Effective Date: May 4, 2020
- 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.
- 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:
- 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 Services.
- 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 information for its own legitimate interest, (such as direct marketing or improvement of services) or where it is required to do so by law.
- 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.
- 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.
- TRANSFER OF CLIENT DATA
- 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).
- PRIVACY SHIELD
In compliance with the Privacy Shield Principles, NuCompass commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact NuCompass at email@example.com.
NuCompass Mobility Services Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. NuCompass is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, 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 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 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, NuCompass is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. 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.
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 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.
- SHARING YOUR INFORMATION
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.
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 email. 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. We ensure you information pursuant to our Personal Information Security 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.
- 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.
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.
- CONTACTING NUCOMPASS WITH PRIVACY QUESTIONS OR CONCERNS
- e-mail firstname.lastname@example.org
- phone+1 925 734 3434
- mail to NuCompass Mobility Services Inc.; Attn: Privacy Office; 6800 Koll Center Parkway, Suite 105, Pleasanton, CA 94566
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 any material changes, we will also notify you by email or by means of a notice on this web site prior to the change becoming effective.
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.
CHANGES TO OUR PRIVACY & SECURITY POLICY
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.