Human Capital Resource Software Inc., including its affiliates and subsidiaries (each, “HCR Software”), is committed to the protection of the personal information that we collect and/or maintain in the course of our business activities. As part of this commitment, we have set out this Privacy Statement to describe the manner in which we treat our customers’ employee (and prospective employee) personal information when hosted on our cloud-based talent management services offerings (“HCR Software CompensationXL”), as well as the personal information we collect via other means, such as through our website at www.hcrsoftware.com (“Website”). This Privacy Policy describes how HCR Software collects, uses, shares and secures the personal information you provide. It also describes your choices regarding use, access and correction of your personal information.  As used in this Privacy Statement, “personal information” means information about an identifiable individual.  The use of information collected through our service shall be limited to the enabling the compensation planning and reporting functions for which the Client has engaged HCR Software Solutions Inc.

HCR Software Solutions Inc participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.  HCR Software Solutions Inc is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.  To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]

HCR Software Solutions Inc is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.  HCR Software Solutions Inc complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

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

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

HCR Software Solutions Inc has further committed to cooperate with EU data protection authorities (DPAs) and Swiss Data Protection and Information Commissioner with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Collection and Use of Information
1. HCR Software’s CompensationXL allows our customers to upload information about their organization’s employees and prospective employees (collectively, “Employees”), including names, performance reviews and compensation information. Our customers choose the types of Employee information they upload into the HCR Software CompensationXL. We do not collect or use the Employee information of our customers for any purpose other than as described in this Privacy Statement, to provide the compensation management services our customers request or as otherwise described in the agreement between us and our customer.
2. Website & Other
We may collect and use the following information obtained via our Website or our other online activities:
A. If you contact us with a question, comment or complaint, we may collect your name and contact information (such as your email address or mailing address) in order for us to respond to your request. We may also keep a record of the correspondence in order to assist you again in the future.

B. If you request information or a demo we may collect your name, job title, email address and certain information about your company. We use this information to contact you and otherwise facilitate your free trial, demo, or participation in the webinar, as applicable.

C. It is important to note that, while you can generally visit our Website without telling us who you are or submitting any personal information, we do collect the following information via our Website and/or via our online activities:

1. We collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity, and to monitor and improve our Website.
2. Our Website, like many other commercial websites, uses a standard technology called a “cookie”. A cookie is a small data file that a website can send to a browser, which may then be stored on your computer system. When you browse our Website, we may use a cookie to help us provide you with better customer service by (i) identifying your browser as one that has visited our Website before; and (ii) saving and remembering any preferences that you may have set during previous visits to our Website. Cookies help make your visit to our Website more user friendly. Any personal information collected about you through our use of cookies will be treated in accordance with this Privacy Statement. You can set your browser to reject cookies or to notify you when you receive a cookie, which will give you the opportunity to decide whether you want to accept the cookie or not. Note that if you reject cookies, it may not be possible for you to use HCR Software services which require registration.
3. Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.  HCR Software Solutions Inc 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 our 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.  Our CompensationXL application uses session variables only on the server to verify successful authentication. These variables expire when the connection times out.
4. We may use third parties to serve our advertisements on other websites. These companies may use cookies, tracer tags or web beacons to collect information (such as web pages you visit and your response to ads) when you visit our Website and use that information to serve advertisements tailored to your interests on our website or other third-party websites.  If you wish to opt out of interest-based advertising click here [or if located in the European Union click here]. Please note you will continue to receive generic ads.
5. Our Website may contain links to other websites that are provided and maintained exclusively by third parties. We carefully select the third party websites to which we link; however, as such third party websites are not subject to this Privacy Statement, we are not responsible for either such third parties’ content or privacy practices. We encourage you to read the privacy policy of every website you visit.

Depending on the situation, HCR Software may obtain consent to the collection of personal information in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained through your use of HCR Software CompensationXL or other HCR Software services, or when you approach us to obtain information, inquire about or request services from us. We will indicate when your consent is a condition of obtaining a service.

Opt Out
You may sign-up to receive email or newsletter or other communications from us.  If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us at privacy@hcrsoftware.com.

If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly.

Transfers and Disclosures of Personal Information
As a matter of practice, HCR Software does not disclose, trade, rent, sell or otherwise transfer personal information provided to us, except as set out in this Privacy Statement and, in the case of information provided to us via HCR Software CompensationXL, also as provided in our agreement with HCR Software with our customer. With respect to both CompensationXL and our Website, the following applies:

Service Providers: We may disclose or transfer personal information to our partners, consultants and suppliers who provide services on our behalf (collectively, our “service providers”). Our service providers are given only the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own purposes.
These services may include:
• Providing and managing cloud computing infrastructure
• Monitoring and Securing cloud computing infrastructure
• Fulfilling subscription services and ensuring resilience of data
• Sending marketing communications
Transfers to subsequent third parties are covered by the service agreements with our Clients.

Sale of Business: HCR Software may disclose or transfer personal information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of HCR Software or its divisions, or of any of the business or assets or shares of HCR Software. 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

Legal obligations: We and our service providers may provide personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable law. We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons, data or property.  In certain situations, HCR Software Solutions Inc may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Safeguarding We understand that data security is an important issue and we are committed to safeguarding the personal information provided to us, whether through CompensationXL or our Website. In addition, with respect to the personal information provided to us by way of our HCR Software CompensationXL, HCR Software has implemented information security program that includes written policies and procedures, and security controls, as further described in our Information Security White Paper which is available upon request.  We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy@hcrsoftware.com.

Retention and Storage
1. HCR Software CompensationXL Personal information provided to HCR Software by way of our cloud-based compensation management services offerings is stored in the United States. We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. HCR Software Solutions Inc will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements
2. Website & Other Personal information that we collect via our Website or other means may be transferred to, stored and processed at various locations around the world, by staff who work for us or for one of our service providers. Such staff may be engaged in, among other things, providing demos, managing contests or other promotions and making hiring decisions on behalf of HCR Software. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Accuracy and Access
HCR Software Solutions Inc. acknowledges that you have the right to access your personal information.  HCR Software Solutions Inc. has no direct relationship with the individuals whose personal data it processes. HCR Software’s Compensation Customers, not HCR Software, control what personal information is contained in CompensationXL. Accordingly, if we receive a request from an individual to access, update, delete or update personal information we maintain on behalf of a particular customer as part of our cloud-based talent management services offerings, we will direct that individual to the relevant HCR Software customer for assistance.  If requested to remove data we will respond within a reasonable timeframe.

Website & Other: Upon request HCR Software Solutions will provide you with information about whether we hold any of your personal information.  If you submit personal information via our Website or otherwise provide us with your personal information, you may request access, updating or correction of your personal information by submitting a written request and satisfactory identification to our Privacy Officer (see “Contact Us” below). If you find any errors in your personal information, please contact our Privacy Officer as soon as possible.  We will respond to your request within a reasonable timeframe.

Changes to this Privacy Statement
This Privacy Statement may be updated periodically to reflect changes to our personal information practices. The revised Privacy Statement will be posted on this Website. If we make any material changes we will 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.  We encourage you to periodically check this Privacy Statement to ensure that you are aware of the most recent version.

Contact Us
Please contact the Privacy Officer with any questions or concerns that you may have about this Privacy Statement or our personal information practices. Our Privacy Officer may be contacted via email at privacy@hcrsoftware.com
13400 Sutton Park Drive South
Suite 1102
Jacksonville, FL 32224

This Privacy Statement was last updated on October 27, 2017

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