Privacy Policy

Effective Date: November 10, 2023

We understand the need for determining and enforcing all privacy-related rules and regulations. To this end, we have produced this privacy policy aligned to the requirements of ISO/IEC 27001:2013 to ensure that NuCompass shall comply with all relevant standard requirements.

  1. DATA PROTECTION

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). NuCompass acts as data processor of Personal Information that it receives from a client and the client is the data controller. 

NuCompass understands the importance of safeguarding and protecting all user provided information and therefore undertakes to process all Personal Information pursuant to the terms of this Privacy Policy and its Record Retention Policy and its Data Protection Policy. 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.

This Privacy Policy applies to the NuCompass portals located at nucompass.com. This policy does not apply to third party websites accessed from the portals via internet links. NuCompass makes no representations or warranties as to any content contained in third party websites and takes no responsibility for such websites. Our link to another website is not an endorsement of that website. Because we cannot guarantee that the privacy policies of such websites meet our standards, we recommend that you read the privacy policy of the website to which you link before you submit any Personal Information. We are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties.

  1. COLLECTION AND DISTRIBUTION OF INFORMATION

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:

  1. Name
  2. Address
  3. Telephone Number
  4. Social Security Number
  5. 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 services.

  1. DATA PROCESSING

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. NuCompass may also maintain certain anonymized information for its own legitimate interest, (such as improvement of services) or where it is required to do so by law. 

  1. 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.

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.

  1. 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’ 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.

  1. TRANSFER OF CLIENT DATA

NuCompass will relocate Mobility Services offshore, in another country, only with prior written approval from clients and in any event only where there is an agreement in place that obliges the entity to safeguard all personal information on the basis of terms equivalent to those in this Privacy Policy and the Record Retention Policy and its Data Protection Policy. 

  1. STORAGE OF CLIENT DATA

We will retain personal information for as long as needed or permitted in light of the purposes for which it was obtained. The criteria used to determine our retention periods include: (a) the length of time we have an ongoing relationship with you, (b) whether there is a legal obligation to which we are subject, and (c) whether retention is advisable in light of our legal position (such as in regard to applicable statues of limitations, litigation or regulatory investigations).

  1. EU-U.S. DATA PRIVACY FRAMEWORK WITH UK EXTENSION AND SWISS-U.S. DATA PRIVACY FRAMEWORK

NuCompass complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), 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.  NuCompass has certified to the U.S. Department of Commerce that it 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 in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF.  NuCompass has certified to the U.S. Department of Commerce that it 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/.

NuCompass is responsible for the processing of personal data it receives, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf.  NuCompass complies with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission [OR U.S. Department of Transportation] has jurisdiction over NuCompass’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, NuCompass may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, NuCompass commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States.  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint.  These dispute resolution services are provided at no cost to you.

For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S DPF, and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

  1. SHARING YOUR INFORMATION

We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We do not sell your personal information to third parties.

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 Privacy 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.

  1. 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 email. You do so at your own risk.

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.

  1. 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.

  1. 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 communications@nucompass.com.  

  1. 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. We ensure your information pursuant to our Record Retention Policy and its Data Protection Policy.  

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.

  1. 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 HTML to collect and store information. Various browsers may offer their own management tools for removing HTML.

We partner with a third party to display advertising on our website or to manage our advertising on other sites. Our third-party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here [or if located in the European Union click here]. Please note you will continue to receive generic ads.

Our Web 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 IP address, which page you are visiting on our site, 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 policy of the company providing it.

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. The privacy policy was updated to align with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) requirements, including the right to know, delete, and opt-out of the sale of your data. information. These changes reflect our commitment to data privacy and protection, and they provide clear information on how we collect, use, and safeguard your Personal Information. 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 privacy@nucompass.com.

  1. CONTACTING NUCOMPASS WITH PRIVACY QUESTIONS OR CONCERNS

If you have any questions, concerns or comments related to the protection of Personal Information or this Privacy Policy, you may contact us in the following ways:

  • e-mail privacy@nucompass.com
  • phone+1 925 734 3434
  • mail to NuCompass Mobility Services Inc.; Attn: Privacy Office; 6800 Koll Center Parkway, Suite 105, Pleasanton, CA 94566
  1. CHANGES TO THIS PRIVACY POLICY

NuCompass reserves the right to change this policy at any time to maintain compliance and protection of Personal Information. Changes, additions or deletions to this policy will be highlighted for 30 days following the effective date. Notification of Change will be posted on the Home Page of your NuCompass portal. If we make a change to this privacy policy, we will provide you with notice (for example, by email, sign-in notification, or other means) prior to the change becoming effective.

By continuing to use the Service after those changes become effective, you are agreeing to be bound by the revised Privacy and Security Policy. If you do not agree to the change, simply don't use the Service after the change is effective, in which case the change will not apply. You may, at any time, elect to no longer provide NuCompass with your Personal Information. Your continued use of your NuCompass portal will signify your acceptance of these changes.

Responsibility for upholding this policy is truly company-wide under the authority of the Information Security Office who encourages the personal commitment of all staff to address information security as part of their skills.

  1. ACCEPTANCE OF THIS PRIVACY POLICY

By logging in and using your NuCompass portal, you consent to the collection and use of your Personal Information in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the NuCompass portal.

 

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