Last update: April 1, 2022
Personal Information We Collect and How We Use It
When you access or use the Services, we will collect your Personal Information. “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Depending on how you interact with us, we may collect the following categories of Personal Information:
- Identifiers include name, email address, billing and shipping address, phone number, and IP address. We collect this information to provide and promote our Services. This includes responding to your questions or comments and providing you with information about significant changes to Services, new functionality, and offers we think you may find valuable.
- Internet or other electronic network activity information, including but not limited to, browsing history, search history, and interaction with our online Services. We collect this information to understand how you interact with our websites and online services.
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We collect this information to track your transactions, maintain records, and customize our service.
- Inferences drawn from any information identified in this subdivision, such as your behaviors and preferences. We collect this information to refine and enhance our Service offerings.
We may collect your Personal Information through your direct interactions with us, such as if you email a question or comment or submit a customer review. We may also collect your Personal Information through tracking technologies (such as cookies and web beacons).
Disclosure of Personal Information to Third Parties
We may share your Personal Information with third parties in certain circumstances, including the following:
- With service providers – We may share your Personal Information with companies or individuals we contract with to receive services. These services may include, among other things, providing products or services to you on our behalf, creating or maintaining our databases, researching and analyzing the people who request information from us, preparing and distributing communications, or responding to inquiries. We do not allow our service providers to use or disclose your personal information other than providing services to us.
- With affiliates – We may share your Personal Information with companies that we own or control or that are under common ownership or control.
- On blogs, online postings, and testimonials – In certain circumstances, you may have the ability to share comments, testimonials, and other postings in public forums. If you choose to participate in these public forums, your Personal information may be available to the general public.
- In a business transition – If PeopleStrategy, or any portion of our assets, are acquired by, merged with, transferred to, or invested in by another company, we may share your Personal Information with that company or other third parties involved in the business transition.
- To protect our rights – We reserve the right to release your information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies or the release of your information may protect the rights, property, or safety of PeopleStrategy, or another person.
- As required by law or in response to a legal process – We may disclose information about you to law enforcement or in response to a legal process if we have a good faith belief that we are required to do so by law, including for national security or law enforcement requirements. This includes sharing your information with governmental entities or third parties in response to subpoenas, court orders, other legal processes, or as we believe necessary to exercise our legal rights or defend against legal claims.
You may be able to limit or opt-out of the disclosure of Personal Information in some circumstances. For more information, see the COOKIES and MARKETING OPT-OUT sections below.
- Strictly necessary – These cookies and other technologies are strictly necessary to use our website, such as accessing your Account and providing you with the website you have requested.
- Preferences – These cookies and other technologies allow us to remember your choices, such as your user name, language used, or country. They may be used for user preferences purposes.
- Third-party analytics – Our third-party partners place these cookies and other technologies for web analytics purposes. Examples of these cookies and other technologies include Google Analytics. You can opt-out of Google Analytics by following the instructions provided at https://tools.google.com/dlpage/gaoptout.
- Third-party targeting and/or advertising – These cookies and other technologies are implemented by third-party advertising networks with our consent and are used to deliver you more relevant ads. They may also remember the locations on the websites you have visited, limit the number of times an ad is displayed to you, and measure the effectiveness of an advertising campaign, promotions, and e-newsletters. You can opt-out of Google Advertising by following the instructions provided at http://www.google.com/policies/technologies/ads/.
You may set your Internet web browser to notify you when you receive a cookie or prevent cookies from being sent. If you prevent a cookie from being sent, you may limit the functionality we can provide you when you visit our website.
Currently, our systems do not recognize browser “do-not-track” or DNT signals. You may, however, disable certain tracking as discussed in this section.
Aggregate and Non-Identifiable Data
We reserve the right to use aggregated, non-identifiable, and statistical data (“Aggregated Data”) that we can derive from the operation of the software or services we provide.
Retention and Disposal
We retain Personal Information as long as necessary to fulfill the purposes for which we collected it, for legitimate business reasons or as legally required. When we dispose of Personal Information, we aim to use secure means, such as physically or electronically erasing the Personal Information or making it anonymous in a non-recoverable manner.
Our Services are not directed toward children under 18 years of age, and PeopleStrategy does not knowingly collect any information from children under 18 through our Services.
We implement security measures and controls to protect the confidentiality, integrity, and availability of the Personal Information we collect.
You have the following rights and choices concerning the Personal Information we collect about you:
You can always unsubscribe or opt-out of the marketing and promotional emails we send you. Please click the “unsubscribe” link at the bottom of any marketing emails you receive from us.
Your Privacy Rights
The laws of certain jurisdictions may afford you the right to access your Personal Information held by PeopleStrategy and request correction, amendment, portability, or deletion of your Personal Information. In addition, you may have the right to object to processing based on legitimate interests and to withdraw consent where consent is the legal basis for processing. These rights may be limited, for example, if fulfilling a request would reveal Personal Information about another person or if the processing is required by law or another compelling legitimate interest. You can exercise your privacy rights by contacting us at firstname.lastname@example.org. We will handle your request under applicable law or regulation. When you request, we may verify your identity to protect your privacy and security.
In some circumstances, PeopleStrategy processes Personal Information on behalf of our clients and is subject to the control and instructions of our clients. If you believe PeopleStrategy may have Personal Information about you due to services PeopleStrategy provides or has provided to a PeopleStrategy client with whom you have a relationship, it may not be possible for PeopleStrategy to respond to your request. In that circumstance, please direct your request to the PeopleStrategy client you have a relationship with.
PeopleStrategy is committed to resolving complaints about our collection or use of your Personal Information. All individuals, including European Union (EU) and Swiss individuals, with inquiries or complaints regarding our privacy practices or Privacy Shield policy, are encouraged to contact us at email@example.com to address your concerns or dispute.
Additionally, PeopleStrategy has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) concerning unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
As a last resort and under limited circumstances, individuals from the EU and Switzerland with residual privacy complaints may invoke a binding arbitration option before the Privacy Shield Panel.
Your California Privacy Rights
California residents are entitled to the following privacy rights listed below.
- The right to know. You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed to a third party for a business purpose in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information. Generally:
- Within the preceding 12 months, PeopleStrategy has collected the categories of Personal Information detailed in the PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT section above. That section also describes the categories of sources from which your Personal Information is collected and the purpose for collecting your Personal Information.
- PeopleStrategy does not disclose your Personal Information to third parties who are not our service providers.
- You have the right to opt-out of the sale of your Personal Information. PeopleStrategy does not sell your Personal Information.
- The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintained about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your deletion request, we will let you know why.
- The right to equal service. If you choose to exercise any of these rights, PeopleStrategy will not discriminate against you. If you exercise certain rights, understand that you may be unable to use or access certain features of PeopleStrategy’s websites or services.
You may exercise your right to know and deletion twice a year free of charge. To exercise your right to know or deletion, contact us via email at firstname.lastname@example.org. Prior to processing your request to know or to deletion, we will attempt to verify your identity. We may do this by requesting additional information from you to verify your identity. We will inform you if we cannot verify your identity, in which case we will not be able to complete your request.
You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify your and your agent’s identity and request a signed document from you that authorizes your agent to request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that you have authorized them to act on their behalf.
Our Services may provide hyperlinks that, when clicked, take you to a third-party website that we do not own or control. It is also possible that third parties’ websites or emails may link to our website. These hyperlinked third-party websites may collect and disclose your personal information differently than we do. We are not responsible for collecting, using, or disclosing information collected through these websites, nor are we responsible for the content or the privacy practices employed by third parties. We expressly disclaim any liability related to such collection, use, or disclosure.
International Data Transfer
PeopleStrategy is an organization established in the United States of America (USA). For individuals located in the European Economic Area (“EEA”), United Kingdom, or Switzerland, your Personal Information will likely be transferred to, stored, and processed in the USA outside of where you live. When we conduct such transfers, we rely on various legal bases to lawfully transfer Personal Information, including the European Union Commission approved Standard Contractual Clauses (SCCs).
PeopleStrategy is responsible for processing Personal Information it receives or subsequently transfers to a third party acting as an agent on its behalf. PeopleStrategy complies with applicable data protection laws for all onward transfers of Personal Information from the EU, EEA and Switzerland.
Personal Information received or transferred by PeopleStrategy is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, PeopleStrategy may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have questions about our Privacy Shield certification, please get in touch with us at email@example.com
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