Enboard.Me Pty Ltd, together with its related corporate bodies Enboarder Ltd in the United Kingdom and Enboarder LLC in the United States (collectively, Enboarder, we, us, our) are committed to protecting your privacy.
Enboarder offers our employer clients an onboarding and engagement platform available through its website and accessible on any device (Platform). Using our Platform, our employer clients (“Clients”) build customized workflows on their own to create engaging experiences with their employees.
Notice at Collection
1. Information We Collect
“Personal information” or “personal data” is any information about you, from which you can be identified, directly or indirectly. Our processing of your personal information will depend on our relationship with you, the circumstances of collection and the types of products and services you request from us. We may collect additional personal information from you from time to time.
“Sensitive personal information” is a category of personal information defined as sensitive under certain laws. This could include certain personal identifiers like Social Security numbers, passport numbers, or driver’s license numbers; financial information, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.
Categories of Personal Information We Collect
Personal identifiers – such as your name, e-mail address, address, phone number, and other information about yourself.
Client record information – such as contact details (e.g. telephone number and address), or payment information (e.g., credit card numbers);
Commercial information – such as information about any transactions, both free and paid, that you enter into via the Platform or on the Website.
Internet or online information – such as information about your computer and your activity on the Website or Platform including your IP address, operating system, geographical location, browser type, referring website addresses, length of visit and pages viewed.
Geolocation data – such as device location.
Audio, electronic, visual, thermal, or similar information – such as recordings of conversations with our sales representatives or client support services. In these instances, you will be notified in advance of the recording and given the opportunity to request your interaction not be recorded.
Professional or employment related information – such as employment history, experience, or current role with our Clients or prospective clients.
Sensitive personal information – such as social security numbers, certain health information, and race or ethnicity information, which we only collect for employment related purposes. Otherwise we do not collect sensitive personal information about you unless you provide it to us voluntarily. If we need to collect any sensitive information for a specific purpose, we will ask for your consent.
We do not collect or process sensitive personal information to infer characteristics about you. As it pertains to personal information of Californians, Enboarder only uses sensitive personal information consistent with the exceptions to the right to limit sensitive personal information under California law. For example, Enboarder will collect social security numbers and certain health information, and race or ethnicity information of employees for various purposes including identity verification, background checks, administering payroll or benefits, and tracking diversity initiatives.
Information We Collect from Third Parties
From time to time, we may receive personal information about you from third party sources. This may include publicly available information from service providers, or contact information from partners with which we offer co-branded services or engage in joint marketing activities. Examples of these type of partnerships would be when we co-author a white paper, co-sponsor a webinar series, or attend a conference as a vendor and receive information from the host regarding attendees. In all of these situations we confirm our partners are collecting this information in accordance with applicable law.
We may also receive personal information about you from social media companies based on your engagement with us on their site (e.g. liking or commenting on our posts, or viewing our profile). For more information on how your engagement with us on social media may impact how your personal information is collected or shared, see Section 6 Social Media Features.
Information About Children
The Website and Platform are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at email@example.com, so that we may delete the information.
2. How We Use Information We Collect
To Support Everyday Operations
- Provide marketing communications or promote our services. We may use your personal information to send Enboarder promotional and informational content we think may be of interest to in accordance with your communication preferences. We may also use your personal information if it is contained in a client testimonial or comment on our Website. We obtain each Client’s consent via email prior to posting the client’s name and testimonial.
- Comply with legal requirements and protect the safety and security of our business. We may use your personal information to comply with laws, regulations or other legal obligations, to assist in an investigation, to protect and defend our rights and property or the rights of third parties or enforce terms and conditions. We may also use your personal information to prevent suspected fraud, threats to our network or other illegal activities, prevent misuse or for any other reason permitted by law.
- Facilitate recruiting, hiring and employment. If you are an Enboarder employee or a prospective employee of Enboarder, we may collect personal information directly from you or indirectly from recruitment agencies, your references, or past employers as part of the recruitment process and human resources management. This may include name, address, phone number, employment history and experience and other employment related information. If you are an employee, we may also collect sensitive information about you and you consent to us collecting this information. This may include health information or racial or ethnic origin.
Where There is a Legal Basis for Processing Personal Information (UK and EEA visitors only)
If you are a visitor located in the European Economic Area (“EEA”), Enboarder Ltd in the United Kingdom is the data controller of your personal information. Enboarder’s Data Protection Officer can be contacted at firstname.lastname@example.org.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
3. How We Share Information We Collect
We do not sell or share your personal information to third parties as those terms are defined by California law.
We may disclose personal information in accordance with the applicable law and for the purposes described above, including:
- To your employer who is our Client;
- To our related bodies corporate;
- To anyone to whom our assets or businesses (or any part of them) are transferred;
- When we may be required, authorized or permitted by law, including to government agencies, regulatory bodies and law enforcement agencies; and
- To any other service provider, contractor or third party where you have provided your consent.
We may also disclose personal information to third parties such as our contractors, suppliers, agents and service providers who help us deliver, administer and support our functions and activities, including:
- Hosting our servers and website;
- Conducting research, surveys and data analysis;
- Providing IT services;
- Data processing, storage and back-up;
- Processing payments; and
- Delivering marketing and digital marketing services
We employ other companies and people to provide services to visitors to our Websites and our Clients and Client Users of the Platform and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
International Data Transfers
Enboarder is an international company based in the US, with locations in Australia and the UK as well. We may transfer your personal information to countries other than the one in which you live, including transfers to the United States. To the extent that personal information is transferred abroad, Enboarder will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with our obligations.
In particular, Enboarder uses Standard Contractual Clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK where appropriate) for transfers to, among others, Australia, UK, and the United States. Enboarder will transfer your personal information to facilitate the provision of the Services. A copy of our standard data processing addendum, incorporating the Standard Contractual Clauses, can be found in our Data Protection Addendum in our Terms of Service.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Enboarder on the Website and the Platform. In this event, you will be notified via email and/or a prominent notice on our Website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
We reserve the right to use or disclose your personal information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information collected, as further described below.
We retain personal information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your personal information, we securely delete the information or anonymize it so that it is no longer personal information or, if this is not possible, securely store your personal information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the “How to Access & Control Your Personal Data” below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Enboarder account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
Security of Your Personal Information
We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. We secure the personal information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All personal information is protected using appropriate physical, technical and organizational measures. For more on security at Enboarder, please see https://enboarder.com/information-security-policy/.
4. Cookies and Similar Technologies
5. Direct Marketing
As mentioned above, as our Client, we may, from time to time, send direct marketing communications to you about our activities and services and other material that we consider you would find interesting or useful. If you do not wish to receive such direct marketing communications, you can always opt out. If you are receiving email communications from us, there will be a mechanism to opt out contained in each of those emails. To stop receiving other communications from us, you can contact us via any of the channels listed below.
If you choose to opt out of all direct marketing communications, please note that Enboarder may still contact you and your employees for other reasonable purposes, including information that Enboarder is legally required to send, notifications of changes to Enboarder services or policies and information regarding the use, rights, benefits or obligations of users of our services.
6. Social Media Features
If You Make a Public Post, Others May See It.
Your personal information may be publicly available if you identify us in your social media pages or on various social media platforms by tagging us using a hashtag (#) or “at” (@) indicator. Your personal information also may be publicly available if you make a post on a social media site on a page we maintain. We maintain Enboarder social media pages on the following sites:
- Facebook at https://www.facebook.com/enboarder/
- X at https://twitter.com/enboarder
- LinkedIn at https://www.linkedin.com/company/enboarder/
- Instagram at https://www.instagram.com/enboarder/
7. External Websites
8. Public Forums
We offer publicly accessible blogs. Please keep in mind that if you directly disclose any information through our public blogs, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in “Opting Out and Unsubscribing” below.
9. How to Access & Control Your Personal Data
Reviewing, Correcting and Removing Your Personal Information
If you are a California consumer, please see the section entitled “California Consumer Rights” for more information on access and control of your personal data.
We will take all reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date, and we will try to confirm your details through our communications with you and promptly add updated or new personal information to existing records when we are advised. However, we rely on the accuracy of personal information as provided to us both directly and indirectly. We encourage all users (whether of the Website, on our Social Channels or Platform) to regularly review and update their personal information. If any of your details change, please notify us as soon as you can or log into your online profile or subscription center to update it. If you believe we are holding information about you that is inaccurate, incomplete, irrelevant or misleading, you can ask us to correct it, or delete it altogether.
You Have the Following Data Protection Rights:
You can request access, correction, updates or deletion of your personal information.
You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)
To exercise any of these rights, please contact us at email@example.com or by mail to Enboarder, 728 Northwestern Ave, Building B, Austin, TX 78702, Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
To Unsubscribe from Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at firstname.lastname@example.org or postal mail to Enboarder, 728 Northwestern Ave, Building B, Austin, TX 78702, Attention: Privacy. Customers cannot opt out of receiving transactional emails related to their account with us.
California Consumer Rights.
- You have the right to request that we provide you information on what personal information we collected, used and disclosed in the past twelve months, including:
- The categories of personal information we collect
- The categories of sources from which we collect personal information
- The business or commercial purpose for collecting, selling, or sharing that personal information
- The categories of third parties to whom we disclose that personal information
- The specific pieces of personal information we have collected about you
- You have the right to request that we delete personal information that we, or our service providers, store about you, subject to some exceptions. For example, if we need the personal information to complete a transaction, provide a good or service you requested, perform our contract with you, or otherwise take actions reasonably expected in the course of our business relationship. Other exceptions may include if the personal information is needed to detect security incidents, protect against fraudulent or illegal activity, prosecute those responsible for such activity, or comply with a legal obligation.
- You may request that we not sell or share your personal information; as noted previously, Enboarder does not sell or share your personal information.
- You have the right to designate an authorized agent to make a request on your behalf.
Please see Identity Verification Requirement for information on our process for verifying we have received a legally valid request.
Identity Verification Requirement.
We will verify that any request for access to personal information, or any other right legally granted in relation to personal information, is made by someone with the legal authority to make the request or access the information. Before accessing or disclosing information to an individual, we may request additional information so we can verify your identity and legal authority. To protect you and your personal information, we will only respond to access or deletion requests that we have been able to properly verify through our authentication processes.
To make a request if you are a California consumer, please contact us via email at email@example.com with “Personal Information Request” in the subject line and provide full details relevant to your request, including your contact information. Please note that in either instance, we may need additional information from you or require that you take additional steps to validate your identity. We will provide a response to an access request within the timeframe required by applicable law. If we cannot substantively respond in a timely manner, we will notify you with the reason for the delay.
Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, when we cannot verify your identity, if your request involves disproportionate cost or effort, or we have a legal right to do so. But we will respond within a reasonable time and in accordance with the law and provide an explanation.
10. Making A Complaint
We take your complaints seriously and we will attempt to resolve any issues quickly and fairly. If you think that an act or practice of Enboarder has interfered with your privacy in relation to your personal information, you can contact us using the details below. Please include your name, email address, telephone number and clearly describe your complaint.
If we cannot resolve your complaint to a satisfactory standard, you are entitled to lodge your complaint:
- With the Office of the Australian Information Commissioner at: http://www.oaic.gov.au; or
- For residents of the European Economic Area and the UK, with the relevant supervisory authority. A list of EU national data protection authorities can be found on the European Commission website at: https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection_en.
- Enboard.Me Pty Ltd, 121 Sussex St, Sydney NSW 2000, Attn: Legal
- Enboarder LLC, 728 Northwestern Ave, Building B, Austin, TX 78702, Attn: Legal
- Enboarder Limited, 10 John Street, London, England WC1N 2EB, Attn: Legal