Privacy Policy

Effective Date: July 2nd, 2024 

At WorkStep, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy. 

Remember that your use of WorkStep's Services is at all times subject to our Terms of Service, as may be updated or amended from time to time, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Service. 

You may print a copy of this Privacy Policy by clicking here. 

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon material changes, we will alert you to any such changes by placing a notice on the WorkStep website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our website available at https://workstep.com/ (the “Site”) and the services, features, content or applications offered by Workstep Inc. (“we”, “us” or “our”) (together with the Site, the “Services”). “Personal Data” means any information that identifies or relates to an identifiable individual or could be used to identify a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. Some of our Services are provided to Company Customers pursuant to a SaaS Agreement (such as our our Workstep employee engagement offering) (“Workstep Platform”). Please contact your employer if you have any questions about how your Personal Data is treated by them. 

Categories of Personal Data We Collect

This chart details the categories of Personal Data we collect if you visit our website, sign up for our marketing materials, request a demo, or otherwise engage with us before becoming a Workstep customer. 

This chart details the categories of Personal Data that we collect and have collected over the past 12 months in connection with our Workstep HIRE job network offering (please note that HIRE is not currently offered in Canada):

With respect to the Workstep Platform, we may collect Personal Data on behalf of and as determined by our Company Customers, including responses to surveys that we provide on their behalf. In connection with the Workstep Platform, below are categories of Personal Data we collect and have collected in our role as a data controller over the past 12 months:

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You
  • When you provide such information directly to us.
    • When you create an account or use our interactive tools and Services, including our jobs boards.
    • When you voluntarily provide information through the Services or through responses to surveys or questionnaires (including via email and SMS text message).
    • When you request a demo or sign-up to receive our marketing communications.
    • When you send us an email or otherwise contact us.  
  • When you use the Services and such information is collected automatically.
    • Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
    • If you use a location-enabled browser, we may receive information about your location (with your consent, where required by law).
    • If you use or platform, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
• Third Parties
  • Company Customers/Employers
    • We may receive information about you from your employer (such as name and contact information and other employment data such as start and end date) to help facilitate creation of your account for the Services and allow us to send you our surveys and questionnaires on behalf of your employer. We rely on our employer clients to ensure that they have the lawful authority to provide this data to us.
  • Vendors
    • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
    • We may use third-party artificial intelligence model and platform providers to power certain features of the Services including our feedback processing capabilities. 
    • We may use vendors to obtain information to generate leads and create user profiles.
  • Advertising Partners
    • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services
  • Creating and managing your account or other user profiles.
  • Providing you with the products, services or information requested.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Verifying and maintaining the quality of the Services.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”).
• Marketing the Services
  • Marketing and selling the Services.
  • Showing you advertisements, including interest-based or online behavioral advertising.
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about WorkStep or the Services.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.
• Meeting Legal Requirements and Enforcing Legal Terms
  • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, WorkStep or another party.
  • Enforcing any agreements with you.
  • Responding to claims that any posting or other content violates third-party rights.
  • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CCPA regulations and we do not collect or process sensitive personal information with the purpose of inferring any characteristics about California residents.

How We Disclose or Transfer Your Personal Data

We disclose or transfer your Personal Data to the categories of service providers and other parties listed in this section. If you are in the US, depending on state laws that may be applicable to you, some of these disclosures or transfers may constitute a “share” or “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology and communication providers.
  • Third-party artificial intelligence model and platform providers that power certain features of the Services including our feedback processing capabilities.  
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
• Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
  • Ad networks.
  • Marketing providers.
• Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
  • Companies that track how users found or were referred to the Services.
  • Companies that track and audit how users interact with the Services.
• Company Customers. These are our enterprise customers (such as your employer in connection with the Workstep Platform) related to whom you access our Services. 
• Parties You Authorize, Access or Authenticate
  • In connection with your use of our Services, including current and prospective employers, as further described below in the “Company Customers/Employers or Prospective Employers” section below. 
  • Businesses that you have a relationship with, including any business you interact with in connection with our Services. 

Company Customers/Employers or Prospective Employers

• Workstep HIRE: For our Workstep HIRE offering, we may share your resume information, job credentials, or other information with prospective employers to help match you with potential employment opportunities. Please note:
  • This Privacy Policy only applies to WorkStep. We do not control how any prospective employer processes or discloses your Personal Data. Despite commercially reasonable efforts, we cannot guarantee the privacy of your Personal Data. 
  • If you exchange messages with a prospective employer to whom you were introduced by us, such employer may retain the message history after you terminate communications and/or close your user profile. We therefore urge you to think carefully about including private in communications sent through the Services.
• Workstep Platform: Survey responses will be associated with other identifying information about you, such as your name or employee ID. We may share your survey responses and feedback along with such identifying information with your employer in connection with our WorkStep employee engagement offering, without notice to you.

Legal Obligations

We may disclose any Personal Data that we collect to third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above. 

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a prospective of completed merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it to third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could be used to identify you.  

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, serve advertisements, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). 

We use the following types of Cookies:

• Strictly Necessary Cookies. Strictly Necessary Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance Cookies. Performance Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
• Targeting Cookies. Targeting Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information About Interest-Based Advertisements.”

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work. 

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking here. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union or United Kingdom, respectively.

For more information about the Cookies we use in connection with the Services, you can access our current list of Cookies and Cookie providers using the Cookie Preferences link in the Site footer or on the My Account page.

Session Replay Technology

We may use session replay technology in order to identify and resolve customer issues, to monitor and analyze how you use our Services, to better understand user behavior, and to improve our Services. By continuing to use the Services, you consent to the use of session replay technology.

Information About Interest-Based Advertisements

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services and on other websites. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.  Users in the United States should visit the US Digital Advertising Alliance website https://digitaladvertisingalliance.org/ and Users in Canada should visit the Digital Advertising Alliance of Canada’s website http://youradchoices.ca/choices.

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal or contractual obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

• Generally, we retain your profile information and credentials for as long as you have an account with us.
• Generally, we retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

Personal Data of Children

As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data from or about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@workstep.com.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Except as otherwise specified below, please see the “Exercising Your Rights” section for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@workstep.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting, selling or sharing your Personal Data.
• The categories of third parties to whom we have disclosed your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data disclosed to each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Personal Data Sales and Sharing Opt-Out and Opt-In

In this section, we use the terms “sell” and “share” as they are defined in the CCPA. We may sell your Personal Data, subject to your right to opt-out of these sales.

We may sell or share your Device ID and Web Analytics data via Cookies to Advertising Partners and Analytics Partners. Our use of Cookies is further described in the “Tracking Tools, Advertising and Opt-Out” section above. Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Certain third parties that provide these Cookies may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” and/or “share” of information and California residents have certain rights when a business “sells” or “shares” Personal Data with third parties, including for purposes of cross-contextual behavioral advertising. We may also sell your Profile or Contact Information (specifically, your name and email address) with Advertising Partners for the purpose of generating leads or otherwise marketing our services to you. 

You can opt out of these sales and the sharing of Personal Data by following the instructions in this section.

In the past 12 months, we have sold or shared the foregoing categories of Personal Data for the following business or commercial purposes:

• Marketing and selling the Services.
• Showing you advertisements, including interest-based or online behavioral advertising.

You have the right to opt-out of the sale or sharing of your Personal Data. You can opt-out using the following methods:

• For Cookie-related selling or sharing: 
  • By accessing the Cookie Preferences link in the footer of the Site or on the My Account page.
  • By implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.

• For non-Cookie related selling:
  • By emailing us at: privacy@workstep.com 

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale or sharing of your Personal Data for at least 12 months. To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Exercising Your Rights Under CCPA

To exercise the rights described in this Privacy Policy, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your name and email address), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

• Email us at: privacy@workstep.com 

If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@workstep.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@workstep.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

European Union and United Kingdom Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. WorkStep will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@workstep.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity:  We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data. 
  • Profile Data
  • Contact Data
  • Consumer Demographic Data
  • Professional or Employment-Related Data
  • Categories of Data Considered “Sensitive” Under the CCPA.
  • Other Identifying Information that You Voluntarily Choose to Provide
• Legitimate Interest:  We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties: 
  • Contact Data
  • Device/IP Data
  • Web Analytics
  • Consumer Demographic Data
  • Professional or Employment-Related Data
  • Categories of Data Considered “Sensitive” Under the California Privacy Rights Act as amended by the California Privacy Rights Act
  • Inferences Drawn From Other Personal Data Collected
  • Other Identifying Information that You Voluntarily Choose to ProvideWe may also de-identify or anonymize Personal Data to further our legitimate interests. 

Examples of these legitimate interests include (as described in more detail above):

• • Providing, customizing and improving the Services.
  • Marketing the Services.
  • Corresponding with you and your current or prospective employer.
  • Meeting legal requirements and enforcing legal terms.
  • Completing corporate transactions.
• Consent:  In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. 
• Other Processing Grounds:  From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties. 

EU and UK Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@workstep.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.  

• Access:  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. Depending on your relationship with us, you may be able to access certain of your Personal Data by logging on to your account.
• Rectification:  If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Depending on your relationship with us, you may be able to correct some of this information directly by logging on to your account.
• Erasure:  You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent:  If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability:  You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection:  You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing:  You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint:  You have the right to lodge a complaint about WorkStep's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through WorkStep and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to WorkStep in the U.S. and will be hosted on U.S. servers, and you authorize WorkStep to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

Canada Data Subject Rights and Additional Information

Personal Data We Collect and Use

WorkStep makes the Workstep Platform offerings available to its Company Customers (employers) in Canada and processes Personal Data through this offering on behalf of and in the course of providing Services to such customers. If you have any questions regarding the personal information we process on behalf of one of our customers, we encourage you to first contact the customer directly and/or review their applicable privacy policy. If you signed-up to receive marketing communications from one of our customers and now wish to unsubscribe, please contact the customer directly.

We rely on our Company Customers to ensure that their use of our Services complies with their obligations under applicable privacy laws, and to provide all necessary notice and consents. Except as set out in this Privacy Policy, we do not collect or use personal information from our customers for any purpose other than to provide Services on behalf of our Company Customers.

Canada Data Subject Rights and Choices

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@workstep.com. Please note that in some circumstances, we may not be able to fully comply with your request due to exceptions under applicable law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.  

If we receive a request from an individual to access or update personal information we maintain on behalf of a Company Customer, we will direct that individual to the relevant customer. We will assist our Company Customers wherever possible in responding to individual access requests.

• Access:  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. 
• Correction or Rectification:  If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. 
• Withdrawal of Consent:  If we are processing your Personal Data based on your consent, you have the right to withdraw your consent at any time subject to legal and contractual restrictions and reasonable notice. Please note that if you withdraw your consent, we may not be able to provide certain Services to you. 

If you have signed-up or otherwise receive our email marketing communications, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Information” section below. Please note that you may continue to receive transactional or account-related communications from us. To withdraw your consent to our use of non-essential cookies, including interest-based advertising, please see “Tracking Tools, Advertising and Opt-Out”.

Sharing of Personal Data 

We and our service providers (including affiliates) may access, store and otherwise process Personal Data outside of Canada (including, for residents of the province of Quebec, outside of Quebec), including in the United States, or other foreign jurisdictions, where we or our service providers are located.

We and our Canadian, US and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. 

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we or our service providers collect, use and disclose your Personal Data or your choices and rights regarding such collection, use and disclosure, please do not hesitate to contact our Vice President of Finance at privacy@workstep.com.

• https://www.workstep.com
• privacy@workstep.com
• 9450 SW Gemini Drive, Suite 57190, Beaverton, Oregon  97008

If you are located in the EU or UK, you may use the following information to contact our EU or UK-Based Member Representative:

• European Representative
  European Data Protection Office (EDPO)
  Avenue Huart Hamoir 71, 1030 Brussels, Belgium
  Please use EDPO’s online request form and specify "WorkStep Inc." as the company to whom you wish to submit your request:
  https://edpo.com/gdpr-data-request/
  
  
• UK Representative
  EDPO UK Ltd
  8 Northumberland Avenue, London WC2N 5BY, United Kingdom
  Please use EDPO’s online request form and specify "WorkStep Inc." as the company to whom you wish to submit your request:
  https://edpo.com/uk-gdpr-data-request/