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Privacy Policy

Introduction

viaPeople, Inc. (“viaPeople”) is committed to protecting the privacy of your personal information while using our Web site (www.viapeople.com) or while using the web applications (www.viaPeople.net) to access the viaPeople software. viaPeople has therefore established this Web Privacy Policy Statement to assist you to understand how viaPeople collects and uses personally identifiable information if and when you use our Website or provide information to us in connection with your visit. By using our Website, you are agreeing to the collection and use of personal information in the manner described in this Privacy Statement. Although viaPeople has never been required to release information without an individual’s permission we acknowledge that in the extremely rare case of a court order, we might be compelled to do so.

Privacy Shield Certification

viaPeople complies with the United States/European Union Privacy Shield Frameworks and is thus committed to complying with the U.S.-EU Privacy Shield Principles with respect to all personal data received from the EU (see https://www.privacyshield.gov) through the use of this Website and all viaPeople applications.

viaPeople complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. viaPeople has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

In compliance with the EU-US Privacy Shield Principles, viaPeople commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first click here to contact us.

We will respond to any complaints within 45 days of receipt.

viaPeople has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Complaints will be processed at no cost to the consumer.

For residual claims not resolved through these channels, viaPeople also agrees to binding arbitration where provided for in Annex II of the Privacy Shield Framework.

viaPeople further agrees to cooperate with the EU Data Protection Authorities, and to participate in the dispute resolution program provided by the European Data Protection Authorities Panel, with respect to complaints relating to human resources data collected in the context of the employment relationship.
viaPeople is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Web Site Versus Web Applications

We maintain a marketing and general information website, http://viaPeople.com for the purpose of publishing marketing and general business communication. The applications, where we provide services in the area of human resources, are located in a number of domains under the base domain viapeople.net.

Web Applications Data Collection

Our web applications collect information about our customers’ employees including title, reporting hierarchy and basic identifying information (e.g., name, email address, user id). By using the applications, we may also accumulate textual and numeric indications of employee performance. We do not receive or store any financial or government identifying information. The information is used within the applications to assist the customer with personal performance feedback, managing goals and similar human resource assessments.

Customers may also provide certain demographic information, such as gender and age about the customer’s employees. This information may be sent back to the customer in the form of individual or aggregated reports. viaPeople does not process this information for any other purpose.

Information provided is accessible only to the customers’ employees and management team. ViaPeople accesses and uses this information only to support the functions contracted by our customer. There is no data sharing across customers or to any third parties.

All data entering or leaving our applications are encrypted using industry standard secure sockets. viaPeople also maintains strict rules regarding security of all customer data and remains successful at maintaining confidentiality of all customer information. viaPeople commits to inform the HR personnel at our customers if at any time a security breach occurs which has the potential to compromise customer data.

All data is maintained in a secure system, encrypted at rest, and made available only within a customer’s environment. No customer information will be disclosed to any other entity by viaPeople. However, all information provided (except the identity of the author in the case of anonymous feedback) is made available to our customer – the employer. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, viaPeople is potentially liable.

viaPeople also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

You have access to data pertaining to you as defined by our customer (your employer) and in coordination with our customer, any inaccurate data will be promptly corrected. viaPeople acknowledges that EU individuals have the right to access the personal information/data that we maintain about them. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should click here to contact us. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. Individuals have an opportunity to opt-out of using viaPeople applications. The customer will establish the language and interface for the end-user (employee) to opt out.

Web Site Data Collection Overview

Our server software gathers in log files, general demographic information from all users of our Web site. For each visitor to the viaPeople Web site, our Web server automatically recognizes the visitor’s domain name, browser type, operating system, referring domains, entry page, exit page, and average time on the Web site. This information is used for internal purposes only, to help us improve our Web site and better understand our visitors’ needs.

We currently contract with several online partners to help manage and optimize our Internet business and communications. We use the services of marketing companies to help us collect and/or log Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the viaPeople Web site, the files visited, the time spent in each file, and the time and date of each visit. We use Web cookies provided by our marketing companies. Cookies are identifiers that can be sent from a Web site via your browser to be placed on your computer’s hard drive. Thereafter when you visit a Web site, a message is sent back to the Web server by the browser accessing the Web site. You may elect not to accept cookies by changing the designated settings on your Web browser. However, not utilizing cookies may prevent you from using certain functions and features of our Web site. The information collected from the use of cookies is used and analyzed to improve our Web site. We use cookies to personalize the experience of our visitors, provide support to customers, record visitor preferences, provide personalized and specialized content, record session information, track visitor clickstream behavior throughout the Web site, and customize site content based on your browser type, operating system, and preferences. By gathering such information to supplement our records, we learn things like what pages are most attractive to our visitors, which of our products most interest our customers. Although our marketing companies log the information coming from our site on our behalf, we control how that data may and may not be used. If you do not want to help us learn how to improve our site, products, offers and marketing strategy, you can opt-out of this Web site analysis tool by disabling your cookies. If you disable your cookies, you may still use our Website; however, you may not be able to access certain areas within it.

If you choose to receive company or product information, you will need to complete our online request forms. The online forms provide site visitors with an opportunity to request free product downloads and demos, view viaPeople white papers, register for free viaPeople E-guides, and review other content. These forms require your name, company name, e-mail address, company address, phone number as well as other information to help us determine and respond to your needs. All information provided by the visitor is voluntary. We use this information to send updates about our company and our products and to contact you if requested or necessary. We also use the demographic information you provide on these forms in connection with studies and reports regarding our Web site, such as Web site usage patterns, in order to better understand the needs of visitors to our Web site. We will not, however, associate any personally identifiable information which you provide with the information in these studies and reports.

E-mail Addresses (viaPeople.com only)

We do not collect e-mail addresses without the site visitor voluntarily providing us with this information (typically via our online information request form, whitepaper request form, and other Web site forms and surveys). We will periodically use your e-mail information for service, sales, support, and marketing purposes. From time to time, we may share your e-mail address with our partner organizations and companies for service, sales, support, and marketing purposes. If you do not wish to receive marketing e-mail from us or our partners in the future, you may opt-out as described below.

Data Security

We use a variety of security measures and employ appropriate physical, administrative and technical safeguards to protect against the loss or unauthorized use, alteration or disclosure of, or unauthorized access to, the personal information under our control. We have licensed the industry-standard Secure Sockets Layer (SSL) technology, which permits encryption of potentially sensitive information such as your name, address and email address. This will make your information unusable in the event of unauthorized third-party interception. We store this information in a secure environment.

viaPeople personnel with access to this information have been trained and advised of the importance of maintaining the security and confidentiality of such information and of using it only for the purposes described in this Privacy Statement.

Other than as expressly described in this Privacy Statement, we will not share personally identifiable information with anyone outside of viaPeople without your prior permission unless we believe in good faith that such release is reasonably necessary to (i) comply with applicable law, (ii) enforce the terms of any of our user agreements, or (iii) protect the rights, property or safety of viaPeople, our visitors, or others.

In the event your personal information is acquired, or is reasonably believed to have been acquired, by an unauthorized person, and applicable law requires notification to you by viaPeople, viaPeople will notify you of such breach promptly by phone, email, fax, and/or U.S. mail, as permitted by law and consistent with the reasonable investigatory needs of law enforcement and/or viaPeople.

Notification of Privacy Policy Changes

viaPeople may amend this Privacy Statement from time to time. If viaPeople decides to make material changes in the way we use your personal information, we will post the changes on this page so that you always will know what information we collect, how it is used, and when and how it will be disclosed. Your use of the viaPeople Website following notice of such change will be deemed acceptance of the revised Privacy Statement, which may include an application of the new policy to information provided prior to the date of such change.

Choice/Opt-Out and Updating Information

If you receive marketing or similar e-mail messages from us and wish to opt out of receiving such messages, you may simply follow the opt-out procedure specified in such e-mail.

Contact Us

If you have questions or concerns about the Privacy Policy, please click here to contact us. You may also contact us by regular mail addressed to: viaPeople, Inc., Attn: Privacy, 101 Morgan Lane, Suite 206, Plainsboro, NJ 08536