Privacy Policy
INTRODUCTION
This Privacy Policy outlines the practices concerning the information collected from users who have accessed our website at www.how-r.com ("the Site"), registered on our Site, or shared personal information with us through contact forms (collectively: "Users"). The purpose of this privacy policy is to provide maximum transparency regarding the information the Site collects and how it is used in compliance with obligations arising from national regulations (Italian Legislative Decree 30 June 2003 n. 196, Personal Data Protection Code) and European legislation (General Data Protection Regulation No. 679/2016, GDPR) and subsequent amendments. The processing of personal data will be guided by principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, integrity, and confidentiality.
DATA CONTROLLER
The "Data Controller" is HOWAR Srl, Via Filippo Turati, 40, Milan, Italy. If you have any questions about this Privacy Policy, your personal data, or data protection on this Site, you can contact me at the following email address: info@how-r.com.
LEGAL BASIS FOR DATA COLLECTION
This website processes data based on consent. Processing User personal information (i.e., information that allows their identification through reasonable means, hereinafter "Personal Information") is necessary to fulfill our contractual obligations towards the User, provide our services, protect our legitimate interests, and comply with legal and tax obligations. By registering on the Site, using the Site, and opting-in to our Privacy Policy at the beginning of each assessment, the User consents to the collection, storage, use, disclosure, and other uses of Personal Information as described in this Privacy Policy. We encourage our Users to carefully read this Privacy Policy to make informed decisions.
WHAT DATA WE COLLECT
We collect the following categories of data:
1. Registration Information: When a User registers on our Site to purchase an assessment, they will be asked to provide certain details such as name, email, physical address, and other billing information necessary for issuing invoices.
2. Company/Organization Information: When taking an assessment, Users may provide general information about their company or organization, such as business sector, workforce composition, remote work prevalence, etc.
3. Assessment Answers: We collect and process the answers provided by Users to the assessment questions to calculate the result and generate the resulting report. The report may contain the name of the company/organization if inserted by the User.
4. Usage Data: We may collect information about User activity on the Site (e.g., pages viewed, online navigation, clicks, actions, etc.).
5. Device Data: We may collect certain software and hardware information from the User's device (such as the type of browser and operating system used by the device, language preferences, access time, etc.), used to improve the functionality of our Site.
CONSULTANTS' USE OF OUR SERVICES
If a User is a consultant completing the assessment on behalf of a client company/organization (hereinafter "Client"), we encourage the consultant to avoid providing named or directly identifiable information about their Clients wherever possible. If the consultant needs a way to identify the assessment for their own purposes, we suggest using an internal reference number or code rather than the Client's name.
If a consultant User does provide their Client's name or identifying information, the User represents and warrants that they have obtained all necessary consents and permissions from the Client to share their data with us for the purposes outlined in this Privacy Policy. The consultant User is responsible for ensuring they have the necessary permissions and rights to share their Client's data.
We only collect the minimum amount of data necessary for the purpose of the assessment. If the Client's name or other identifying details are not actually required, we may remove the free text field altogether.
HOW DO WE RECEIVE USER INFORMATION?
We receive personal information from various sources:
- When the User voluntarily provides personal data to register on the Site;
- When the User voluntarily provides personal data and company/organization information while taking an assessment;
- When the User uses our Site or accesses it in connection with the use of our services;
- From third-party providers, services, and public records (e.g., traffic analysis providers).
HOW WE MAY USE THE INFORMATION
Legal obligations: when strictly necessary, we will process your personal data to comply with a legal or binding tax obligation.
Communicate with the User, send service-related notifications, provide technical information, and respond to any requests for information or assistance;
Communicate with the User and inform them of the latest updates and services;
Process assessment answers to calculate results and generate reports;
Perform analysis and statistics aimed at improving the Site and our assessments.
USE OF ANTHROPIC'S CLAUDE AI AND DATA SHARING
For the purpose of assessment report generation and certain other Services, we utilize Claude, an artificial intelligence model developed by Anthropic Ireland, Limited. Claude is used to generate analysis, interpretations, and insights on the data we provide, which may include the User's general company/organization information and assessment responses.
While Claude employs advanced natural language processing capabilities, the accuracy and precision of its analysis are subject to the inherent limitations of current generative AI technology. In particular, factual assertions in Claude-generated analyses should not be relied upon without independently verifying their accuracy, as they may be inaccurate, incomplete, misleading, or not reflective of recent events or information. The information contained in reports generated using Claude is provided for informational purposes only and shall not be construed as professional advice. We make no representations or warranties of any kind about the completeness, accuracy, reliability, suitability, or availability of the analysis contained therein.
In the course of utilizing Claude, we share User data with Anthropic. We encourage Users to review Anthropic's privacy policy (available at https://www.anthropic.com/legal/privacy) for information on their data handling practices.
USE OF ANONYMIZED DATA
We may use the general company/organization information and assessment answers provided by Users to create anonymized, aggregated datasets for the purposes of benchmarking, comparing assessment results, and improving our assessments. This anonymized data will not contain any personally identifiable information. Please note that once data is anonymized, it cannot be associated with an individual User, and therefore requests for deletion of this anonymized data cannot be fulfilled.
DATA RETENTION
The Services conclude with us making the Report containing the user's assessment results available to the Client. We will retain the generated reports for 90 days following the completion of the assessment, after which they will be deleted and it will no longer be possible to obtain a copy. If a Client deletes their registration on the Site, any completed assessment reports associated with their account will also be deleted.
The possibility of accessing the Services has no expiration after its purchase; however, we reserve the unequivocal right to cease the provision of Services at any time, notifying the Client with at least 60 days' notice. We will retain User personal information for as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements. Once Services are ceased, we will delete or anonymize User personal information within a reasonable period, unless a longer retention period is required or permitted by law. Anonymized, aggregated data used for benchmarking and assessment improvement may be retained indefinitely.
THIRD-PARTY PROVIDERS
We may engage third-party suppliers to assist in providing the Services. Some of these suppliers may process User personal information on our behalf. We will ensure appropriate data protection safeguards are in place with these suppliers.
PAYMENT PROCESSING
We use Paypal to process payments for assessment purchases. Paypal may collect and process personal information related to these transactions. We encourage Users to review Paypal's privacy policy (available at https://www.paypal.com/webapps/mpp/ua/privacy-full) for information on their data practices.
SECURE HOSTING
The Site and the Services are stored and made available on the secure hosting platform of Register S.p.A. Viale della Giovine Italia 17, Firenze, CAP 50122, Italy (www.register.it).
We may also disclose information in good faith if we believe it is useful or reasonable to: (i) comply with applicable laws, regulations, legal processes, or government requests; (ii) enforce our policies (including the Contract), including investigations into potential violations; (iii) investigate, detect, prevent, or take action regarding illegal activities or other unlawful actions, suspected fraud, or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to our rights, property, or safety, or the rights, property, or safety of our customers, Users, or third parties; or (vi) to cooperate with law enforcement and/or where we believe it is necessary to enforce intellectual property or other legal rights.
USER RIGHTS
The User can request to:
- Receive confirmation if personal information concerning them is being processed and access stored personal information, along with additional information.
- Receive a copy of voluntarily provided personal information in a commonly used, structured, and machine-readable format.
- Rectify personal information within our control.
- Delete personal information, excluding anonymized and aggregated data mentioned above.
- Object to the processing of personal information by us, excluding anonymized and aggregated data mentioned above.
- Restrict the processing of personal information by us, excluding anonymized and aggregated data mentioned above.
- File a complaint with the supervisory authority.
However, please note that these rights are not absolute and may be subject to our legitimate interests and regulatory requirements. If you wish to exercise the above rights or receive more information, please contact our Data Protection Officer ("DPO") using the details provided below: write to HOWAR Srl, via Filippo Turati, 40, Milan, Italy, email info@how-r.com
If a User is a consultant who has provided a Client's name or identifying information, and the Client wishes to exercise their data subject rights under the GDPR, the consultant User is responsible for facilitating such requests and ensuring the Client's rights are upheld.
DISPUTE RESOLUTION
As detailed in our Terms and Conditions, any disputes arising in relation to our Services will first be submitted to mediation under ADR Piemonte in Vercelli, Italy, before initiating any judicial proceedings.
RETENTION
We will retain the User's personal information for as long as necessary to provide our services and fulfill our legal obligations, resolve disputes, and enforce our rules. Retention periods will be determined considering the type of information collected and the purpose for which it is collected, taking into account applicable requirements and the need to destroy obsolete and unused information as soon as possible within reasonable limits. In light of applicable regulations, we retain records containing customer personal data, documents related to account opening, communications, and anything else required by applicable laws and regulations. For newsletter delivery, we will process the data until the User unsubscribes from the service. In any case, the data will be kept for fulfilling tax obligations and until allowed by law to protect my interests according to art. 2947(1)(3) Italian Civil Code.
SECURITY
We implement appropriate security measures aimed at preventing unauthorized access, disclosure, alteration, or destruction of User data. However, no online data transmission or storage method is 100% secure, so we cannot guarantee absolute security.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Site. If we make material changes to this policy, we will notify you here that it has been updated so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. We will communicate any changes to this Privacy Policy via email with at least 10 days' notice.
CONSENT
By registering on our Site, using our Site, and opting-in to our Privacy Policy at the beginning of each assessment, you hereby consent to our Privacy Policy and agree to its terms.
LAST MODIFICATION DATE
This Privacy Policy was last modified on November 7, 2024.