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WPO is committed to protect all personal and private information in accordance with any and all applicable laws, regulations and standards, including without limitation any standards established in the United States under the Health Insurance Portability and Accountability Act and in the United Kingdom under the Data Protection Act of 1998. In case of use of this website within the European Union, WPO is subject to, the Privacy Shield Framework, the General Data Protection Regulation (Regulation (EU) 2016/679), effective as of May 25, 2018 and any national legislation implementing the foregoing.WPO complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. WPO has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
WPO maintains appropriate administrative, technical and physical safeguards designed to protect your personal information in accordance to the applicable law. WPO uses industry standard encryption on this website. Unfortunately, the transmission of information via the Internet is not completely secure. Although WPO will do its best to protect your personal data, WPO cannot guarantee the security of your data transmitted to this website; any transmission is at your own risk.
WPO will not evaluate any computer, tablet, or other mobile device that you may use to access WPO’s services for the secure handling of your personal information. WPO disclaims any liability for any loss resulting from any security and data protection shortfalls originating from you own electronic devices.
What kind of information do we collect?
You must be registered with WPO in order to have access to our services and this website. WPO may collect some information from interactive features such as online surveys, contact and registration forms, and through the use of ‘cookies’ as explained below. The information WPO receives in such a manner depends on the settings on your browser. For example, if you visit this website to read or download information, such as information about a health condition or about one of WPO’s products, WPO may collect certain anonymous, unrestricted, non-personal information about you from your computer, including the type of web browser software you use, the links that you select, traffic data, the name of your Internet domain, the Internet address of the website used for access, location data, the pages you have visited on this website, web logs and other communication data. Depending on your choices, products and services (e.g. for behavioral and health services), WPO may with your explicit consent collect and process personal information which may include:
- date of birth/other vital statistics records
- email address
- physical/mailing address
- telephone number
- racial or ethnic origin
- sexual orientation or religious beliefs
- private ID number/residency number
- personal health information
- family health information.
What kind of information do we collect (Adapt)?
How will your personal information be used?
Your employer will not have access to your Personal Data stored on WPO systems. However, if your employer offers an incentive plan that offers rewards for completion of WPO’s online programs, with your explicit consent via the tick box on the registration page, WPO may share your personal information with your employer including your name, employee identification, and details of which online programs or assessments you have completed including the dates. Neither the scores nor responses from your online programs will be disclosed to your employer as part of an incentive plan.
If your employer provides a coaching plan that includes an outreach call from a WPO coach, with your explicit consent via the tick box on the registration page, a coach may contact you using the contact information and preferences you provide. Your employer will not be given any detail regarding the content of your discussion with a coach; however, WPO may share with your employer your personal data including your name, employee ID, and number of coaching sessions you have completed including the dates.
What is information transfer?
WPO may transfer the personal information collected about you to countries other than the country in which the information was originally collected. These transfers will be to a service center operated by WPO or one of WPO’s network of providers in order to provide you with the service you requested. WPO adheres to adequate safeguards required for the international transfers of your personal information outside of the European Economic Area. If you are located in the European Union or Switzerland, WPO may transfer data outside of the European Union in accordance with standards set forth by European Union law, the EU model clauses, and/or the EU-US Privacy Shield framework for transatlantic information transmission as adopted. Nevertheless, access to your personal information may be provided only on a “need-to-know” basis so that WPO may deliver its services upon your request; your personal information will not be disclosed to any other person or entity other than in aggregate reports or in de-identified form without your written consent.
In the context of an onward transfer Workplace Options has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Workplace Options shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
Who do we share your information with?
We do not sell your email address or other information identifying you to third parties. However, we do share your information with companies that are part of WPO or with selected third parties in order to pursue the objectives set out in this policy, in other contacts with you or on the site (e.g. “lettershops” that send you additional advertising and information material that may be of interest to you).
We disclose information about you to others when we believe in good faith that we are required by law or legal process to respond to claims or to protect the rights, property or safety of WPO or others.
What information may be required to be disclosed?
Under certain circumstances WPO may be expected to disclose personal data. These circumstances include those as set out in Article 6.1 of the GDPR, which establishes that processing shall be lawful only if and to the extent that at least one of the following applies:
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
- processing is necessary for compliance with a legal obligation to which the controller is subject;
- processing is necessary in order to protect the vital interests of the data subject or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
What are your rights?
You have certain rights regarding the personal information WPO collects and maintains about you. WPO offers you choices about what personal information is collected from you, how that information is used, and how WPO communicates with you:
- You can expect that WPO will collect and process your personal information fairly and in accordance with applicable law.
- You can choose not to provide personal information to WPO by refraining from conducting electronic transactions.
- You can elect not to have a unique cookie identification number assigned to your computer.
- Your personal data may be used for statistical analysis and reporting purposes in a manner that does not identify you in any way.
- You may agree to the release of any or all of your personal information to anyone or any organization by giving your consent to WPO; otherwise, your personal data will not be routinely released unless WPO has a legal obligation to do so.
- You may withdraw any consents you previously provided to WPO, or, on legitimate grounds, object at any time to the processing of your personal information or specific categories of data that you consider sensitive.
- You have the right of data portability so that you can retrieve and reuse your personal information for your own purposes.
- You have the right to request at any time correction of any error(s) in your personal information that is collected and processed by WPO.
- You have the right to lodge complaints with any supervisory authority.
- You have right, under certain circumstances, to invoke binding arbitration to resolve any dispute regarding the collection, processing, retention, and/or release of your personal information.
- You may, subject to local law requirements, have the right to (a) to request access to and receive information about the personal information WPO collects and maintains about you; (b) update and correct inaccuracies in your personal information; and (c) have your personal information blocked or deleted, as appropriate.
- You have the right to ask WPO to no longer collect your personal information for information purposes (e.g. sending information to you by email or SMS text; asking your opinion on WPO products and services) by withdrawing your consent. You can exercise your right to withdrawal at any time by contacting WPO.
In compliance with the Privacy Shield Principles, WPO commits to resolve complaints about our collection or use of your personal information. WPO is subject to the investigatory and enforcement powers of the Federal Trade Commission. Individuals domiciled in the EU and/or Switzerland with inquires or complaints regarding our Privacy Shield policy should first contact WPO at: firstname.lastname@example.org
WPO has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
Security of your data
Your personal data provided to us will be secured by taking all technical and organisational security measures in such a way that they are inaccessible for access by unauthorised third parties. When sending very sensitive data or information, it is recommended to use the postal service, as complete data security by e-mail cannot be guaranteed.
Duration of storage
The personal data provided by you will be stored by us for the duration of use of the website or in the event of the provision of information, services or support until expiry of the statutory storage period, taking into account the basic principles of the GDPR and BDSG to the permissible extent.
California Privacy Rights
Any other questions or concerns
Data Protection Officer of Workplace Options GmbH
Data Business Services GmbH
Jurisdiction and Applicable Law.
The laws of the State of North Carolina govern this Privacy Statement (“Statement”) to the extent as not overruled by applicable local law as the GDPR for data subjects within the EEA. You irrevocably consent to the jurisdiction of the courts located in the County of Wake, State of North Carolina, U.S.A. for any action arising out of or relating to this Statement if not local law gives you the inevitable right to apply to your local court. If the information and materials presented on this website includes the sale of goods (e.g. publications, books), then any following rights and obligations that you or WPO may have shall not be governed by the United Nations Convention on Contracts for the International Sales of Goods (“CISG”) and its application is excluded. You may be able to access this site from any region in the world. If your use of any benefit offered by this website conflicts with the laws of your region, then WPO respectfully requests that you do not use this website; you are responsible for your own knowledge and understanding of the laws of your region as well as your compliance with them.