This policy applies only to individuals who visit our Sites or interact with us through e-mail. It does not apply to information which we may collect offline or through any other means, including on any other website operated by any third party, or to any information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Sites.
THE PERSONAL INFORMATION WE COLLECT
We collect and maintain different types of personal information that you and/or your employer provide to us on a voluntary basis. This may include:
- contact and identification information, such as your name, address, telephone number, e-mail address and employer information;
- product and service related information concerning the products and services that we provide to you or programs that we offer;
- 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.
We may also collect market-related information, which may include personal information, 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.
As a general rule, we collect personal information directly from you or through your employer. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions) or rely on the permission you have given to the third party.
From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
HOW WE COLLECT AND USE PERSONAL INFORMATION
We collect personal information 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, or receive from you, the programs, products and services that have been requested;
- to be able to review the products and services that we provide to you so that we may understand your requirements for our programs, products and services and so that we may work to improve our products and services;
- to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such 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 help us create and publish content most relevant to you;
- to enable us to comply with applicable law or regulatory requirements; and
- any other reasonable purpose to which you consent.
Your personal information 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 information 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 use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. For example, we may share your personal information from time to time with our third party information technology and data processing service providers so that we may operate our business. Additionally, we may share your information in connection with real estate services, destination services, corporate housing, household goods shipments, language and cultural training and other ancillary relocation related services.
When you visit our Site, we may automatically collect website use information, such as information about your Internet service provider, your operating system, browser type, domain name, Internet protocol (IP) address, your access times, the website that referred you to us, the Web pages you request, and the date and time of those requests. We use this information only to monitor our Site’s performance and improve our Site’s content and structure.
SOCIAL MEDIA WIDGETS
Our Site includes social media features, such as the Facebook Like button, and Widgets, such as the “Share This” button or interactive mini-programs that run on our Site. These features may collect your Internet protocol address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it.
CALIFORNIA’S DO NOT TRACK NOTICE
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 information.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please contact us using the methods described below.
CONSENT AND OPT-OUT
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified at the relevant time.
From time to time, we communicate via email or text with users who request information or subscribe to our newsletters of email mailing lists. 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. You also may opt-out of receiving emails by clicking on the “unsubscribe” link within the text of the email. Additionally, for other communications the opt-out choice may be exercised by ticking or un-ticking the appropriate box if such checkbox is available at the points where personally identifiable information is collected or by contacting us. For text messages, should you choose to “unsubscribe” or stop receiving such messages, you can contact us directly at firstname.lastname@example.org or reply with the message “STOP” to a message after it is received. Further, you hereby confirm consent to receiving a confirmatory message in response to your STOP request. Message and data rates may apply.
We partner with a third party to either display advertising on our Sites or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this Site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here – http://preferences-mgr.truste.com (or if located in the European Union click here – http://www.youronlinechoices.eu). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
PLUS RELOCATION’S ELO ONLINE COMMUNITY
We typically collect information under the direction of your employer. If you are a relocating employee of one of our clients and would no longer like communication provided by your employer that use our service, please contact the employer that you interact with directly. We may transfer personal information to companies that help us provide our service. 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 EloSM account or email us at email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
We will retain personal data we process for as long as needed to provide our services. Plus Relocation will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Users of the Plus Relocation’s EloSM 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 firstname.lastname@example.org.
We do not intend our Sites to collect personal information from children under the age of 13. We urge parents to regularly monitor and supervise their children’s on-line activities.
LINKS TO OTHER WEBSITES
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 website 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 information. You should review the privacy policies of these websites before providing them with personal information.
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.
Once we receive your transmission, we make reasonable efforts to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. 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 information only for the purpose of performing their work, we do not control such third parties’ website or other security measures.
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Sites or providing personally identifiable information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Sites. We may post a notice on our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
UPDATING OR ACCESSING YOUR PERSONAL INFORMATION
Upon request Plus Relocation Services will provide you with information about whether we hold any of your personal information. If you wish to obtain access to the personal information that we maintain about you, or to correct, amend, update or delete such information, please contact our Privacy Officer in writing using the contact information provided below or login to your EloSM account to make the changes yourself. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavor to respond within an appropriate timeframe and, in any event, within any timeframe required by law. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event, we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions. In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
GOVERNING LAW / VENUE / FORUM
USERS LOCATED IN THE EEA AND SWITZERLAND
If you are a user in the EEA or Switzerland, the following information applies with respect to personal data collected through your use of our Sites.
Purposes of processing and legal basis for processing
Retention of Personal Data
We will take reasonable steps to accurately record the personal data that you provide to us and any subsequent updates. We will retain your personal data as long as necessary to fulfill the purposes for which it was collected. Thereafter, we will either delete your personal data or de-identify it so that it cannot be attributed to your identity. Please note that we may continue to retain personal data for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you are a resident of the EEA or Switzerland, you have certain rights under EU General Data Protection Regulation, as set forth below:
- Right of access: You have the right to request a copy of the information that we hold about you.
- Right of rectification: You have the right to have information that we hold about you that is inaccurate or incomplete corrected.
- Right to be forgotten: In certain limited circumstances, you have the right to request that we erase from our records the information that we hold about you.
- Right to restriction of processing: In certain limited circumstances, you have the right to restrict the processing of your information.
- Right to withdraw consent: If you have provided consent for the processing of your information, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
- Right of portability: In certain limited circumstances, you have the right to have the information we hold about you transferred to another organization.
- Right to object: You have the right to object to certain types of processing of your information such as direct marketing (to the extent applicable).
- Right to object to automated processing, including profiling: You have the right to not be subject to the legal effects of automated processing or profiling.
- Right to lodge a complaint: You have the right to lodge a complaint with a regulatory authority, if you believe that we have not complied with the requirements of the GDPR with regard to your personal information. A listing of EU data protection authorities can be located at: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
EU – U.S. PRIVACY SHIELD AND SWISS-US PRIVACY SHIELD
Plus Relocation is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Plus Relocation complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Plus Relocation is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Plus Relocation may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you believe that we are not processing your personal data within the scope of our Privacy Shield certification, you may direct any inquiries or complaints concerning our Privacy Shield compliance in the following ways:
(1) In the first instance, please send your inquiry or complaint to Stacey A. Myhro at email@example.com or by writing to the following mailing address:
Stacey A. Myhro, CCMAP
Senior Vice President, Contracts & Compliance
Plus Relocation Services, LLC
600 Hwy 169 South, Suite 500
Minneapolis, MN 55426
United States of America
(2) If you are not satisfied with our response, for complaints that cannot be resolved with us directly, if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
(3) Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Our commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Stacey A. Myhro, CCMAP
Senior Vice President, Contracts & Compliance
Plus Relocation Services, LLC
600 Hwy 169 South, Suite 500
Minneapolis, MN 55426
United States of America
Phone: (952) 512 5530
Fax: (952) 593 2748
You may also call us Toll-Free 1-888-251-2825 (Mon-Fri, 8 am – 5 pm CST) or email us at firstname.lastname@example.org. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.