Revised Date: JANUARY 30, 2023
The Work From Anywhere Team Limited and its affiliates (“WFA Team”, “we” “us” or “our“) is committed to protecting and maintaining the privacy of personal information it collects and processes.
WFA Team provides a Global Talent Mobility platform (“Platform”) that empowers HR, Tax and Finance teams to effectively deploy, manage, assess and engage employees across the world. We enable businesses to deliver mobility and immigration as part of a broader talent strategy, encompassing all types of employee work arrangements – remote and distributed workforces, business travel, and more traditional relocations and assignments. WFA Team keeps companies and employees engaged and compliant wherever their work happens.
This privacy notice (“Notice”) describes WFA Team’s role and privacy practices as they pertain to accessing information about WFA Team via our Websites, or events offered by or related to WFA Team or in engaging WFA Team or using our Platform (together, the “Services”).
This Notice distinguishes between the following activities:
WFA Team Visitors and Attendees
This relates to people who visit WFA Team’s Websites (“Visitors”) as well as companies and people who register to attend WFA Team’s corporate events (“Attendees”). WFA Team acts as a Controller of such data.
Agreements with Customers
This relates to any business contact details of personnel at a company that enters into an Agreement (“Customer“) relevant to entering into or administering delivery, of the Services (the “Agreement”) or to the extent necessary for communicating information about the Services under the Agreement and in managing WFA Team’s invoicing and accounts. WFA Team acts as a Controller of such information. The WFA Team local entity with which you contract will also be a Controller.
WFA Team Platform
This Privacy Notice does not apply to any third-party applications or software that integrate with the Services (“Third Party Services”), or any other third-party products, services or businesses.
Information We Process
When you use WFA Team’s Services or otherwise engage with us, we may process from or about you, information by which you can be identified either directly or indirectly (“Personal Information“) which may include the following.
1. WFA Team Visitors and Attendees
WFA Team may collect and receive Visitor and Attendee information, in a variety of ways.
Contact Information – Information such as your name, company title, role, email and/or postal address that for example, you provide if you fill in any forms such as a ‘contact us’ form or if you submit a question or otherwise correspond or engage with us, including by email or phone.
Event Information – When you register for or attend a corporate event or webinar, WFA Team will ask you to provide basic Attendee contact information, including your name, company, title, email address and information about the event registered for and or attended (“Attendee Information”).
Usage Information – Information relating to your online visit:- Technical information – such as your Internet Protocol (IP) address
used to connect your device to the internet, information about your device, browser type and version, time zone setting, operating system and operating platform.- Activity information – including the Uniform Resource Locators (URL), clickstream (including the date and time), information viewed or searched for, page response times, download errors, length of visits to certain pages, content interaction information.- Cookies – as described within our cookie consent management tool and as further set out below.
2. Agreements with Customers
Contact Information (as described above).
3. WFA Team Platform
User Information – Customers or its employees granted access to the Services (“Authorized Users”) and who submit Customer Data to the WFA Team – Customer instance of the Platform.
Usage Information – Where you use the Services under the Agreement the Platform collects Usage Information as described above, in addition to user login information.
Customer Data – Any Personal Information submitted through the Platform is at the discretion of the Customer and under their control. Such data may include Customer employee contact and role details, placement information, documentation required under immigration laws, payroll and compensation information and talent management records. It may also include, but not be limited to, other personal identifiers such as date of birth, tax or social security number, driver’s license number, or financial account details. WFA Team is not responsible for the authenticity of information submitted by Customer or Authorized User while using the Platform.
Purposes for Processing
WFA Team processes Personal Information from or about you in the following ways:
WFA Team Visitors and Attendees
Unless we are required to obtain your consent, we will use this information in our legitimate interests where we have considered that these interests are not overridden by your rights to:
– Ensure content is presented in the most effective manner for and your device,
– Provide any information you request from us, including in responding to any queries you have submitted,
– Administer our Websites and Services for internal operations, including troubleshooting, data analysis, testing and statistical
– Keep our Websites and Services safe and secure,
– Analyze the effectiveness of our social media channels and advertising we serve,
– Register you for events and administer your attendance,
– Participate in a focus group, and
– Allow you to participate in interactive features when you choose to do so.
With your consent, where required, to send you our marketing communications and deliver cookies, including updates leading up to and following an event, and when providing more information to you regarding WFA Team and our selected partners. Every marketing email you receive from us will have instructions on how to update your contact information or manage your communication settings, including the option to opt-out of further marketing emails.
Agreements with Customers
Take steps to enter into any Customer contract or uphold our obligations arising out of a Customer contract, in particular:
– To administer the Customer account under the Customer contract
– Keep a record of the account, including receipt of payments
– Notify you of changes to our Services.
WFA Team Platform
When you log in to the Platform, the Platform stores information that you or your Employer (our Customer) submits and uses. While in some cases you can make certain information private to you, by default your information is available to other Authorized Users of the Customer based on their role permission configuration selections enabled by your employer. Any access to Customer Data by WFA Team personnel is only to the extent authorized by the Customer in order to support the functioning of the Customer-WFA Team instance of the Services and as outlined in our Agreement between WFA Team and your company.
WFA Team may aggregate the metadata and Usage Information of you with regards to the WFA Team Websites and/or Services so that the results are non-personally identifiable with respect to you (“Aggregated Anonymous Data”). WFA Team may use the Aggregated Anonymous Data:
– for its own internal statistical analysis
– to develop and improve the Services, and
– to create and distribute reports and other materials regarding use of the Services. To be clear, WFA Team does not have the right (or ability) to publicly identify you as the source of any Aggregated Anonymous Data.
Cookies enable you to be remembered when using that device and can be used to manage a range of features and content as well as storing searches and presenting personalized content. They allow us to distinguish you from other Visitors or Authorized Users and helps you to receive a good experience. Cookies also allow us to secure access-controlled areas of our Websites and Services.
A number of Cookies we use last only for the duration of your online session and expire when you close your browser. We may also use permanent Cookies or server-side constructs to help us track use of our Services by Authorized Users, such as the number and frequency of visits to our pages and which parts of our Services are visited.
We use these Cookies and other technologies on the basis that they are necessary for the performance of a contract with you or because using them in in our legitimate interests (where we have considered that these are not overridden by your rights and, where required, where you have consented to their use. More information about the Cookies we use and the choices available to you is available within our cookie consent management banner and tool.
Our Disclosure of Personal Information
WFA Team will not sell, license, trade, or rent your Personal Information. WFA Team will not otherwise disclose your Personal
Information except as described within this Notice and within the Agreement. In this regard we may share Personal Information with:
A member of the WFA Team Group
Which means our affiliates, our ultimate holding company and its subsidiaries, who support our processing of Personal Information.
We may share Personal Information with partners of WFA Team in connection with Services that these individuals or entities perform with us, provided that these agents, contractors or partners are restricted from using said information in any way other than to the extent necessary to provide Services.
Organizations acting on our behalf
We may share Personal Information with third-party service providers (e.g., email service providers, analytics services, data
infrastructure hosting storage and processing facilities) to let them perform business functions for us or on our behalf, subject to appropriate safeguards. We do not permit our service providers to use Personal Information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
To Comply with Laws or Enforce our Rights
We may also disclose Personal Information we receive if required by law, such as to comply with a subpoena, or similar legal process, or in response to a government request. We also may be required to disclose Personal Information in response to a lawful request by public authorities in efforts to meet national security or law enforcement requirements. To protect and defend the rights, property or safety of WFA Team or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues, we may disclose Personal Information to relevant parties.
During a Change to WFA Team’s Business
We may disclose Personal Information in connection with any merger, acquisition, debt financing, sale of company assets, or other business transaction in which data could be transferred to third parties as one of our business assets subject to the terms of the Privacy Notice.
Additionally, we may share your Personal Information with third parties when we have your consent to do so, including as indicated in the event registration form when registering for a WFA Team event to which you may specifically opt-in to share your Personal Information with WFA Team event partners. If you choose to share your Personal Information with WFA Team event partners by opting in to do so at event registration, your Personal Information will be subject to applicable business partners’ respective privacy statements. Customers determine their own policies and practices for the sharing and disclosure of Personal Information of its Authorized Users, and WFA Team does not control how they or any other third parties choose to share or disclose Personal Information.
As a company with affiliates and Websites hosted in the US, Personal Information will be processed in the United States when you engage with our Services as a Visitor or Attendee or in the case of Customer Data where our support for the functioning of the Customer-WFA Team instance of the Services may include support provided by WFA Team from the United States. In
cases where this involves a transfer of Personal Information outside of Europe, we will take steps to implement appropriate legal safeguards, for example, implementing standard contractual clauses where appropriate.
Where permitted in our legitimate interest, or subject to your consent, where required by law, WFA Team may contact you with our newsletter or promotions by email. When you receive newsletters or promotional communications from us, you may “opt-out” by following the unsubscribe instructions provided in emails you receive from us or by contacting us directly at the contact information below.
How we protect Personal Information
Personal Information we process is stored on our secure servers. While WFA Team Services are typically accessed via single sign on, where you have been given (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
How long we keep Personal Information
We will retain your Personal Information for as long as your account is active or as needed to provide you Services. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our Agreements.
We may also retain aggregate information for research purposes and to help us develop and improve our Services. You cannot be identified from aggregate information retained or used for these purposes.
Updating Your Personal Information
Depending on from where or how you access our Services (such as a Visitor or Attendee), you may have the right under certain circumstances to:
– Be provided with a copy of your Personal Information held by us;
– Request your data be corrected or erased;
– Request that we restrict the processing of your Personal Information (while we verify or investigate concerns with this information for example);
– Object to further processing of your Personal Information, including the right to opt-out of further marketing (as mentioned in the ‘Choices’ section above) or to withdraw your consent where the processing of your Personal Information is based upon consent; and
– Request that your provided Personal Information be moved to a third party.
– You may email us at firstname.lastname@example.org. We will respond to your request within 30 days, when permitted or required by law. Where you accessing our Services in Europe and your request is not satisfactorily resolved by us, you may approach your local EU data protection authority (see https://commission.europa.eu/law/law-topic/data-protection/data-protection-eu_en or for those in the UK, the data protection authority is the Information Commissioner.
If you are an Authorized User of a Platform Customer, you can view your Personal Information by accessing the profile feature of the Platform. Should you need to modify, remove, or delete the Personal Information you provided, such requests should be directed to the WFA Team Services administrator at your company, where he/she can send an email to email@example.com or contact their WFA Team account manager.
Under our data protection rules, you have rights to access and rectify your personal data, as well as to object to its processing, request erasure, and obtain data portability in certain circumstances. To exercise these rights in connection with your use of this website please use the contact us form on the website.
If you have further queries or complaints related to the processing of your personal data, please contact the Data Protection Officer (firstname.lastname@example.org). If you need further assistance in resolving claims related to personal data protection you can contact the Data Protection Commissioner of Ireland.
The Work From Anywhere Team Limited
Russett House, Ballyclough, Co. Limerick, Ireland