Last updated: January 1, 2021
Global People Strategist, LLC (“we”, “us”, “our”) understands and respects individuals’ data privacy. As the provider of human resource software as a service solutions including Global People Strategist, we are committed to preserving the confidentiality of personal data shared with us and stored in our solutions.
We review and update this Policy from time to time as needed with or without notice. Therefore, you should periodically review the terms of this Policy so that you have an accurate understanding of how we collect and use personal data.
By using our website and using our software solutions, you consent to THE TERMS AND CONDITIONS SET OUT IN THIS POLICY, INCLUDING CONSENTING TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED HEREIN.
IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT USE THE WEBSITE OR USE OUR SERVICES.
We are not required to have a data protection officer, so any inquiries about our use of your personal data should be addressed to the contact details above.
Data collection and use practices
We only collect information with your consent. By using our website and our services, you consent to the collection of information as set forth in this Policy. We are committed to data minimization. As such, we only collect the information which is necessary to facilitate the purposes and uses reflected in this Policy. Importantly, none of the information that you provide to us will be used to make automated decisions about you.
- Information That We Acquire From You Directly.You have the option to provide GPS with Personal Data about yourself to enable us to communicate with you and to provide you with services. For the purposes of this Policy, “Personal Data” is defined as means any information relating to an identified or identifiable natural person, including an individual’s name, contact information, professional title, and employer. In some regions, an individuals’ internet protocol address (“IP address”) may be considered Personal Data.
- Information that You Provide in Connection with Inquiries Submitted on Our Website. When you submit an inquiry via our website, we request certain Personal Data in order to provide you with an accurate and appropriate response, such as your name and contact information. Please note that such a response may require more detailed or multiple communication and exchanges to ensure that we have answered it to your satisfaction. We will do this based on our legitimate interest in providing accurate information prior to a sale.
Inquiries submitted via our website are stored and processed as an email hosted by Google within the United States. Such emails are retained for no longer than is necessary to determine and address legitimate business and administrative purposes. We do not use the information you provide to make any automated decisions that might affect you.
- Information that You Provide in Connection with Newsletter Subscriptions. When you register to receive our newsletter, we request that you provide your name and your email address so that we can provide you with the requested materials and to provide you with additional information about products and services in which you may be interested.
Information collected in connection with your subscription to a newsletter may be shared with a third party mailing service provider by way of our CRM. This system is based in United States. GPS will only engage service providers which have contractually committed to providing data protection safeguards in line with the legal requirements of the European Union and United States.
GPS will retain your personal data for as long as we produce and distribute our newsletter. You can withdraw your consent to the use of this information at any time. Please note, however, that if you withdraw your consent to the use of your information in connection with the receipt of a newsletter but you are a current client who has purchased our products or services, your personal data will be maintained as part of our CRM, but will not be used for marketing purposes.
- Information that You Provide in Connection with Content Downloads, User Generated Feedback, Surveys, Comments, and Reviews. When you download content from our website, complete a survey or otherwise provide or submit comments or reviews on our website, we may request certain Personal Data including your name and contact information via a registration or similar web form for business purposes including the ability to verify that the comments and reviews are being submitted by an individual and to verify the validity of such claims. By submitting this Personal Data to GPS, you agree that GPS may publicly publish your user name or website handle in connection with your comment or review. This information may also be shared with our third party mailing systems and service providers so that we may provide you with content about products and services which may be related to your interests. If you do not agree to the use and sharing of your Personal Data in this fashion, do not complete registration forms or web forms on our website.
GPS will retain your personal data for as long as we continue to market the products or services related to your comment or review. You can withdraw your consent to the use of your information in this manner at any time. Please note, however, that if you withdraw your consent to the use of your information, but you are a current client who has purchased our products or services, your personal data will be maintained as part of our CRM, but will not be used for marketing purposes.
- Information that You Provide in Connection with the Purchase of Products or Services. We may ask for Personal Data in when you purchase products from us through our website, including your name, contact information, and credit card information. We require this information in order to process your payment, deliver your products or services and fulfill our contract with you.
We may also collect your IP address in order to show that the correct tax was applied to the sale, which we are required to do by law. We will use the information collected in connection with your purchase to process your order, provide you with your Services, and communicate with you about the Services.
The information collected in connection with your purchase of Services may be stored on in our systems and servers which are based in the United States. GPS will retain the information provided in connection with your purchase for the length of your product or service license or for so long as there is a legitimate business or administrative purpose for retaining such date. We only use Payment Processors which have certified to the EU-US Privacy Shield.
- Information That We Acquire Indirectly
- Analytical, Behavioral, Log, and Clickstream Data. We may gather certain information about your use of our website, such as your browser type and information about your visit and interaction with the content that we have posted.
We partner with certain Service Providers to collect analytical, behavioral, log, and clickstream data and to engage in analysis, auditing, research, and reporting. For the purpose of this Policy, “Service Provider” means vendors that provide services to GPS with regard to the operation of its website or the collection or review of data from its websites. GPS and its Service Providers may use tracking technologies to identify you when you are online, and to collect information about your online activities, such as the type of browser you use, the websites you visit, your IP address, geographic location, browser type and version, and the content and advertising that you find interesting.
[Although our website currently does not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking steps to limit such tracking within your browser settings.” If you do not wish to have tracking technologies be used when interacting with our website, many web browsers allow you to stop accepting cookies and/or to warn you when a third party is trying to transfer a cookie to you. Please note that some website features and services may not be available to you if tracking technologies are disabled.]
Why we collect Personal Data
We collect information about you in an effort to provide you with purchased products and services and to offer you opportunities to obtain other products and services offered by our team. Additionally, the collection and use of information helps us tailor and improve our services and communicate with you effectively.
Data retention practices
Legal basis for processing Personal Data
GPS relies on both consent and legitimate business interests for processing Personal Data. For example, GPS may process Personal Data with consent when an individual agrees that we may place cookies on their devices, or that we can process information that they submit via our website.
On other occasions, we may process Personal Data pursuant to specific purposes which are in our interests and that enable us to enhance the services we provide. For example, we may process Personal Data pursuant to legitimate business purposes to respond to inquiries and to fulfill requests, to send individuals relevant marketing information and offers, to complete transactions, provide customer service, send administrative information, to personalize users’ website experiences, and where we are required to do this by law.
We also process Personal Data when it is in GPS’s or a user’s legitimate interests to do so and when these interests are not overridden by individuals’ data protection rights. These legitimate interests include providing services to enable us to provide Users with more relevant ads and content.
How we may share your Personal Data
Personal Data collected outside the United States, including in the European Economic Area (“EEA“), is transferred to and stored on our servers in the United States and potentially in or to other countries whose data protection laws may be different to the laws in your country. We will protect your Personal Data in accordance with this Policy wherever it is processed.
GPS has certified to the United States Department of Commerce and the European Commission that it adheres to the EU-US Privacy Shield Framework (the “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States in reliance on Privacy Shield.
GPS has certified that (1) it has certain protections and procedures in place which meet EU data protection and privacy standards, (2) it adheres to the Privacy Shield principals of notice, choice, security, data integration and purpose limitation, access, accountability for the onward transfer of personal data, recourse, enforcement, and liability, and (3) it is committed to cooperating with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the United States in connection with this Policy. To learn more about the EU-US Privacy Shield, and to view GPS’s certification, please visit https://www.commerce.gov/page/eu-us-privacy-shield.
Your rights as a data subject
GPS will only use your Member Information for the purposes described in this Policy or as subsequently authorized by you. We strive to offer you with choices about how your Personal Data is used and shared, as further outlined below.
The accuracy and security of the personal information is important to us. If you contact us to correct your Personal Data, please contact us via the physical address or email address at the end of this Policy. We will correct such inaccuracies in a timely manner.
You may also have a right, in accordance with applicable laws, to access, update, and in some cases request deletion of the Personal Data that we hold about you. When updating your Personal Data, we may ask you to verify your identity before we can act on your request. Additionally, you may request a copy of your Personal Data in our possession in a machine-readable format so that you can transfer it to another provider. Any such requests will be subject to the relevant fee, if any, to meet our costs in providing you with details of the information we hold about you. We will comply with your request as soon as reasonably practicable and in accordance with applicable laws. We may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, or to complete any transactions that you began prior to requesting such change or access.
If you wish to stop receiving email marketing communications from us, please contact us at the address listed below or clicking the “Unsubscribe” in any marketing communications. If you opt out, we may still send you non-promotional communications, such as those about your account or to facilitate services that you have made or accepted.
If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
We are concerned with the security of your personal information and is committed to taking reasonable steps to protect it from unauthorized access and use of that Personal Data. To that end, we have implemented the appropriate policies and procedures to secure your information and we will take reasonable steps to ensure the safety of your Personal Data.
Finally, you have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully. Please note that this may impact our ability to communicate with you or to otherwise deliver products and services.
Notice to California residents
Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with GPS are entitled to ask us for a notice describing what categories of Personal Data we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to us at the addresses listed below.
Questions, comments, and complaints
We are committed to resolving complaints about your privacy and our collection or use of your personal data. If you believe that we have not complied with this Policy, or if you have any other complaint with regard to our collection, use or disclosure of information, please send your complaint by mail to the following address. We will investigate your complaint and respond to you promptly. However, if you do not believe that we have responded to your complaint appropriately or in a timely manner, you may contact our Data Protection Authority, [the Information Commissioner’s Office], or the U.S. Department of Commerce via the information below.
Global People Strategist
220 Winthrop Street, Suite 301
Winthrop, MA 02152
Attention: Data Protection Officer
U.S. Department of Commerce
EU-U.S. Privacy Shield
1401 Constitution Avenue, N.W.
Washington, D.C. 20230
Domestication and international requests
GPS requires that any individual issuing legal process or legal information requests (e.g., discovery requests, warrants, or subpoenas) to us properly domesticate the process or request and serve us in a jurisdiction where it is resident or has a registered agent to accept service on its behalf. GPS does not accept legal process or requests directly from law enforcement entities outside the U.S. or Canada. Foreign law enforcement agencies should proceed through a Mutual Legal Assistance Treaty or other diplomatic or legal means to obtain data through a court where we are located.
The English language version shall prevail. Any translations of this Policy are provided for convenience only.
Our products, services, events and offerings are directed to professionals. Our business is not directed at children, and we do not solicit or knowingly collect any personal information from children under the age of 13 without verifiable parental consent. If you are not 18 or older, you are not authorized to use our website, products or services. Parents should be aware that there are parental control tools available online that you can use to prevent your children from submitting information online without parental permission or from accessing material that is harmful to minors. If you learn that a child under 13 has provided us with Personal Data without consent, please contact us.
Updates to this Policy
We will not reduce your rights under this Policy without your consent. If we change our Policy, we will post those changes on this page in addition to updating the “Last Updated” date at the end of this Policy. For these reasons, we encourage you to read this Policy regularly. Your continued use of our website, products, or services shall constitute your acceptance of the modified Policy. If there will be any changes made to the use of your Personal Data in a manner materially different from that stated at the time of collection, we will notify you by posting a notice on our website or contact you to provide information about this and, if necessary, to ask for your consent before making use of the information in a new fashion. If you object to any of the changes, or the overall Policy, please contact us via the contact information set forth above.