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WORKHUMAN


WORKHUMAN PRIVACY POLICY

Hi Humans!

Thank you for taking the time to review our Privacy Policy. After reviewing our
Privacy Policy, if you still have questions about the use of your personal
information, please contact us at privacy@workhuman.com.

Globoforce Inc. d/b/a Workhuman (US) and Globoforce Limited trading as Workhuman
(Ireland) (“Workhuman”, “us”, or “we”) are committed to protecting your privacy
and complying with our obligations under applicable law (including, with the EU
General Data Protection Regulation 2016/679 (GDPR)). This Privacy Policy
explains how we collect your personal information on our various program sites
(the “Sites”), how we protect such information and the choices and rights you
have concerning your information.

Please remember that this Privacy Policy applies only to personal information
provided by you to Workhuman pursuant to your use of our Sites. For personal
information we receive directly from your employer, we want to ensure you’re
aware that your employer determines the purposes and means of our processing and
we only process such personal information under their instructions. For any
questions related to the personal information provided to us by your employer,
please contact your program manager.

We are not responsible for the privacy practices of websites that are owned or
controlled by third parties.


TYPE OF INFORMATION COLLECTED

We collect personal information as described below.

As used in this policy, Personal Information is information that you provide to
us on our Sites that identifies or relates to or could reasonably be linked to
or associated with you. The personal information we collect may include (but is
not limited to) identifiers such as your name, address, personal email address,
or telephone number and commercial information such as redemption information.


HOW WE USE YOUR PERSONAL INFORMATION

We only keep and process your personal information where we have a legal basis
to do so. The purposes and bases we rely on are as follows:

 * To deliver our service: When you access any of our Sites, we will store and
   process your personal information (combined with any personal information we
   receive from your employer) for the purposes of opening and administering
   your account, fulfilling your orders, responding to your requests and/or to
   communicate with you about your orders.
 * With your consent: We may invite you to provide personal information to us in
   which case we rely on your consent. For example:
   * Information provided to us by your employer: Workhuman requires our
     customers to ensure they have received appropriate consent or other lawful
     basis, according to applicable privacy laws, from their employees before
     transferring personal information to Workhuman. If you no longer wish for
     us receive your data from your employer, you should contact your employer
     directly and apprise them accordingly.
   * o Surveys: If your employer asks us to conduct a survey, we may invite you
     to participate in a voluntary email survey. All survey questions are
     optional; there is no requirement that you answer all or any of the
     questions asked. While Workhuman will not identify your name or email
     address to your employer as someone who was invited to participate or who
     did/did not participate, you should not include personal information in
     your responses to surveys if you do not wish for this information to be
     seen by your employer. We may also invite you to participate in voluntary
     email surveys to evaluate your interaction with our customer service team
     which helps us improve our services. All surveys are optional, and if you
     chose to respond, all survey responses will be kept confidential and will
     not be shared with your employer.
   * Your Content: Certain of our services that you may have access to allow you
     to upload attachments, files, forms or documents including videos and/or
     photos stored on your computer (“Attachments”). Once uploaded, certain
     Attachments may be accessible to your employer company’s program managers,
     HR staff and others who the company may designate from time to time. Other
     Attachments (for example, videos and/or photos uploaded with an award
     message), may be viewed by your colleagues and all other users in your
     program. You agree that you will not upload any Attachments that contain
     (i) personal information that you do not wish to disclose to your company
     or to us or (ii) which include personal information relating to others
     unless you have obtained their explicit consent to posting the Attachment
     or (iii) confidential information which would violate any duties of
     confidentiality you owe to your employer or any third party. If you have a
     question on whether you should provide an Attachment, please contact your
     employer company for guidance.
 * Where we have a legal obligation: We may also disclose your information if we
   believe in good faith that we are required to do so to comply with an
   applicable law, a subpoena, a search warrant, a court or regulatory order or
   other valid legal process or lawful requests by public authorities, including
   to meet national security or law enforcement requirements.
 * Our legitimate interests: We may also process your personal information where
   it is in line with our legitimate interests, but we will not rely on this
   basis if your rights and interests would override ours. Examples of our
   legitimate interests and how we balance them with your rights include the
   following:
   * Tracking Emails: Workhuman may track and collect certain information
     through emails that we send to you. This may include, but is not limited
     to, whether or not an email is opened, and links you click on in the email.
     To balance our interests with yours, we will not share this information
     with your employer, and some emails have no tracking at all. However, the
     ability to track and collect this information allows us to understand how
     our services are meeting your needs.
   * Analytics: We undertake data analytics to understand how our users are
     interacting with our Sites by using our services and how we can improve and
     develop our services. Our analytics are conducted on an anonymous basis so
     as to avoid any privacy impact for individuals.
   * Cookies: Another example of our legitimate interests is where we deploy
     cookies on our Sites that are essential to delivering the service requested
     by you e.g. session cookies, authentication cookies (for the duration of
     the session) and user security cookies. We explain what cookies we use and
     how you can adjust your cookies consents and preferences in our Cookies
     Policy.


INTERNATIONAL DATA TRANSFERS

Workhuman is a global business with headquarters in Ireland and in the US.
Workhuman may regularly transfer personal information to countries other than
the country in which the data was originally collected from you and/or was
provided to us. These countries may not have the same data protection laws as
the country in which you initially provided the information. However, when we
transfer your personal information to other countries, we will protect that
information in accordance with applicable law. For example, the principal way in
which we protect personal information subject to the GDPR that may be
transferred to locations outside of the European Economic Area (EEA) to a
country determined to provide an inadequate level of protection of such personal
information is through the use of EU Commission approved Standard Contractual
Clauses.

While the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks may no longer be
relied upon for transfers of personal information, Workhuman continues to comply
with the Privacy Shield Principles. To learn more about Privacy Shield’s
obligations and to view our certification, please visit
https://www.privacyshield.gov/.


HOW WE USE AGGREGATED INFORMATION

We occasionally provide aggregated information regarding the use of our Sites to
partners, but these statistics never include personal information. For example,
we might inform third parties regarding the number of unique users who visit our
Sites or the activities that visitors to our Sites engage in while on our Sites.
The third parties to which we may provide this information may include potential
or actual advertisers, providers of advertising services (including website
tracking services), commercial partners, sponsors, licensees, researchers and
other similar parties.


DISCLOSURE OF INFORMATION TO THIRD PARTIES

Your personal information will be shared with third parties in the manner
described herein. For example, under our agreement with your employer, your
employer may receive information that you have availed yourself of our services.
However, we believe that your specific redemption data (such redemption data may
be referred to as “Participant Data” under our agreement with your employer and
is data entered by you related to the redemption of GloboCertificates and
includes, but is not limited to, your outstanding GloboCertificate balance) is
personal to you and we will not share this information with your employer. We
may share your personal information with other entities in the context of (i) a
change of ownership of Workhuman’s assets or business, (ii) as required to
deliver a service to you, such as when we may share your information with our
third-party subprocessors listed here: Participant Subprocessor List if it is
necessary to deliver our service, or fulfill or redeem a GloboCertificate, or
(iii) where we are under a legal obligation to do so. We do not and will not
sell, trade or rent your personal information to third parties.


YOUR RIGHTS TO YOUR INFORMATION

You have various rights in relation to your information. Where they relate to
information held by your employer (who has provided such to information to
Workhuman), you should contact your employer to exercise your rights. Where
Workhuman is a “controller” of your information, you have the following rights:

 * Inspection and access: You can request a summary and/or a copy of any
   personal information we hold about you;
 * Correction/addition/removal: Where you believe your information is inaccurate
   or incomplete, you are entitled to request us to correct, amend or delete it;
 * Portability: You may request that we send you any personal information that
   you have provided to us or ask that we send this information to a third
   party;
 * Objection: You may object to us using your personal information where we use
   it based on our legitimate interests to do so;
 * Restriction: You may request that we restrict the processing of your personal
   information where you believe it is inaccurate, our processing is unlawful,
   you believe we no longer need the information or if you have objected to our
   use of it; and
 * Automated Decision Making: Where we undertake automated decision making
   (including profiling), which significantly affects you, you are entitled to
   object to such decision-making. (We do not ordinarily undertake this type of
   processing.)
 * Withdraw Consent: In circumstances where we are relying on your consent to
   process your personal information, you may withdraw such consent by
   contacting us as indicated below.

You may update or correct your account information and email preferences at any
time by logging in to your account settings page. You can also exercise any of
your rights by using the Contact Us details below.

Depending on your request above and the personal information in question, it may
be our legal and contractual duty to contact your employer, as well as promptly
responding to your inquiry. We will respond to your request in accordance with
applicable law.


NOTICE TO CALIFORNIA RESIDENTS

California Privacy Rights: to the extent provided for by law and subject to
applicable exceptions, California residents have the following privacy rights in
relation to the personal information we collect:

 * The right to know what personal information we have collected and how we have
   used and disclosed that personal information;
 * The right to request deletion of your personal information;
 * The right to be free from discrimination relating to the exercise of any of
   your privacy rights.

Exercising Your Rights: California residents can use the Contact Us details
below to exercise the above privacy rights or to access this Privacy Policy in
an alternative format.

Verification: in order to protect your personal information from unauthorized
access or deletion, we may require you to verify your identity before you can
submit a request. If we suspect fraudulent or malicious activity, we may ask you
to provide additional personal information for verification. If we cannot verify
your identity, we will not provide or delete your personal information.

Authorized Agents: you may submit a request through an authorized agent. If you
do so, the agent must present signed written permission to act on your behalf
and you may also be required to independently verify your identity with us.


SECURITY

Workhuman is committed to taking reasonable steps to ensure the security of your
information. To prevent unauthorized access, maintain data accuracy and ensure
the appropriate use of information, we have put in place appropriate physical,
electronic and managerial procedures to safeguard and secure the information we
collect online. We maintain strict data security systems that ensure specific
information will not be made available to any unauthorized person and in order
to protect information from loss, misuse and unauthorized access, disclosure,
alteration or destruction. Our employees are made aware of and are accountable
for compliance with our Privacy Policy. Any information collected by us on
behalf of our clients is stored on our web server or databases but is not
publicly accessible from our Sites or otherwise. When applicable, we use a
multi-level, password protected security system to control access to information
stored about users. We also maintain strict physical security of our properties
and facilities and only provide access to authorized personnel.


CHANGES TO THE PRIVACY POLICY

If we decide to change this Privacy Policy, we will post those changes on our
Sites, so you are always aware of what information we collect, how we use it,
and the circumstances, if any, we disclose it. If at any point we decide to use
personal information in a manner significantly different from that stated in
this Privacy Policy, or otherwise disclosed to you, at the time it was
collected, we will notify you, and you will have a chance to review such changes
prior to reaccepting our terms and conditions. We may also make non-significant
changes to our Privacy Policy that generally will not affect our use of your
personal information.


CONCERNS AND COMMENTS

If you wish to exercise your data protection rights or to raise any concerns,
objections or complaints in relation to this Privacy Policy, please contact us
using the relevant Contact Us details below. If contacting us does not resolve
your issue, EU users of our Sites may contact their local EU Data Protection
Authorities or Swiss users can contact the Swiss Data Protection and Information
Commissioner (collectively, “DPAs”). In the case of users of our Sites within
the EU, our lead DPA is the Data Protection Commission in Ireland which acts as
the “one stop shop” for complaints relating to cross-border processing issues.

The services of the DPAs are provided at no cost to you. Accordingly, if the
DPAs finds us to be in violation of the law, we will correct the situation and,
if necessary, stop processing the data of the individual who brought the
complaint.


CONTACT US

Our geographic contact details are:

 * Globoforce Inc. d/b/a Workhuman, 200 Crossing Blvd., Suite 500, Framingham,
   Massachusetts, United States 01702.
 * Globoforce Limited trading as Workhuman, 19 Beckett Way, Park West Business
   Park, Dublin 12, Ireland

If you wish to exercise your data protection rights or to raise any concerns,
objections or complaints in relation to this Privacy Policy, please email us
at:privacy@workhuman.com.

(Last modified as of February 16, 2022)

©2019 Globoforce Limited trading as Workhuman®. All Rights Reserved.