Last updated: August 3, 2020
A “visitor” is in this case any individual who visits any web-page under the control of Highered AS, regardless of whether they have created a user or started a customer relationship with Highered.
A “user” or “logged-in user” is in this case an individual who uses a personal or shared user account registered with Highered to access our services.
Our websites may contain links to other sites which we have no control over. Highered does not take responsibility for the handling of your data and privacy policies on sites that you are referred to through our pages unless this is explicitly stated. We encourage you to review such other sites’ privacy policies for information on how these collect, use, and disclose your information.
- USE OF YOUR INFORMATION
Information commonly collected or processed by these tools can be the IP address of your device, other unique device identifiers, which pages are downloaded, time, where you click within our pages, which page you came from, the type of browser and operating system. All of this information is handled by Highered as a data controller, and we employ different data processors in order to fulfill our purposes of the processing.
In addition to the technologies used for visitors, Highered makes use of additional cookies and tracking tools for logged-in users that are used to serve your relationship to us, customize our websites, and provide support. Such information will be aggregated to anonymous reports to support our ongoing development efforts. Furthermore, limited individual information is supplied to or tracked by certain data processors in order to provide the best possible experience to users. Identifiable information like what you supply in your profile, your e-mail address, your interactions with employers using our services, etc may be shared with your school to enable them to provide you with tailored on-the-ground counseling services.
Highered has implemented the necessary technical and organizational measures to secure your personal information from being lost or from unauthorized access, use, modification, or distribution. Highered deletes data when continued storage no longer is needed regarding the origin for collecting the information. We also adhere to data security best-practices like strong encryption and access management policies. For details, please reach out to us at firstname.lastname@example.org.
- INFORMATION, UPDATES, AND CANCELLATION OF YOUR PERSONAL INFORMATION
It follows from the GDPR that you have the right to demand knowledge of what personal information we hold about you, as well as updating or deleting such information. Please contact us at email@example.com if you want this.
We strive to keep the information we store about you as accurate and current as possible. Please contact us if you believe the information we have is incorrect or incomplete so that we can correct or update the information.
- OUR LEGAL BASES FOR PROCESSING
Highered employs a combination of legitimate interest, active consent and contractual requirements as our legal basis when processing your data. For most analytics and tracking services, legitimate interest is our legal basis. For your profile data, active consent is our legal basis when you yourself supply the information. When data about you is shared with us from closely related parties, like your school, legitimate interest is our and the other party’s legal basis. This also applies to most of your Highered account data we share with your school’s Career Service representatives. Otherwise, data shared with third parties, like cut-e for handling assessments, is generally based on your active consent. Specific data processing used to identify your user or customer relationship with Highered is based on contractual requirements.
When the legal basis is active consent, we will not process your information until you actively instruct us to or supply the information. You can withdraw this consent at any point in time. Your general rights of viewing, updating, and deleting your data also applies.
When the legal basis is contractual requirements, you can not opt-out of processing that this could lead us to breaching other requirements due to legal policies or render us unable to serve you as a user. In this case, your right of viewing, and in some cases updating your data applies, but you will not have a right to delete this data.
Highered is a complex service managing interactions between students, alumni, career services, universities, and employers – in addition to working with service providers that help us deliver a seamless experience. Listing all our processing activities, legal basis and other details in this document would render it unreadable to most non-technical or non-legal practitioners. For a detailed overview, please reach out to us at firstname.lastname@example.org and we will happily provide you with a further explanation of our processing. Please refer to the British ICO’s guide for a deeper dive into the world of legal basis and your rights as a data subject.
- DATA PROCESSORS
Highered relies on a variety of third-party service providers in order to fulfill our purposes of processing. We have entered contractual agreements with all our service providers handling personal data in order to ensure secure and lawful processing of personal data. Our main data processors are:
- Google, a subsidiary of Alphabet, Inc. Used for three main purposes:
- Most of our services rely on cloud hosting delivered by Google, which means that your user data will reside on servers within their data centers. Such information is not used by Google for any other purposes than helping Highered serve your relationship to us.
- We use Google’s “G Suite” service for internal document handling and general communication, including day-to-day e-mail communication. This means that parts of your data some cases in some cases may be stored on Google’s servers related to this product. Such data is not used by Google for any other purposes than helping us do the internal work necessary to serve you as a user.
- We use Google Analytics for tracking anonymized user behavior. We do not send information to Google Analytics that allows them to identify you.
- Sendgrid, a subsidiary of Twilio, Inc. Used for sending most e-mails related to all types of users. We upload information like your e-mail address, name, and related school data to Sendgrid in order to communicate with you. Sendgrid also collects data to help us keep track of your engagement with our communications. This data is only used on Highered’s behalf.
- Intercom, Inc. We use Intercom to provide support to our visitors and users. Intercom tracks information like approximate location (city or country), and stores certain user information we provide them which allows us to recognize you as a user and provide the best possible support.
- Cronofy, Ltd. Cronofy is used in our calendar functionality for booking appointments and events. Cronofy acts as a middle layer to ensure that calendar information provided in our interfaces are up-to-date with the work calendars of career service representatives, and that booked appointments are connected to the right external calendars.
- Cut-e, a subsidiary of AON PLC. Cut-e is one of our providers of career assessments and is handling personal information whenever assessments are taken and reports are generated.
- Pipedrive OU. Pipedrive is used by our sales and career services support departments to handle efficient interactions with prospective customers and schools we collaborate with.
- TalkJS (Klets B.V). We use TalkJS to manage and handle the in-platform chat system. TalkJS holds all messages sent and received, as well as basic information about the user, including email, name, photo.
A full list of our data processors, their privacy policies, and more detailed descriptions of our data flow with them can be provided by contacting email@example.com. Our data processors may individually employ sub-processors in order to fulfill their agreements with us. We work closely with our data processors and follow data minimization principles in order to avoid unnecessary sharing of data with our data processors, their sub-processors or other third parties.
- WHERE YOUR DATA IS STORED
We store most of our data on servers located in the European Union. For instance, our Google hosted Servers are located at Google’s data centers in St. Ghislain, Belgium. Virtually all our digital data storage is handled through our data processors, which means that the actual destination of certain data points will depend on the architecture provided by the processor. Wherever possible, we explicitly instruct them to keep data stored and process data at data centers located in the EU. If you access our services from or through locations outside the EU, your data will naturally flow through other geographical areas on its way to you.
Highered is a global company, and some sub-processors do not offer the option to store information in the EU. In other cases we find it required to store or process data in other locations due to the nature of our services or legal requirements. In these situations, we enter into specific agreements with the sub-processors, and/or verify that they have the required certifications to ensure the secure handling of your personal data. For details on where your user data is stored or processed, please reach out to us firstname.lastname@example.org.
What are Cookies
What are Web Beacons
Unfortunately, Highered does not currently offer the option to select which cookies you want to disable specifically to our pages. However, we do respect browser settings you have enabled. This means that if you enable “Do Not Track” on your browser or device, Highered will not enable cookies that are used to track your behavior. For information on how to activate this mode, please refer to the guides at https://allaboutdnt.com/. We are planning to offer an option to selectively limit specific cookies on our pages only, but this is not ready yet. The “Do Not Track” mode does, however, cover the same functionality that our internal solution would do – it’s just working across all web pages and not limited to Highered.
An extreme measure you may also employ is to set your browser to “disable all cookies from Highered” by selectively blocking each of our domains. However, this will severely impact the functionality of our sites as we will not be able to recognize you as a user. Therefore we do not recommend this and suggest you rather enable the “Do Not Track” mode.
The Cookies We Set
On the school pages for students and alumni (gethighered.global), the most common cookies are administered by the following entities:
- Highered (to identify a user): refresh_token, access_token, wpcc
- Google analytics (analytics): _gid, _ga, _gat_gtag_UA_*
- Intercom (support): intercom-session-*, intercom-id-*
- Wistia (to show videos and remember your viewing progress): __distilled
* is used in place of a unique code that identifies you, your session, and/or the Highered web-page you are currently accessing.
We strive to always keep our cookie overview up to date and readable. However, there may in some cases be discrepancies between the list in this section and the actual cookie set-up on our pages. For a full and up-to-date list of the cookies being used on our domains, please reach out to us at email@example.com.
How we use Web Beacons
Highered uses web beacons in order to analyze our visitors’ behavior on our pages and perform retargeting. These web beacons are commonly used in conjunction with cookies in order to keep track of new and returning users. In fact, the cookies themselves are never sending information across the internet – this information transfer is being handled by the web beacons, which read the associated cookies.
This means that most of our analytics cookies have one or more corresponding Web Beacons that transfer analytics information to our or a data processor’s systems. See the “Web Beacons we use” section for examples.
Disabling Web Beacons
As with analytics cookies, the only way to disable Web Beacons at Highered’s services is currently to enable the “Do Not Track” setting in your browser or device. A guide to doing that can be found here: https://allaboutdnt.com/
We will soon implement a method for you to disable analytics Web Beacons on Highered specifically. In the meantime, we apologize for any inconvenience caused.
Please be aware that disabling Web Beacons at Highered does not disable click and page view tracking when you interact with job ads and companies. This is tracked independently and not through web beacons and is an integral part of how our service is being delivered to you. Therefore it cannot be disabled. Along with a method for disabling these technologies on Highered specifically, we will provide a more clear overview on which beacons and tracking methods are active at a given moment.
Web Beacons we use
On the school pages for students and alumni (gethighered.global), the web beacons currently in use are:
- Google Analytics Global Site Tag, for anonymized visitor data and event tracking
- Facebook Pixel, for aggregated demographic data on our visitors and retargeting functionality
- Intercom widget, for providing support to you in a seamless way
- Wistia Hosted Videos, for analyzing interactions with the videos on our pages
- Leadpages Exit pop-up, for analyzing interaction with time-based prompts on our page
- Sendgrid E-mail Pixel, a pixel used in e-mails we send you through Sendgrid which help us analyze how many of our e-mails are opened by our users.
We strive to always keep our Web Beacon overview up to date and readable. However, there may in some cases be discrepancies between the list in this section and the actual Web Beacons being used on our pages. For a full and up-to-date list of the Web Beacons on our domains, please reach out to us at firstname.lastname@example.org.
Before you go
As previously mentioned, Highered is a young company and we are doing our best to keep our processing secure, transparent, and lawful at any point in time. If there are any discrepancies between how you experience our processing, the cookies/web beacons we use, and the information provided in this document, please reach out to us at email@example.com.
Telephone: +47 22 44 47 47
Madserud Allé 34
Organization number NO 916 036 043