Global Employment Solutions (“GES” or “We” or “Us”) has a strong commitment to providing excellent service to all of our customers (“Users”), including respecting their concerns about privacy. We understand that visitors to our website may have questions about whether and how this website collects and uses information, and are committed to protecting your privacy. In support of this, we only use the personally identifiable information (“personal information” or “personal data”) that you provide in accordance with the terms outlined below.
Please note that we only knowingly collect and process information from individuals who reside in the United States. Any processing of information of an individual not present in the United States is incidental and unintentional.
1. Notice to EU Residents
This Policy is intended to provide adequate and consistent safeguards for the handling of personal information in accordance Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“the General Data Protection Regulation”).
2. Principles for Processing Personal Information
We respect your privacy and are committed to protecting your personal information in compliance with the applicable legislation. This compliance is consistent with our desire to keep you informed and to recognize and respect your privacy rights. We agree to observe the following principles when processing personal information:
- Data will be processed fairly and in accordance with applicable law.
- Data will be collected for specified, legitimate purposes and not processed further in ways incompatible with those purposes.
- Data will be relevant to and not excessive for the purposes for which they are collected and used. For example data may be rendered anonymous if deemed reasonable, feasible
- and appropriate, depending on the nature of the data and the risks associated with the intended uses.
- Data subjects in the EU will be asked to provide their clear and unequivocal consent for the collection, processing and transfer of their personal data. We do not know who are EU subjects so we can’t guarantee this.
- Data will be accurate and, where necessary kept up up-to-date. Reasonable steps will be taken to rectify or delete personal information that is inaccurate or incomplete.
- Data will be kept only as it is necessary for the purposes for which it was collected and processed. Those purposes shall be described in this Policy.
- Data will be deleted or amended following a relevant request by the concerned data subject, should such notice comply with the applicable legislation each time.
- Data will be processed in accordance with the individual’s legal rights (as described in this Policy or as provided by law).
- Appropriate technical, physical and organizational measures will be taken to prevent unauthorized access, unlawful processing and unauthorized or accidental loss, destruction or damage to data. In case of any such violation with respect to personal data, we will take appropriate steps to end the violation and determine liabilities in accordance with applicable law and will cooperate with the competent authorities.
3. Information We Collect
Users may be asked for and we may collect, as appropriate:
- Contact information;
- Family contact information;
- Date of birth;
- Government-issued identification information, passport or visa information;
- Educational history;
- Employment and military history;
- Legal work eligibility status;
- Information about job performance and compensation;
- Race and ethnicity;
- Financial account information; and
- Other information employees may provide.
Users may, however, visit our Sites anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Sites related activities.
We may collect non-personal identification information about Users whenever they interact with our Sites. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Sites, such as the operating system and the Internet service providers utilized and other similar information.
Web Browser Cookies
We collect information about how you use our Sites by setting and accessing cookies on your computer. A cookie is a small piece of information sent by our Sites that is saved on your hard drive by your computer’s browser. The cookie holds information our Sites may need to personalize or enhance your experience and to gather statistical data, such as which pages are visited, the internet provider’s domain name and the addresses of the sites visited immediately before coming to and immediately after leaving the Sites. The information in the cookie lets GES trace “clickstream” activity (i.e., the paths taken by visitors to our Sites as they move from page to page) to enable us to better serve our customers by revealing which portions of our Sites are the most popular. We may link the anonymous visitor ID from your cookie to a user ID in our database to help us analyze web traffic and statistics. From time to time, other companies may help us with data research and analysis, but they will be prohibited from using that data for any other purpose. You may disable cookies on your browser. Please review your browser’s instructions for doing so. Note that certain features of the Sites may not be available if you delete or reject cookies.
4. How We Collect Information
We may collect personal information from Users in a variety of ways, including when Users:
- visit our site;
- submit a resume or cover letter;
- complete an employment application;
- complete a benefits application;
- complete an insurance form;
- subscribe to the newsletter;
- respond to a survey;
- fill out a form; and
- in connection with other activities, services, features or resources we make available on our Sites.
5. How We Use Collected Information
GES processes Users’ personal information for the following purposes:
- Managing Employee communications and relations
- Providing compensation and benefits;
- Administering payroll;
- Processing corporate expenses and reimbursements;
- Managing Employee participation in human resources plans and programs;
- Carrying out obligations under employment contracts;
- Managing Employee performance;
- Conducting training and talent development;
- Facilitating Employee relocations and international assignments;
- Managing Employee headcount and office allocation;
- Managing the Employee termination process;
- Managing information technology and communications systems, such as the corporate email system and company directory;
- Conducting ethics and disciplinary investigations;
- Administering Employee grievances and claims;
- Managing audit and compliance matters;
- Complying with applicable legal obligations, including government reporting and specific local law requirements;
- Other general human resources purposes;
- Personalizing user experience;
- Improving our Sites;
- Improving customer service;
- Sharing your information with third parties consistent with this Policy;
- Administering a content, promotion, survey or other Sites feature;
- Sending Users information they agreed to receive about topics we think will be of interest to them; and
- If a User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Sites.
We may also use information in the aggregate to understand how our Users as a group use the services and resources provided on our Sites.
6. Consumer Reports
We both receive and transmit data to consumer reporting agencies, either directly or through our partners. We partner with these agencies to assess your creditworthiness and to prevent fraud and identity theft. This is done as part of our regular underwriting, fraud prevention and process of providing services to you.
Information we collect in these reports includes, but is not limited to:
- Information about open and closed credit accounts, including the date opened, the date closed (if applicable), the latest reported monthly balance and monthly payment;
- Information about credit inquiries;
- Information about late payments and collection actions occurring on open and closed credit accounts;
- Information regarding public records of bankruptcy, judgements, tax liens, and other payment statuses;
- The credit score produced by the credit bureau providing the report;
- Information about your transaction history, assets, and account balances; and
- Correcting information maintained by the credit bureaus
Information related to your creditworthiness is maintained by the credit bureaus. If you find that there is an error or you want to dispute the information found in your credit report, please contact the credit reporting bureaus.
7. Sharing your personal information
We may share your information with third parties:
- to help us operate our business and the Sites or administer activities on our behalf, such as sending out newsletters or surveys for those limited purposes provided that you have given us your permission;
- to provide required information to an employee’s insurance provider, employee benefits administrator, travel professionals, clients to illustrate experience and qualifications for business purposes or promotion;
- to conduct background and credit checks;
- to protect payment transactions against fraud or identity theft;
- to provide you with offers and marketing that may be of interest to you;
- as a matter of law (e.g. to tax and social security authorities);
- to protect our legal rights;
- in an emergency where the health or security of an employee is endangered; and
- to law enforcement authorities in accordance with the relevant legislation.
We will always obtain your express permission at the time we collect information before sharing it with third parties for marketing purposes.
8. How We Protect Your Information
We adopt reasonable technical, administrative, and physical safeguards to protect personal data. These include appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Sites.
Sensitive and private data exchange between the Sites and its Users happens over a Secure Socket Layers (SSL) secured communication channel and is encrypted and protected with digital signatures.
9. Third party websites
Users may find advertising or other content on our Sites that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Sites. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Sites, is subject to that website’s own terms and policies.
The Sites are not directed to children under the age of 13 and GES does not intentionally collect any information from or about children under the age of 13. If you believe a child has provided us with information, contact us at email@example.com.
11. EU Resident Rights and Notice
Legal Basis for Processing Information
If you are located in the EU or Switzerland, we rely on several legal bases to process your Personal Information. These legal bases include where:
- The processing is necessary to perform our contractual obligations, such as to provide you with our services;
- You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
- The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims; or
- The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing our services, marketing new features or products that may be of interest, and promoting safety and security as described above.
If you have any questions about or would like further information concerning the legal basis on which we collect and use your Personal Information, please contact us by emailing [firstname.lastname@example.org].
Rights Under the GDPR
If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:
- Right of access. The right to obtain access to your personal data.
- Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
- Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
- Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
If you wish to exercise one of these rights, please email us at [email@example.com].
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Please note that United States law requires that we maintain certain records. If you request to modify or delete these records, we may not be able to facilitate your request. If this is the case we will provide you with the required notice.
12. Additional Enforcement Rights and Mechanisms
If at any time, you believe that your personal information has been processed in violation of this Policy, you may report the concern to the competent GES official. In particular, if you have any inquires or complaints about the use or limitation of use of your personal information, you may contact our corporate headquarters:
10375 Park Meadows Drive
Littleton, CO 80124
or email us at firstname.lastname@example.org.
13. California Privacy Rights
If you are a California resident, you have the right to request information from us regarding the manner in which GES shares certain categories of personal information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:
1. The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
2. The names and addresses of the third parties that received the information; and
3. If the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
This information may be provided in a standardized format that is not specific to you. The designated email address for these requests is: email@example.com.
Also, please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
14. Obligations to Data Protection Authorities
We will respond diligently and appropriately to requests from DPAs about this Policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of personal information, we will (i) cooperate with inquiries from the DPA responsible for the entity exporting the data and (ii) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.
15. Your Consent and Updates to this Policy
If you have any questions about your privacy or security on our Sites, please contact us using the following information:
10375 Park Meadows Drive
Littleton, CO 80124
This document was last updated on July 17, 2018