GLOBOFORCE PRIVACY POLICY

At Globoforce Inc. and Globoforce Limited (Globoforce), we are committed to protecting your privacy and complying with our obligations under applicable law (including, with respect to Globoforce Limited, applicable legislation enacted under Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995, as amended or replaced from time to time).

This Privacy Policy describes the way that Globoforce will treat personal information collected through the Globoforce corporate website at www.globoforce.com (the “Site”) and specifically explains how we collect your personal information on the Site, how we protect such information and the choices you have concerning use of such information. We do not sell, trade or rent your personal information to third parties. By using the Site, you are providing your consent to the processing of your data by Globoforce in accordance with this Policy.

Please remember that this Privacy Policy applies only to information collected through the Globoforce corporate website. This Policy does not apply to information collected through the websites we operate for our customers to manage employee reward programs; those websites have their own privacy policy, which is displayed on each website. We may amend this Privacy Policy from time to time. By using our Site you agree to the terms of this Privacy Policy.

 

EU-US Privacy Shield Privacy Statement

Globoforce is a global business. To provide information on the Site, we may need to transfer your personal information among several countries, including the Ireland and the US, where we are headquartered. We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information to countries outside of the European Economic Area or Switzerland.

Globoforce Inc. complies with the Privacy Shield framework and the U.S.-Swiss Safe Harbor 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) and Switzerland. Globoforce Inc. 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 and commits to process in accordance with these Principles all personal data transferred to it by any EU data controller in reliance on this commitment. To learn more about the Privacy Shield program, and to view Globoforce’s certification, please visit https://www.privacyshield.gov/list.

If you wish to withdraw your consent to our processing of your data or if users feel we are violating the Privacy Shield Principles, they should contact us. If contacting us does not resolve the complaint, users may contact the European Union Data Protection Authorities (“DPAs”). If DPAs finds us to be in violation of the Principles, we will correct the situation and stop processing the data of the user bringing the complaint.

 

Type of Information Collected

We collect two types of information: personal information and non-personal information.

As used in this policy, Personal Information is information that identifies you or can be used to identify or contact you and may include your name, address, email address, or telephone number. Such information is only collected if you voluntarily submit such information to us.

Non-Personal Information is information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of our Site.

 

The Use of Information

We collect personally identifiable information from users of this Site if you choose to submit the information to us, such as by registering for a webinar, downloading a white paper, or submitting a “Request Information” form. We will use the information you submit to respond to your inquiry. We may also add your information to our marketing database and may send you email or hard copy marketing materials about Globoforce and its services.

We occasionally provide aggregated information regarding the use of our Site to partners, but these statistics never include personal information.

 

The Use of Cookies

We use cookies on our Site 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 Site although this may impair the functionality of the Site. Please read our Cookie Policy for more information on what cookies are, how we use them, and how you can control them.

 

Consent

By submitting information to Globoforce, you agree to the information practices described in this Privacy Policy. If you are submitting information on behalf of a third party (for example, registering a fellow employee for a webinar), Globoforce expects that you have received appropriate consent, according to applicable privacy laws, before transferring, in printed, electronic, facsimile or any other format, personally identifiable information to Globoforce.

 

Disclosure of Information to Third Parties

When you submit information to the Site, we will store and process your Personally Identifiable Information only for the purposes of responding to your query and sending you marketing information on Globoforce. Your personal information will not be shared with third parties other than for these purposes (unless a transfer is necessary in the context of a change of ownership of Globoforce’s assets or business).

We may provide to 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 Site. For example, we might inform third parties regarding the number of unique users who visit our Site, the demographic breakdown of our community users of our Site or the activities that visitors to our Site engage in while on our Site. 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.

Globoforce may transfer personal information to countries other than the country in which the data was originally collected.  These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy.

Pursuant to the Privacy Shield program, Globoforce Inc. remains accountable, as described in the Privacy Shield Principles, for personal data that it receives under the Privacy Shield and subsequently transfers to a third party. In particular, Globoforce Inc., remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Globoforce Inc. proves that it is not responsible for the event giving rise to the damage.  Globoforce commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to personal data transferred from the EU in the context of the providing its Services.

 

Access to Personal Data/Amending of Personal Details

If you have submitted Personally Identifiable Information to Globoforce through the Site, and you wish to:

  • update or correct your personal information,
  • verify what personal information we maintain about you,
  • change your preferences with respect to communications and other information you receive from us, or
  • delete the personal information maintained about you on our systems.

please contact us

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). Fees may be payable for the processing of data access requests in certain instances.

 

Security

Globoforce is committed to taking reasonable steps to ensure the security of your information. To prevent unauthorised 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 online.

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.

 

Changes to the Privacy Policy

If we decide to change this Privacy Policy, we will post those changes on our Site 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 Privacy 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. We may also make non-significant changes to our Privacy Policy that generally will not affect our use of your personal information.

 

Concerns and Comments

You may email us with any further questions or concerns regarding this Privacy Policy or if you have a Privacy Shield related complaint at privacy@globoforce.com or you contact us by regular mail addressed to:

 

Globoforce Inc.

144 Turnpike Road

Southborough, Massachusetts

United States 01772

 

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

 

Globoforce Limited

21 Beckett Way

Park West Business Park

Dublin 12, Ireland

 

Recourse

In the event that any complaint related to the Privacy Shield program cannot be resolved directly between you and Globoforce Inc., Globoforce Inc., has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.  If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint.  The services of EU DPAs are provided at no cost to you.

Globoforce Inc., 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. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

 

(Last modified as of September 1, 2016)

 

©2015 Globoforce Inc., and Globoforce Limited. All Rights Reserved.