Certify Privacy Policy

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Privacy Notice
Last Updated: January 31, 2020

Certify, Inc., is a developer of certain web-based software products and services and adheres to this privacy notice (“Privacy Notice”) for all its products and services. This Privacy Notice applies to Certify Inc., as well as its affiliate Certify (UK) Ltd., (collectively, "Certify”). Certify's Privacy Notice applies to all of its users of the service, website and mobile application users, job applicants and anyone who participates in our marketing program. This Privacy Notice describes how we collect, receive, use, store, share, transfer, and process your personal information, as well as your rights in determining what we do with the information that we collect or hold about you. Certify works very hard to maintain the confidentiality of all data that is submitted to it. The use of information collected through the Certify service is limited to the purpose of providing the service for which you have engaged Certify.

Data Controller
When you visit a Certify website, except as provided further in this Privacy Notice, the data controller is the Certify entity named in the terms section on the Website.

EU-U.S. and Swiss-U.S. Privacy Shield
Certify, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from the European Economic Area, United Kingdom and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
[https://www.privacyshield.gov/list].

Certify, is responsible for the processing of personal data it receives, under each Privacy Shield Frameworks, and subsequently transfers to a third party acting as an agent on its behalf. Certify complies with the Privacy Shield Principles for all onward transfers of personal data from the European Economic Area, United Kingdom and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Certify, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Certify may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Dispute Resolution
If you have an unresolved privacy or data use concern that Certify has not addressed satisfactorily, please contact Certify's 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 be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Information we collect
We collect, store and process your personal data by different methods depending on whether you are a candidate, or website user.

Where you are a candidate
You may be a past candidate or a candidate in process or you may have participated in our recruitment or other similar events.

How we collect your data:
  • You may provide personal data to us by email, post, telephone, face to face during meetings or at our events or through our website; or
  • We may collect your data indirectly or from third parties: through recruitment agencies, social media searches (such as LinkedIn), research companies, client or supplier conversations, or referrals from other third parties.
What data we collect:
  • The Personal Data we collect about candidates includes: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, right to work, social security/national insurance number, nationality, employment and education history, skills proficiency, references, or qualifications information contained in your resume/CV, or written records of our conversations or meetings.
  • We do not mandate the collection of any Special Categories of personal data about you through this website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, ,information about your health, genetic and biometric data).
  • We will ask for your explicit consent before we collect Special Category personal data, including where required to carry out criminal or other background checks. We will not disclose such Special Category personal data without your express consent.
When you are a User of the Website
When you access, use and/or interact with our website, we directly collect information you voluntarily provide us, such as when you download content or contact us, which includes:
  • personal information that you provide by completing online registration forms, complete questionnaires or surveys, by applying for roles via our website, or when you create or update any of your marketing preferences. This information might include username, password, email address and SMS number; as well as:
  • data collected via cookies, in line with cookie consent, server logs and other similar technologies preferences and settings in your browser, as further described below; or
  • personal information you provide when requesting asset downloads about our businesses and partners.
We also obtain business information and personal data (such as your name, title, company name and email) about you from third party sources, as permitted by applicable law, such as the following:
  • information collected by our marketing service providers on our behalf, which are a variety of marketing lead generation service providers, marketing opt-in lists or data aggregators or professional event organizers
  • information shared with us by Certify business partners as part of their referral activities
  • public databases or other data you may have made publicly available, such as social media posts on professional networks and social media platforms;
  • information shared with us by a third party who recommended you, once you have confirmed your agreement for us to keep and process such data (for the purpose of providing you with updates about Certify’s services).
When you are a User of our Services (including the mobile application)
Certify offers a variety of software services such as expense tracking and management, travel booking and management, time tracking and management, and vendor procurement and invoice management. In order to provide these services, Certify collects different types of information based on the software application, nature of user interaction, and the specific types of information our business customer requests that we collect on their behalf. In collecting and hosting customer data within our system, Certify acts as the data processor; our business customer is the data controller.

Certify does not make any decisions in relation to the content of personal information submitted or use of the information by any customer and nor does Certify have a direct relationship with the individuals whose personal data it processes. If you are a user with one of our business customers and would no longer like to be contacted regarding the use of Certify service, please contact the customer directly regarding the issue.

Data we collect includes the personal data of individual users and may include: Name, email, phone number (optional), employee and payroll ID (optional), credit card transaction data (optional), credit card user credentials (optional), and direct deposit banking information (for ACH, wire transfer service). Billing information is encrypted at all times and is stored on secure servers.

Log Information
While using the Certify website or a Certify service, Certify servers automatically record information that your browser sends. These logs may include information such as login and logout times, your web request, IP address, browser type, browser language, mobile device type, operating system, the date and time of your request and one or more cookies that may uniquely identify you.

How we use the Information
Certify uses personal information only for the purposes for which it was collected and in accordance with this Privacy Notice. Certify takes reasonable steps to ensure that the personal information it processes is accurate, complete, and current, but Certify depends on its users to update or correct their personal information whenever necessary. Client/users are solely responsible for their data and Certify is under no obligation to independently review such data for accuracy or potential liability.

Certify may use the information you provide about yourself to fulfill your requests for Certify products, programs, and services, to respond to your inquiries about Certify services, and to offer you other products, programs or services that Certify believes may be of interest to you. We are collecting data through the application process which we transfer to the US for the purpose of reviewing and analyzing your candidacy with different teams leads within Certify.

Certify may use your personal information to create anonymous data records or aggregations of data, to perform statistical analyses and for other purposes, by removing information that makes the data personally identifiable to you.

Sharing the Information
At Certify, we only share personal information in ways that we tell you about. We do not sell or rent personal information to third parties and we do not share personal information with third parties that are not owned by us or under our control or direction except as described in this Privacy Notice.

Legal compliance: In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Certify may r disclose your information as required by law, such as to comply with a subpoenas, court orders, or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, respond to a government request or to establish or exercise its legal rights or defend against legal claims.

If Certify believes it is necessary, it shall share your information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or the security of Certify network or services, violations of Certify's Terms of Use Agreement, or as otherwise required by law.

Corporate Transaction: If Certify is involved in a merger, acquisition, or sale of all or a portion of its assets, we reserve the right to sell or transfer your information as part of the transaction. In such an event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

Business Partners: Certify offers some of the services in connection with business partners. In some cases, information you provide under your Certify account may be shared with our business partners to provide services specifically requested by you. Certify processes your information in accordance with this Privacy Notice. If you no longer require the service and would prefer that we do not share your personal information on a goingforward basis with business partners for their direct marketing purposes, you may opt-out of this sharing by contacting us as described in this Privacy Notice. Please note that once we share your personal information with another organization, the information received by the other organization is controlled by that organization and becomes subject to its privacy notice and practices.

Third Party Service Providers/Vendors: Certify may provide access to your personal information and usage data to our trusted sub-processors that assist us with the operation and maintenance of this site. For example, we may contract with third parties to process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, reporting, and software maintenance and development services. In addition, our sub-processors will be given access to your information only as is reasonably necessary to provide the services for which they are contracted, pursuant to written instructions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal information they receive from us for any other purpose. For a full list of our sub-processors, please contact privacy@certify.com

Within Our Corporate Family: Certify may disclose personal data to affiliated companies related by common ownership or control within Certify, to carry out regular business activities, such as to provide, maintain and personalize Certify sites and services, to communicate with you, and to accomplish Certify’s legitimate business purposes, pursuant to contractual safeguards.

Transfer of Information
Certify may transfer personal information to companies that help it provide the service. These companies are authorized to use your personal information only as necessary to provide these services to us. Transfers to subsequent third parties are covered by the Certify Terms of Use Agreements entered into between Certify and its customer. . Certify may also transfer information to any third party you authorized by you.

Cross-bored transfer
To facilitate our operations, Certify may transfer, store and process your personal information in jurisdictions other than where you live [including in the United States, UK and Canada]. Laws in these countries may differ from the laws applicable to your country of residence. For instance, if you are a European Economic Area (EEA) data subject and your personal information is shared with our affiliates, partners, or third-party service providers acting on our behalf outside of the EEA, then it is done so pursuant to necessary means to ensure an adequate level of protection.

Tracking Technologies
Certify and its partners use cookies or similar technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about its user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Certify uses mobile analytics software to allow it to better understand the functionality of its Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. Certify does not link the information it stores within the analytics software to any personally identifiable information you submit within the mobile application.

Online Advertising & Remarketing
In order to reach people, like you who have previously visited Certify's website and shown interest in its services, Certify uses Google's AdWords "remarketing" service. This service allows Certify's ads to be shown to you as you travel across the internet, by placing a cookie on your web browser. All it does is, it says, this person visited this page, so show them ads relating to that page. Using a cookie for remarketing purposes only allows Certify to tailor its marketing programs to better suit your needs by only displaying ads that are relevant to you. However, you are free to opt out of Google's use of cookies by visiting Google's Ads Settings web page.

Certify partners with a third party to display advertising on its website or to manage its advertising on other sites. Certify's 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 may continue to receive generic ads.

Communications
When you communicate with other users or Certify's staff through the Certify website or via a Certify service, those communications are saved in order to process your inquiries, respond to your requests and improve Certify services.

You may sign-up to receive communications from Certify, including any online or physical forms of communication. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” or "Update Subscription Preferences" links found in emails Certify sends to you or at your member profile on Certify's website or by contacting Certify at privacy@certify.com.

Links to Unaffiliated Websites, Apps and Other Digital Properties
Although Certify chooses its business partners carefully, it cannot be responsible for the privacy practices of websites operated by third parties that are linked to or from Certify's website. Once you have left Certify's website, you should be sure to check the applicable privacy statement of the third party website to determine how they will use information they collect from you.

Protecting Your Data
Every precaution is taken to insure the security of your data while using the Certify website or a Certify service. Certify uses industry-standard firewalls, secure web servers (https), data encryption and authentication procedures, among other techniques, to maintain the security of your data and your online session.

Still, no system can be guaranteed to be 100% secure. If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, please contact us immediately as described in this Privacy Notice.

Data Ownership
Any data you submit while using the Certify website or a Certify service belongs to you. You may be able to delete some data yourself, while other data may be deleted by your Certify administrator except where it will impact core functionality of the If you ask Certify to delete your account, Certify shall make commercially reasonable efforts to remove all of your data from its servers. Despite such removal efforts, portions of your data may remain on Certify's production and back-up servers indefinitely.

Any information you submit that can identify you personally on a blog, bulletin board or chat room through the Certify website or a Certify service can be viewed and used by other Certify users, and could be used to send you unsolicited messages. Certify is not responsible for your disclosure of this information in these forums. To request removal of your personal information from our message boards, blogs, or community forums, contact us at privacy@certify.com.

Data Retention
Certify will retain your data and Personal Information as long as we have a need for it, or until we are requested to delete it. Retaining your data allows Certify to provide customer historical reporting and customer reactivation. In certain circumstances, Certify may be required by law to retain your personal information for a longer retention period or may be obligated to retain your personal information in order to maintain core functionality of the Certify service for the customer. If you would like your data and Personal Information deleted, please provide a request to privacy@certify.com.

Your Privacy Rights
If Certify holds your information as a controller (for instance, if you have provided your information on our website), upon request Certify will provide you with information about whether or not Certify holds any of your personal information. You have the right to access, correct inaccurate or incomplete personal information, request that we no longer use it or request deletion of your personal information by logging in to your account, contacting your Certify Account Manager, or by contacting us at support@certify.com. Certify will respond to your request within a reasonable timeframe.

Certify acknowledges that you have the right to access your personal information. Certify has no direct relationship with the individuals whose personal data it processes on behalf of our clients. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Certify's client (the data controller). We will honor and support any instructions they provide us with respect to your personal information.

Your California Privacy Rights
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information collect, including the categories of sources, please see the Information We Collect section above. We collect this information for the business and commercial purposes described in the How We Use the Information section above. We share this information with the categories of third parties described in the Sharing the Information section above. Certify does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in the Tracking Technologies section above.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@certify.com. We will verify your request using the information associated with your account, including email address. Government identification may be required.

Privacy Notice Changes
Certify reserves the right at its sole discretion to make changes to this Privacy Notice y at any time. You may review updates to Certify's Terms of Use Agreement and/or Privacy Notice at any time via links on Certify's website. You agree to accept electronic communications and/or postings of any revised Terms of Use Agreement and/or Privacy Notice on the Certify website, and you agree that such electronic communications or postings constitute notice to you of the revisions to the Terms of Use Agreement and/or Privacy Notice, as applicable. If Certify makes any material changes we shall notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective.

Questions?
If you have any questions or concerns about our collection, use, or disclosure of your information, please email us at info@certify.com or contact us at Certify Inc., 20 York Street, Portland ME 04101.