EFFECTIVE DATE: June 1, 2019
PLEASE READ THIS PRIVACY STATEMENT AND NOTICE OF PRIVACY PRACTICES CAREFULLY.
Your privacy and trust are important to us. This statement describes our privacy practices, including
how we collect, handle, store and protect personal information about you in the context of your
interaction with ActionTrac resources, including this website. Covered information includes
Personal Data (which means any employee information relating to an identified or identifiable
natural person), we obtain from and about individuals interacting with ActionTrac and ActionTrac
Center Stage app, Reunion Resort Employee Recognition app and its websites, mobile applications, and any other ActionTrac services. All
Personal Data collected, other than information collected in the employment context, is subject to
this Privacy Statement.
of your personal information for the purposes described below. You further affirm your consent by
submitting content or materials to or through our Services.
We take the privacy of your personal information seriously. If you have any questions or concerns
mailing address listed in Section 16 (Contact Us).
This privacy statement may be revised from time to time, resulting in updates and modifications to
this page. ActionTrac will make the most current version of the Statement accessible by clicking on
- Types of Personal Data Collected
To enable visitors to take advantage of our services, we collect certain types of Information, such as
during registration for a demo, when in full production or when submitting a contact form request
this Information may include:
- Your first and last name
- Company information
- Job title
- Telephone number
- Postal/email addresses
- Billing information
- Log files, information collected by cookies and similar technologies about the pages viewed
- links clicked and other actions taken when accessing our website, which may be considered
- Mobile Phone Number
Sharing and Disclosure of Personal Information
Primarily, we may share or disclose your personal information in the following instances:
- To provide support. For example, if you e-mail us a question, We may use your e-mail address to process your request and respond to your question
- To provide the ActionTrac services to you. ActionTrac product services enable our customers to use their own personal information as disclosed under “Type of data collected.”
- In order to provide a quality service ActionTrac support will have access to personal data
as listed under Types of personal data collected.
- To complete your purchase of the Services. We may ask you for your credit card number
billing address, and other information in connection with completing such purchase, and
We may use such information to fulfill your purchase. We may also provide such
With Whom We Share Personal Data
ActionTrac may share Personal Data we collect with the following categories of third parties in
accordance with law and for the purposes defined below. All such parties shall be bound by legal or
contractual obligations to maintain the privacy of data handled on behalf of ActionTrac.
- Approved subsidiaries who provide defined, approved processing services on behalf of
ActionTrac for the purpose of supporting and providing services to its customers
- Third party service providers contracted to provide defined services on behalf of ActionTrac
for discrete business purposes such as provision of IT related services, event planning, talent
recruiting, and travel services
- Corporate entities when a business transaction occurs such as a merger or acquisition
ActionTrac may disclose Personal Data in special cases when we have a good faith belief that it is
necessary: (a) to conform to legal requirements or to respond to lawful requests by public
authorities, including to meet national security or law enforcement requirements; (b) to protect and
defend our rights or property; (c) to enforce the website Terms and Conditions; or (d) to protect the
interests of our users or others.
- Retention of Data
We will keep your Personal Data as reasonably necessary to fulfill the purposes for which Personal
Data is collected as stated herein; for as long as is necessary for the performance of the contract
between you and us, if any; and to comply with legal and statutory obligations, such as in tax, trade
and corporate laws. When you no longer need your Personal Data, we will destroy, delete or erase
that Personal Data
- Legal Disclosure
We may disclose information about you and your use of the services if we believe that such
disclosure is reasonably necessary to: (i) comply with the law and/or legal process where a formal
request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena,
court order or judicial or administrative proceeding); (ii) protect or defend Our rights and/or property
Policy; (iv) respond to claims that the content(s) of a communication violates the rights of
another; and (v) to meet Our legal and regulatory obligations, including, without limitation, as an
employer and for tax purposes.
Also, circumstances may arise where, for business reasons, We may decide to reorganize, or
divest all or part of Our business through sale, assignment, merger, acquisition, bankruptcy
proceedings, or We may acquire a new business. In these circumstances, personal information
may be shared with the actual or prospective purchasers or assignees, or with the newly acquired
- Information Security
Although we are serious about protecting the security of your Personal Information and have
taken steps to protect your Personal Information from loss, misuse, unauthorized access,
disclosure, or destruction, no security measures are completely secure and we do not and cannot
guarantee the security of your information. If you have reason to believe that your information has
been lost, stolen, or otherwise compromised from our sites, please contact us immediately via
- Sharing for Business Transactions
If ActionTrac is involved in any merger, acquisition, sale of assets, bankruptcy, or insolvency
event, we may sell or transfer some or all of our assets, including some or all of your Personal
Information in connection with such a transaction. We will notify you before your personal
- Sharing for Legal and Compliance Purposes
We may share Personal Information collected through the use of our corporate website to
respond to valid legal processes (e.g., a court order or subpoena). We may also share your
information to comply with applicable laws, to protect the safety of any person, to address fraud,
security, or technical issues, or to enforce this Policy, Terms of Service, and any other terms or
conditions you have agreed to with us.
8.1 Sharing with Third-Party Service Providers
ActionTrac uses third-party service providers to help us provide and improve our corporate
websites and services. We may share the Personal Information you provide to us or that we
collect from you through our corporate website to these third-party service providers. When we do
so, we will only provide the information necessary for the third-party to perform its agreed upon
services and require that they use such information for no other purpose than to provide the
services to us.
Your California Privacy Rights
9.2 Exercising Your Rights
This section applies only to California residents and provides additional details about the
Personal Information we collect about California consumers and the rights afforded to them
under the California Consumer Privacy Act of 2018 (the “CCPA”).
9.1 Your Rights Under the CCPA
If you are a California resident, you have rights in relation to your Personal Information; however,
your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of
Personal Information if the disclosure would create a substantial, articulable, and unreasonable
risk to the security of Personal Information or the security of our systems. Additionally, we will
only be able to act on your requests if we can verify your identity against the Personal Information
we have collected about you. Below are the specific rights provided to you by the CCPA:
- Right to Know. You have the right to request, in writing, (a) the categories of Personal
Information we have collected about you, (b) the business or commercial purposes for the
- Right to Delete. You have the right to request that we delete any Personal Information we
have collected from you or maintain about you, subject to certain exceptions.
- Right to Non-Discrimination. You have the right not to be discriminated against for
exercising any of the rights described in this section. We will not discriminate against you for
exercising any of the rights described in this section.
You may exercise your rights described in this section by sending an e-mail to
firstname.lastname@example.org. To verify your identity, we may request additional information from you,
which we will only use to verify your identity, and for security or fraud-prevention purposes.
California Do Not Track Disclosures
When you visit a website (such as ActionTrac’s website), your browser automatically shares certain
information with that website, such as your IP address and other device information, which may also
be considered Personal Data under applicable laws. Some of this data may also be sent to
third-party content providers (for example: advertisers, website analytic companies, etc.) that provide
content on the website. Such sharing may allow the website and/or content providers to track you
over time and across multiple websites. You may opt out of any of the above-referenced uses
through the Do Not Track functionality in your web browser. Some browsers offer similar settings for
HTML5 local storage, and Flash storage can be managed here. Please note, however, that if you
refuse to accept cookies, you may not be able to access some of the benefits offered on our Sites.
This website is not intended for children under the age of 18. We will not knowingly collect
information from website visitors in this age group. By using the Site, you represent that you are age
13 or over. If you believe that a child may have provided his or her Personal Data to us, please
contact us using the contact information at the end of this Statement. In the event that we become
aware that we have collected Personal Data from a child under the age of 18, we will dispose of that
Personal Data immediately.
International Transfers of Your Personal Data
By using the website or providing Personal Data to ActionTrac, your Personal Data may be
transferred to the United States where ActionTrac is headquartered. If you are not a resident of the
United States, your country’s laws governing data collection and use may differ from those in the
United States. For example, the data protection laws of the United States have not been found by the
European Commission to provide the same level of protection as EU data protection law. Some of
the third parties with whom we share your Personal Data are also located in third countries that do
not provide the same level of protection to your Personal Data. Certain third countries have been
officially recognized by the European Commission as providing an adequate level of protection (list
available here ) Transfers to third parties located in countries outside the European Economic Area
(“EEA”) take place using an acceptable data transfer mechanism, such as the EU-U.S. Privacy Shield
for transfers to self-certified U.S. organizations, the EU Standard Contractual Clauses, Binding
Corporate Rules, approved Codes of Conduct and Certifications or in exceptional circumstances on
the basis of permissible statutory derogations.
Your EU Privacy Rights
If you are visiting the website from the EU or where applicable EU data protection laws so provide,
you have the right to:
Request Access. You have the right to obtain from us a copy of the personal data we hold about you.
Request Correction. You have the right to request the correction of inaccurate Personal Data we hold
about you and to have incomplete data completed.
Objection. You have the right, when we process Personal Data on the grounds of legitimate interests,
to object to the processing of your Personal Data for compelling and legitimate reasons relating to
your particular situation, except in cases where legal provisions expressly provide for that
processing. In addition, you have the right to object at any time where your Personal Data is
processed for direct marketing purposes.
Portability. You may receive your Personal Data that you have provided to us in a structured,
commonly used and machine-readable format and have the right to transmit them to other data
controllers without hindrance. This right only exists if the processing is based on your consent or a
contract and the processing is carried out by automated means.
Restriction. You may request to restrict processing of your Personal Data (i) while we verify your
request – if you have contested the accuracy of the Personal Data about you which we hold; (ii) if the
processing is unlawful and you oppose the erasure of it and request restriction instead; (iii) if we no
longer need it, but you tell us you need it to establish, exercise or defend a legal claim; or (iv) while
we verify your request if you have objected to processing based on public or legitimate interest.
Erasure. You may request to erase your Personal Data if it is no longer necessary for the purposes
for which we have collected it, you have withdrawn your consent and no other legal ground for the
processing exists, you objected and no overriding legitimate grounds for the processing exist, the
processing is unlawful, or erasure is required to comply with a legal obligation.
Right to lodge a complaint. You also have the right to lodge a complaint with a supervisory authority,
in particular in the EU Member State of your residence, or the location where the issue that is the
subject of the complaint occurred.
Right to refuse or withdraw consent. You have the right to withdraw consent at any time when we are
relying on your consent to process personal data. The lawfulness of any processing of your Personal
Data that occurred prior to the withdrawal of your consent will not be affected. Withdrawal of
consent may result in our inability to provide certain products or services, in which case ActionTrac
will notify you after you submit notification of consent withdrawal.
For any questions regarding ActionTrac’s approach to enforcement of EU Privacy rights, please
contact us at email@example.com.
This cookies policy describes the way in which any website (“Site”) operated by ActionTrac stores or
accesses information on the device that you use in order to access the Site.
By using the Site, you are providing your consent to ActionTrac storing and using cookies and web
beacons in accordance with this cookies policy. However, you can adjust the settings on the
browser you use to view the Site to remove or limit the types of cookies that it accepts.
We automatically collect some information about your computer activity when you visit our Sites to
help us customize your user experience. We will collect session data, including the time at which you
visited our Sites, your IP address, geolocation, web browser software, simple device information,
referring website and information collected through cookies, web beacons and other tracking
technologies. We will also collect information about your online activity, such as content viewed,
pages visited, actions taken on pages, features used and keywords searched.
We may send a cookie which may be stored by your browser on your computer’s hard drive. We may
also use that information to recognize your computer when you visit our Site, and to personalize our
Site for you.
Some cookies used on the Site are temporary and remain on your device until you leave the Site, at
which point they are deleted. These are often called session cookies. Session cookies are typically
used on the Site to allow you to carry information across pages of the Site and avoid having to
re-enter information, and to allow you to access stored information whilst you are logged into a user
account on the Site.
Other cookies used on the Site remain on your device once you have left the Site (though how long
will depend on the lifetime of the specific cookie). These are often called persistent cookies.
Persistent cookies are typically used on the Site to help it recognize your device when you return to
it, and to help us improve the structure of the Site by compiling anonymous, aggregated statistics
that allow us to understand how users use the Site.
The technologies we use for this automatic information collection may include:
We use these Web Technologies for the following general purposes:
- Cookies. Cookies are small files placed on the hard drive of your computer. Unless you have
direct your browser to our Sites.
- Flash Cookies. Flash Cookies are local stored objects used by certain features of our Sites to
collect and store information about your preferences and navigation to, from and on our
Sites. Flash cookies are not managed by the same browser settings as used for browser
- Web Beacons. Web Beacons are small electronic files (clear gifs, pixel tags and single-pixel
gifs), which may be used by parts of our Sites to track the number of users who have visited
those pages and other related website statistics (e.g., verification of system and server
- To help us recognize your browser as a previous visitor and save/remember any preferences
registration information so you need not log into our Sites each time you visit.)
- To help us customize your user experience on our Sites and on other websites across the
Internet. (e.g., when you access a web page on our Sites, a cookie is automatically set by us,
our service providers or our partners to recognize your browser as you navigate the Internet
and to present you with information we believe may be of interest.
- To help measure and research the effectiveness of Site features and offerings and
advertisements (e.g., we work with third-party service providers such as Google Analytics to
collect data about your use of the Sites).
You may opt out of any of the above-referenced uses through the Do Not Track functionality in your
web browser. Some browsers offer similar settings for HTML5 local storage, and Flash storage can
be managed here . Please note, however, that if you refuse to accept cookies, you may not be able to
access some of the benefits offered on our Sites.
ActionTrac does not store any specific personal health data as it relates to the company’s
COVID-19 screening questionnaire solutions. Employee answers to the self assessment questions
are not stored and cannot be viewed or accessed. ActionTrac only stores (logs) a”trigger”
indicator that informs a specified user (or users) that an employee answered “Yes” to one or more
of the screening questions.
This trigger could still be considered identifiable health information. As a result ActionTrac is
committed to protecting the privacy of this information as outlined under section six.
- Contact Us
We have taken great measures to ensure that your visit to our website and your interactions with
ActionTrac are satisfying and that your privacy is respected. If you have any questions, comments
or concerns about our privacy practices, please contact us by e-mail us at firstname.lastname@example.org