Last Updated: January 31, 2021
Welcome to the web site (the "Site") of Human Capital dba Onboardly ("Onboardly", "we", "us" and/or "our"). Onboardly provides an integrated platform of personnel management tools and services, mobile applications and related services (together with the Site, the "Services") to our Service visitors ("you" or "your").
OUR PRIVACY PRINCIPLES
We recognize that you must entrust us with information about you to receive our Services. Maintaining your trust is extremely important to us. We share our privacy principles to enable you to understand the key hallmarks of Onboardly’s approach to data privacy.
- We safeguard the security of your Personal Data as if it were our own. We believe that security certifications are good, but that security by design is better. We bake security into our product features and protect your data with the same security safeguards used to protect our own data.
- We do not sell your Personal Data. We recognize that receiving your Personal Data is vital to provide our Services to you. Selling Personal Data would be a grave violation of trust. We want to make clear that we are not in the business of selling Personal Data and we do not intend to be.
INFORMATION WE COLLECT
When you interact with us through the Services, we may receive Personal Data as well as other information and data (“Other Information”), as explained in more detail below.
- Information You Provide Us. We collect your Personal Data when you, your employer, or your employer’s vendors register to use the Service, provide information when using the Site or Service, update your account information, add additional services, submit information to verify your identity, contact customer support, contact us with questions or feedback, or otherwise communicate with us. This Personal Data may vary depending on what you choose to share with us and the Services you use, and may include identification information, professional or employment-related information, benefits enrollment information, financial information, demographic information, commercial information, photographs, online activity information, geolocation data, background screening information, and preference information. If you or your employer manages or obtains health insurance benefits through our Services, we may also receive health information about you and your dependents to assist you with eligibility and enrollment in insurance coverage, which we may obtain directly from you, from the primary policyholder on your benefits plan if you are a spouse or dependent of the primary policy holder, from your employer, from insurance carriers, from third-party administrators, or from other service providers used to provide Onboardly’s benefits administration and broker services.
- Information Third Parties Provide Us. We may collect and receive information about you, including Personal Data, from third parties, such as your employer, your employer’s service providers, financial institutions, and our own service providers, including for identity verification, fraud protection, providing the Service, and other purposes. We may also receive demographic and business industry information about you from third parties to help us better understand our users and to improve and market our Service. If you use us to manage integrated Third Party Services, we may also have access to your Personal Data from such Third Party Services. For example, if you use an integrated Third Party Service to conduct employee and contractor background checks, we may receive the background reports from that integrated Third Party Service in order to display the background check results to you.
- Other Information: We may also collect, generate, and/or receive Other Information as follows:
- Services Metadata. When you interact with the Services, metadata is generated that provides additional context about the way our authorized users utilize the Services. For example, we may log what Third Party Services are used (if any).
- Log Data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Site or Services and record it in log files. Such log files may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time Services were used, information about browser configuration and plugins, language preferences and cookie data.
- Device Information. We collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
- Location Information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. We may also collect location information from devices in accordance with the consent process provided by your device.
- Additional Information Provided to Us. We also may receive Other Information when submitted to our Site or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by Onboardly or a vendor, request support, interact with our social media accounts or otherwise communicate with us.
HOW WE USE INFORMATION
Onboardly uses information that we collect in accordance with Customer instructions, including our Terms of Service and related agreements, if applicable, Customer’s use of Services functionality, and as required by law. Onboardly acts the “data processor” or “service provider,” where applicable, of Personal Data, and Customer acts as the “controller” or “business,” where applicable. A Customer may, for example, use the Services to assign roles and configure settings, access, modify, export, share and remove Personal Data and otherwise apply its policies to the Services.
More specifically, we may use and share the information we collect as follows:
- To provide our Services. We use the information we collect to provide, update, maintain, and protect the Services. For example, if you participate in our benefits administration or broker services, we may use health information to confirm insurance enrollments and carry out insurance payments, health care, and other benefits-related services and operations.
- To improve and customize the Service. As we seek to improve your experience with the Service, we may analyze data we collect about your use of the Service to inform how we can improve our Services, including our software, infrastructure, user interfaces, and integrations with our partners.
- To respond to inquiries, comments, feedback, or questions.If you contact us, we may use the information that you provide to respond.
- To communicate with you. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them.
- To advertise and market to you. We may contact you to tell you about new product features, promotional communications or other news we believe may be of interest to you. Additionally, as noted above, we may also utilize cookies, beacons, and mobile SDKs, to recognize your browser or mobile device in order to serve you advertisements, and analyze the effectiveness of our advertising and marketing campaigns. We may also use third party services, data, and software tools to provide advertising to you, help us identify and reach potential customers, and perform analysis on the performance of our site and advertising. Our advertising vendors do not have any independent right to use Onboardly data or that of its customers. Please note that you can control whether you receive marketing communications and advertisements by following the instructions under “Your Choices” below.
- To investigate and help prevent security issues and abuse of our Services. We may use your Personal Data and Other Information to protect the rights, property, and safety of Onboardly, our employees, Customers, our users, and third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With consent. We may use Personal Data and Other Information with third parties when we have consent to do so.
HOW WE SHARE INFORMATION
Onboardly is not in the business of selling your information. We consider maintaining your trust over your information to be a vital part of our relationship with you. In certain circumstances, however, Onboardly may share the information we collect with third parties, including our service providers and sub-processors, for the legitimate business purposes set forth below.
- To comply with Customer’s instructions. We may share and disclose Personal Data in accordance with a Customer’s instructions, including any applicable terms in the Terms of Service or related agreements, Customer’s use of Services functionality, and in compliance with applicable law and legal process. In addition, Customer administrators and other personnel may be able to access, modify, or restrict access to Personal Data and Other Information. This may include, for example, your employer using Service features to export logs of Services activity.
- To integrate with Third Party Services. To provide an integrated platform of HR and IT solutions, Customers may enable integrated Third Party Services, including 401(k) providers, applicant tracking platforms, performance management services, corporate card providers, enterprise communication tools, among others. When enabled, Onboardly may share Personal Data and Other Information with Third Party Services. Third Party Services are not owned or controlled by Onboardly and third parties that have been granted access to Personal Data and Other Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third Party Services or contact the provider for any questions. Any permissions you have granted to that Third Party Service will govern their use of your data.
- To work with our vendors and service providers. We may engage third party companies or individuals as service providers, vendors, or business partners to process Personal Data and Other Information and support our business. These third parties may, for example, provide cloud computing and storage services, work as a contractor to support some development initiatives, or we may share business information to develop strategic partnerships with Third Party Service providers to support our common customers. Additional information about the sub-processors we use to support delivery of our Services is set forth.
- To facilitate a change in Onboardly’s business. As our business develops, we may be involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, and the information we collect may be shared or transferred in the diligence or conclusion of any such corporate event.
- To investigate and help prevent security issues and abuse of our Services. We may share your Personal Data and Other Information to protect the rights, property, and safety of Onboardly, our employees, Customers, our users, and third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- To comply with applicable law, regulation, or legal process. We may disclose your Personal Data and Other Information if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of Onboardly, prevent fraud, act in urgent circumstances to protect the personal safety of users of the Services or the public, or protect against legal liability.
- With consent. We may share Personal Data and Other Information with third parties when we have consent to do so.
We respect your choices over your Personal Data. When visiting our Site or using our Services, you have the following choices with respect to your Personal Data.
- Accessing the Site. You can visit our Site without providing any Personal Data.
- Reviewing, Updating, and Correcting Your Information. You can review, update, or correct your Personal Data through your account. If you have questions, please contact us.
- Marketing and Promotional Communications. You may unsubscribe from marketing emails that we send to you by following the instructions contained in each promotional email we send you. If you unsubscribe, you will no longer receive marketing emails, but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests. You may also opt-out of online behavioral advertising on the Internet by visiting the Network Advertising Initiative, or the Digital Advertising Alliance opt-out pages. You may also opt out of online behavioral advertising on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices App. Depending on your mobile device, you may also control marketing and other tracking technologies through your settings by resetting your advertising ID.
- Do Not Track. Some web browsers may transmit “Do Not Track” signals. There is no current standard that governs what, if anything, websites should do when they receive these signals. We do not currently respond to “Do Not Track” signals. If and when a standard is established, we may revise our policy on “Do Not Track” signals.
If you would like to take additional steps to correct, amend, object to the processing or profiling of, or to delete your Personal Data not currently available through the Onboardly platform, please coordinate your request with the Customer whose account you use (e.g. your employer or former employer). Because Onboardly acts as a service provider to our Customers, in some situations, we must hear from your employer before taking additional steps. Please note that your employer may or may not be able to honor such requests in order to maintain a legally compliant HR and IT record-keeping system. For example, employers in the United States are legally required to maintain records of various work eligibility, tax, and other employment documentation.
a. Our Policy Toward Children
b. Links to Other Websites
We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction and to comply with applicable state and federal privacy and security laws. We also apply the same standards to your data that we apply to our own data. However, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed to prevent interception or misuse. As a result, we must also depend on you to protect your information. You should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to us via the Internet. If you become aware of any breach of security or privacy, please notify us immediately.
d. Data Retention
e. Aggregated or Pseudonymized Data.
In an ongoing effort to better understand and serve the users of our Services, we conduct research on our Customer demographics, interests and behavior based on the Personal Data and Other Information provided to us. Such research may be compiled and analyzed on an aggregated or pseudonymized basis. This aggregated or pseudonymized information does not identify you. We may share aggregated or pseudonymized data with affiliates and partners for business or research purposes. We may also disclose aggregated or pseudonymized user statistics in order to describe our services to current and prospective business partners, and to third parties for other lawful purposes.
f. International Users
By using our Service, you understand and acknowledge that your Personal Data may be transferred from your location to our facilities and servers in the United States.