Hyperion Global Partners, LLC and its affiliates (“Hyperion,” “we,” or “us”) cares about your privacy.  This Privacy Policy sets forth how we handle information we obtain from you and learn about you when you visit our Web Site, located at www.hyperiongp.com and www.hgpresearch.com, and any subdomains of these sites (the “Web Site”).

Hyperion supports the right to privacy, including the rights of individuals to control the dissemination and use of personal data that describes them. Hyperion is committed to protecting personal data of the users of our Web Site, and utilizes technical and organization measures to protect your data. Hyperion supports and complies with domestic and international laws and regulations that seek to protect the privacy rights of such individuals.

We recognize that many visitors and users of this Web Site are concerned about the information they provide to us, and how we treat that information. This Privacy Statement has been developed to help you understand and describe how we collect, use, and disclose information that we obtain about users of our websites, services, and published materials.

Please review this Policy before you give us any information. By using our Web Sites or published materials or registering for our services and events, you consent to the collection and use of your information as described in this Policy.

If you have any questions or concerns regarding this Privacy Statement, please contact: DPO@hyperiongp.com.

Hyperion Global Partners, LLC is the data controller and has its principal place of business at 2245 Texas Drive, Sugar Land, Texas, 77479, USA.

Hyperion’s Data Protection Officer can be reached at DPO@hyperiongp.com or by mail at:

Hyperion Global Partners, LLC
2245 Texas Drive, Suite 300
Sugar Land, Texas 77479
USA

This Policy describes the following:

• What information we collect and how it is collected;
• How we use the information;
• With whom we may share information;
• Legal basis for processing the information;
• Your rights and choices;
• Security and storage of the information;
• Third party Web Sites;
• Users outside the United States;
• Changes to the Policy and Contact Information.

WHAT INFORMATION ABOUT YOU DO WE COLLECT?

When you visit our Web Site, you may provide us with two types of information: (1) personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you browse the Web Site. In some cases, if you choose not to provide us with requested information, you may not be able to access all of our Web Site’s content or services.

PERSONALLY IDENTIFIABLE INFORMATION YOU CHOOSE TO PROVIDE

When visiting our Web Site, you are not required to provide any personal data. Hyperion relies on consent or other lawful principles established for data collection under applicable laws. Therefore, you have the option to abstain from providing personal data when visiting publicly available portions of the Web Site.

However, when registering for an event, subscribing to receive our marketing materials or when purchasing or using our products or services or in other circumstances, we may ask you to provide some or all of the personal data listed below. If you have provided us with your personal data, you have the rights described below in the Your Rights and Choices section below.

Hyperion collects additional non-personal data as described in the subsequent section of this Notice (Additional Data Collection Activities).

Any data collected may be used in Hyperion’s business to provide you the products we offer and to aid in Hyperion’s sales and marketing efforts, and may result in you being contacted by Hyperion. In some cases, contact information may be required for Hyperion to create an account, enable delivery of materials requested on the Web Site or to otherwise communicate with you. This may include: providing product or other requested information, making responses to inquiries, registration for Hyperion events, and distributions for marketing purposes. You may also be able to register for Hyperion services through the Web Site.

For the purposes mentioned above, Hyperion may collect the following personal data about you:

• Full name
• Company name
• Company location
• Position in company
• Department
• Billing information
• Telephone number
• Email address

NON-PERSONALLY IDENTIFIABLE INFORMATION WE COLLECT

Hyperion automatically receives and records information about the use of the Web Site either directly or through third party tracking utility providers. This may include cookies, IP addresses, your browser type, operating system version, language settings, which locally installed Hyperion applications you use (if any) and how you use them, the web page you were visiting immediately prior to visiting our Web Site, pages of our Web Site that you visited, the time spent on those pages, information you searched for on our Web Site, access times and dates, and other statistics. This data is not combined with your personal data collected directly from you.

Hyperion utilizes cookies on its Web Site. Click here for Information About Cookies on this Hyperion Web Site.

Hyperion uses IP addresses to help diagnose problems and to administer the Hyperion Web Site. When you visit our Web Site, we recognize only your domain name and not your e-mail address. We will see your e-mail address only if you provide it or send us an e-mail message.

Hyperion does not ask you for, access or track any location-based information from your device. If Hyperion wishes to do so in the future to enhance our Web Site, Hyperion will specifically ask your permission.

As stated above, the collection of personal data is not required for accessing this Web Site. However, Hyperion collects the additional data for the maintenance and optimization of its Web Site.

HOW WE USE THE INFORMATION WE COLLECT

We use your personally identifiable information to provide you with the information or content that you have requested, and, in some cases, to contact you about our programs, products, features or services. If you no longer wish to receive press releases or any other type of information from us, you may send us an email through our “Contact Us” link.

We use non-identifying information collected on our Web Site in the aggregate to better understand your use of the Web Site and to enhance your enjoyment and experience. For example, we may use the information to improve the design and content of our Web Site or to analyze the programs and services that we offer.

We may employ other companies and individuals to perform functions on our behalf, and these vendors are data processors. However, any such processing is limited to facilitating Hyperion’s own activities. Hyperion does not share, sell or rent your personal information to any third parties for their promotional purposes.

Additionally, data processors utilized by Hyperion are subjected to Hyperion’s due diligence process and required to make contractual assurances that they will take adequate precautions to protect your data. Hyperion will require such service providers to adopt adequate technical and organizational security measures to ensure the processing of personal data only as instructed by Hyperion and for no other purposes.

We may provide access to your personally identifiable information when legally required to do so, to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorized use of our Web Site, to limit our legal liability and protect our rights, or to protect the rights and safety of visitors to this Web Site or the public. In those instances, the information is provided only for that limited purpose.

SECURITY OF YOUR INFORMATION

To help protect the privacy of data and personally identifiable information you transmit through use of this Web Site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

However, no data transmission over the Internet can be guaranteed to be completely secure. Accordingly, we cannot ensure or warrant the security of any information that you transmit to us, so you do so at your own risk.

CONSENT TO TRANSFER

This Web Site is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Web Site, participating in any of our services and/or providing us with your information, you consent to this transfer.

The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Hyperion relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, Hyperion collects and transfers to the U.S. personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Hyperion in a manner that does not outweigh your rights and freedoms. Hyperion endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship Hyperion and the practices described in this Privacy Notice. Hyperion also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.

THIRD-PARTY LINKS

This Web Site contains links to third party sites as well as to other sites owned and/or operated by Hyperion Global Partners. PLEASE BE AWARE THAT HYPERION GLOBAL PARTNERS IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF ANY THIRD-PARTY SITES. Please also be aware that the privacy policies of other Hyperion Global Partners sites may differ significantly from the privacy policy of this Web Site. Hyperion Global Partners acknowledges the potential liability in cases involving onward transfers of Privacy Shield data to third parties. Therefore, we encourage our users to read the privacy statement of each and every Web site that collects personally identifiable information. This Privacy Statement applies solely to information collected by this Web Site.

PRIVACY SHIELD

Hyperion complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union or Switzerland to the United States. Hyperion has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.

In accordance with our obligations under the Privacy Shield, and subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission, we hereby affirm our commitment to subject to the Privacy Shield Principles all personal data transferred from the EU in reliance on the Privacy Shield. This means that, in addition to our other obligations under the Privacy Shield Principles, we shall be liable to you for any third party agent to which we transfer your personal data and that processes such personal data in a manner that violates the Privacy Shield Principles, unless we can demonstrate that we are not responsible for the resulting damages.

If there is any conflict between the terms in this Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit the U.S. Department of Commerce’s Privacy Shield site.

YOUR RIGHTS AND CHOICES

REVIEW AND UPDATE OF ACCOUNT INFORMATION

You may access information that you have voluntarily provided to Hyperion Global Partners through your account on the Web Site, and to review, correct, or delete it by following the instructions on the Web Site, or contacting Hyperion Global Partners in writing as set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note we will retain and use your data, including server/backup copies, to comply with our legal obligations, resolve disputes, and enforce our agreements, and we may decline to process change or deletion requests that require disproportionate technical effort or jeopardize the privacy of others. Data subjects in Europe have additional rights as set forth in the section entitled “Your European Privacy Rights” below.

TRACKING TECHNOLOGIES GENERALLY

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device. Please be aware that if you disable or remove these technologies some parts of the Web Sites may not work and that when you revisit the Web Site your ability to limit browser-based tracking technologies is subject to your browser settings and limitations.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.

COMMUNICATIONS

If you decide at any time that you no longer wish to receive newsletters or promotional communications from us, please follow any unsubscribe instructions provided in our communications to you, update your user preferences via our subscription management tools on our Web Site, or contact us as set forth in the section below entitled “Contact Us” and specify your request. Please note that you cannot opt out of non-promotional e-mails, and we may use your information to contact you with important notifications, such as notices with respect to purchases, safety, or changes to our terms, conditions, and policies. Also, your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions.

YOUR EUROPEAN PRIVACY RIGHTS

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Web Site. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

The U.S. Federal Trade Commission has jurisdiction over Hyperion’s compliance with the Privacy Shield.

Rights you may have under Privacy Shield or applicable regulation, such as the General Data Protection Regulation (GDPR), are described below.

DATA SUBJECT RIGHTS

EVERYONE

You may request from Hyperion access to, correction of, blocking of and/or deletion of your personal data in line with applicable data protection law. You may also withdraw your consent for Hyperion to process your personal data.

PRIVACY SHIELD

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Hyperion commits to resolve complaints about our collection or use of your personal information. European Union residents with inquiries or complaints regarding our Privacy Shield policy should direct any such request and any other questions you may have with regard to the Privacy Shield Principles to Hyperion’s Data Protection Officer, whose contact information is listed in the introduction to this Notice.

Hyperion has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States, with a global presence. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit JAMS for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Under certain circumstances you may invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For more information please visit the U.S. Department of Commerce’s Privacy Shield Site.

GDPR

Data Subjects covered by the GDPR are afforded additional rights including:

• The Right to be Forgotten: you have the right to request the erasure of the personal data submitted to Hyperion; this means you can request Hyperion restrict your data from any further processing, and have your data deleted if possible.
• Complaints may also be submitted to the applicable supervisory authority in the European Economic Area, which includes the data protection authority in your locality (for example, in the U.K., the supervisory authority would be the Information Commissioner’s Office).

CHILDREN’S PRIVACY

Hyperion encourages parents and guardians to take an active role in their children’s online activities. Our Services are not aimed at people under 18 and Hyperion does not knowingly collect personal information from children without appropriate parental or guardian consent. If you believe that we may have collected personal information from someone under the age of 13 (or the applicable age of consent) without proper consent, please let us know using the methods described in the “Contact Us” section below.

HYPERION CUSTOMERS

Hyperion may also collect personal data from customers as required to provide support and delivery of Hyperion products and services. If you have an agreement in place with Hyperion for specific Hyperion products or services, that agreement takes priority over this Notice; a customer’s use of Hyperion or an affiliate’s products and services is governed by the terms of the contract between Hyperion or an affiliate and the customer.

UPDATES TO THIS PRIVACY NOTICE

Hyperion may update this Privacy Notice from time to time. If we modify this Privacy Policy, we will post the revised version here including the effective date of the updated Policy. We may also provide notification of material changes by other means such as posting a notice on our website.  Your use of the Service following any such notice will signify and constitute your assent to and acceptance of such revised Privacy Policy.

CONTACT US

If you have any questions about this Privacy Policy, including our compliance with Privacy Shield or applicable law, please feel free to contact Hyperion Global Partners directly:

• By e-mail at DPO@hyperiongp.com
• By mail at Hyperion Global Partners, LLC, 2245 Texas Drive, Suite 300, Sugar Land, Texas, 77479, USA

Revised: 25 October 2018