Last updated: Feb. 05, 2020

Definitions

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.

PRIVACY POLICY

  1. GENERAL

The website you are now about to use is owned and operated by Highered AS (Highered). The following privacy policy applies to your use of our websites https://gethighered.global, https://talentpanel.io, https://highered.global, https://multipost.io, including all sub-domains and sub-pages. By using these websites you are deemed to have accepted our Privacy Policy as it applies to visitors. As a logged-in user, you are accepting this privacy policy as part of the sign-up process.

Highered treats your right for privacy seriously and treats all information in accordance with the Norwegian Personal Data Act/EU Directive 16/679 (commonly referred to as the GDPR) and the EU Directive 02/58/EC (the ePrivacy directive). Our Privacy Policy informs you about how we treat personal information that you either provide yourself or we collect provide when you are using our websites mentioned above.

Our website contains 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.

  1. USE OF YOUR INFORMATION

Information and data are continuously collected on our website through the use of cookies (“cookies”), tracking pixels (“web beacons”), users supplying information through our interface and other general mechanisms like event tracking (click and page view data sent directly to our systems). For an explanation of how cookies and web beacons are used in particular, please refer to our cookie policy below.

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 processing. 

Visitor information is used to prepare aggregated statistics used for the operation, optimization and further development of the websites. We also employ a limited set of pixels or cookies for visitors that enable retargeting through other channels or providing support. For details on this, our cookie policy is the place to go..

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 account e-mail, your interactions with employers and jobs etc. may be shared with your school to enable them to provide you with tailored on-the-ground counseling services.

  1. SECURITY

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 data@highered.global.

  1. 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 data@highered.global 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.

  1. OUR LEGAL BASES FOR PROCESSING

Highered employs a combination of legitimate interest, active consent and contractual requirements as our legal bases 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 legitimate interest, we will inform you about the processing (either through this privacy policy or in separate communications) but not ask for your specific opt-in before doing so. In this case you have the right to say no to such processing, in addition to your general rights of viewing, updating and deleting your data.

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 bases 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 data@highered.global 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 bases and your rights as a data subject.

  1. 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.
  • Vendemore Nordic AB, a subsidiary of Bisnode Business Information Group AB. Vendemore is assisting Highered in some of our marketing efforts. They provide certain analyses on our website visitors, as well as services to enable re-targeting towards employers.
  • Hotjar Limited. Hotjar is being used to analyze how users and customers interact with our pages in an anonymized way, for us to better understand how we can improve our services.
  • ZYL TECNOLOGIA, CONSULTORIA E INVERSIONES (ZYLCAST). Zylcast is the company behind the EasyVirtualFair virtual career fair platform which we we have signed an agreement with for running the EFMD Virtual Career Fair Series. Their privacy policy can be found here.

A full list of our data processors, their privacy policies, and more detailed descriptions of our data flows with them can be provided by contacting data@highered.global. 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.

  1. 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 secure handling of your personal data. For details on where your user data is stored or processed, please reach out to us data@highered.global.

  1. MODIFICATION OF PRIVACY POLICY

Highered is a young company in constant development. Our Privacy Policy may therefore be updated from time to time. The updated version will take effect immediately upon publication. Your use of our website is governed at all times by the version published at the time of use. We will inform our users when major changes to our privacy policy is being implemented.

COOKIE POLICY

What are Cookies

As common practice with almost all professional websites, Highered uses cookies. Cookies are tiny files that are downloaded to your computer, to improve your experience. This policy describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent cookies that are not critical to the site’s functionality from being stored on your device.

What are Web Beacons

Web Beacons, in some cases referred to as “Tracking pixels” and “Javascript tags” are small pieces of code that can be loaded as part of a web-page or e-mail in order to monitor visitors and users’ interaction with a service. This policy describes in brief what kinds of beacons we currently make use of, and what information they capture. We will also share how you can limit the amount of data tracked by such beacons.

For a detailed explanation of cookies and web beacons, please refer to these explanatory pages (cookie / pixel).

How We Use Cookies

We use cookies for a variety of reasons. A website’s ability to recognize you as a user and keep you logged in as you navigate the page is dependent on so-called “functional cookies” which uniquely identify your user account. Such cookies are crucial for us to deliver our service to you. Intercom is storing cookies on your device in order to help us recognize whether you are a user or not, and which user you are. This can also be categorized as functional cookies. Google Analytics, Vendemore and our video provider Wistia are also storing cookies in order for us to keep track of new and returning visitors to our service. Such cookies do not identify you directly, and are not critical to the functionality of our website.

Disabling Cookies

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-*
  • Vendemore (analytics): vlmref, vaid
  • Wistia (to show videos and remember your viewing progress): __distilled
  • Hotjar (analytics): _hjIncludedInSample, _hjid

* 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 data@highered.global.

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 apologise 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
  • Hotjar Product Analytics beacon, for understanding how users interact with our pages and effect of improvements
  • Leadpages Exit pop-up, for analyzing interaction with time-based prompts on our page
  • Vendemore Javascript Tag, for aggregated visitor analytics and measuring the efficiency of marketing efforts
  • 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 data@highered.global.

Before you go

Hopefully, this privacy and cookie policy has clarified things for you. If you feel like you are left with more questions than answers by reading these policies, please drop by our offices or reach out to us at data@highered.global – we will be happy to assist you.

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 data@highered.global.

CONTACT INFORMATION

Highered AS
Email: data@highered.global
Telephone: +47 22 44 47 47
Madserud Allé 34
0274 Oslo
Norway
Organization number NO 916 036 043