Privacy Policy

Effective on: 2024-08-22
Last Updated on: 2024-09-26

Plus Relocation Services, LLC and Plus One, LLC (collectively “Plus Relocation”, “we”, “us”, “our”) take the protection of Personal Data (“Personal Data”) very seriously. Please read this Privacy Policy to learn what we are doing with your Personal Data, how we protect it, and what privacy rights you may have under applicable data protection and privacy laws, such as the European Union General Data Protection Regulation (“EU GDPR”) and the United Kingdom General Data Protection Regulation (“UK GDPR”), collectively, the “GDPR” and the California Consumer Privacy Act of 2018 (“CCPA”).

In the context of this Privacy Policy, Plus Relocation acts as a data controller for the Personal Data we process. This means that we decide how and why Personal Data is collected and further processed.

This Privacy Policy addresses data subjects (which includes both individuals and households) whose Personal Data we:

• receive from our customers (“Customers”) in our web-based software applications, Point C, Elo for Mobility, Elo for Employees, and Elo Assist (collectively, the “Services”) as well as in the course of providing consulting services and customer support.
• receive directly from our websites: https://plusrelocation.com, https://elo.plusrelocation.com, https://www.plusoneinnovates.com, and https://pointc.com;
• receive from our business partners; or
• process to promote our products and services.

Plus Relocation collects your Personal Data to provide our products and services to you; otherwise, we may not be able to process the transactions you request. We will only process your Personal Data when we have a lawful basis for doing so. We will collect and process your Personal Data as necessary for the performance of a contract to which you are a party or because we have another legitimate interest in doing so relating to our business purposes arising from your relationship with us. We may also seek your prior consent or rely on some other lawful basis to process your Personal Data.

Our legitimate interests include but are not limited to:

• Provide you with the products and services you request, view, engage with, or purchase.
• Communicate with you regarding your account or transactions with us; and
• Operate, understand, optimize, develop, or improve our sites, applications, products, services, and operations.

For the purposes of this Privacy Policy, Personal Data is any information about or that can be linked to an identifiable individual or household.

We collect and maintain different types of Personal Data that you and/or your employer provide to us on a voluntary basis. This may include:

• contact and identification information, such as your real name, alias, unique personal identifier, online identifier, IP address, postal address, telephone number, e-mail address, Social Security number, passport number or other similar identifiers internet or other electronic network activity information, including, but not limited to, information regarding your interaction with the Site.
• product and service-related information concerning the products and services that we provide to you or programs that we offer;
• any other 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;
• for parties with whom we do business, credit, and financial information such as your payment methods and preferences, and billing and credit history, where applicable; and
• business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feed-back and information requested by or provided to you.

If you email us a question or request, we may use your email address to process your request and respond to your question, which may involve collecting any Personal Data that you choose to provide to us in your email.

We may also collect market-related information, which may include Personal Data, concerning market trends and activities impacting our business. This information may include contract terms, financial information, and other information for the purpose of market analysis, resource planning, financial advisory services, and strategic planning. We may also collect information related to our media, investor and public relations activities, and information related to our interactions with financial, resource planning, regulatory, and other analysts, and advisors.

We may receive your Personal Data when:

• you or your partner provide it directly to us as part of using our Services;
• our customers, your employer (including their employees, contractors, and other representatives of the company) provide it to us;
• our service providers provide it to us.

We collect Personal Data from you to enable us to manage, maintain, and develop our business and operations, including:

• to establish, maintain and manage our relationship with you so that we may provide you with, products and services that have been requested;
• to perform services on behalf of you or your employer, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, and processing payments;
• to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
• to administer or otherwise carry out our obligations in relation to any agreement you or your employer have with us;
• to protect us against error, breach of contract, negligence, fraud, theft, illegal activity and damage to our goods and property;
• to alert you to updated information and other new products and services from us, or third-parties, or to forward promotional materials to you, where you have consented to receive such information;
• to complete a transaction or service requested by you or your employer;
• to respond to inquiries or requests submitted by you or your employer;
• to ensure the Sites are relevant to your needs;
• to detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• to debug to identify and repair errors that impair existing intended functionality;
• to undertake internal research for technological development;
• to help us create and publish content most relevant to you;
• to further any commercial purposes, including any purpose to advance your interests, such as by inducing you to buy, rent, lease, join, subscribe to, or provide products, goods, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction;
• to enable us to comply with applicable law or regulatory requirements; and
• any other reasonable purpose to which you consent.

Your Personal Data may be used and disclosed:

• as permitted or required by applicable law or regulatory requirements;
• to meet national security or law enforcement requirements;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of our regular reporting activities;
• to protect our rights and property;
• where the Personal Data is publicly available;
• during emergency situations or where necessary to protect the safety of a person or group of persons investigate fraud, or respond to a government request; or
• for any additional purposes for which we have obtained your consent.

We may share your personal information with other companies within our group, service providers who help manage our business and deliver services, vendors and other parties for business and commercial purposes and government organizations, agencies, law enforcement and regulators for the purpose of complying with applicable laws.

We may share your Personal Data with our service providers, who process Personal Data on behalf of Plus Relocation. Such third parties include those:

• Providing IT systems and infrastructure
• Managing our IT systems and infrastructure
• Providing customer support.

Our service providers may be located outside of the United States; however, we will either obtain your explicit consent to transfer your Personal Data to such third parties, or we will require those third parties to maintain at least the same level of confidentiality that we maintain for such Personal Data ourselves. Plus Relocation remains liable for the protection of your Personal Data that we transfer to our service providers, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing.

We retain your Personal Data for as long as needed for the purpose we collected it and any other permitted linked purpose and in accordance with our data retention policies. For example, we will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We retain and use your Personal Data as required to meet legal obligations, resolve disputes, and enforce our agreements and policies. If we use your data for multiple purposes, we keep it until the purpose with the longest retention period expires, discontinuing use for shorter periods. Our retention periods align with our business needs and industry standards.

We give you the opportunity to choose (opt out) whether your Personal Data is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected.

If we seek additional information from you, beyond the information provided by you or your employer, we will seek your consent at the time that we collect any such Personal Data. If we plan to use or disclose your Personal Data for a purpose not previously identified (either in this Privacy Policy or separately), we will request your consent before such use or disclosure.

From time to time, we communicate via email with users who request information. For example, we may use your email address to confirm a request you have made, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. If you do not wish to receive email communications from us, you may change or withdraw your consent at any time by contacting our Privacy Officer in writing using the contact information provided below.

We typically collect information under the direction of your employer or its designated representative. If you are a relocating employee of one of our clients and would no longer like communication provided by your employer using our services, please contact the employer that you interact with directly. Transfers to subsequent third parties are covered by the service agreements with your employer.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should log into their Elo^SM account or email us at elo@plusrelocation.com. If requested to remove data, we will respond within a reasonable timeframe.

We will retain Personal Data Personal Data we process for as long as needed to provide our services. Plus Relocation will retain this Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Users of the Plus Relocation’s Elo^SM Online Community (the “System”) opt-in to permit us to make certain information available to (i) their employer, or other third party that is sponsoring their use of the System, and (ii) service providers that provide services related to relocation, for the purpose of providing those relocation services.

System users may at any time also opt-out of receiving information from us, or from us making your information accessible through the System. If you wish to “opt-out” please email elo@plusrelocation.com.

Our Sites are not intended to collect Personal Data from children under the age of 13. We urge parents to regularly monitor and supervise their children’s on-line activities. Please contact us if you believe we have inadvertently collected Personal Data from a child under the age of 13, so we can delete such information.

Our Sites may offer links to other websites that may be subject to less stringent privacy standards. If you visit one of these linked websites, you are then subject to the privacy policies and other policies of such websites and are no longer protected by our policies. We are not responsible for, or able to monitor or control, the policies and practices of other companies, including with respect to their collection, use or disclosure or your Personal Data. You should review the privacy policies of these websites before providing them with Personal Data.

Plus Relocation secures your Personal Data from unauthorized access, use or disclosure, alteration or destruction by implementing and maintaining technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software.

In addition, although we obligate third parties who support our Sites and their related offers or other programs to use any Personal Data only for the purpose of performing their work, we do not control such third parties’ websites or other security measures.

Under the California Consumer Privacy Act, California residents have the right to:

• Request that a business delete any Personal Data about the consumer which the business has collected from the consumer.
• Request that a business that collects Personal Data about the consumer disclose to the consumer, free of charge, the following:
  • The categories of Personal Data that it has collected about that consumer.
  • The categories of sources from which the Personal Data is collected.
  • The business or commercial purpose for collecting or selling Personal Data.
  • The categories of third parties with whom the business shares Personal Data.
  • The specific pieces of Personal Data it has collected about that consumer.
• Request that a business that sells the consumer’s Personal Data, or that discloses it for a business purpose disclose, free of charge, to the consumer:
  • The categories of Personal Data that the business collected about the consumer.
  • The categories of Personal Data that the business sold about the consumer and the categories of third parties to whom the personal was sold, by category or categories of Personal Data for each third party to whom the Personal Data was sold.
  • The categories of Personal Data that the business disclosed about the consumer for a business purpose.
• Direct a business that sells Personal Data about the consumer to third parties not to sell the consumer’s Personal Data.

You may submit a request under the California Consumer Privacy Act through the following methods:

• You may call us toll-free at 1-888-251-2825.
• You may email us at privacy@plusrelocation.com.

To submit a request, we are required to verify your identity. Please be prepared to provide us with your address, phone number, email address and employee ID. We will match the Personal Data that you provide to us with Personal Data that we already maintain about you to verify your identity. We may also need to contact you to confirm your request.

You may also designate an authorized agent to make a right to know or deletion request on your behalf. To use an authorized agent, you as the California resident must provide the agent with written authorization, including the verification information above. In addition, the agent will be required to verify their own identity with us. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

We may not be able to honor each request that we receive, but if we are unable to do so, we will respond to let you know our reasons. We will not discriminate against you if you choose to exercise any of your rights as described in this section.

We do not track our web visitors across third party websites to provide targeted advertising and, therefore, our Sites do not respond to Do Not Track (DNT) signals. We do not support Do Not Track browser settings and do not currently participate in any Do Not Track frameworks that would allow any of our Sites to respond to signals or other mechanisms from you regarding the collection of your Personal Data.

This section of our Privacy Policy contains information for persons located in the European Union (“EU”), a European Economic Area (“EAA”) member state, United Kingdom (“UK”) or Switzerland. Before Plus Relocation collects any Personal Data from you, you are entitled under the EU and UK General Data Protection Regulation (“GDPR”), to the information in this section of our Privacy Policy.

Plus Relocation acknowledges the right of EU, UK and Swiss individuals to access their Personal Data pursuant to the Data Privacy Framework and will grant individuals reasonable access to Personal Data it received pursuant to the Data Privacy Framework Principles. In addition, Plus Relocation will take reasonable steps to permit individuals to correct, amend, or delete such information that is demonstrated to be inaccurate or processed in violation of the Principles. An individual may request to access their information, or otherwise correct, amend, or delete their information in line with the EU-U.S. (and its UK Extension) and Swiss-U.S. Data Privacy Framework Principles by contacting us at privacy@plusrelocation.com.

Right to know what happens to your Personal Data

This is called the right to be informed. It means that you have the right to obtain from us all information regarding our data processing activities that concern you, such as how we collect and use your Personal Data, how long we will keep it, and who it will be shared with, among other things.

We are informing you of how we process your Personal Data with this Notice. We will make every effort to let you know how we use your Personal Data. However, if we did not get your data directly from you, the GDPR does not require us to inform you in these cases: (1) When it is impossible or too costly to provide the information. (2) When the law obliges us to gather or share the data. (3) If the Personal Data must stay confidential because of professional or other secrecy obligations.

Right to know what Personal Data Plus Relocation has about you

This is called the right of access. This right allows you to (1) get confirmation of whether we process Personal Data about you (2) ask for full details of the Personal Data we hold about you and certain related information; (3) get a copy or access to the Personal Data.

You have the right to ask us to confirm whether or not we process Personal Data concerning you, and, where that is the case, to request a copy or access to the Personal Data and certain related information.

Once we receive and confirm that a request came from you or your authorized agent, we will disclose to you:

• The categories of your Personal Data that we process;
• The categories of sources for your Personal Data;
• Our purposes for processing your Personal Data;
• Where possible, the retention period for your Personal Data, or, if not possible, the criteria used to determine the retention period;
• The categories of third parties with whom we share your Personal Data;
• If we carry out automated decision-making, including profiling, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you;
• The specific pieces of Personal Data we process about you in an easily-shareable format;
• If we rely on legitimate interests as a lawful basis to process your Personal Data, the specific legitimate interests; and
• The appropriate safeguards used to transfer Personal Data from the EEA or the UK to a third country, if applicable.

Under some circumstances, we may deny your access request. In that event, we will respond to you with the reason for the denial.

For security and legal compliance, we cannot disclose certain sensitive information like Social Security numbers, driver’s license numbers, financial account numbers, health insurance or medical IDs, passwords, or security questions and answers. However, we can inform you if we have such information without disclosing specific details.

Right to change your Personal Data

This is called the right to rectification. It gives you the right to ask us to correct without undue delay anything that you think is wrong with the Personal Data we have on file about you, and to complete any incomplete Personal Data.

Right to delete your Personal Data

This is called the right to erasure, right to deletion, or the right to be forgotten. This right means you can ask for your Personal Data to be deleted.

For individuals enrolled within a clinical trial, please contact your study coordinator or principal investigator. Others, please email privacy@plusrelocation.com.

Sometimes we can delete your information, but other times it is not possible for either technical or legal reasons. If that is the case, we will consider if we can limit how we use it. We will also inform you of our reason for denying your deletion request.

Right to ask us to limit how we process your Personal Data

This is called the right to restrict processing. It is the right to ask us to only use or store your Personal Data for certain purposes. You have this right in certain instances, such as where you believe the data is inaccurate or the processing activity is unlawful.

Right to ask us to stop using your Personal Data

This is called the right to object. This is your right to tell us to stop using your Personal Data. You have this right where we rely on a legitimate interest of ours (or of a third party). You may also object at any time to the processing of your Personal Data for direct marketing purposes.

We will stop processing the relevant Personal Data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms; or (ii) we need to continue processing your Personal Data to establish, exercise, or defend a legal claim.

Right to port or move your Personal Data

This is called the right to data portability. It is the right to ask for and receive a portable copy of your Personal Data that you have given us or that you have generated by using our Services, so that you can:

• Move it;
• Copy it;
• Keep it for yourself; or
• Transfer it to another organization.

We will provide your Personal Data in a structured, commonly used, and machine-readable format. When you request this information electronically, we will provide you a copy in electronic format.

Right to withdraw your consent

Where we rely on your consent as the legal basis for processing your Personal Data, you may withdraw your consent at any time. If you withdraw your consent, our use of your Personal Data before you withdraw is still lawful.

To exercise these rights please contact us using the Contact Information below. For your protection, we may need to verify your identity before responding to your request. If we refuse a request, we will provide you a reason as to why.

You also have the right to lodge a complaint with a data protection regulator in one or more of the European Union Member States. Specifically, you can lodge a complaint in the Member State of the European Union of your habitual residence, place of work, or the alleged violation of the GDPR. In the UK, you can lodge a complaint with the UK Information Commissioner’s Office.

We are a global company headquartered in the United States, and our affiliates, our service providers and other third parties with whom we share Personal Data with operators globally. Personal Data that you provide while in the EU, an EAA member state, UK or Switzerland will be transferred to the United States. The GDPR permits such transfer when necessary for the performance of a contract between you and Plus Relocation, if Plus Relocation obtains your explicit consent to such transfer, or if it is in our legitimate interest to transfer the Personal Data. The laws in the United States may not be as protective of your privacy as those in your location.

Plus Relocation Services, LLC and Plus One, LLC (collectively, “Plus U.S.”) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Plus U.S. has certified to the U.S. Department of Commerce that it is subject to and adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Plus U.S. has also certified to the U.S. Department of Commerce that it is subject to and adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Plus Relocation is responsible for the processing of personal data it receives, under the Data Privacy Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Data Privacy Framework for all onward transfers of personal data from the EU, UK and Switzerland, including the onward transfer liability provisions.

Where a privacy complaint or dispute cannot be resolved through Plus Relocation’s internal processes, Plus Relocation has agreed to participate in the VeraSafe Data Privacy Framework Procedure. Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

If your dispute or complaint cannot be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you pursuant to the Data Privacy Framework’s Recourse, Enforcement and Liability Principle and Annex I of the Data Privacy Framework.

Plus Relocation is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

We will retain your Personal Data until the Personal Data is no longer necessary to accomplish the purpose for which it was provided. We may retain your Personal Data for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements

A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide basic relevant ads, website functionality, authentication (session management), usage analytics (web analytics), to remember your settings, and to generally improve our websites and Services.

We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device through our Services are first-party cookies which are placed directly by us. Other parties, such as Google, may also set their own (third-party) cookies through our Services. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.

If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all features of our Services. For more information, please visit https://www.aboutcookies.org/.

How We Respond to Opt-Out Signals. You may also set your browser to send a Do Not Track (DNT) signal or Global Privacy Control (GPC) signals. For more information, please visit https://allaboutdnt.com/ and https://globalprivacycontrol.org/. Please note that our Services do not have the capability to respond to DNT signals and GPC received from web browsers. However, please note that the technology to detect whether a website honors Do Not Track and Global Privacy Control signals does not always work as intended.

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. To ask questions or provide any comments about this Privacy Policy or our privacy practices, please contact our Privacy Officer by telephone or by email at:

You may also call us at Toll-Free 1-888-251-2825 (Mon-Fri, 8 am – 5 pm Central Time). We will answer your questions and advise you of any steps taken to address the issues raised by you.

We have appointed VeraSafe as our representative in the EU for data protection matters. While you may also contact us, VeraSafe can be contacted on matters related to the processing of Personal Data. To contact VeraSafe, please use this contact form: https://www.verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland

We have appointed VeraSafe as our representative in the UK for data protection matters. While you may also contact us, VeraSafe can be contacted on matters related to the processing of Personal Data. To contact VeraSafe, please use this contact form: https://www.verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +44 (20) 4532 2003.

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.
37 Albert Embankment
London
SE1 7TL
United Kingdom

From time to time, we may revise this Privacy Policy as well as the Terms and Conditions of Use. Any revisions made will be posted within the Privacy Policy or Terms and Conditions of Use, as applicable, on the Sites and will take effect immediately as indicated by the ‘last updated’ date, unless otherwise noted. Collection and use of information from that point forward will be subject to the revised terms. If you do not agree with any revision to this Privacy Policy or Terms and Conditions of Use, you must stop using and accessing the Sites. Your continued access or use of the Sites after any such revisions are posted will constitute your acceptance of these changes. You should review the Privacy Policy and Terms and Conditions of Use from time to time for any changes.