Relocity Privacy Statement
Last Updated: December 4, 2023
2. NOTICE TO END USERS
3. DATA WE COLLECT AND RECEIVE
3.1 Client Data
The Client and its users may routinely submit Client Data to Relocity when using the Services. Client Data is governed by the applicable Client Agreement. Client Data may include User Information, Hosted Data, or any Client
Data otherwise defined in the applicable Client Agreement. If you have any questions about your Personal Data with respect to Client Data, please contact your Sponsor.
3.1.1 User Information. To create or update a user account for the Services or use certain features of the Services, you or the Client may provide us with your Personal Data, such as:
● Authorized User Information
● Financial Information
● Services Information
● Client and Employment Information
3.1.2 Hosted Data. When you use or interact with the Services, we may collect, process, and store any data that is created, posted, uploaded, stored, displayed, transmitted, or submitted on or through the Services (collectively, “Hosted Data”), as a function of rendering the Services. Hosted Data may contain Personal Data to the extent you disclose Personal Data on or through the Services. Relocity is generally a passive recipient and takes no active part in collecting or storing Hosted Data. Except to the extent necessary to render the Services or related support for the Services, Relocity does not purposefully access any Hosted Data. For example, if you message a personal host, the Services passively processes such messages for the purpose of rendering the Services, and we will only access such information to the extent necessary to provide the Services and related support for the Services.
3.2 Other Information
Relocity may collect Other Information from you related to your usage of the Services and interactions with Relocity. Other Information may include Metadata, Log Data, Technical Data, Cookie Data, Third Party Services, and Additional Information Provided to Relocity. If you have any questions about your Personal Data with respect to Other Information, please contact Relocity at email@example.com.
3.2.1 Metadata. When you interact with the Services, metadata is generated that provides additional context about the Services and the way you use the Services (“Metadata”). Relocity collects aggregated Metadata of the Services, so that the resulting data and statistics are not personally identifiable to any individual user.
3.2.2 Log Data. Like most websites and web-based technology services, our servers
automatically collect data when you access or use the Services and record it in log files (“Log Data”). The Log Data may include your Internet Protocol (“IP”) address, Internet service provider (“ISP”), browser type and settings, information about browser plugins, language preference, default email application, referring/exit websites, operating system, date and time stamp, cookie data, and certain user activities.
3.2.3 Technical Data.
Relocity collects technical data, such as information about devices accessing the Services, including the type of device, device settings, operating system, application software, peripherals, and unique device identifiers (“Technical Data”). Technical Data does include any Personal Data and Relocity does not relate any Technical Data to any individual user.
3.2.4 Cookie Information.
3.2.5 Third Party Services.
Third Party Services may be integrated with or made available in connection with the Services. When enabled, Third Party Services may share certain data with Relocity to effectuate the integration or offering. You should check the privacy settings and notices of these Third Party Services to understand what data may be disclosed to Relocity.
3.2.6 Additional Information Provided to Relocity.
Relocity receives data when submitted on or through the Services, or if you contact us (e.g., by email, telephone, written correspondence, web based forms, or otherwise), request support, apply for or take a job with us, contract with us, interact with our social media accounts, or otherwise communicate with us.
3.3 Limited Sensitive Personal Data
Relocity may collect, process, or store on or through the Services certain “Special Categories of Personal Data,” “Sensitive Personal Information,” or similarly sensitive Personal Data as defined under applicable privacy and data protection laws (collectively, “Sensitive Personal Data”). Sensitive Personal Data, for the sake of clarity, includes, without limitation, government-issued identification numbers; financial account numbers; credit or debit card numbers; any code or password that could be used to gain access to personal accounts; information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs; trade-union membership; genetic information; biometric information; or information concerning mental or physical health, sex life, or sexual orientation. Relocity collects, processes, and stores only such Sensitive Personal Data required to perform the Services, and limits its use and disclosure to that reasonably necessary and proportionate for this purpose. Except for any Sensitive Personal Data expressly identified in Section 3.1.1 “User Information,” Relocity does not intentionally collect, process, or store, and we request that you do not upload, transmit, or submit on or through the Services any other Sensitive Personal Data on or through the Services. Relocity is not responsible and will not be liable for any loss or damages you or another individual may experience due to your unsolicited disclosure of Sensitive Personal Data while using the Services.
3.4 No Children’s Data
The Services are intended for use only by those who are 18 years of age and older. The Services are not directed to or intended for children without parental or guardian consent. Relocity does not intentionally collect, process, or store any Personal Data from any person under 13 years of age without verifiable parental consent. In the event we discover we have inadvertently collected, processed, or stored any Personal Data from a person under 13 years of age, we will promptly take the appropriate steps to delete such data or seek the necessary verifiable parental consent for that collection in compliance with the Children’s Online Privacy Protection Act (“COPPA”) or applicable law.
4. HOW AND WHY WE USE DATA
Client Data will be used by Relocity in accordance with the terms of the applicable Client Agreement, the Client’s instructions, the Client’s or its users’ use of the Services, which includes your use of the Services, and as otherwise required by applicable law. The Client may, for example, use the Services to configure settings, access, modify, share, restrict, export, and remove Client Data and otherwise apply its own policies to the Services.
Other Information will be used by Relocity to perform the Services and related support for the Services, in furtherance of our legitimate interests in operating our business and providing the Services, or pursuant to your express consent for a specific purpose. Specifically, Relocity may use Other Information for these purposes and legal bases:
5. HOW WE SHARE AND DISCLOSE DATA
7. SECURITY MEASURES
Relocity maintains physical, technical, and administrative procedures to safeguard and secure the data we collect. We work hard to protect data in our custody and control from loss, misuse, and unauthorized access, use, disclosure, modification, or destruction. For more information about our security measures, please visit: https:// trust.relocity.com. You provide Personal Data at your own risk. You are responsible for safeguarding your user account and password. Unfortunately, no data transmission over the Internet is guaranteed to be 100% secure, and we cannot guarantee that unauthorized access, hacking, data losses, or other breaches will never occur. If you believe your privacy has been breached, please contact us immediately at firstname.lastname@example.org.
8. IDENTIFYING THE DATA CONTROLLER AND DATA PROCESSOR
Privacy and data protection laws in certain jurisdictions differentiate between the “controller” and “processor” of data. In general, the Client is the controller of Client Data. In general, Relocity is the processor of Client Data and the controller of Other Information.
9. INTERNATIONAL DATA TRANSFERS
Relocity does not transfer Personal Data from the European Union (“EU”), the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland to, or process such Personal Data in, a location outside of the foregoing, without the Client’s prior written consent. However, Relocity may transfer Personal Data from the EU, the EEA, the UK, and Switzerland to, or process such Personal Data in, the United States where Relocity has implemented an international data transfer mechanism compliant with applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”), which for example may include an international data transfer: (i) subject to an adequacy decision by the European Commission; (ii) subject to the Standard Contractual Clauses for the transfer of Personal Data from Controller to Processor, which are incorporated herein by reference; (iii) where another appropriate safeguard pursuant to Article 46 of the GDPR applies; or (iv) where a derogation pursuant to Article 49 of the GDPR applies.
10. YOUR RIGHTS
Individuals located in certain countries and jurisdictions have certain statutory rights in relation to their Personal Data. Subject to any exemptions provided by law, you may have the right to exercise your rights and request certain actions with respect to your Personal Data.
10.1 General Privacy Rights
The Services are global and Relocity endeavors to comply with all applicable privacy and data protection laws. Please direct any requests to exercise your rights under applicable privacy and data protection laws to your Sponsor. For any other requests related to your rights under applicable privacy and data protection laws, please contact us at email@example.com. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
Relocity is committed to maintain accurate information that you share with us and will use commercially reasonable efforts to allow you to access your Personal Data. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Data. To request this information or if you wish to access, modify, or remove your Personal Data, please contact us at firstname.lastname@example.org. Relocity will endeavor to respond to all reasonable written requests to access, modify, or remove Personal Data in a timely manner within thirty (30) days.
If you seek to access, modify, or remove Personal Data held or processed by us on behalf of the Client, you should direct your inquiry to your Sponsor. Upon receipt of a data subject request from your Sponsor or the RMC, as applicable, we will respond to their request in a timely manner within thirty (30) days.
10.2 Additional Rights for Europe
Please direct any requests to exercise your rights under the GDPR to your Sponsor. For any other requests related to your applicable rights under the GDPR, please contact us at email@example.com. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
10.3 Additional Rights for California
10.3.1 California Consumer Privacy Act
Relocity will not discriminate against you for exercising your rights under the CCPA. Specifically, if you exercise your rights, we will not deny you services, charge you different prices for services, or provide you a different level or quality of services.
When rendering the Services to the Client subject to the CCPA, the Client acts as a “business” and Relocity acts as a “service provider”, and Relocity’s receipt and collection of any Personal Data is completed on behalf of the Client in order for Relocity to provide the Services.
Please direct any requests to exercise your rights under the CCPA to your Sponsor. For any other requests related to your applicable rights under the CCPA, please contact us at firstname.lastname@example.org. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
10.3.2 California “Shine the Light” Notice
Relocity does not disclose Personal Data to third parties for any third parties’ direct marketing purposes and will not do so unless you affirmatively consent to such disclosure. Since Relocity provides its California users with notice of its rights as described above, pursuant to Section 1798.83(c)(2) of the California Civil Code, Relocity complies with California’s “Shine the Light” law and is not obligated to provide California users with the names and addresses of
all the third parties that received Personal Data from Relocity for the third parties’ direct marketing purposes during the preceding calendar year.
13. CONTACT RELOCITY
You may contact us at:
10250 Constellation Blvd., Suite 100
Los Angeles, CA 90067