Springrole (Service Provider Administrator thereafter referred as “Administrator”) acknowledges their customers (thereafter referred as “Customer”) may provide Personal Information of California Consumers (the “Consumer Information”) to Administrator for the purpose of receiving the Services, and such Consumer Information may be subject to the California Consumer Privacy Act of 2018 (the “CCPA”), Cal. Civ. Code, Section 1798.100.For the purposes of this Section 15.xx, “Personal Information” and “California Consumers” have their respective meanings as set forth in 1798.140 of the CCPA.
Solely with respect to any such Personal Information, Administrator represents and agrees that:
a). It functions as a service provider to Customer and it provides the Services to Customer for the business purpose of enabling the ongoing administration of the Employee engagement services (the “Business Purpose”);
b). It will only retain, use or disclose the Consumer Information received from Customer for the purpose of providing the Services to Customer and for the Business Purpose, and it may not use, disclose or otherwise exploit the Consumer Information for any other purpose beyond the uses contemplated by Section 15.01 herein; and
c). Promptly following the Effective Date of 1st March 2023, the Administrator agrees to develop reasonable policies, procedures and standard work to ensure Customer is able to meet its obligations pursuant to applicable privacy laws, including to comply with the CCPA.
d). As part of (c) any affected California customers who are utilizing Springrole Services can raise a request to [email protected] for purposes mentioned below:
(i) REQUESTS TO KNOW PERSONAL INFORMATION (RIGHT TO KNOW)
(ii) REQUESTS TO DELETE PERSONAL INFORMATION (RIGHT TO DELETE)
(iii) REQUESTS TO CORRECT PERSONAL INFORMATION (RIGHT TO CORRECT)
(iv) RIGHT TO BE FORGOTTEN
(v) OPT OUT OF DATA SALES and MARKETING
To exercise one or more of your rights, you or someone you authorize, may call us at +1-917.913.9970 or raise a request via sending an email to [email protected] and follow the instructions provided.
If you are a California resident you may have certain rights under the California Consumer Privacy Act regarding your personal information, including:
The right to request the specific pieces of personal information we collected about you; the categories of personal information we collected; the categories of sources used to collect the personal information; the business or commercial purposes for collecting your personal information; and the categories of third parties with whom we share your personal information each as it pertains to our activities in the preceding twelve (12) months
The right to request, on legitimate grounds, deletion of your personal information that we collected;
The right to have someone you authorize make a request on your behalf; andthe right, in certain circumstances, to correct inaccurate personal information we collected about you; and
The right not to be discriminated against for exercising any of these rights.
The information that follows shows the types of personal information we may collect about California residents who are subject to the CCPA, the sources from which we collect it, and the ways in which we use and disclose it.
Categories of Personal Information
Personal identifiers, including those listed in other California statutes: Real name; alias; email address ; telephone number; account name; online identifier; device identifier; IP address
Professional or Employment: title; salary; employment files; references
Education information: details of your education and qualifications
Internet or other electronic network activity information:, information regarding your interaction with a website, application or advertisement
Geolocation data: any information used to identify your physical location
Category of Sources from which we Collect Personal Information
We obtain your personal information when you provide it to us (e.g., while registration or usages of our application)
We receive your personal information from third parties who provide it to us (e.g., our customers)
We collect or obtain personal information when you visit any of our Sites or use any features or resources available on or through a Site.
When you visit a Site, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data
Business and Commercial Purposes for Use of Personal Information
Marketing/Prospecting: communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate
Operation of our Sites: operation and management of our Sites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Sites
IT operations: management of our communications systems; operation of IT security; and IT security audits
Research: conducting market or customer satisfaction research; and engaging with you for the purposes of obtaining your views on our products and services
Investigations: detecting, investigating and preventing breaches of policy, and criminal offenses, in accordance with applicable law
Legal compliance: compliance with our legal and regulatory obligations under applicable law
Legal proceedings: establishing, exercising and defending legal rights
Improving our products and services: identifying issues with existing products and services; planning improvements to existing products and services; and creating new products and services
Risk Management: Audit, compliance, controls and other risk management
Fraud prevention: Detecting, preventing and investigating fraud
Categories of Third Parties to Whom Personal Information is DisclosedYou and, where appropriate, your family, your associates and your representatives
Anti-fraud services
Data aggregation services
Accreditation bodies
Third party service providers (such as payment services providers; shipping companies; etc.)
Credit reporting agencies
Governmental, legal, regulatory, or other similar authorities and/or local government agencies, upon request or where required
Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties
Any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation)
We take reasonable steps designed to ensure that your personal information is only processed for the minimum period necessary for the purposes set out in this disclosure.
The criteria for determining the duration for which we will retain your personal information are as follows:
We will retain copies of your personal information in a form that permits identification only for as long as:
We maintain an ongoing relationship with you (e.g., while you remain an employee, or where you are still receiving services from us); or
Your personal information are necessary in connection with purposes set out in this disclosure plus:
The duration of any applicable limitation period under applicable law; and where required and
In addition, if any relevant legal claims are anticipated/brought, we may continue to process your personal information for such additional periods as are necessary in connection with that claim.
During the periods noted above we will restrict our processing of your personal information to storage of, and maintaining the security of, that information except to the extent that that information needs to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods above, each to the extent applicable or permitted by applicable law, have concluded, we will 1) permanently delete or destroy the relevant personal information, or 2) archive your personal information so that it is beyond use; or 3) anonymise the relevant personal information.
Springrole does not engage in the sale of personal information as contemplated by the CCPA. As noted elsewhere in this disclosure, we disclose personal information to other businesses for a variety of reasons. While we often benefit from such disclosure, we do not disclose personal information for the sole purpose of receiving compensation for that information.
Customer consents to Springrole's use of the sub-processors hereto. Springrole may update its list of sub-processors from time to time, and shall make available any updates to such list
We may change this disclosure from time to time. When we do, we will let you know by appropriate means such as by posting the revised disclosure on our CCPA web site with a new “Last Updated” date. Any changes to this disclosure will become effective when posted unless indicated otherwise.
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