Privacy Policy

Last Updated: November 1, 2023 (the “Effective Date”)

By accessing or using Our Service, you agree to comply with and be bound by this Privacy Policy and all Applicable Laws and regulations. If you have any questions about this Privacy Policy, please email us at hello@castle-hr.com.

This Privacy Policy constitutes a legally binding agreement between you and Castle HR Inc. (“Castle HR”, the “Company”, “We”, “Us”, or “Our”) governing your access to, and use of Our Services and Our collection and use of Your Personal Data in connection with such use and access.

We reserve the right in Our sole discretion to revise and update this Privacy Policy from time to time. Any and all such modifications are effective immediately upon posting and apply to all access, and continued use of, Our Service. You agree to periodically review this Privacy Policy to be aware of any such modifications. Your continued use of Our Service shall constitute Your acceptance of the then-current Privacy Policy.

If You do not agree to this Privacy Policy, You must not access or use Our Service. You understand that by using Our Service after the Effective Date, You agree to be bound by this privacy policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural form.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access Our Service or parts of Our Service.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Castle HR Ltd.
  • Cookies are small files that are placed on Your computer, mobile Device or any other Device by a website, containing the details of Your browsing history on that website among its many uses.
  • Device means any internet-connected electronic accessory that can access Our Service such as a computer, a cellphone or a tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to this Website and its content, including courses.
  • Service Provider means any natural or legal person who processes the data on behalf of Castle HR. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to Castle HR, accessible from www.castle-hr.com.
  • You means the individual accessing or using Our Service, or the company, or other legal entity on behalf of which such individual is accessing or using Our Service, as applicable.

Overview

This Privacy Policy covers Our handling of any Personal Data we store about You and describes Our practices regarding the collection, use and disclosure of Personal Data. It also describes the choices available to You regarding Our use of Your Personal Data and how You can access and update that data.

This Privacy Policy does not apply to third-party services, websites, or applications We may link to through Our Service. When You use one of these links to leave Our Service, We encourage You to review the privacy policies and terms of use that apply to the services, websites, or applications You access.

Personal Data We Collect

The Personal Data we collect falls into one of three categories: 

  • Necessary Personal Data refers to any information You are required to submit to Use Our Service. 
  • Voluntarily Provided Personal Data refers to any information You knowingly and willingly provide us when using our Service. 
  • Automatically Collected Personal Data refers to any information automatically sent by Your Devices in the course of accessing Our Service.

Personal Data that is Necessary to Use Our Service

The categories of Personal Data described below are necessary to help with Your use of Our Service and for Castle HR to meet Our obligations under Applicable Laws as well as Our contracted obligations to Our clients (i.e., Your employer). As a best practice, We collect the minimum amount of Personal Data that is required to successfully provide Our Service. 

  • Account Information. When You sign up for an Account, We require certain Personal Data such as Your first name, last name, email address, and employer name. If You are accessing Our Service on behalf of an organization, we may require more information about the organization such as entity name, entity type and size, nature of business/operations, and answers to qualitative questions about Your organization.
  • Course Enrollment. When You enroll in Our Workplace Training courses We collect and store Personal Data such as your first and last name, email address, employer name and course progress status. We collect only the information necessary for compliance and verification purposes, and nothing more. 
  • Payment Transaction Information. We use the services of Rotessa to process, route and deliver funds under Applicable Laws in exchange for Our Services. These payment services, including the charging, processing and delivery of Our fees are ultimately subject to the policies located here: https://rotessa.com/legal/.

Personal Data You Voluntarily Provide to Castle HR

Castle HR collects the Personal Data You choose to provide to Us through your use of Our Service, as described here.

  • Communications. When You communicate directly with Castle HR, such as booking a meeting, messaging Us or subscribing to Our marketing list through Our Website, We collect and store Personal Data from such communications, as provided by You.

Personal Data Generated from Your Use of Our Service

Like most Websites, We use technologies, such as Cookies and web beacons, to collect information about the pages You view, the links You click and other actions You take while using Our Service. 

When We send emails through Our email distributor, such as newsletter or marketing emails, We are able to monitor certain activities such as how many emails were viewed, by whom, and which links You clicked on. These insights help Us improve Our content and ensure We are sending You valuable content. We do not share this information with anyone else.

Castle HR may automatically collect information relating to Your access and usage of Our Service, as further described here.

  • Usage Information. Castle HR collects information about Your interactions with Our Service, such as the links, pages, and content You view and click on, as well as how long You spend on a particular page. Other information We collect may include Your Device type, operating system, browser type, IP address, MAC address, and the website or application from which You navigated to Our Service.
  • Geo-location Information. Castle HR collects information about Your precise or approximate location as determined through data such as Your IP address or Your mobile Device’s GPS. Most mobile Devices let You control or disable the use of location services for applications in the Device’s settings menu. Most modern browsers will ask if You agree to share your location information with Our Website, and You may choose not to. 
  • Log Data and Device Information. We automatically collect log data and Device information when You access and use Our Service, even if You have not created an Account. That information includes, among other things: details about how You’ve used Our Service (including if You clicked on links to third-party applications), Your IP address, access dates and times, hardware and software information, Device information, Device event information, unique identifiers, crash data, Cookie data, and the pages You’ve viewed or engaged with before or after using the Castle HR Website. 
  • Cookies, Pixels and Similar Technologies. We use Cookies and similar technologies when You use Our Service, engage with Our online advertising or engage with Our email communications. Cookies are small files saved onto Your Device or browser through Your web browser that allow Us to collect certain usage information, and Pixels are tiny graphics with unique identifiers embedded in Our Service that allow Us to collect certain usage information. We may collect certain information by automated means using technologies such as Cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. Often, the information We collect using Cookies and the other methods listed here is only used in an anonymized non-identifiable format without reference to Personal Data. For example, We may use data We collect to better understand website traffic patterns or correct issues with Our Service’s user experience. Sometimes, We associate the information We collect using Cookies and other similar technology with Your Personal Data.
  • Third-party Cookies, Pixels and SDKs. Third parties may use Cookies, web beacons, and other storage technologies to collect or receive information from Our Service and elsewhere on the internet, then use that information to provide measurement services and targeted advertising. Similarly, such third parties may collect or receive information from Your Account and other applications and use that information to provide targeted advertising. Users can opt out of the collection and use of their Personal Data for advertising targeting by updating their browser privacy and advertising settings or by contacting Us with a description of Your request and validation information.

Personal Data Received from Third Parties

Castle HR may receive Personal Data about You from third parties and combine that information with information We collect from Your use of Our Service. We are not responsible for how these third parties collect, control, manage, process, disclose or share Your Personal Data, and any request or query regarding any such management or disclosure of Your Personal Data should be directed to such third parties.

Personal Data received from third parties may include, but is not limited to:

  • Third-party Services. If You create, connect, or login to Your Account with a third-party service (Google, Facebook, etc.), the third-party Service Provider may send us information such as Your registration and profile information from that service. This information varies and is controlled by that Service Provider or as allowed by You via Your privacy settings with that Service Provider.
  • Employer Records. To the extent permitted by Applicable Laws, we may obtain records related to Your employment from Your Employer. This may include Your employment contract, previous performance review notes, disciplinary notices, training logs and anything else directly related to Your ongoing employment with Your employer. 
  • Referrals. Referring persons may submit Personal Data about You such as Your email address or other contact information.

Use of Your Personal Data

Castle HR may use Your Personal Data for the following purposes:

  • To provide and maintain Our Service, including to monitor the usage of Our Service.
  • To manage Your Account: to manage Your registration as a user of Our Service. The Personal Data You provide can give You access to different functionalities of Our Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and delivery of courses available to You through Our Service.
  • To contact You: To contact You by email, telephone call, or SMS regarding updates or informative communications related to the functionalities, products or contracted services when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or previously inquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us related to business inquires or issues with Our Service. 
  • To enable internal business analytics: Such as tracking the source of marketing inquiries or an individual’s progress in each Castle HR workplace training course.  

We may share Your Personal Data for the following purposes:

  • With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyze the use of Our Service or to contact You.
  • For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With Your employer: We may share information related to Your engagement with Our Service back to Your employer.

Retention of Your Personal Data

Castle HR will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), market and provide Our Service, resolve disputes, and enforce Our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. Where feasible, Usage data will be anonymized (i.e., all personally identifiable information removed) and aggregated for the purposes of analyzing long-term trends and patterns.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at Castle HR’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

Where permissible under Applicable Laws We may use certain limited Personal Data about You, such as Your email address, to hash it and to share it with digital platforms, such as Facebook or Google, to generate leads, drive traffic to Our Service or otherwise promote our Service. These processing activities are based on Our legitimate interest in undertaking marketing activities to offer You products or services that may appeal to You.

The digital platforms with which we share Your Personal Data are not controlled or supervised by Us. Questions about how each digital platform Service Provider processes Your Personal Data should be directed to those providers.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to these transfers.

We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or country unless there are adequate controls in place including the security of Your Personal Data.

Your Choices and Rights

Limiting Information Collected and Opting-out

You have choices regarding Your Personal Data:

  • You can choose not to use Our Service;
  • You can limit the information You provide to Us;
  • You can choose not to participate in Our promotions;
  • You can limit the communications that We send to You; and
  • You can opt out of marketing emails by clicking the “unsubscribe” link at the bottom of any marketing email We send You or by changing the notification settings in Your Account.

You may exercise the rights described in this section by emailing hello@castle-hr.com.

Managing your Information

You are responsible for keeping Your Personal Data up to date. You can access and update some of Your Personal Data through Your Account settings. You may ask Us to correct inaccurate or incomplete Personal Data about You (and which You cannot update Yourself within the Account).

Data Access and Portability

You may request copies of Your Personal Data held by Us. You may also request copies of the Personal Data You have provided to us in a structured, common, and machine-readable format or request us to send this information to another Service Provider (where technically feasible).

Data Removal

You can request the removal of all Personal Data that We have on file for You. You may update, amend, or delete Your information at any time by signing into Your Account, if You have one, and visiting the Account settings section that allows You to manage Your Personal Data. You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us.

If You request the erasure of Your Personal Data:

  • We may keep some of Your Personal Data for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if We suspend an Account for fraud or safety reasons, We may keep certain information from that Account to prevent a User from opening a new Account again;
  • We may keep and use Your Personal Information as needed to comply with Our data retention obligations under Applicable Laws or contractual agreements. For example, Castle HR may keep certain records as required for tax purposes, legal reporting, audits, and the continued delivery of Our Service obligations to Your employer.
  • Residual copies of Your Personal Information may not be removed from Our backup systems for a limited time span after Your request has been processed.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but You should know that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use all commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised based on actual or suspected unauthorized use of Your Account, please contact Us by email.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We will remove that information from Our systems. 

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a thirdparty link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last Updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective the moment they are posted to this page.

Severability

If any term, provision, covenant, or condition of this Privacy Policy is held invalid or unenforceable for any reason, the other provisions will continue in full force and effect as if this Privacy Policy had been produced without the invalid portion.

Contact Us

If You have questions or complaints about this Privacy Policy or Our Personal Information handling practices, You may email Us at hello@castle-hr.com.

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