Privacy Policy

GLOBOFORCE PRIVACY POLICY

On July 16, 2020, the Court of Justice of the European Union invalidated the European Commission’s Decision 2016/1250/EC of July 12, 2016 on the adequacy of the EU-US Privacy Shield Framework. In light of this decision, Workhuman is reviewing alternative transfer mechanisms to ensure transfers of data from the EEA to the U.S. continue to be afforded an adequate level of protection. We will further update this Privacy Policy with our adopted transfer mechanism as soon as we receive additional guidance on the ruling. In the meantime, we will continue to follow our robust privacy and security practices to safeguard the privacy of your data. If you have any questions, please do not hesitate to contact us at workhumanprivacy@workhuman.com.

At Globoforce Inc. d/b/a Workhuman (US) and Globoforce Limited trading as Workhuman (Ireland) (“Workhuman”, “us” or “we”), we are committed to protecting your privacy and complying with our obligations under applicable law (including, with the General Data Protection Regulation 2016/679 (GDPR)). This Privacy Policy (“Policy”) describes the ways that we will treat personal information collected through the Workhuman corporate website at www.workhuman.com, www.workhumanlive.com, and any other websites, software applications and/or mobile applications that link to this Policy (the “Sites”). This Policy specifically explains how we collect your personal information on the Sites, how we protect such information and the choices you have concerning use of such information. By using the Sites and submitting information to Workhuman, you agree to the processing of your personal information by Workhuman in accordance with this Policy.

Please remember that this Policy applies only to information collected through the Sites. This Policy does not apply to information collected through the websites we operate for our customers. Our customer websites display their own privacy policies.

It is also important to note that the Sites may contain links to third-party websites. This Policy does not apply to the privacy practices of such third-party websites. We encourage you to review the terms and policies on these websites before providing any personal information to them.

EU-US and Swiss-US Privacy Shield Privacy Statement

Globoforce Inc. d/b/a Workhuman complies with the EU-U.S. Privacy Shield framework and the 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 from European Union member countries (including from Globoforce Limited in Ireland), the United Kingdom, and Switzerland to the United States. Globoforce Inc. d/b/a Workhuman has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.

This means that Globoforce Inc. d/b/a Workhuman remains accountable, as described in the Privacy Shield Principles and in this Policy, for personal information that it receives under the Privacy Shield and subsequently transfers to a third party (unless Globoforce Inc. d/b/a Workhuman proves that it is not responsible for the event giving rise to the damage). If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

International Data Transfers

Workhuman is a global business with headquarters in Ireland and in the US. Workhuman may transfer personal information to countries other than the country in which the data was originally collected from you and/or was provided to us. These countries may not have the same data protection laws as the country in which you initially provided the information. However, when we transfer your personal information to other countries, we will protect that information in accordance with applicable law. The principal ways in which we protect information is through the use of EU-approved “model contract clauses” or through our certifications to the EU-US Privacy Shield (governing transfers from the EU to the US) and the Swiss-US Privacy Shield (governing transfers from Switzerland to the US).

Type of Information Collected

As used in this policy, personal information is information that identifies you or can be used in combination with other information to identify or contact you and may include your name, address, email address, telephone number, internet protocol address or billing information. Such information may be collected on our Sites when you:

The Use of Information

Some of the ways we use your personal information are as follows:

Legal Basis for Processing

We only keep and process the personal information where we have a valid legal basis to do so. The legal basis for collecting and using the personal information described above will depend on the information collected and the way in which we use it. The bases which we rely on are as follows:

If you have questions or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

The Use of Cookies

We use cookies on our Sites in order to provide you with the best possible user experience. Most web browsers are automatically set to accept cookies; however, you do not have to accept cookies to use the Sites although this may impair the functionality of the Sites. Please read our Cookie Policy for more information on what cookies are, how we use them, and how you can control them.

Disclosure of Information to Third Parties

Workhuman will share personal information with third parties to the extent required to fulfill the purposes set forth herein, including to contracted service providers so that they may provide certain services on our behalf (for example, credit card processing services, or an event management portal). With your consent, Workhuman may also share personal information you provide to us as part of an event or conference registration process or with event sponsors that wish to connect with you. Where required, Workhuman requires that these third parties guarantee equivalent levels of protection as applied by Workhuman when handling personal information.

We may provide third parties information about you that does not allow you to be identified or contacted, including where such information is combined with similar information of other users of our Sites. For example, we might inform third parties regarding the number of unique users who visit our Sites, the demographic breakdown of our community users of our Sites or the activities that visitors to our Sites engage in while on our Sites. The third parties to which we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties.

We may also disclose your information (including personal information) if we believe in good faith that we are required to do so in order to comply with an applicable law, a subpoena, a search warrant, a court or regulatory order or other valid legal process or lawful requests by public authorities, including to meet national security or law enforcement requirements.

Except as otherwise set forth in this Policy, we do not and will not sell, trade or rent your personal information to third parties.

Rights to your Information

You may exercise the following rights in relation to the personal information that we hold about you:

Further, every marketing email from Workhuman contains instructions on how to opt out of receiving further marketing emails from us. If you wish to unsubscribe, follow the instructions in the email. Please contact us if you have any problems using this opt out mechanism.

You can exercise any of your rights above by using the Contact Us details below. We undertake that promptly after receiving your request (subject to any statutory time periods), all personal information stored in databases we actively use and other readily searchable media will be updated, corrected, changed, deleted or confirmed to you, as appropriate, as soon as reasonably practicable and in accordance with applicable law or the Privacy Shield Principles (as relevant).

Notice to California Residents

California Privacy Rights: to the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the personal information we collect:

Exercising Your Rights: California residents can use the email address provided below to exercise the above privacy rights or to access this Privacy Policy in an alternative format.

Verification: in order to protect your personal information from unauthorized access or deletion, we may require you to verify your identity before you can submit a request. If we suspect fraudulent or malicious activity, we may ask you to provide additional personal information for verification. If we cannot verify your identity, we will not provide or delete your personal information.

Authorized Agents: you may submit a request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.

Security

Workhuman is committed to taking reasonable steps to ensure the security of your information. To prevent unauthorized access, maintain data accuracy and ensure the appropriate use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect from you.

We maintain strict data security systems that ensure specific information will not be made available to any unauthorized person and in order to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Our employees are made aware of and are accountable for compliance with our privacy policy. Any information collected by us is stored on our Web server or databases but is not publicly accessible from our Site or otherwise. When applicable, we use a multi-level, password protected security system to control access to information stored about users. We also maintain strict physical security of our properties and facilities and only provide access to authorized personnel.

Retention of Personal Information

Except as otherwise permitted or required by applicable law or regulatory requirements, Workhuman will only retain your personal information for as long as it is necessary to fulfill the purposes for which the personal information was collected. After such time, personal information will be securely destroyed or obfuscated so that it cannot be associated with or tracked back to you.

Changes to the Privacy Policy

Workhuman reserves the right to change this Policy. If we decide to make changes, we will post the updated policy on our Sites so you are always aware of what information we collect, how we use it, and the circumstances, if any, we disclose it. If at any point we decide to use personal information in a manner significantly different from that stated in this Policy, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your personal information in the new manner.

Concerns and Comments

If you wish to exercise your data protection rights or to raise any concerns, objections or complaints in relation to this Policy, please contact us using the relevant Contact Us details below. If contacting us does not resolve your issue, EU users of our Sites may contact their local EU Data Protection Authorities or Swiss users can contact the Swiss Data Protection and Information Commissioner (collectively, “DPAs”). In the case of users of our Sites within the EU, our lead DPA is the Data Protection Commission in Ireland which acts as the “one stop shop” for complaints relating to cross-border processing issues.

As part of our commitment to the Privacy Shield, Workhuman commits to cooperating with relevant DPAs and to comply with the advice given by such authorities with regard to personal information transferred from the EU or Switzerland under the Privacy Shield Framework. The services of the DPAs are provided at no cost to you. Accordingly, if the DPAs finds us to be in violation of the law or applicable Privacy Shield Principles, we will correct the situation and, if necessary, stop processing the data of the individual who brought the complaint. For processing governed by the Privacy Shield, Globoforce Inc. d/b/a Workhuman will make available a binding arbitration option to you in the event that the complaint is unresolved, under certain conditions as further explained in the Privacy Shield Principles.

Globoforce Inc. d/b/a Workhuman is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Concerns and Comments

You may email us at workhumanprivacy@Workhuman.com with any further questions or concerns regarding this Policy, if you wish to exercise your data protection rights, or if you have a Privacy Shield related complaint. You can contact us by regular mail addressed to:

Globoforce Inc. d/b/a Workhuman

200 Crossing Blvd., Suite 500
Framingham, Massachusetts
United States 01702

Alternatively, regular mail may also be directed to Globoforce Limited in Ireland trading as Workhuman, by addressing it to:

Globoforce Limited trading as Workhuman

19 Beckett Way
Park West Business Park
Dublin 12, Ireland

(Last modified as of October 7, 2020)