Effective Date: September 13, 2016
NuCompass Mobility Services Inc., also referred to as NuCompass, has long-term experience delivering relocation management services. Our clients and their employees entrust NuCompass with the relocating employee’s personal information (“Personal Information”) to facilitate the delivery of mobility services on our web site www.nucompass.com, NuCompass portals (client.nucompass.com, navigate.nucompass.com, copilot.nucompass.com, and supplier.nucompass.com), and NuCompass Mobile apps. NuCompass understands the importance of safeguarding and protecting all user provided information. The use of information collected through our service shall be limited to the purpose of providing the service for which our clients have engaged with us. We are committed to complying with all applicable state and federal privacy laws. NuCompass maintains internal best practices, controls and standards to manage protection and compliance.
NuCompass 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.
The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged NuCompass.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request.
NuCompass Mobility Services Inc. complies with 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 data from Switzerland. NuCompass Mobility Services Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view NuCompass Mobility Services Inc.’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
NuCompass Mobility Services Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. NuCompass Mobility Services Inc. is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s www.privacyshield.gov/list.
NuCompass Mobility Services Inc. 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. NuCompass Mobility Services Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, NuCompass Mobility Services Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, NuCompass Mobility Services Inc. 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 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.
Under certain conditions, more fully described on the www.privacyshield.gov/welcome, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Following are NuCompass’ privacy practices:
Collection and Distribution of Information Information Provided to NuCompass. The collection of Personal Information, including Personally Identifiable Information (as defined below), about you is voluntary. You may elect to not provide information to NuCompass at any time. If you choose to not provide certain information to NuCompass, it may affect our ability to deliver services your employer has authorized. You will be notified if services will be affected due to lack of information. Please notify your NuCompass Consultant if you wish to opt-out of information sharing. The types of Personal Information we ask you to provide are based upon the services you are authorized by your employer to receive. We use this information to administer your account, provide the authorized services, and respond to your concerns.
“Personally Identifiable Information” is a subset of Personal Information and includes, but is not limited to, the following:
- Telephone Number
- Social Security Number
- E-mail Address
When you use our Services, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”). We do not ask for, access or track any location based information from your mobile device at any time while downloading or using our Mobile Apps or Services.
Information Related to Data Collected through the NuCompass Portals NuCompass collects information under the direction of our clients, and has no direct relationship with the individuals whose personal data it processes. NuCompass works with its clients to help them provide notice to their employees concerning the purpose for which personal information is collected.
Choice We collect information to provide services authorized by our clients for their employees. If you are an employee of one of our clients and would no longer like to be contacted about our services, please contact the client directly.
Service Provider, Sub-Processors/Onward Transfer NuCompass may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this policy regarding notice and choice and the service agreements with our clients.
Access to Data Controlled by our Clients NuCompass acknowledges that you have the right to access your personal information. NuCompass has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the NuCompass‘s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.
Data Retention NuCompass will retain personal data we process on behalf of our clients for as long as needed to provide services to our client. NuCompass will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
NuCompass may need to share your Personally Identifiable Information with certain third parties to facilitate the services you receive. These third party suppliers, such as realty service or moving provider, are acting on our behalf, and are subject to our data privacy requirements. These third party suppliers only receive information related to the services they are performing. NuCompass’ Supplier Management Team monitors these suppliers to ensure compliance with our strict Data Protection Policy. These third party suppliers are restricted from sharing your Personally Identifiable Information with other organizations or using such information for any other purposes. If you do not want us to share your personal information with these companies, Please contact us.
We reserve the right to disclose your Personal Information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We may share certain Personal Information when necessary to prevent against fraud or other unauthorized activities, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or to any other third party with your prior consent to do so.
Your Personal Information may be transferred in the event of a corporate sale, merger, acquisition, or divestiture. You will be notified in advance of any transfer of information that may affect you. The notification will be via e-mail and posted on your NuCompass portal.
Submitting and Updating Your Information Upon request NuCompass will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. If, at any time, you wish to access, submit, delete or update your Personal Information, you may log into your portal and provide the information online via our Interactive Forms. You may also contact your NuCompass Consultant and provide such information offline. Information transmitted via e-mail is not considered secure. NuCompass is not responsible for the safeguarding of your Personal Information if you transmit it to us via e-mail. You do so at your own risk. We will respond to your request to access within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Collecting Information from Children NuCompass is committed to protecting the privacy of children in accordance with the Federal Trade Commission (FTC) Children’s Online Privacy Protection Act (COPPA). NuCompass will not knowingly or intentionally collect Personal Information from children under the age of 13.
Opt-out Preference If you, as our client, wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at firstname.lastname@example.org.
Securing Information NuCompass employs a combination of industry-standard security technologies, procedures, and organizational measures and controls to protect against the loss, misuse, and unauthorized access of your Personal Information in our possession. To facilitate the securing of your information, we take the following steps:
- User Access Controls – We maintain several layers of application access control (physical and logical) to ensure your information is only available to those that require access to perform services to you or on your behalf.
- Privacy and Data Protection Policies are communicated to all NuCompass employees annually.
- All physical documents containing Personal Information are stored in secure areas.
- Dual Authentication is required to access our Data Center.
- Nightly backups are performed for all data. Encrypted tapes are stored offsite at Iron Mountain to ensure maximum protection.
- Navigator Log-in pages, Passwords and other Personally Identifiable Information data are encrypted in transit as well as at rest in our database.
- Navigator utilizes 2048-bit encryption using Secure Socket Layer (“SSL”) and Secure HTTP (“https”) technologies
NOTE: No method of data storage or transmission is guaranteed to be 100% secure. We continue to enhance our security measures to protect your information using commercially accepted tools and practices. If you have any questions about our security, please contact us.
Cookies and Other Tracking Technologies We track site access and utilization directly through our application. We do not use third party tools to capture this information and we maintain secure control over any usage tracking. This allows us to continue to improve the experience and usability of our applications. No Personal Information is used in developing features and monitoring behavior of our websites.
Technologies such as: Cookies, beacons, tags and scripts are used by NuCompass and our analytics or service providers also use tags and scripts. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We do not link this automatically collected data to other information we collect about you.
Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
California Privacy Rights Residents of the State of California, under provisions of the California Civil Code, have the right to request from companies conducting business in California, a list of all third parties to which the company has disclosed Personal Information for marketing purposes. NuCompass strictly forbids the distribution of your Personal Information to third parties for the use of direct marketing.
If you are a California resident and have questions regarding the disclosure of Personal Information to third parties for marketing purposes, you may send your inquiry request to email@example.com.
- e-mail firstname.lastname@example.org
- phone +1 925 734 3434
- mail to NuCompass Mobility Services Inc.; Attn: Privacy Office; 7901 Stoneridge Dr Suite 390; Pleasanton, CA 94588 USA
Our complete Data Protection Policy is available here: nucompass-data-protection-policy