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").

This Privacy Policy describes and is intended to help you understand our privacy principles, what information we collect (including Personal Data), how we use that information, how we share that information, your choices concerning our data practices, and other important information. We consider “Personal Data” to be any information that alone or in combination with other information in our possession could be used to identify you. This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Onboardly platform (“Third Party Services”), which are governed by their own respective privacy policies. When you access our Services through your employer or another entity (our “Customer”), please note that our Customers maintain control over the Services accounts for their organization, including the data associated with their account. If you have any questions about the specific settings and privacy practices of a Customer account, please contact the Customer whose account you use for more information.

Before using the Service or submitting any information to us, please review this Privacy Policy carefully and contact us if you have any questions. If you do not agree with the terms, please do not access or use the Services, Site, or any other aspect of Onboardly’s business.

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.

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.

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:

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.

YOUR CHOICES

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.

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.

IMPORTANT INFORMATION

a. Our Policy Toward Children

Onboardly does not knowingly collect Personal Data from children under the age of 13, except to the extent necessary to provide our benefits administration and broker services. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Onboardly through the Services, please contact us, and we will endeavor to delete that information from our databases.

b. Links to Other Websites

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Onboardly (the "Third Party Sites"). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of those Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these Third Party Sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

c. Security

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

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy while we have a business need to do so, or if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this Privacy Policy, our Terms of Service, or related Customer agreements. We may also retain Personal Data, for a limited period of time, if requested by law enforcement.

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.

g. Changes to Onboardly's Privacy Policy

The Services and our business may change from time to time. As a result, it may be necessary for Onboardly to make changes to this Privacy Policy. Onboardly reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated to be effective as of the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy indicate your agreement with the terms of such revised Privacy Policy.

CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at [email protected]