Last Updated: April 22, 2024
HTCD, Inc. (“HTCD”, “we”, “us” or “our”) respects the privacy of our Website visitors (“you” or “your”). This privacy policy (as posted on our website here at https://htcd.com/privacy and as amended from time to time and effective as of the date posted) (“Privacy Policy”) describes the types of information we collect from you or that you may provide when you visit or use our htcd.com website (“Website”), and our practices for collecting, using, maintaining, protecting, disclosing, retaining, and transferring that information. This Privacy Policy applies to the data collected by us, or those working on our behalf, through the information you enteror from the data imported from sources authorized or approved by us. It does not apply to data collected through third-party websites, or to products, or services not approved by us.
If you are acustomer, the collection, use, disclosure, etc., of Personal Information in connection with the services we provide customers (“Services”) is governed by the terms of our Subscription Agreement with your company, and this Privacy Policy does not apply to data collected under such agreement.
By visiting our Website in any manner you acknowledge that you accept the terms, practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, process, share, retain, and transfer your information as described herein. If you do not agree with our policies and practices, your choice is not to use our Website. Your use of our Website is at all times subject to our Terms of Use (available at https://htcd.com/terms and as amended from time to time and effective as of the date posted (the “Terms”)), which is incorporated by reference herein. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.
We are constantly working to improve our Website, and we may need to change this Privacy Policy from time to time as well. Our current Privacy Policy will always be on our Website at https://htcd.com/privacy and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates. Under certain circumstances, we also may elect to notify registered Users of changes or updates to this Privacy Policy by additional means, such as posting a notice on the Website or by sending you an email, but you should not rely on receiving such additional notice.
If you use the Website after any changes to the Privacy Policy have been posted, you agree to the new Privacy Policy. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.
This Privacy Policy covers our treatment of your personally identifiable information. “Personal Information” generally refers to any unencrypted or non-deidentified information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person. However, the definition of Personal Information may vary depending on the state or country in which you reside, and that state’s or country’s definition will apply to your Personal Information in the context of this Privacy Policy. Please see additional information below on the particular information we may collect.
If you are a citizen or resident of the European Economic Area (“EEA”), United Kingdom, or Switzerland, the definition of Personal Information is defined under the General DataProtection Regulation (“GDPR”) and you have certain rights; therefore, please see the section below entitled“GDPR”.
Personal Information does not include information publicly available from government records or information excluded by applicable law. Personal Information also does not include your Personal Information that has been de-identified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).
We also may collect Personal Information from you through means other than our Website. This may include offline collection, such as if you submit a paper application, make a payment by check, or call or visit our office. It also may include emails, or other electronic communications that you send to us separate from our Website or by way of our Service Providers (as defined herein). However, if we combine the Personal Information we collect from you outside of our Website with Personal Information that is collected through our Website or by another means as described above, the Privacy Policy will apply to the combined information, unless specifically disclosed otherwise.
Other than as stated herein, this Privacy Policy does not apply to information collected by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our Website. We are not responsible for the practices of sites linked to or from the Website, and before interacting with any of these sites you are advised to review their rules and policies before providing them with any private information.
We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under the age of 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.
We collect several categories of Personal Information from and about you as summarized in the following table:
The Personal Information we collect through our Website, or from our resellers, representatives, business partners, Service Providers, affiliates, divisions, subsidiaries, exhibitors, and sponsors may include the following:
Our Careers Website page (available here) contains a link which directs you to a third party’s website through which you can submit information or an employment application. This application will request certain Personal Information of you. That third party’s website has its own terms of use and privacy policy which you should review before submitting any Personal Information through that website. We may be provided your application, including some or all of the Personal Information (and other information) you submit.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including the following:
We do not allow personalized third-party behavioural tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
The technologies we use for automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF, IP address, and other technologies. Each of these is discussed below.
Browser Cookies
Browser cookies are small files placed on the hard drive of your computer or mobile device. They may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Browser cookies are managed by the web browser (Internet Explorer, Firefox, Safari, Google Chrome, etc.) on your computer or mobile device. Different types of cookies which have different purposes are used on our Website.
Essential Cookies
Essential cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.
Performance Cookies
Performance cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Website pages from their site and whether your visit has led to the use or purchase of a Service from our Website, including the references for the Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.
Functionality Cookies
Functionality cookies enable our Website to remember the choices you have made when browsing. For example, we can store your general geographic area (but not precise geolocation) in a cookie so that the Website corresponding to your geographic area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies also may be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
It is possible that you will come across third-party cookies on some pages of sites that are not under our control.
We also use cookies such as functionality cookies to implement tracking technology on our Website. This allows us to display advertising that is tailored to you on our Website, to understand which parts of our content interest you the most, and which Service categories you request. This tracking uses De-Identified Personal Information data. Some of our Service Providers are allowed to place cookies on our Website. Those companies also may provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.
At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected; e.g., you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Local Storage Cookies
Certain features of our Website may use local stored objects to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.
Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
In addition to using cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our Services and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we also may be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.
We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
Our servers (or those of our Service Providers) automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.
We respond to the Global Privacy Control (“GPC”) signal. The GPC signal is a browser-level signal that can reflect the desire to opt-out of having Personal Information shared or sold. Some browsers allow transmission of GPC signal. By broadcasting this signal, We will not transmit your Personal Information to third parties who perform analytics services or who advertise to you based on this information. Please note that when your browser broadcasts the GPC signal, we will limit the functionality of our Website and prevent the Website from transmitting your Personal Information to third parties. We will also treat this GPC signal as a verified request to stop selling your Personal Information and stop processing your information for purposes of targeted advertising. However, the GPC signal does not fully identify you by name or email address. Therefore, we may not be able to honor this request for other interactions you may have or have had with us. You may also submit an opt-out privacy request with your email, phone number and other Personal Information for us to complete the opt-out process.
We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website.
Some content or applications, including advertisements, on the Website is served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect or compile information regarding user interactions with ad impressions and other ad service functions as they relate to our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website. More information on how to opt-out of third-party advertiser tracking mechanisms is available here.
We use tools provided by Google as described below.
Google Analytics. We use, and/or some of our third-party Service Providers may use, Google Analytics or other analytics service to help us understand the use of our Website and Services. Google Analytics is a web analysis service provided by Google. Google utilizes data it collects to track and examine the use of our Website to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. The Personal Information collected and processed may include cookies, usage data, and other internet information. Such service providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.
Google reCAPTCHA. We use Google reCAPTCHA, which identifies bots by collecting hardware and software information and sending that data to Google for analysis. More about Google reCAPTCHA is available here.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.
We use tools provided by Microsoft as described below.
Microsoft Clarity. We use, and/or some of our third-party Service Providers may use, Microsoft Clarity or other analytics service to help us understand the use of our Website and Services. Microsoft Clarity is a web analysis service provided by Microsoft. Microsoft utilizes data it collects to track and examine the use of our Website to prepare reports on its activities and share them with other Microsoft services. Microsoft may use the data collected to contextualize and personalize the ads of its own advertising network. The Personal Information collected and processed may include cookies, usage data, and other internet information. Such service providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.
We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:
We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice thereof.
We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; and/or, (f) help you efficiently access your information after you sign in.
We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more of the following purposes:
We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third-party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, data analysis, credit checks, screening checks, collection services, marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, providing search results and links (including paid listings and links), processing credit card payments, or managing our conferences and other events. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).
From time to time, we may conduct events, run contests, make special offers, or other activities (“Events”), possibly together with an exhibitor, sponsor or other Service Provider. If you provide information to such third parties, you give them permission to use it for the purpose of that Event and any other use to which you consent. We cannot control such third parties’ use of your information. If you do not want your information to be collected by or shared with such third parties, you can choose not to participate in these Events.
Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process (e.g., subpoena), including, but not limited to, in order to respond to any government, regulatory, or licensing request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, service providers, or partners, or investigate, prevent; (b) enforce our Terms or customer agreement (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations or to investigate, prevent, or take action regarding suspected or actual illegal activities; (e) assist government enforcement agencies or to meet national or other security requirements; (f) to protect the security or integrity of our Website and Services; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others. We will attempt to notify you, where practicable, about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of harm to an individual or group, or create or increase a risk of acts of fraud done upon us or our users. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
We may share De-Identified Personal Information with third parties for any purpose except as prohibited by applicable law. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Website. It may be utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose.
You consent (and shall not object) to our disclosure, transfer, and/or sale of your Personal Information, De-Identified Personal Information, and other information you provide to us, as well as the rights you have granted or consented to in this Privacy Policy (collectively, “Transferred Information”) to a potential or actual buyer or acquirer of assets or equity of our company or other successor for the purpose of considering or undergoing a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. We cannot make any representations regarding the use or transfer of Transferred Information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. Furthermore, except as required by law, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the Transferred Information that is disclosed to us.
We have implemented technical, administrative, and organizational security measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, destruction, alteration and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of Service Providers who have special access rights to our systems, and who are required to keep the information confidential. Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safe.
Our agents, contractors, Service Providers, and partners who require access to your Personal Information in order to provide services to us or to you on our behalf are also required to keep the information confidential in a manner consistent with this Privacy Policy and are not permitted to disclose the information to third parties or use the information for any purpose other than to carry out the services they are performing for us, or as permitted pursuant to our agreement with them.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, or hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or used with our Services. You hereby release and forever discharge us and our affiliates, subsidiaries, officers, directors, employees, and agents, and their respective successors and assigns, and you will indemnify, defend and hold us harmless, from and against any liability, claim, or cost (including attorneys’ fees), arising directly or indirectly from any failure by you to maintain the security of your email that directly or indirectly results in an unauthorized third party having access to such email or causes us to transfer funds based on instructions purporting to have originated from you (i.e., “wire transfer fraud” or “business email compromise” events).
In general, the time period for which we retain your Personal Information depend on the purposes for which we use it. We will retain your Personal Information for as long as we have a legitimate business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration. We will also retain Usage Data for analytics purposes. “Usage Data” refers to data collected automatically (for example, the duration of a page visit). 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.
We have the right to delete all of your Personal Information and other data at any time without notice to you. We may retain De-Identified Personal Information for as long as we deem appropriate.
If you prefer not to receive marketing-related communications from us, please let us know by clicking on the unsubscribe link within a marketing message or newsletter you receive, or by updating your email preferences under your profile, or by contacting us. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You cannot opt out of receiving Service-related notices by email.
By providing us with your phone number and/or email address you consent to our using the email address and/or phone number to send you Service-related notices by email or by calling you, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail. You also agree that we may send you notifications by email, phone, or text, of activity regarding our Services, the Website, your Personal Information, or any aspect of our relationship, to the email address or phone number you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, where available, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
If you have any questions about this Privacy Policy or our privacy practices, please contact us: by email at legal@htcd.com; or, by mail at HTCD, Inc., Attn: Legal, 111 Congress Ave., Suite 500, Austin, TX 78701
We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. You consent to our and our service providers’ transmission and/or transfer of your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.
If you are a resident or citizen of the UK, European Economic Area (“EEA”), or Switzerland, please see the section below on GDPR compliance.
If you are a citizen or resident of the UK, EEA, Switzerland, or other regions with laws governing data collection and use that may differ from the laws in the United States, please note that we may transfer your information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. We may do so to process your information by staff, contractors, or service providers operating outside the these countries who work for us.
If you are a resident of a country other than the United States, you acknowledge and consent to our (and our service providers) collecting, transmitting, processing, transferring, and storing your Personal Information out of the country in which you reside.
The following provisions apply only if you are a citizen or resident of the UK, EEA, or Switzerland (collectively referred to in this section for convenience as the “EU Region”). For such citizens or residents, all processing of your Personal Information is performed in accordance with privacy rights and regulations, in particular, (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (“GDPR”, and which includes the UK’s similar law), and our processing will take place in accordance with the GDPR. For purposes of the GDPR, we will be the “data controller” of Personal Information (defined in the GDPR (available here) as “Personal Data”, but still referred to herein as Personal Information) we collect through the Website, unless we collect such information on behalf of a “data controller” in which case we will be a “data processor.” This Privacy Policy does not apply to websites, applications or services that do not display or link to this Privacy Policy or that display or link to a different privacy policy. For EU Region residents and citizens only, to the extent any definition in this Privacy Policy conflicts with a definition under the GDPR, the GDPR definition shall control.
We provide adequate protection for the transfer of Personal Information to countries outside of the EU Region through one or more of the following methods: (a) a series of intercompany agreements based on or incorporating the Standard Contractual Clauses, (b) we may rely on the European Commission’s adequacy decisions about certain countries, as applicable, (c) we may obtain your consent for these data transfers from the EU Region to the United States to other countries, (d) we may adopt binding corporate rules, or (e) to the extent applicable, we may rely on derogations as set forth in GDPR Article 49 for the transfer and onward transfer of Personal Information collected from individuals in the EU Region to the United States and other countries that the EU Region may view as not providing adequate data protection. Regarding method (e), we may transfer Personal Information to a third party to perform a contract with you, with your explicit consent or in a manner that does not outweigh your rights and freedoms. If this Personal Information is not processed and transferred, we will not be able to execute the contract with you or you will not have access to any or all the benefits and features associated with your transaction.
We also may need to transfer your Personal Information to other group companies or service providers in countries outside the EU Region. This may happen if our servers or suppliers and service providers are based outside the EU Region, or if you use our or Services while visiting countries outside these areas.
If you are a visitor using our Website from the UK, EEA, or Switzerland, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only where we need the Personal Information to provide and/or perform our Services, or where the processing is in our legitimate interests or rely upon your consent where we are legally required to do so and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we also may have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.
The collection and processing of your Personal Information may be necessary for the purposes of our legitimate interests. Such legitimate interest purposes may include:
If you are subject to GDPR, your rights include the following: