Effective date: February 10, 2021
Emplify, Inc. (“us”, “we”, or “our”) operates the emplify.com, insights.emplify.com websites, and the Emplify mobile application (hereinafter referred to as the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
- Service. Service includes the emplify.com websites and mobile application operated by Emplify, Inc.
- Personal Data. Personal Data consists of data about a living individual who can be identified from those data elements (or from those and other information either in our possession or likely to come into our possession).
- Usage Data. Usage Data is data collected automatically via the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Cookies. Cookies are small amounts of data generated by a website and saved by your web browser for the purpose of remembering information about you, including login information, site-specific user preferences, and access tracking.
- Data Processors (or Service Providers). Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers to process your data more effectively.
- Data Subject (or User). Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). It may also include other information that may be associated to your Personal Data, such as Usage Data, if that information can be used to identify you, your household, or your device. Personally identifiable information may include, but is not limited to:
- Email address
- First name, middle name, and last name
- Birth date
- Phone number
- Name of your employer
- Number of employees at your employer
- ZIP/Postal code
- Employer-assigned employee identifier
- Employment status
- Employment start date
- Departure date
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
In addition to the above, when you visit or download information from our Service, we may also collect website usage information that your browser sends over time (“Usage Data”). Usage Data is non-Personal Data that may not by itself identify a specific person but rather describes how our users use and navigate our Service.
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
In some situations, this Usage Data may be used or combined in a way that identifies you. In those situations, such information will be treated like Personal Data.
Tracking & Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
Most browsers are initially set up to accept cookies. However, you can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. You can also delete or remove cookies through your browser’s settings. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
The Service may also contain a small graphic image called a web beacon (also known as a web bug or clear gif) that allows the party that sets the web beacon to monitor and collect certain information about the viewer of the web page, web-based document, or e-mail message. This may include the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to, and the time the web beacon was viewed. Web beacons can be very small and invisible to the user, but any electronic image viewed as part of a web page or e-mail, including HTML-based content, can act as a web beacon. Emplify, Inc. does not have control over web beacons used by third parties and does not have access to what information, if any, they may collect.
Use of Internet Protocol (IP) Addresses
An IP address is a number that is automatically assigned to your device or network when you are on the network. Although Emplify, Inc.’s core Service does not directly capture this information, this information may be captured when utilizing its analytics platforms. We may use IP addresses for several purposes including system administration, reporting aggregate information to our business customers, or to audit the use of the Service. We may also use IP addresses in cooperation with Internet service providers (“ISPs”) or to respond to appropriate and enforceable law enforcement requests, or if necessary, to comply with relevant laws or legal obligations, or to protect the Service or its users.
Use of Location-based Technology
We may collect your precise, real-time location using GPS, cell phone towers, WIFI signals, and/or other location-based technologies for purposes such as analytics. Although Emplify, Inc.’s core Service does not directly capture this information, this information may be captured when utilizing its analytics platforms to report upon performance.
Use of Data
Emplify, Inc. uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To personalize our Service and make recommendations
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To share with our vendors and contractors
- To provide you and others with news, special offers, advertisements and general information about other goods, services and events offered by us and others which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
You agree to provide Emplify, Inc. your own Personal Data, or the Personal Data of others you are authorized to provide. We will only communicate to those who agreed to or indicated desire to hear from us.
Please note that information submitted to our Service via a “contact us”, “help”, or other similar contact method will not necessarily receive a response. We will use the information provided to these methods of contact only to respond, if at all, to any question or comment submitted. We will not use the information provided to these email addresses or forms for marketing purposes unrelated to your request.
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
Emplify, Inc. may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- To comply with the law
Retention of Data
Emplify, Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
Disclosure of Data
Emplify, Inc. will not sell, rent, or lease your Personal Data. Personal Data collected by Emplify, Inc. when you utilize our Services, will only be shared with the business customer contracting the specific Service.
Your Personal Data may also be disclosed when we employ third parties to perform functions on its behalf. These may include third party hosting companies, communication services, data analysts, and other custom service companies. These third parties are granted access to your information only to perform tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Emplify, Inc. may also disclose non-personally identifying information, such as aggregated user statistics, to third parties for several reasons, including, without limitations, describing Emplify, Inc. and its Service to third parties or improving the performance of the Service.
Disclosure for Law Enforcement
Under certain circumstances, Emplify, Inc. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Emplify, Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Emplify, Inc.
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data
Emplify, Inc. stores the information we collect from you on limited access servers, and we take all appropriate measures to maintain the security of Emplify, Inc.’s servers and to protect your personal information from unauthorized disclosure. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, Emplify, Inc. cannot ensure or warrant the security of any information transmitted and you do so at your own risk.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”) or similar mechanisms. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We cannot and do not control third parties’ responses to “do not track” signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to “do not track” signals are governed by their respective privacy policies.
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
- Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
- For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Google Ads (AdWords)
- Google Ads (AdWords) remarketing service is provided by Google Inc.
- You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
- Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
- For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Emplify, Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us using the information below.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate, incomplete, or obsolete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your Personal Data.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Emplify, Inc. relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA). European Economic Area (EEA) data subjects also have the right to object to automated decision-making that produces a legal effect on the data subject.
Your California Privacy Rights
California residents are afforded certain rights related to their information under state law. Emplify, Inc. is committed to taking reasonable steps to allow California residents to access, delete, or know about the use of your Personal Data and exercise other rights available under applicable law. Where applicable under relevant laws, individuals may be entitled to the following:
- Right to Access/Disclosure: to have access to your Personal Data upon simple request, meaning that you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the collection or processing.
- Disclosure of Direct Marketers: to have access upon simple requests, and free of charge, the categories, and names of addresses of third parties that have received personal Data for direct marketing purposes. Please see the “Direct Marketers Disclosure” section below for more information.
- Collecting, Selling, Sharing, or Disclosing Personal Data: upon receipt of a verifiable request, to obtain a list of:
- The specific pieces of your Personal Data that Emplify, Inc. holds
- The categories of Personal Data collected about you, sold to third parties, or disclosed to third parties for business purposes
- The categories of personal Data sold within the last 12 months
- The categories of sources from which personal Data is collected
- The business or commercial purpose for collecting or selling Personal Data
- The categories of third parties with whom Personal Data is shared, sold, or disclosed for a business purpose.
- Right to Opt-out of the Sale of personal Data: California residents have the right under the California Privacy Act (“CCPA”) to opt-out of the sale of their Personal Data under certain circumstances. As noted elsewhere though, Emplify, Inc. does not sell individuals’ Personal Data.
- Right to Deletion / “Right to be Forgotten”: to obtain the deletion of your Personal Data in the situations set forth by applicable data protection law and upon receipt of a verifiable request.
- Right to Data Portability: to have your Personal Data directly transferred by us to a third-party processor of your choice (where technically feasible; may be limited to situations when processing is based on your consent).
- Right to Non-Discrimination: As defined under relevant law, you have a right to non-discrimination in the Service or quality of the Service you receive for us for exercising your rights.
Please contact us at the information in the “Contact Us” Section below in relation to exercising these rights. Note that we may ask you to verify your identity before responding to such requests.
Direct Marketing Disclosures
California Civil Code section 1798.83 allows customers who are California residents to ask us for a notice describing what categories of Personal Data we share with third parties or corporate affiliates for their direct marketing purposes. If you are a California resident, you have the right to request the following information:
- The categories of information new disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year
- The names and addresses of the third parties that received the information
- If the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
To make such a request, please provide sufficient information that will allow us to determine if this applies to you and attest to the fact that you are a California resident. Please also provide a current California address for our response. You may make this request in writing to us at the below address. Any such request must include “California Privacy Rights Request” in the first line of the description, and you must include your name, street address, city, state, and zip code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the address provided for this purpose below.
Note that responsive information may be provided in a standardized format that is not specific to you.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Submitting a Verifiable Request to Emplify, Inc.
In connection with the processing of your Personal Data, you may also request that we change how we use the personal data you have provided. This includes the right to withdraw consent or permission for us to keep your personal data, and right to change how we use or share the information we have collected about you. To make changes to how we use your information, please contact us via the information in the “Contact Us” section below.
As mentioned, California residents have certain rights to access, delete, or control the use, collection, and/or disclosure of their information. We will respond to an individual’s “verifiable request” to exercise his or her rights under such laws, meaning that where a request comes directly from the individual and the individual’s identity has been confirmed. This is critical in ensuring that information requested is not shared with anyone pretending to be said resident or someone who is not authorized to act as your agent.
You may submit a verifiable request via our email address, mailing address, or toll-free number, listed in the “Contact Us” section below, or as otherwise provided on our website. Emplify, Inc. will ask you to provide information about yourself so that your identity can be verified. This information may include your name, your address, or any other information deemed necessary by Emplify, Inc. to reasonable verify your identity and to ensure that your information is not shared with anyone impersonating you.
We may ask for additional information if we have difficulty confirming your identity. We will not share your information or honor other requests in those situations in which we are unable to confirm your request is verifiable.
Under California law, a consumer can appoint an “authorized agent” to make certain verifiable requests upon their behalf, such as the right to know what information we collect or to request deletion of information. Because the security and privacy of your information is critical, we will ask that you identify and provide permission in writing for such persons to act as your authorized agent and exercise your applicable rights under California law in such situations. This may require us to contact you directly and alert you that an individual has claimed to be your agent and is attempting to access or delete your information. We will also independently verify your identity to ensure that an unauthorized person is not attempting to impersonate you and exercise your rights without authorization. We will not share your information or honor any other requests in those situations where you cannot or do not grant permission in writing for an identified authorized agent to act on your behalf, or where we cannot independently verify your identity.
- By email: firstname.lastname@example.org
- By phone (toll-free): 800-277-3014
- By mail: 8626 E. 116th Street, Suite 350; Fishers, IN 46038