Privacy policy

Last revisited: 4 December, 2022

1. Introduction

High-Performing Leaders Institute wants all of its online visitors to be confident that we process information about you in accordance with applicable privacy legislation. Our Privacy Policy describes how High-Performing Leaders Institute handles and protects your personal data in our capacity as a data controller. It also describes your rights and how to proceed in case you wish to exercise them.

Customers who subscribe to High-Performing Leaders Institute services, such as participants in our programs, are contractually obligated to comply with the agreement, terms and conditions. Please see our general Terms & Conditions for more information about our data processing when you apply to a High-Performing Leaders Institute program.

High-Performing Leaders Institute is committed to respecting your privacy and protecting your personal data – any information that may identify you as an individual person and which is collected via our digital channels links to this Privacy Policy.

It is important to us at High-Performing Leaders Institute that you feel safe in our processing of your personal data. High-Performing Leaders Institute would never knowingly sell or release your personal data to another party in other ways than as follows from this Privacy Policy and you are always welcome to contact High-Performing Leaders Institute if you have any questions.

2. The personal data we process – and why

2.1 Application to our programs

2.1.1 Type of processing

Identification;
Correspondence regarding the application procedure;
Handling of payment such as forward invoices (this may also include control of payment history and collection of credit information) and the use of third-party PCI-compliant service providers;
Internal record keeping and audits.

2.1.2 Categories of personal data

Name, e-mail address, invoice address, company name, personal identification number or organizational number, phone number, correspondence.

2.1.3 Legal ground

The legal ground for processing is the performance of the agreement with you. Data collection is required to fulfill our rights and obligations under the agreement with you (please see our Terms & Conditions). Should the requested information not be provided, High-Performing Leaders Institute may not be able to fulfill its obligations according to the agreement and may, therefore, deny your application.

2. 1.4 Retention period

The retention period is 36 months following collection of the data.

2.2. Compliance with legal obligations

2.2.1 Type of processing

Necessary administration for the fulfillment of the company’s legal obligations (e.g. laws and regulations related to bookkeeping, tax payments).

2.2.2 Categories of personal data

Name, email, company name, personal identification number or organizational number, phone number.

2.2.3 Legal ground

The legal ground for processing is compliance with legal obligations to which High-Performing Leaders Institute is subject. The processing is necessary to fulfill our legal obligations. In case data is not provided High-Performing Leaders Institute may not approve your application.

2.2.4 Retention period

The retention period as legally required (e.g. 7 years under the Swedish Bookkeeping Act).

2.3. Customer service

2.3.1 Type of processing

Questions regarding services, programs etc. via phone or digital channels (incl. social media);
Identification;
Claims and support (incl. technical support)

2.3.2 Categories of personal data

Name, contact info (phone number, email, address), company name, personal identification number or organizational number, your correspondence, info about your purchase and potential error/complaints.

2.3.3 Legal ground

The legal ground for processing this data is legitimate interest. The processing is necessary to administer yours and our need to process customer/student service matters. The secondary reason is consent where you have provided your consent to receive a requested syllabus and product related information.

2.3.4 Retention period

The retention period is 36 months following collection of the data or the consent is revoked.

2.4. Administration of invitations to events and newsletters

2.4.1 Type of processing

Identification;
Correspondence, surveys and evaluation regarding the event such as confirmation of registration, requests and evaluations.

2.4.2 Categories of personal data

Name, contact info (phone number, email), company name, personal identification number or organizational number, information from evaluations and other personal preferences.

2.4.3 Legal ground

The legal ground for processing this data is legitimate interest. The processing is necessary to adhere to our and our customers’ legitimate interest to evaluate, develop and improve our services and systems. The secondary reason is consent where you have provided your consent to receive our invitations and newsletters.

2.4.4 Retention period

The retention period is 36 months following collection of the data or consent is revoked

3. Sources of information

Generally speaking, High-Performing Leaders Institute only processes data you have provided or that we register based on your purchases and the use of our services. In certain cases, High-Performing Leaders Institute may supplement this data with information from third parties for the purpose of evaluating and improving our digital channels and services.

The information that High-Performing Leaders Institute could collect from third parties is as follows:

Address information from public registries to ensure we have the right address;
Information from social media for marketing or anti-fraud purposes.

3.1 Information to other parties

3.1.1 Data processors

Other than as provided in this Privacy Policy, High-Performing Leaders Institute will not knowingly share personal data you provide with any third party. In cases where it is necessary for High-Performing Leaders Institute to carry out our services, we may retain external suppliers (processors) for services in connection to our digital channels or the services. These suppliers may process personal data and sometimes require limited access to personal data collected via our digital channels or services. High-Performing Leaders Institute may use the following types of suppliers:

Payment solutions (banks, other payment service providers);
Marketing (social media, CRM providers);
IT (companies that handle necessary operations, technical support and maintenance of our IT solutions, such as Google, Zoom);
Events, statistics and surveys (companies that handle evaluations, statistics and surveys of our services).

High-Performing Leaders Institute endeavors to limit third-party access and only share information that is necessary to enable suppliers to carry out their work. High-Performing Leaders Institute always checks that our suppliers can meet our high standards and provide sufficient safeguards and require them to protect your personal data in accordance with this Privacy Policy and refrain from using or disclosing your personal data for any purpose other than providing High-Performing Leaders Institute with the agreed product or services.

3.1.2 Transfers to third countries

High-Performing Leaders Institute tries at all times to keep personal data within the European Economic Area (EEA) but engage suppliers located outside of the EEA such as Google and Zoom. During support and maintenance, High-Performing Leaders Institute may have to transfer the information outside of EEA, also when High-Performing Leaders Institute shares data with our group companies in order to carry out our services. Any such data will always be kept to a minimum relevant for the purpose. No matter where your personal data is transferred High-Performing Leaders Institute always takes appropriate technical and organizational measures to ensure that the security level is the same as in the EEA and at an adequate security level, for example by using the EU Commission’s Standard Clauses.

4. Amendments to the privacy policy

High-Performing Leaders Institute reserves the right to change this Privacy Policy. Changes to the terms of the policy will be notified by email, one month before the change of terms enters into force. The current terms and conditions are available at highperformingleaders.institute/privacy-policy

You should not supply High-Performing Leaders Institute with any personal data if you do not accept changes which are made to this Privacy Policy.

5. Deletion of data

Personal data will not be stored for longer than is necessary in light of the purposes of the processing and, in general, High-Performing Leaders Institute will delete personal data in the manner which follows from applicable legislation. Where information is known to be unreliable, irrelevant or excessive, it will be securely deleted or access will be removed, as soon as is reasonably possible.

6. Your rights

You are entitled once each year and free of charge to request information regarding the personal data, if any, about you which High-Performing Leaders Institute processes and to have any erroneous information corrected. Please note that High-Performing Leaders Institute may request additional details about you in order to ensure secure and effective handling of your request and to ensure that the information is provided to the correct person.

Should you have reason to believe that any personal data that High-Performing Leaders Institute holds about you is inaccurate, please let us know and we will update the information.

You may request us to delete personal data we hold about you. For example, if the information is no longer necessary to fulfill the purpose they were collected for, they are processed in an illegal way, or you opt out from direct marketing. Please note that, when legally required, High-Performing Leaders Institute could decline your request, for example if the data is needed for tax or bookkeeping purposes, or are necessary to defend legal claims.

You always have a right to opt out from direct marketing activities and request limitation of processing based on legitimate interest – including potential profiling for direct marketing purposes.

7. Links

Our digital channels may include links to websites which are provided by other group companies or companies which do not belong to High-Performing Leaders Institute. This Privacy Policy shall not apply to such websites. You should therefore review the privacy policy of any such website before you provide personal data.

8. Security

High-Performing Leaders Institute takes all appropriate technical and organizational security measures which are necessary to the safeguard personal data against unauthorized access, modification, or destruction. However, providing personal data over digital channels always entails a risk since it is not possible to completely protect technical systems from unauthorized access.

9. Social media and external websites

The High-Performing Leaders Institute website can in the future contain social media features, such as a Facebook ‘Like’ button and widgets (for example ’Share this’ button). These features may collect your IP address, which pages you visit on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by third parties or directly on our website. This Privacy Policy does not apply to these features. Your interactions with these features are governed by their privacy policies and other routines of the companies providing them.

Our website may provide hyperlinks to other websites. High-Performing Leaders Institute does not control, and is not responsible for, the content or practices of other websites.

Contact information If you have any questions regarding our Privacy Policy or any other question regarding our processing, please contact us:

C/o Liungman

Growth by Liung AB

Döbelnsgatan 31

11358 Stockholm

Or email hello@highperformingleaders.institute

In case your personal data is not being processed in accordance with this Privacy Policy or with the General Data Protection Regulation (EU) 2016/679, you have the right to file a complaint with Integritetsskyddsmyndigheten (former Datainspektionen) in Sweden, Information Commissioner’s Office (ICO) in the UK or any other European Supervisory Authority.