participate in Services offered by us. If you direct us to share your Personal Information with designated third parties in connection with our delivery of the Services, we will do so in accordance with your consent and direction in the scope of our delivery of the Services.
From time to time, we may establish a business relationship with other businesses that we believe to be trustworthy and have privacy practices consistent with ours ("Service Providers"). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, accounting, data analytics and data storage and management, assessment-related activities, Internet-based platforms, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, processing or disclosure. Service Providers are prohibited from using Personal Information other than as specified by Hogrefe.
We may share Personal Information and Usage Data with businesses controlling, controlled by, affiliated with, or under common control with Hogrefe. If Hogrefe is merged, acquired, or sold, or in the event of a transfer of some or all of our assets or equity, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
Hogrefe will cooperate with courts, government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other content and information about you to courts, government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to or comply with legal requests (including court orders and subpoenas), to protect the safety, property, or rights of Hogrefe or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
Please be aware that whenever you share information on a publicly available page or any other public forum on the Site or Services, others may access that information. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.
With regard to assessment data, consider that information you may wish to share for research or conversational purposes is governed by your obligations to others. Do not share Personal Information of others in any manner that could compromise the privacy of patients, students or any third party to whom you have a duty to maintain confidentiality.
We maintain physical, technical, and organizational safeguards to protect the confidentiality and security of Personal Information and other information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.
Hogrefe’s assessment services for educational institutions require the collection, processing, use, storage and disclosure of student educational records that may be governed by the U.S. Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99), including K-12 schools, colleges and universities that receive funding from the United States Department of Education. Any educational institution using Hogrefe’s assessment services authorizes Hogrefe to collect and store the data on behalf of the program for the sole purpose of Hogrefe providing the assessment services. Institutions that use Hogrefe’s assessment services are responsible for limiting access to Hogrefe’s assessment services and related data to only those individuals who need to use them and revoking access when those individuals no longer require access.
For assessments administered through HTS that are subject to U.S. Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99), if the subject of a Hogrefe assessment administered through HTS or the parent or legal guardian of the subject (under the age of 18 ) of a Hogrefe assessment administered through HTS would like to request to access, review, refuse further collection of, or delete the assessment subject’s Personal Information within HTS, all such requests must be submitted directly to a corresponding customer of Hogrefe that required the assessment subject’s submission of such data (for example, a school or therapist). Because Hogrefe is required to comply with contractual confidentiality and data retention obligations related to our customers’ data, we are not able to respond to these requests directly. Customers of Hogrefe may direct requests to access, delete or restrict further collection, processing or use of an assessment subject’s Personal Information to customersupport(at)hogrefe.com. Notwithstanding the foregoing, Hogrefe will not, under any circumstances, provide access to assessment response data other than the data included in the score report or results of the assessment, or delete or modify assessment response data, score reports or results of assessments, after they are administered.
When California customers provide personal information to a business, they have the right to request certain disclosures if that business shares personal information with third parties for the third parties' direct marketing purposes. Once per calendar year the customer may request that the business provide a list of companies with which it shares personal information for those companies' direct marketing purposes, and a list of the categories of personal information that the business shares. Hogrefe generally does not share personal information with third parties for the third parties' direct marketing purposes without Your explicit consent and direction. However, if you receive a solicitation from a third party that you believe obtained Your information from the Hogrefe without your consent,
You may request information about our compliance with this law by contacting us at:
Hogrefe Publishing Corporation
Attention: Data Protection Officer
44 Merrimac Street; Suite 207
Newburyport, MA 01950
Any such inquiry must include "California Privacy Rights Request" in the first line of the description and include Your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
The following Additional Data and Privacy Practices Information for Specific Hogrefe Services shall apply to all users of the Hogrefe Testsystem (“HTS”) that are required to comply with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the privacy and security regulations promulgated under Title II, Subtitle F, §§ 261-264 of HIPAA, the administrative regulations issued by the Department of Health and Human Services (“DHHS”) as found in 45 C.F.R. Parts 160 through 164 (hereinafter HIPAA or DHHS regulations), and the Health Information Technology for Economic and Clinical Health Act of 2009, Public Law 111-005 (“the HITECH Act”), as such laws and regulations may be amended from time to time.