General Business Operations 

We use contact information to market, sell, and service Hiteks Products, subject to your consent where required by law. We allow recipients of marketing messages and collateral to opt out of receiving further communications from Hiteks at any time without detriment. We use your financial or payment information, and your contact details, to support, establish, and conduct customer relationships if you were to purchase a Hiteks Product or service. For example, your data would be necessary for the performance of our terms of service with you (including, for example, completing purchase transactions, fulfillment of an order, order confirmations, responding to requests for information about products and services, and the provision of purchased products and services). If you fail to provide the personal data we need, we may be unable to complete your transaction. We use personal data from employment applications where necessary to support our legitimate interest in processing your application and to contact you if future opportunities arise. We use personal data of individuals associated with proposed resellers, co-development partners, and distributors to conduct reference and background checks before entering into a contract and as necessary for compliance with legal obligations to which we are subject

Data Processed Within Our Products 

We use the personal data that is processed within our Products, such as voice data within voice recognition products, medical data within medical data products, personal data processed in communications products, biometric data processed in our biometric products, and any personal data contained within product usage data we collect, to deliver our Products sold to Hiteks customers and for our legitimate interests and business purposes in tuning, maintaining, enhancing, and developing Products. A small percentage of audio recordings received by Hiteks, which may include personal data, are reviewed by human reviewers and transcribed into text for Hiteks’s product maintenance and improvement efforts. We never use this data, referred to as “Product Personal Data,” for marketing purposes; and we never sell or transfer your data to third parties for the third party’s own purposes.We use aggregated, non-identifying, electronic data collected from use of our Sites and Products to operate, analyze, improve, and develop our Sites and Products. This information is not used to inform decisions about specific individuals; rather, it is processed to understand how different categories of users interact with our Sites and Products so that we can consistently provide our Products.

When We Share Personal Data

We do not sell your personal information.

Hiteks does not sell your personal information. However, we may share certain personal information for a business purpose. If we share your personal data (including Product Personal Data) with affiliates, co-development partners, or with vendors acting on our behalf, we do so under binding agreements that require the third party to use and protect the personal data in accordance with the principles described in this Privacy Statement. These third parties are authorized to use your personal data only as necessary to provide services to us.

We may share Personal Data in the following situations:

• With our affiliates and subsidiaries and with vendors acting on our behalf to perform services for Hiteks for a specific business purpose, support the Sites or the delivery of Products;
• With the customer on whose behalf and at whose direction we are processing the data; and
• When we have your consent to use your Personal Data for a specific purpose.

We may share personal data with our affiliates, co-development partners, subsidiaries, resellers, suppliers, sub-contractors, and distributors, and with vendors acting on our and their behalf, to service our customers and perform any contract we enter with you (including, for example, with resellers who support our management of potential clients and vendors who conduct transcription in connection with our products and services). We may also share aggregated, anonymous, or non-identifiable electronic data with our affiliates, co-development partners and with vendors acting on our behalf. We may share personal data derived from Site usage (excluding Product Personal Data), with analytics and search engine providers that assist us in the improvement of our Sites, subject to the cookie section of this Privacy Statement. Our Sites may use Google Analytics. The way Google collects and processes data when delivering Google Analytics is described here. We may share personal data from employment applications with vendors acting on our behalf who help us in recruitment, background check and human resources matters. We may also share personal data to comply with law and legal process, to respond to governmental inquiries and lawful requests from by public authorities (including to meet national security or law enforcement requirements), and to protect life, property, or the security of Hiteks or its customers. If Hiteks enters any merger, acquisition, or asset sale of all or any part of its business, personal data held by Hiteks may be transferred to a buyer or successor entity.

Control Of Your Personal Data

You can change your preferences to opt out of marketing communications at any time by completing the Privacy Request  webform. Alternatively, please follow the opt-out instructions in the relevant communication. If you opt out, we will retain your email address to confirm that we do not send you further communications. If you have submitted an employment application to Hiteks or if your personal data has been collected by Hiteks to review a proposed reseller or distributor relationship, you may contact us by completing the Privacy Request webform to request deletion of your data. We will respond to your request within a reasonable timeframe. If you wish to access, correct, or request deletion your Product Personal Data, you may contact us by completing the Privacy Request  webform. Hiteks generally processes Product Personal Data on behalf of our healthcare, enterprise, and corporate customers. If you contact us, we may direct your inquiry to our customer on whose behalf the Product Personal Data is being processed. We will make reasonable efforts to delete your Product Personal Data upon your request within a reasonable timeframe. Hiteks may refuse your request to access, request or delete Product Personal Data where entitled to do so under applicable law. If you have submitted Product Personal Data to Hiteks using your own user account which allows you to control your own data, you may delete the data you submitted by logging into your account and following the guidelines in the help system.

Location Of Processing and Cross‑Border Transfers

Hiteks operates in many countries. We may transfer personal data across international borders and may process personal data in jurisdictions other than the location of original collection.

We may transfer personal data that we collect to other Hiteks affiliates or other companies performing support functions on our behalf (each as described above) based in other countries including to the United States, India or the Philippines or other countries outside the European Economic Area or your country of residence and this personal data lawfully may be stored and/or processed in such countries. Whether your personal data is processed within your country of residence or beyond, we will take steps to ensure that your data is subject to appropriate safeguards required of us under the Privacy Statement, applicable data protection laws, and appropriate legally recognized data transfer adequacy mechanisms. Personal data that is transferred outside your country of residence may be subject to lawful access by courts, law enforcement and other governmental authorities in accordance with the laws of the foreign jurisdiction.

General Data Protection Regulation (“GDPR”)

General Data Protection Regulation (“GDPR”)

Hiteks has a range of privacy and security controls across its organizations to ensure compliance with the General Data Protection Regulation (GDPR), including, but not limited to:

• GDPR-compliant data protection agreementswith all customers for whom Hiteks Processes Personal Data;
• A PIA driven process to ensure that all products and services are built with Privacy By Design;
• An extensive, on-going training program for its employees, with data privacy and protection education upon hiring and then again at least on an annual basis;
• State-of-the-art technical and security measures, including data encryption at rest and in transit;
• Records of processing which include mapped storage and transfer of Personal Data throughout Hiteks’s product-lines;
• Appropriate access right limitations;
• Company-wide systems for protecting Data Subject rights, ensuring that individual access/portability/right-to-be-forgotten rights are respected; and
• Appointment of a Data Protection Officer.

Whenever Hiteks transfers personal information beyond the country of origin, we will do so in accordance with applicable laws. In the context of its European operations, Hiteks may transfer Personal Data abroad to other states in the European Economic Area or to third countries. With the decision by the Court of Justice of the European Union in the Schrems II case, Hiteks has evaluated the data transfers necessary for its multinational operations. In light of Schrems II, Hiteks will ensure that importers of any Personal Data offer an adequate level of protection, whether through an adequacy decision or appropriate safeguard under Article 46.  To the extent Personal Data processed by Hiteks would be transferred to a country outside the EEA not deemed to ensure an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of Personal Data, Hiteks has in place requirements relating to such international data transfers. For example, where data is transferred: (i) between Hiteks affiliates, this is done pursuant to an agreement based on the EU’s Data Export Contractual Clauses, and (ii) to third parties, Hiteks uses standard contractual clauses designed to ensure those third parties respect the confidentiality of personal data and use it only in connection with provision of specific services and in compliance with applicable data privacy laws. The EU Standard Contractual Clauses can be viewed on the European Commission’s website here.  As per the guidance of the European Data Protection Board, Hiteks has implemented programs to review such data transfers and to employ additional safeguards when appropriate for the data processing required by law and our customer contracts.

With respect to personal data received or transferred, Hiteks and its U.S. Subsidiaries are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Storage and Security

We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. Information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using current PCI-DSS standards. If Hiteks has issued you a password, you are responsible for keeping the password confidential. If you have any questions about the security of your personal data, you can contact us for more information by completing the Privacy Request webform. We retain personal data to the extent necessary to provide Products to our customers, employees, and prospective employees. Generally, we retain personal data for as long as you remain an active customer or user of our Sites and Services and for 3 years afterwards, or otherwise as required for our business operations or by applicable laws. We will permanently destroy biometric data when the initial purpose for collecting or obtaining such data has been satisfied, or within 3 years of your last interaction with us, whichever occurs first. Different retention of personal data may be necessary under contractual terms with the data controller for whom we provide services, for fraud prevention, to identify technical problems, or to resolve legal proceedings. Images added to PowerShare are automatically deleted after 45 days.  We may retain non-personally identifiable aggregate information beyond this time for research purposes and to help us improve and further develop our Products. You cannot be identified from aggregate information retained or used for these purposes. Any record of a stated objection by you to receiving marketing communications will be retained by us so that we respect your wishes by not contacting you further.

Children

If a Hiteks customer puts Hiteks voice recognition Product technology in a customer product or service that is likely to be accessed by children, Hiteks may receive speech data from product users to provide voice recognition to the user. This is a function of how Hiteks’s voice technology works. This means that if the user is under the age of 16, Hiteks may receive personal data from children under the age of 16. It is the responsibility of the Hiteks customer to obtain any consents required under applicable law, including under the Children’s Online Privacy Protection Act and relevant data protection laws, for the collection of such personal data.

Except as described in the preceding paragraph, Hiteks does not sell services to children and does not knowingly collect personal data directly from children under the age of 16. Hiteks has adopted a policy that Hiteks will not provide hosted services to primarily child-directed websites and online services. No child under 16 should directly submit personal data to Hiteks. If you become aware that a child under the age of 16 has submitted personal data to Hiteks except as described in the preceding paragraph, please inform us by completing the Privacy Request webform and we will promptly delete the data.

Your Rights

You may have the right under applicable laws in certain circumstances to:

• ask for access to details of the personal data held by us about you, free of charge;
• to request the rectification, restriction or erasure of your personal data held by us;
• to object to the processing your data;
• to request that any personal data provided by you, be transferred to a third party.

Hiteks never sells or transfers your data to third parties for the third party’s marketing purposes. You can object to receiving further marketing from Hiteks at any time without detriment.

Hiteks partners with a third party to display advertising on our website or to manage our advertising on other sites. Our third-party partner may use cookies and similar tracking tools in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising. Please note you will continue to receive generic ads.

You can also exercise the rights listed above, or write to us with any complaints, at any time by contacting us, specifying the nature of your request, at:

Privacy Request webform. Alternatively, you may contact us at privacy@Hiteks.com or by mail (Worldwide) at:

Chief Privacy Officer
525 Junction Road, Suite 6500 Madison, Wisconsin 537 USA

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.

California Residents Rights

If you are a California resident, as defined in the California Code of Regulations, you have rights under the California Consumer Privacy Act of 2018 (“the CCPA”). Below are the disclosures about your personal data and a description of your rights.

Categories of information we collect and disclose for a business purpose

We may collect the following categories of personal information, as defined in the CCPA, from you in connection with the products and services you have purchased from Hiteks. In addition, during the past twelve months, we may have disclosed these categories of personal information for a business purpose:

• Identifiers, such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar identifiers.
• Personal information categories listed in the California Customer Records provisions, including telephone number, and payment information, such as your credit card number.
• Healthcare Information
• Characteristics of protected classifications under California or federal law, such as your gender
  and age.
• Commercial information, such as the record of Hiteks products or services purchased, obtained or considered.
• Internet or other electronic network activity information, such as session logs.
• Geolocation data.
• Audio, electronic, visual, or similar information, such as voice recording, voice prints, keystrokes and photos.
• Professional or employment-related information.
• Inferences drawn from any of the above information to create a profile reflecting your preferences, characteristics, behavior, abilities, and aptitudes.

According to California law, personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.

Other disclosures about your personal information

• This Statement provides additional disclosures about your personal information as required by the CCPA. Refer to the following sections to learn more about the sources of personal data we collect, the business or commercial purposes for which we use personal data, and the categories of third parties with whom we share personal data.

Your Rights and Choices

In addition to the above, the CCPA provides you with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  — We do not provide these access and data portability rights for B2B personal information. You may send us a request to correct inaccurate personal information.

Deletion or Correction Request Rights

You have the right to request that we delete or correct your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) or correct, as applicable, your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Exercising Your Rights

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You can also exercise the rights listed above, or write to us with any complaints, at any time by contacting us, specifying the nature of your request, at:

Privacy Request webform. Alternatively, you may contact us at privacy@Hiteks.com or by mail (Worldwide) at:

Data Protection Officer or Chief Privacy Officer
Hiteks Solutions, Inc.
525 Junction Road, Suite 6500 Madison, Wisconsin 537
USA

Hiteks Employees and Contingent Workers

This Privacy Statement does not cover Hiteks’s collection of personal data from employees and contingent workers, which is described in a separate HR Privacy Statement made available to Hiteks personnel.

Changes To This Privacy Statement

We may update this Privacy Statement from time to time by publishing an updated version on Hiteks’s Sites. Each updated version will include the date the statement was last updated. Please review the latest version of this Privacy Statement periodically to keep current with Hiteks’s use of personal data. If we make material changes in the way Hiteks uses or shares personal data, we will publish the updates on our Sites. Any such material changes will only apply to personal data collected after the revised Privacy Statement takes effect.

Updated: February 11, 2023.