Effective Date: July 16, 2019
WORKPLACE21, Inc. (“WP21”) provides a technology solution designed to help workplaces be more human. Our technology service (“Service”) understands humans at work and helps businesses and users achieve higher performance and professional growth.
3.1 Types of Personal Information We Collect
WP21 collects Personal Information regarding its current, prospective, and former customers and their Employees, users, visitors, and guests (collectively “Individuals”).
Information You Provide Directly to Us.
WP21 collects Personal Information regarding its current, prospective, and former customers and their Employees, users, visitors, and guests (collectively “Individuals”).
Communications with Us.
We may collect Personal Information from you such as name, address, phone number, emails and email address, resume, social media logins, or mailing address when you choose to request information about our Services, create an account, register for our newsletter or blog, request to receive customer or technical support, or otherwise communicate with us.
From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or Services and in any manner consistent with the policies provided herein.
Our social media sites and Services may contain interactive functionality that allow you to engage with other users on our Facebook page, to participate in surveys, and otherwise to interact with the Services and with other users. If you use any interactive functionality that requests or permits you to provide Personal Information (including, for example, any Services that allow you to post User Materials on any of our Services), we and/or Third Party Services collect the Personal Information that you provide in the course of using these interactive features. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
Automatic Data Collection.
We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, unique identifiers, mobile carrier, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
Information from Other Sources.
We may receive information about you from other sources, including through Third Party services and organizations to supplement information provided by you.
3.2 How WP21 Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested.
WP21 may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Generally manage Individual information and accounts;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of our Services;
- Contact you to answer requests for customer support or technical support; and
- Allow you to register for events.
Information We Process on Behalf of Our Customers
- If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with us to use the Service to Process this data. Our customers control the Personal Information in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our customers to address any concerns you may have, in accordance with the terms of our contract with them.
We may use Personal Information about you for its administrative purposes, including to:
- Measure interest in our Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity;
- Communicate about Individual accounts and activities on our Services and systems, and, in our discretion, changes to any WP21 policy;
- Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- Process payment for products or Services purchased;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities; or
- Enforce our terms.
Marketing Our Products and Services.
WP21 may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and Services that may be of interest to you;
- To provide Services to you and our sponsors; or
- For other purposes disclosed at the time that Individuals provide Personal Information.
- You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described below.
Research and Development.
WP21 may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, WP21 may perform research (online and offline) via surveys. We may engage Third Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share de-identified Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing.
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on WP21’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions below.
De-identified and Aggregated Information Use.
WP21 may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Site and the Services. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within WP21 and with Third Parties for our or their purposes in a de-identified or aggregated form that is designed to prevent anyone from identifying you.
WP21 may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, LOCAL STORAGE, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site and/or Services may not work properly.
Local Storage and Local Shared Objects:
We use local shared objects such as cookies and local storage to enhance your experience by storing your user preferences, behavior, and settings on the Site and Services. Local storage is similar to browser cookies but can store more data. Like cookies, local storage can only access personal data that you have provided or actions you have taken on the Site or Services. Various browsers may offer their own management tools. If you block or delete local storage, the Site and/or Services may not work properly.
Pixel Tags/Web Beacons.
A pixel tag (also known as a web beacon) is a piece of code embedded on the Site and in our Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Social Media Buttons and Widgets:
We may use analytics services such as Google Analytics and LinkedIn Analytics to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop Site content. For more information about Google Analytics, please visit google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. For more information about LinkedIn Analytics, please visit http://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences?lang=en.
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related.
We may use first-party or Third Party cookies and web beacons to deliver content, including ads relevant to your interests on Third Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our Site, Services, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third Party Websites, Social Media Platforms, and APIS
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about Third Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Site and our other Services may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such Third Party services you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes.
We may use Third Party code, SDKs or APIs as part of the functionality of our Services.
4 HUMAN RESOURCES DATA
WP21 collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals. We Process Human Resources Data for a variety of business purposes including:
- Workflow management, including assigning, managing and administering projects;
- Human Resources administration and communication;
- Payroll and the provision of benefits;
- Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
- Job grading activities;
- Performance and Employee development management;
- Organizational development and succession planning
- Benefits and personnel administration;
- Absence management;
- Helpdesk and IT support services;
- Regulatory compliance;
- Internal and/or external or governmental compliance investigations;
- Internal or external audits;
- Litigation evaluation, prosecution, and defense;
- Diversity and inclusion initiatives;
- Restructuring and relocation;
- Emergency contacts and services;
- Employee safety;
- Compliance with statutory requirements;
- Processing of Employee expenses and travel charges; and
- Acquisitions, divestitures, and integrations.
5. Onward Transfer—How we May Disclose Your Information
5.1 Information We Share
We Use Vendors and Service Providers.
We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site and Services. WP21 has entered into appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners whose products or services we believe may be of interest to you.
Marketing – Interest-Based Advertising and Third Party Marketing.
On our Site, WP21 may allow Third Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-WP21 related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third Party advertising partners, you may opt out of such sharing at no cost by following the instructions below.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures).
We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) enforce our policies or contracts; (v) collect amounts owed to us; (vi) prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) disclose your Personal Information in good faith where it is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Merger, Sale, or Other Asset Transfers.
5.2 INTERNATIONAL Data Transfers
You agree that all Personal Information collected via or by WP21 may be transferred, Processed, and stored anywhere in the world, including but not limited to the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to WP21, you explicitly consent to the storage of your Personal Information in these locations.
6. Opt-Out (RIGHT TO OBJECT TO PROCESSING)
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to WP21’s Processing of your Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting us as the address below.
6.2 Email and Telephone Communications
6.3 HUMAN RESOURCES DATA
We will use Personal Information we collect for Human Resources activities only for employment-related purposes as more fully described above. If we intend to use this Personal Information for any other purpose, we will notify the Individual and provide an opportunity to exercise their rights under applicable law.
6.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6.5 Cookies and Interest-Based Advertising
7. Rights of Access, Rectification, Erasure, and Restriction
8. Data Retention
9. Security of Your Information
10. International Users
11. Children’s Privacy
The Services are not directed to children under 13 years of age (16 in some jurisdictions) (“Children”), and WP21 does not knowingly collect Personal Information from Children. If you learn that your Child has provided us with Personal Information without your consent, you may alert us as described below. If we learn that we have collected any Personal Information from Children, we will promptly take steps to delete such information.
12. Redress/Compliance and Accountability
13. Other Rights and Important Information
New Uses of Personal Information.
Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, we will endeavor to comply with the law or contract.
13.2 California Privacy Rights
The following capitalized terms shall have the meanings herein as set forth below.
means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, WP21 or to which WP21 discloses Personal Information for use on its behalf.
refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of WP21 or its subsidiaries worldwide.
is any information relating to an identified or identifiable natural person (“Individual”).
“Process” or ‘Processing’
means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
is any company, natural or legal person, public authority, agency, or body other than the Individual, WP21 or WP21’s Agents.
15. CONTACT US
If you would like to contact us about our privacy practices, or exercise any of your data subject rights, please send a written request to the data controller of your Personal Information or to WP21 at admin@WP21.com or Privacy Office, 800 Bellevue Way NE , Bellevue, WA 98004.