Privacy Notice Around Marketing

Effective: July 7, 2021

About us (the “Data Controller”)

WorkForce Software, LLC
38705 Seven Mile Road, Suite 300
Livonia, MI 48393
United States of America
+1‐877‐493‐6723
[email protected]

…including subsidiaries:

Data Protection Officer

We have contracted with IT Governance in the UK for Data Protection Officer Services. The Data Protection Officer (DPO) provides advice and guidance around our General Data Protection Regulation Compliance. Generally, questions you may have around privacy should be sent first to [email protected] and we will escalate to the DPO as necessary. Our Data Protection Officer is:

GRCI Law
Unit 3 Clive Court
Bartholomews Walk
Cambridgeshire Business Park
Ely, Cambridgeshire
CB7 4EA, UK
[email protected]
+44 (0) 333 800 7000

EU Representative

We have appointed GRCI Law to act as our EU Representative and all requests, questions and comments should either be emailed to [email protected] or addressed to:

c/o Head of Data Privacy Manager Service
GRCI Law Limited
Unit 3, Clive Court
Bartholomew’s Walk
Cambridgeshire Business Park
Ely, Cambridgeshire, CB7 4EA, UK

or:

Head of Data Privacy Manager Service
IT Governance Europe
Third Floor, The Boyne Tower, Bull Ring,
Lagavooren, Drogheda, Co. Louth, A92 F682, Ireland

UK Representative

WorkForce Software Limited
Precedent Drive, Rooksley
Milton Keynes
Buckinghamshire MK13 8PP
United Kingdom
Phone: +44-1908-242-042

What information do we collect?

On some WorkForce Software web pages, you can register for access to specific materials or to participate in an event, or request that a WorkForce representative contact you. The types of Personal Information collected to manage these requests can include any combination of the following:

• Your first and last name
• Your job title, phone number, and email address
• Your postal address for work
• The name of your employer
• The number of employees retained by your employer
• The HR and payroll software products that you currently use
• The business goals that have prompted you to contact us

We may also receive your personal information from third-parties. If we receive your information from a third-party, once we contact you, you must opt-in when you receive our first communication to continue receiving future communications from us.

We also collect data for advertising and marketing, such as analyzing and predicting business buying behavior or business interests – based on your access to our marketing sites – and deliver interest-based advertising and content to your device, such as ads, widgets, or website content tailored to you around our products and services.

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

• Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: [email protected].

Why do we process personal data?

When we collect information through registration forms or from trade shows, we may use it for any number of the following reasons:

• To determine the appropriate WorkForce representative to contact you or to fulfill your request
• To determine your eligibility for a requested event or digital file
• To send you invitations or special offers that may be of interest based upon the information you supplied
• To extend invitations from select partner organizations that may be of interest based upon the information you supplied
• To contact you regarding your potential interest in workforce management products and services

We require your consent to process your personal data for marketing purposes.  Individuals must opt-in prior to their personal information being processed for a different purpose.

If you are a customer (i.e., you have one or more of our products), we have a legitimate interest to keep you informed of upgrades and enhancements, new or changes to products and services, and of events around our products and services. We will provide you an opportunity to object to these marketing communications.

Who has access to your data?

We may share personal information in the following ways:

• Within WorkForce Software, including with any of our worldwide subsidiaries for purposes of data processing or storage.
• With WorkForce business partners or vendors, so that they may share information with you about their products or services.
• With business partners, service vendors, authorized third-party agents, or contractors to provide a requested Solution, service or transaction. Examples include, but are not limited to: assisting with sales-related efforts, customer setup and configuration, and post-sales support.
• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.

We contract with third-parties (“Data Processors”) to manage your personal information. We only use third-parties who will process strictly according to our instructions and in a manner that secures your personal data. We are responsible for any data that is transferred to third parties.

Your personal information may be transferred out of your home country. For example, we store all marketing-related personal information in the United States. Data is transferred outside the EEA or UK based on declaration of adequacy or other safeguards (e.g., the Standard Contractual Clauses or EU-US Privacy Shield Certification). You may request more details about those safeguards by sending an email to [email protected]).

We may share your personal information with law enforcement officials, government authorities, or other third parties as necessary to comply with legal processes or to meet national security requirements; protect the rights, property, or safety of WorkForce Software, its business partners, you, or others; or as otherwise required by applicable law.

WorkForce Software is subject to the investigatory and enforcement powers of the FTC and is required to disclose personal information in response to lawful requests by public authorities to meet national security or law enforcement requirements.

We do not sell your information.

How does the organization protect your data?

The organization has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by authorized staff in the performance of their duties.

We ensure to only use third-parties who will process your personal information strictly according to our instructions and in a manner that secures your personal data.

How long does the organization keep your data?

The organization has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by authorized staff in the performance of their duties.

We ensure to only use third-parties who will process your personal information strictly according to our instructions and in a manner that secures your personal data.

Your rights

You have several privacy rights. You can:

• access and obtain a copy of your data within one month of a written request and free of charge;
• require us to change incorrect or incomplete data;
• require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where we are relying on legitimate interests as the legal ground for processing; and
• ask us to stop processing data for a period if data is inaccurate, processing is found to be unlawful and you object to your data being deleted, your data is no longer needed for processing or there is a dispute about whether your interests override our legitimate grounds for processing data.
• provide a copy of your data to you in an industry-standard format.

If you would like to exercise any of these rights, or if you have any questions or issues, please contact

Privacy Officer WorkForce Software, LLC 38705 Seven Mile Road, Suite 300 Livonia, MI 48152 United States of America +1‐877‐493‐6723 (Toll Free) [email protected]

What if you do not provide personal data?

If you do not provide your personal data, we will be unable to send you marketing materials around our products.

Automated decision-making

No automated decisions are made by the data collected.

Dispute resolution

If you believe we have not complied with your data protection rights, please contact

Privacy Officer WorkForce Software, LLC 38705 Seven Mile Road, Suite 300 Livonia, MI 48152 United States of America +1‐877‐493‐6723 (Toll Free) [email protected]

If the Privacy Officer is not able to provide a satisfactory response, you may escalate to:

People in the European Economic Area (EEA):

Supervisory Authority: You may seek resolution by contacting the Supervisory Authority in your country or our lead Supervisory Authority:

The Information Commissioner’s Office Water Lane, Wycliffe House Wilmslow – Cheshire SK9 5AF Phone: +44 1625 545 745 Email: [email protected]

Privacy Shield: You may also seek resolution through Privacy Shield. WorkForce Software complies with the EU-U.S. Privacy Shield Framework and 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 transferred from the European Union and the United Kingdom , and Switzerland to the United States. WorkForce Software has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this privacy 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/.

In compliance with the Privacy Shield Principles, WorkForce Software commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact:

Privacy Officer WorkForce Software, LLC 38705 Seven Mile Road, Suite 300 Livonia, MI 48152 United States of America +1‐877‐493‐6723 (Toll Free) [email protected]

WorkForce Software has further committed to refer unresolved Privacy Shield complaints to International Centre for Dispute Resolution, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://go.adr.org/privacyshield.html for more information or to file a complaint (https://go.adr.org/rs/294-SFS-516/images/PrivacyShield_Notice_of_Arbitration.pdf).  The services of International Centre for Dispute Resolution are provided at no cost to you. Under certain conditions, you may invoke binding arbitration.

People who are not in the European Economic Area

Disputes that cannot be resolved between WorkForce Software and you will be handled, free of charge, in accordance with applicable dispute resolution procedures through the American Arbitration Association, which are available for review at https://go.adr.org/privacyshield.html.