Privacy Around Information Collected from Third-Parties

Effective: November 3, 2020

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:

WorkForce Software processes personal data from third-parties who provide services or support to WorkForce Software or WorkForce Software’s customers.

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
[email protected]

What information do we collect?

If you are a third-party who works with WorkForce Software, we collect the following business-related information from you:

• your name, job title, business address and contact details, including email address and telephone number
• information included in any support tickets you file

Why do we process personal data?

We require your personal data to fulfill obligations under any contractual agreement we have with you:

• To contact and collaborate with you
• To receive goods and services from you
• To provide product support
• To develop new business opportunities
• To subcontract work to you.
• To be subcontracted by you.
• To provide training to you or be trained by you

If we do not have a contractual agreement with you, then any information you provide us is by consent. You may withdraw consent at any time.  Individuals must opt-in prior to their personal information being processed for a different purpose.

Who has access to your data?

Your information will be shared internally with staff who are responsible for your business account, as well as staff who provide services as per the contractual agreements we have in place with you. Your information may also be shared with third-parties we have contracted with to provide services to you.

Your personal information may be transferred out of your home country. For example, we centrally store and process business contact information in the United States. Our learning management system is also based in the United States. Any data transferred outside the EEA or UK will be based on a declaration of adequacy, 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 are responsible for any data that is transferred to third parties.

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 do we protect your data?

We have 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 employees and partners in the performance of their duties. We are ISO 27001 certified.

Where we engage third parties, they process your data based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organizational measures to ensure the security of your data. We have a third-party risk management program.

You may request more details about those safeguards by sending an email to [email protected]).

How long does we keep your data?

We hold your personal information for as long as you provide services to us or we provide services to you, plus three years.

Your rights

You have several privacy rights. You can:

• access and obtain a copy of your data within one month of any 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 rely 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 the company’s 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 don’t provide us the required personal information, we would not be able to provide contracted services to you or may not be able to proactively contact you with information related to our processing activities.

Do we use automated decision-making?

No automated decision-making is performed on your data.

What do I do if I have a dispute?

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
[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
[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.