Effective: January 1, 2020
This Privacy Notice explains how Motus Operations, LLC, via its subsidiary Runzheimer International LLC (“Runzheimer” or “we”) collects, uses, shares, and handles information about User of the relocation portal, and other relocation services. For example, Users include employees of Clients (defined below) assigned as account administrators who use the Runzheimer Solution to obtain relocation data pertinent to their employer’s business. By visiting Runzheimer.com, or using any Service, Users accept the practices described in this Privacy Notice and consents to the collection, use and disclosure of information described herein.
Runzheimer collects Users’ information on behalf of Users’ employers. Runzheimer has a contractual relationship with such employers either directly, or via a Relocation Management Company (collectively, “Clients”). Users may be direct employees or independent contractors of Clients. Users also may be direct employees or independent contractors of Clients’ Permitted Affiliates, as defined in the Runzheimer Client Agreement.
This Privacy Notice does not limit collection, use, sharing, or handling by Runzheimer of aggregated, de-identified, or anonymized information, provided that the information cannot be associated with an individual.
If you have any questions or concerns about this Privacy Notice, e-mail us at firstname.lastname@example.org.
INFORMATION WE COLLECT
Runzheimer may collect User information from Users and Clients in order to administer and provide Services to Clients and Users and for the other purposes identified in this Privacy Notice. Information that may be collected includes:
- Email address
- Telephone number
- Home and office address
- Employer name
- Website log and user agent data such as Internet Protocol (“IP”) address, browser type, metadata, and the date and time that you accessed Services
- Device type and operating system information
- Information collected via cookies and web beacons (described below),
- Simple web page actions
- Any other information that Users or Clients choose to communicate to Runzheimer (such as sending information to Runzheimer via e-mail, app, or a Web form).
The Services are not directed to children under the age of 13. Runzheimer does not knowingly collect or store personal information about children under the age of 13.
If a User would like to review or request changes to his or her information that is collected through a Service (subject to certain exceptions prescribed by law), the User may email email@example.com.
HOW WE USE THE INFORMATION
We use the User information that we collect to administer and provide our services to Clients and Users. We may use User information for the following purposes:
- Maintaining, providing, repairing, personalizing, understanding, and improving the Services, including but not limited to Runzheimer’s relocation, compensation, and travel management services;
- For the purpose for which the information was submitted;
- Processing transactions with Clients and Users, such as billing and processing account information;
- Communicating with Users and Clients about the Services and affiliated third party services, via methods such as e-mail notifications;
- Protecting the rights of Runzheimer and others;
- Responding to the inquiries of Clients and Users;
- Complying with IRS (CRA in Canada) guidelines; and
- For any other purpose to which you consent at the time that your information is collected.
If Runzheimer collects User information on behalf of a Client, it may share any of that User information with that Client. Additionally, Runzheimer affiliates may share User information to deliver and market Services.
Additionally, under the following circumstances, Runzheimer may provide third parties with the information that it has collected from a User, provided that the sharing is conducted for one of the following purposes:
- To obtain services from Runzheimer third-party service providers. Examples of such third-party services include technical support and analytics.
- To comply with legal requirements and respond to lawful court orders and other valid legal process;
- To protect the rights, property, or safety of Runzheimer or others, or to assist in the investigation of fraud or any other unlawful activity;
- As part of a merger, partial or complete acquisition, bankruptcy, asset sale, financing, consolidation, restructuring, liquidation, or similar corporate transaction. Runzheimer may share information with any of our parent companies, subsidiaries, joint ventures, or companies under common control with us. In the event of a corporate transaction that would result in the transfer of User information, Runzheimer would inform Users via their most recent e-mail address on record with Runzheimer and a prominent notice on the Runzheimer.com website;
- To transfer any aggregate or anonymized information, provided that no individual could be identified by the information;
- Under any other circumstance to which the User consents after being notified.
COOKIES, WEB BEACONS, AND DO-NOT-TRACK
Web beacons are transparent graphic images placed in emails or web pages to record the simple actions of users. Web beacons collect only limited information, such as time and date of a page being viewed, and a description of the page on which the web beacon resides (the URL). Runzheimer uses web beacons to support analytical programs like Google Analytics and New Relic (our SLA monitoring system).
As described in this Privacy Notice, other parties may collect a User’s personally identifiable information about an individual User’s online activities over time and across different Web sites when the User uses the Services. Runzheimer does not respond to Do-Not-Track signals.
You can visit the AdRoll cookie opt-out page and Google Ads personalization page to opt-out of certain targeted advertising. You can also opt-out of targeted advertising by modifying your browser settings or by using a browser plug-in. For more information about targeted advertising and your choices, visit AdChoices.
Although it is impossible to absolutely guarantee the security of personal information, we take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal information within our custody or control. These include security measures for and internal reviews of our data collection, storage, and processing practices. We also implement physical security measures to guard against unauthorized access to systems where we store personal data.
We restrict access to User information to Runzheimer employees, contractors, and agents who need to know that information in order to operate, develop, or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
Runzheimer is headquartered in the United States and, regardless of where you use our Services or otherwise provide information to us, your information may be transferred to, maintained, and processed by Runzheimer and our service providers in the United States or other jurisdictions in which we or they operate. Please note that privacy laws, regulations, and standards in the jurisdictions in which your information may be maintained and processed may not be equivalent to the laws in your country of residence and such information may be subject to lawful access by U.S. or other foreign courts, law enforcement, and governmental authorities.
YOUR CALIFORNIA PRIVACY RIGHTS
On January 1, 2020, the California Consumer Privacy Act (CCPA) went into effect. The law requires companies to notify California residents about how their data is collected, used, and shared, and in some cases gives them rights to access and delete that data. This section provides Runzheimer’s disclosures as required by the CCPA. These disclosures supplement and incorporate the statements in the other portions of the Privacy Notice. This section applies to all visitors, users, and others who reside in the State of California.
Information We May Collect
Runzheimer collects User information from Users and Clients in order to administer and provide Runzheimer Services to Runzheimer Clients and Users and for the other purposes identified in this Privacy Notice. We may collect the following categories of information, as defined in the CCPA. The examples listed are only illustrative of potential types of data within each category, and Runzheimer does not necessarily collect that data about every individual.
Sources of California Personal Information
We obtain the above categories of personal information from the following categories of sources:
- Directly from you: For instance, you may provide us with information when signing up for an account
- Indirectly from you: For example, we may observe your interactions on our website
- From third parties: For example, your employer may provide us with information related to the services that we provide.
- From publicly available information
Use of California Personal Information
We may use any of the above categories of collected User information to provide services requested from Users or Clients, maintain and improve our services, communicate with Users and Clients about Runzheimer Services and affiliated third-party services, market Runzheimer services, prevent potentially illegal activities, protect the rights and property of Runzheimer and third parties, respond to inquiries of Runzheimer Clients and Users, and for any other purpose to which the User has consented. Our use and disclosure of California Personal Information is more fully described above, in the section entitled “How We Use This Information”.
Sharing California Personal Information
We may disclose your personal information to your employer or to another third party, as more fully described in the section above entitled “Sharing Information). The vast majority of data that Runzheimer collects and discloses to its clients is in its capacity as a service provider, as defined by CCPA. Accordingly, Runzheimer does not “sell” CCPA-covered personal information.
In the past 12 months, Runzheimer has disclosed the following categories of personal information for a business purpose:
- Categories of personal information described in Cal. Civ. Code 1798.80(e)
- Commercial Information
- Internet or other electronic network activity information
In the past 12 months Runzheimer has disclosed personal information to the following categories of third parties:
- Clients (i.e., the users’ employers)
- Service providers
Your rights under the CCPA
The vast majority of the personal information that Runzheimer collects is related to employees, as part of a service that we provide via their employers. Most of the rights provided under the CCPA do not currently apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. The CCPA also currently exempts personal information reflecting a written or verbal business-to-business communication from many of its requirements.
Moreover, Runzheimer typically acts as a service provider to its Clients, which are typically employers. The Clients solely determine the purposes and means of processing Clients’ personal information. To the extent that Runzheimer collects or processes CCPA-covered personal information in its capacity as a service provider, requests for access to CCPA-covered data and deletion must be directed to the Runzheimer Client. For instance, if you want to access or delete data collected via Runzheimer, you must contact your employer, which will then work with Runzheimer to process your request.
In the rare instance that the CCPA rights apply to the personal information and Runzheimer does not collect or process data in its capacity as a service provider, you have the following rights:
- Access to Personal Information Collected or Sold and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Your Rights” section), we will disclose to you:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting that personal information;
- The categories of third parties with whom we share that personal information;
- The specific pieces of personal information we collected about you (also called a data portability request;
- If we disclosed your personal information for a business purpose, a separate list disclosing disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Deletion of Personal Information: You have the right to request deletion of personal information. If you wish to do so, please contact us at any method listed below. The right to deletion is subject to certain exceptions, such as if we need the personal information to provide Services or comply with legal obligation.
- No Discrimination: You will not be subject to discrimination for exercising any of your privacy rights.
To exercise any applicable access, data portability, and deletion rights, please submit a verifiable consumer request by: sending an email to firstname.lastname@example.org, calling toll-free +1 (866) 618-5646, or sending mail to Runzheimer International LLC, a subsidiary of Motus Operations, LLC, Two Financial Center, 60 South Street, Boston, MA 02111.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- Your name
- Additional information depending upon the type of request and the sensitivity of the information.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You may designate an authorized agent to make a request under the CCPA on your behalf.
The California Shine the Light Law, Cal. Civ. Code Section 1798.83, requires companies to disclose certain information about information shared with third parties that is used for the third parties’ direct marketing purposes. These disclosure requirements only apply if Runzheimer were to share personal information with third parties for the third parties to market their own services and products directly to consumers. If you are a California resident, you may request information about the disclosure of your personal information to third parties for the third parties’ direct marketing purposes by emailing email@example.com, calling +1 (866) 618-5646, or sending mail to Runzheimer International LLC, a subsidiary of Motus Operations, LLC, Two Financial Center, 60 South Street, Boston, MA 02111.
If you have any questions about this Privacy Notice or our privacy practices, please contact us at firstname.lastname@example.org or write to us at:
Runzheimer International LLC, a subsidiary of Motus Operations, LLC
Two Financial Center
60 South Street, Boston, MA 02111
Phone: +1 (866) 618-5646