PRIVACY POLICY

Last Updated: November 26th, 2020

Hult Prize Certificate Program (“HPC”) is a program of Hult International Business School AG, a company incorporated under the laws of Switzerland, with office located at Haldenstrasse 4, 6006 Lucerne, Switzerland (“HULT,” “we,” “our,” “us”). At HULT, we understand that privacy is important and that you trust us to keep secure any information we obtain from you or about you. We are committed to protecting the privacy of visitors of HPC website located at www.hultprize.org (the “Website”), and making you aware of the ways in which we may use any information that we collect from you.

HPC offers world-class courses that empower you to think differently, learn collaboratively and join a global community of learners and doers with a burning desire to change the world (the “HPC Courses”).

This Privacy Policy is designed to help you better understand the information we gather, use, and share and store information when you use our Website and the HPC Courses.

For purposes of this Privacy Policy, the Website and the HPC Courses, discussion forums and all content, information and services hosted on our Website are collectively called the “Services.” This Privacy Policy also describes the choices you have regarding our use of your information. Please note that this Privacy Policy applies only to HPC and our Services and not necessarily to other companies with whom we work or to organizations’ websites to which we may link.

INFORMATION WE COLLECT AND HOW WE COLLECT IT A. Information You Provide Directly to Us To provide you the Services, we may collect information that you disclose to us through your use of the Website, or the Services. For example, we collect information from you when you sign up for and participate in our online courses; when you contact us by email, over the telephone, or by other means to ask us questions; or respond to our surveys, promotions, or requests. The information we collect may include, but is not limited to, your name, age, contact information such as telephone number, mailing address, and email address, payment information, employment and education information, and learning preferences.
Information Collected Through Your Use of the Services When you browse our Website or use our Services, we may collect certain network and device information. We collect this information primarily to provide an enhanced online experience. The information we collect may include, but is not limited to, the type of operating system in use e.g. Macintosh, Windows and the domain name and the type of browser being used [e.g. Chrome, Internet Explorer, etc.], weblogs and other communication data, including your IP address, and the date and time you accessed or left this website and which pages you viewed.
Use of Cookies, Local Storage, Aggregate Data Collected Online Cookies are text files created by websites that transfer information to your computer. Cookies allow websites to remember information about a user, such as a user’s preferences when visiting the website. As with most websites, HPC, by itself and through third-party services such as Google Analytics, uses cookies to evaluate use of this website and improve services. You can generally opt to disable cookies in your browser. However, if you disable cookies, you may not be able to access certain parts of this website or certain aspects of this website may not work correctly. We do not track or collect personally identifiable information unless you provide information to us when you sign up for and use our Services. Our Website does not have the ability to respond to a ‘do not track’ signal on a user’s browser. Our Website utilizes web beacons, pixel tags, cookies, local storage, embedded links, and other commonly used information-gathering tools.
Information Collected from Third Parties We also collect information about you from third parties. For example, portions of the Website may include features or widgets from various social media platforms, such as Facebook, Twitter, Pinterest, Instagram, Tumblr and YouTube (each, a “Social Media Platform”), and we may enable you to register or log in to our Website through a Social Media Platform. These features use Cookies to collect information about your IP address and the pages on our Website that you have visited. Your interactions with those features are governed by the terms of use and privacy policies of the companies that provide them.
When you sign up for or access one of our HPC Courses through a third party platform, you allow us to collect certain information from the third party as permitted by the terms of that third party, your privacy settings, and in accordance with this privacy policy. For example, a third-party platform may share with us your name; email address; demographic information; course activity; course results; and course survey responses.

HOW WE USE AND SHARE THE INFORMATION WE COLLECT A. How we use the information we collect: HPC will use the information we collect for the following purposes:
To respond to your questions and requests, as well as to keep track of support and customer service requests;

To provide you the Services and Website features;

To maintain and improve the Services and Website;

To prevent fraud;

To email or contact you regarding HPC Course feedback, solicitations related to our work, our newsletters, and promotions and special offers from us, our partners and organizations we are associated with;

To manage your account and account access;

To provide you with purchase confirmations;

How we share the information we collect: HPC will not sell your personal information to third parties. However, we may disclose information we collect to third parties for the following purposes:
To comply with applicable law, regulation or governmental request; protect safety of HPC, users of this website, or others; protect the rights or property of HPC; to comply with contractual obligations of HPC; and other instances when HPC is legally required to disclose your information; to enforce our terms and conditions or a contract; to protect our operations or those of any of our affiliates; to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and to allow us to pursue available remedies or limit the damages that we may sustain.

To share information that is public or does not include personal information, for example, aggregated data or a publicly posted comment;

To provide third parties with statistical information about the users of our website;

To third parties if you use certain third-party features to share information about user activity through our Website, for example, the “Share” button on blog posts allows users to share posts on social networks. If you use these features, HPC will share this information with the third-party website or service, along with additional information you provide to use the feature (e.g., a Twitter username). By accessing these third- party websites, you are consenting to those terms and privacy policies of those websites. You should read those third-party website privacy policies and terms of use. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them;

To any affiliated business entities or third parties necessary to provide services to you, including, but not limited to, our subsidiaries, our holding company and its other subsidiaries (if any), as well as third parties involved in the administration and operation of our services;

To third party course platform partners, any affiliated business entities or associated organizations to market products and services to you;

To third parties to process payments if you make a purchase through the Services;

To collaborate with third parties such as our course partners on HPC Course creation and improvement;

To a third party if we sell any or all of our business and/or assets to them;

In other ways when we have your consent to do so.

III. SECURITY We use appropriate organizational, technical and administrative measures to keep your personal information under our control accurate and up-to-date, as well as to protect the personal information against unauthorized or unlawful processing and the accidental loss, destruction or damage of the personal information.

THIRD-PARTY WEBSITE INTERACTION This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the Services contain a link. The inclusion of a link on the Services does not imply endorsement of the linked site by us or by our affiliates.
CHILDREN The Services offered by HPC are only intended for use by those who have reached age 18 and older. HPC does not knowingly collect personal information from users under 18. If you believe that a user under the age of 18 has provided information to the Services, please notify us at hello@hultprize.org. If we inadvertently collect information of users under 18, we will delete that information immediately upon notice.
INTERNATIONAL DATA TRANSFERS HPC offers its Services in a variety of countries. If you are in the European Economic Area (EEA) or other region with laws governing data collection and use which differ from those of the United States, please note that your information, including your personal information, may be transferred to countries located outside the EEA, in particular to the United States, and those countries may not have the same level of protection as the country in which you initially provided that information. We have put appropriate safeguards in place for transfers of your Personal Data outside the EEA/Switzerland, including the standard data protection clauses adopted by the European Commission, available at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915 and http://eur-lex.europa.eu/legal- content/en/TXT/?uri=CELEX%3A32010D0087.
NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS A. CA “Shine the Light” Disclosure: For California residents, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information, as that term is defined in Section 1798.83, to third parties for the third parties’ direct marketing purposes. To make such a request, you may contact us at hello@hultprize.org.
CA “Privacy Rights for California Minors”: California minors under 18 years old may request the removal of any information that they have posted to the Website by contacting us at hello@hultprize.org Upon such request, HPC will anonymize, or remove from public view, any content posted by a minor to its Website, unless required by law to retain such content or information.
CA “Do Not Track” Disclosure: We have disclosed our collection practices herein, but at this time, we do not honor do-not-track signals.
VII. SENSITIVE DATA We do not generally seek to collect any sensitive personal information. Sensitive personal information is data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or medical condition, criminal background or trade union membership. In certain situations, this might however be necessary (for example in order to provide you with the services and products you have ordered). We will make sure that we receive your explicit consent to such processing and treat this information securely.

VIII. HOW LONG DO WE STORE PERSONAL INFORMATION? We will only keep your personal information for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims or unless a specific time period has been communicated.

We will keep limited parts of your personal information which are necessary for marketing purposes until you withdraw your consent, but in no event for longer than 10 years after your last completed service or delivery of product.

YOUR RIGHTS AND CHOICES Subject to applicable law, you may have the right to request access to and receive information about the personal information we maintain about you, update and correct inaccuracies in your personal information, and have the information blocked or deleted, as appropriate. The right to access personal information may be limited in some circumstances by local law requirements. You also have the right to withdraw your consent to the collection of your personal information.
If you receive promotional messages from us, you may unsubscribe at any time by following the opt-out instructions contained within the message. Even after you opt out of receiving promotional messages from us, you may continue to receive administrative messages from us regarding our Services.

You may also opt out of our use of your information at any time, but you might not be able to use certain features of our Services if you opt out of our use of your information.

To exercise your rights and choices to your personal information, please contact us at hello@hultprize.org

PRIVACY POLICY CHANGES We may, from time to time, make changes to this policy. The most current version of this policy will always be available at HPC website, along with the date last revised. Any modifications will become effective immediately upon posting. By continuing to use this Website, you accept such modifications. If we make any substantial changes in the way we use your personal information, we will notify you via email or by posting a prominent announcement on our Website or as otherwise required by applicable law. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.
HOW TO CONTACT US We would like to thank our visitors for taking the time to understand more about HPC by browsing our Website.
If you would like to have a copy of the information HPC holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights,

Hult International Business School AG, Haldenstrasse 4, 6006 Lucerne, Switzerland, or at hello@hultprize.org

If you have complaints about our handling of your Personal Data, you have a right to contact the supervisory authority in the country where you live.