Privacy policy | Workstream

This Privacy Policy ("Policy") describes our practices regarding the use, disclosure, and protection of Personal Information (as defined below) collected by and on behalf of Workstream Technologies, Inc. ("Workstream," "we," "us," or "our") through our website www.workstream.us , our mobile application, and any other webpage, software, service, feature, product, program and element (including e-mail messages, notifications, and other messages) that links to or references this Policy (collectively, the "Site"), when you register, access, interact with, or use our Site (the "Services").

This Policy applies when Workstream collects, uses, and shares your Personal Information for its own purposes through the Services. For example, this Privacy Statement covers when you:

Visit a Workstream Site that links to this Policy, including when you are directed to a Workstream Site through your interaction with certain job boards, social media sites, QR Codes, or other referral sources;
Interact with the Services as a representative of an organization that has an account with Workstream (e.g. you are our Business Customer (as defined below));
Interact with our Services;
Provide us with feedback about our products or services; or
Interact with Workstream including SMS messages, emails or chatbot communications.

This Policy does not cover how we process personal or financial information on behalf of our business customers and business partners ("Business Customers") during our provision of services to such Business Customers as a service provider. Workstream is not responsible for the privacy or data security practices of our Business Customers, which may differ from those set forth in this Policy. Information we collect, receive, or process on behalf of our Business Customers is governed by our contractual agreements with them and we only process such information in accordance with our Business Customer's instructions. You may interact with Workstream as a prospective, current or former employee of an organization that uses a Workstream product or service, including for its hiring, onboarding, payroll, human resources or other administrative services.

If you have questions or concerns about the Personal Information your organization holds in Workstream about you, please direct your request to that organization and review such Business Customer's privacy policy, terms of use, employment policies and procedures or other applicable notices. Where Workstream processes your Personal Information in the capacity of a service provider, and you have questions or other requests regarding your Personal Information, we will provide you with the contact information of the Business Customer on whose behalf we collected and processed the Personal Information, so you can contact them directly.

This Policy does not apply to employees of Workstream.

This Policy incorporates our Term of Use ("Terms") found here.

STATE SUPPLEMENTAL PRIVACY NOTICES:

Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia Residents: If you are a resident of one of the states listed here, please see the State Supplemental Privacy Notice below for additional rights and terms that may apply to you.

California Residents: If you are a California resident, please see the California Privacy Rights Notice below for additional rights and terms that may apply to you.

MODIFICATIONS TO THIS POLICY.

We may modify this Policy at any time. Material changes will be posted on the Site or otherwise communicated to you. We encourage you to periodically review this Policy for any changes.

WHAT IS PERSONAL INFORMATION?

The definition of "Personal Information" under applicable law (or similar terms like "personal data" or "personally identifiable information") varies based on where you live, but generally means information that identifies or can be used to identify an individual person.

1. Categories of Personal Information We Collect

We may collect Personal Information: (a) that you provide directly to us, (b) automatically through your use of our Site and Services (e.g., via cookies), and (c) from third-party sources.

WE COLLECT PERSONAL INFORMATION YOU PROVIDE TO US.

You may visit our Site without providing us with your Personal Information. However, if you choose to use certain functions on the Site or our Services, we may collect the following types of Personal Information:

Identifiers and Contact Information: such as a real name, date of birth, gender, email address, zip code, postal address (including street address, city, and state), phone number, online identifiers and usernames, social media profile, profile photo, internet protocol address, and other similar identifiers;
Employment Information: your resume and other materials shared when you apply to a job through Workstream, your activity in relation to our Services, and other information related to your job title, contact information, information on your current position and employment history, job status, and location;
Communication Data: interactions with or through Workstream, including through third-party messaging services, apps, and websites or by telephone, including calls and SMS texts and also emails and notifications;
Internet Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement; and
Technical and Device Data: Information about your device, system, and application software, peripherals and other data related to your interactions with our Site.

More about the Personal Information We May Collect.

Accounts. We collect any information you provide when creating and using an account with us, which may be linked to your activity in our Service when you are signed-in to that account.

Feedback. When you provide comments or feedback about our Site or Services or the content on our Site or Services, we will not treat that feedback as confidential, and we may use that feedback for any purpose contemplated by this Policy. Feedback will be used without attribution or compensation to you.

Job Application and Employment Information. When you submit job application materials or employment information for an employment opportunity or communicate with a Business Customer through the Service or in connection to any other Service offered by us, your information will be submitted directly to us. We will use and disclose such information to the Business Customers with whom we have contracted or with your consent.

Business Contracts with Us. When a business contracts directly with us for our Services, we may collect Personal Information pursuant to terms of that relationship. The processing of any information provided in such a business context is governed by the agreements between that business and Workstream.

PERSONAL INFORMATION WE COLLECT AUTOMATICALLY.

When you use our Site or Services, we may automatically collect certain information from you using tracking technologies such as cookies, web beacons and pixel tags. A cookie is a small text file that our Site saves onto your computer or device that provides us information about your online activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser. Web beacons or pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

What is the purpose of using cookies?

We use cookies to make our Site function properly, provide personalized experiences, tailor our interactions with you, provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site, and help us improve our services.

What type of information do cookies collect?

The cookies on our Site and Services may collect information such as the internet protocol addresses assigned to the computers and other devices you use, your internet service provider, the device ID number, approximate geographic location, the Site or Services pages visited or clicked on, the date and time you visited the Site or Services, and the amount of time spent on the Site or Services, your operating system, browser type, search requests, and other similar information, the websites you access before and after visiting the Site or Services, and data related to how and when you use the Site or Services.

How long do cookies last?

A cookie can either be a "session" cookie or a "persistent" cookie. Session cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent cookie, the persistent cookie is renewed and that cookie will remain active until its predetermined expiration date. You can manually delete persistent cookies through your browser settings.

How do you manage cookies or opt-out?

Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable cookies. You cannot disable all cookies, such as cookies that are essential to the functioning of the Site.

"Do-Not-Track" Requirement.

We currently do not respond to "do not track" requests.

Google Analytics.

Google Analytics are used to collect and process information about your use of the Site, including Business Customer's employment postings on our Site. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site and provides reports to our Business Customers so they can better understand and measure how users interact with our Business Customers' employment postings on our site. To learn more about how Google uses data, visit Google's Privacy Policy and Google's page on "How Google uses data when you use our partners' sites or apps." You may download the Google Analytics Opt-out Browser Add-on for each web browser you use. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

Online Behavioral Advertising.

We use third-party vendors to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including this Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites and may be sent to you via email.

To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.

Google Ads.

We use Google Ads to serve ads across various websites. Google uses Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google's collection or use of such data, visit Google's Safety Center and Google's Ad Settings and follow Google's personalized ad opt-out instructions. Opting out will not affect your use of the Site.

Device Data.

When you access our Service by or through a mobile device, we may receive or collect and store unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers ("IDFA"), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings and your explicit consent, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.

CONSENT MANAGEMENT

For certain types of Personal Information or specific uses, we may seek your explicit consent before collecting or using such information. This includes the use of your information for marketing purposes outside of the services provided to our Business Customers.

You have the right to withdraw your consent at any time by:

Adjusting your device settings
Updating your preferences in your account settings
Contacting us at privacy@workstream.us

Please note that withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.

2. Purpose for Collecting Personal Information

In addition to the uses described elsewhere in this Policy, we may collect, use and disclose any of the Personal Information described in Section 1 above for the following purposes:

As Stated or Agreed to at the Point of Collection.

We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you such as to offer you our Services, including sending your application information in response to a job posting or specific employment opportunity or your other communications to a Business Customer, communicating with you regarding your applications and about other similar position(s) for which you may be interested at the applicable Business Customer.

Feedback. When you provide comments or feedback about our Site (“Feedback”), we will not treat that Feedback as confidential, and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.

Marketing Communications. If we receive your contact information, including when you request to receive information about our Services, we may use this information to send you information about other programs that we think may be of interest to you, as well as promotional and marketing communications. To opt-out of marketing communications, please contact us as set forth below.

Managing Our Job Application Process with Us.

We may use Personal Information for the purposing of reviewing, assess, recruiting, and managing your job applications, including:

scheduling and conducting interviews;
identifying your potential candidacy;
providing your job application information to various Business Customers;
reviewing, assessing and verifying information you provided, and otherwise evaluating your qualifications, suitability and relevant characteristics;
communicating with you regarding your applications and about other position(s) for which you may be interested at one or more Business Customers;
maintaining your Personal Information for future consideration; and
satisfying our legal and regulatory obligations.

Administration.

We use Personal Information for administrative purposes, such as to inform our business strategies and to understand demographics and user preferences for our Services.

Site Management.

We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.

Business Analytics.

We use Personal Information for business analytics including consumer and operations research, to assess the effectiveness of our services, product development, and to analyze market trends and (future) customer demand.

Communications.

We may use Personal Information to notify you of new features of our Service, to notify you of changes to our Terms or this Policy, to get your feedback regarding our Services and potential Services and for other similar communications.

Mobile Numbers & SMS Communications

Any information collected for the purpose of SMS communication will be handled in accordance with our Privacy Policy. We will not share your mobile phone number with third parties for marketing or promotional purposes without your consent. Information sharing to subcontractors in support services, such as customer service is permitted. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

OPT IN CONSENT: by submitting your phone number, you are authorizing to send you text messages and notifications. Message/data rates apply. Reply STOP to unsubscribe to a message sent from us.

To Protect Our Rights.

We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests and regulatory obligations.

3. Disclosure of Personal Information.

We may disclose Personal Information with the following categories of parties, in compliance with applicable laws:

Workstream Customers.

We may disclose Personal Information with our business Customers (as defined above) with your consent.

Employees and Affiliates.

We may disclose Personal Information with our employees and affiliates who have a need to know the information for our business purposes.

Third Parties, Vendors, and Contractors.

In addition to the vendors referenced elsewhere in this Policy, we may disclose your Personal Information to third parties, service providers, and contractors who process your Personal Information on our behalf for the purpose of carrying out administrative, Service features, billing or technological support functions and otherwise to provide you the communications and Services contemplated in this Policy. This may include AI technology providers and voice processing services that help us deliver and improve our AI phone chat tools.

Change in Ownership.

We may disclose Personal Information in connection with a sale, merger, reorganization, or other similar transaction, or in the event of a bankruptcy, receivership or a similar transaction (and with respect to due diligence related to the foregoing).

Advisors.

We may disclose Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to us.

Legal.

Finally, we may disclose your Personal Information to legal or governmental authorities (a) if we believe in good faith we are legally required to disclose that Personal Information, (b) if we are advised to disclose Personal Information by our legal counsel, or (c) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with our legal rights or any other party's legal rights.

Other Users.

By submitting a copyright infringement notice, counter-notice or other similar notification, you consent to having that communication forwarded to any person or entity to whom the notice or counter-notice relates to, in order to facilitate a prompt resolution of the copyright infringement claim. Copyright infringement notices and/or counter-notices from you will be treated in accordance with our Copyright Policy found here.

Other.

We may disclose Personal Information with third parties when explicitly requested by or consented to by you.

SOCIAL MEDIA

We are active on social media, such as Facebook, Facebook Messenger, Google, Twitter, Instagram and LinkedIn ("Social Media"). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site, Services, and our Social Media pages any comments or content that you post on Social Media pages. Your use of Social Media platforms are governed by the applicable privacy policies and terms of the providers that own and operate those platforms and not by this Policy. We encourage you to review those policies and terms.

The Site and Services may allow you to connect and share data with Social Media platforms, including job postings in which case we may also collect information available through that third party service. Please always check your permissions on third party sites before connecting them to our Service. These features may require us to use cookies, plug-ins, and application programming interfaces provided by such Social Media platforms to facilitate those communications and features. The Site and Services may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Site and Services.

CHILDREN'S PERSONAL INFORMATION.

The Site and Services are not directed at children under 13 years old. We do not knowingly collect, use, or disclose Personal Information from children under 13. If your child has provided us with their Personal Information, please contact us and we will make commercially reasonable attempts to delete such Personal Information.

DATA SECURITY

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

NO DATA TRANSMISSION OVER THE INTERNET OR BETWEEN DEVICES CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.

ACCESS FROM OUTSIDE THE UNITED STATES

If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States and in any other country in which Workstream or its subsidiaries, affiliates or service providers maintain facilities. Certain governmental authorities may not consider the level of protection of Personal Information in the United States or in such other jurisdictions to be equivalent to that required in other jurisdictions.

THIRD-PARTY WEBSITES

The Site and Services may contain links to third-party websites that we do operate or control. We do not assume responsibility for the activities of such third parties, do not control these websites and are not responsible for their content, security, or privacy practices. We urge you to review the privacy policy posted on each website you visit prior to using the site or providing Personal Information.

RETENTION

We will keep Personal Information for the period necessary to fulfill the purposes described in this Policy, unless a longer retention period is permitted or required by law. We take reasonable steps to delete Personal Information we collect when: (i) we have a legal obligation to do so; (ii) we no longer have a purpose for retaining the information; or (iii) if you ask us to delete you Personal Information, unless we determine that doing so would violate our existing legal, regulatory, dispute resolution, contractual, or similar obligations.

We do not control Personal Information once it has been shared with our Business Customer. You may contact the Business Customer directly to learn more about how the Business Customer uses and stores your Personal Information.

AGGREGATE OR DE-IDENTIFIED INFORMATION

We may process Personal Information to create aggregated, de-identified or anonymized data from the Personal Information we collect so that the information cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual. Any such aggregated, de-identified, or anonymized data is no longer subject to this privacy policy. We may collect, use, disclose, share, create, transfer, and otherwise process de-identified and aggregated information that we receive or create for any purposes in our sole discretion, in compliance with applicable laws. Once we have de-identified data, we will not attempt to re-identify the data and we will contractually obligate any recipients of the de-identified data to do the same.

CONTACT US

If you have any questions or concerns about this Policy or our data practices, please contact us at:

Workstream Technologies, Inc.

521 7th St San Francisco,

CA 94103 United States

Email: privacy@workstream.us

Phone: 1-888-983-0030

SUPPLEMENTAL PRIVACY NOTICES

NOTICE TO CALIFORNIA CONSUMERS

This section applies only to California residents. It describes how we collect, use, and share Personal Information of California residents in our capacity as a "business" under the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA") and their rights with respect to that Personal Information.

For purposes of this section, "Personal Information" has the meaning given in the CCPA This section does not apply to information we collect from you in our capacity as a "service provider" on behalf of our Business Customers.

Categories of Personal Information We Collect: In the last 12 months, we have collected the following categories of Personal Information:

Identifiers consisting of: real name, alias, postal address, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, or other similar identifiers.
Consumer information under Cal. Civ. Code 1798.80(e) consisting of: bank account number, credit card number, debit card number, signature, physical characteristics or description, telephone number, state identification number, and any other financial information.
Internet Activity consisting of: browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
Geolocation Data: approximate GPS geolocation, IP address, and other data from sensors on or around your device, depending in part on your device and account.
Employment Information: Professional or employment-related information.

Categories of Personal Information Collected. The categories of sources from which Personal Information is collected is described in Section 1 above.

Purposes for collecting Personal Information. The purposes for collecting Personal Information are described in Section 2 above.

Categories of Personal Information Sold or Shared. Additionally, the CCPA defines "sale" as disclosing or making available to a third-party Personal Information in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available Personal Information to a third party for purposes of cross-contextual behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may disclose the following categories of Personal Information: identifiers, profiles and inferences, and internet or other electric network activity information to third party advertising networks, data analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share Sensitive Personal Information, nor do we sell or share any Personal Information about individuals who we know are under sixteen (16) years old.

Categories of Personal Information Disclosed for a Business Purpose. In the last 12 months we disclosed all of the categories of Personal Information described in Section 1 for our or one of our service provider’s operational purposes.

Sensitive Personal Information. We have not used or disclosed Sensitive Personal Information for any reason other than the reasons for which it was provided to us. We do not use Sensitive Personal Information to infer characteristics about individuals.

YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you have the following rights:

Right to Know or Portability: You have the right to request that we disclose certain information to you regarding our collection and use of your California Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we have collected about you
- The categories of sources from which the Personal Information is collected
- Our business or commercial purpose for collecting, selling, or sharing Personal Information
- The categories of third parties with whom we share Personal Information
- The specific pieces of Personal Information we have collected about you
Right to Delete: You have the right to request that we delete any Personal Information about you that we have collected from you, subject to certain exceptions.
Right to Correct: You have the right to request that we correct inaccurate Personal Information that we maintain about you, subject to certain restrictions.
Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to limit our use and disclosure of your Sensitive Personal Information to only what is necessary to perform the services or provide the goods.
Right to Opt-Out: You have the right to opt-out of the sale or sharing of your Personal Information. Workstream does not sell or share your Personal Information as defined by the CCPA.
Right to Non-Discrimination: You have the right not to be discriminated against for exercising any of these rights.

How to Exercise Your California Privacy Rights

To exercise the privacy rights described above, please submit a request by:

Emailing us at: privacy@workstream.us
Calling us at: 1-888-983-0030

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.

Verification Process

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. In order to verify your request, we may require additional information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request. This information may vary depending on the Personal Information we already have. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why. We may reject or deny your request as permitted or as required by law.

If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to be your agent and to make the specific request submitted, unless the agent is subject to a Power of Attorney under California probate laws. If the agent is a Power of Attorney under California probate laws, we may require evidence of that status.

Response Timing and Format

We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please contact us at privacy@workstream.us.

We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

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 usable 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.

YOUR STATE PRIVACY RIGHTS

If you are a resident of Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia, this State Supplemental Privacy Notice explains how to exercise consumer privacy rights you may have under the laws of your state (“State Privacy Laws”).

This State Supplemental Notice is only intended to supplement the Policy. Please refer above to find detailed information about Categories of Personal Information We Collect, Why We Collect Personal Information, and How We May Disclose Personal Information along with additional information about our privacy practices.

Right to Access: You have the right to confirm whether we are processing your Personal Information and to access such information. Depending on your state of residence, you may also have the right to receive a list of specific third parties with whom we disclose Personal Data.
Right to Correction: You have the right to correct inaccuracies in your Personal Information.
Right to Deletion: You have the right to delete certain Personal Information that we have collected about you.
Right to Data Portability: You have the right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format.
Right to Opt-Out: You have the right to opt out of:
- The sale of your Personal Information
- The processing of your Personal Information for targeted advertising
- The use of your Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects
Right to Appeal: You have the right to appeal our decision regarding your request. Upon receipt of your appeal, we shall respond in writing of any action taken or not taken within 60 days after receipt.

To submit a request to exercise any of the rights above, you may submit your request to us by:

Emailing us at: privacy@workstream.us
Calling us at: 1-888-983-0030

You must provide sufficient information to allow us to reasonably verify you are the data subject to whom the Personal Information relates, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

When we receive your rights request (i) we will acknowledge receipt of your request; (ii) we will try to match the information you provide in making the request with information we already maintain about you; (iii) in order to verify your identity, we may ask you to provide additional information, which may include Personal Information; and (iv) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, and the likelihood of fraud.

We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why. In addition, we may decline to comply with your request as permitted by the applicable State Privacy Laws. We may charge a fee as permitted by the applicable State Privacy Laws, such as to process or respond to your request if it is excessive, repetitive, manifestly unfounded, or if we believe the request is fraudulent or submitted for purposes other than exercising applicable privacy rights.

Some State Privacy Laws permit the submission of consumer requests by an authorized agent. If we receive a request from an authorized agent, we will need to verify and authenticate your identity as the data subject, the agent’s identity, and the agent’s authority to act on your behalf. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf or if applicable State Privacy Laws do not permit requests by anyone other than you.

Furthermore, a parent or legal guardian may make a request on behalf of their dependent or non-adult child. We may deny a request if you are unable to prove that you are the custodial parent or legal guardian.

If we reject or deny your request, you may appeal our decision within 30 days of receiving our denial by responding directly to the communication denying your request or by submitting your appeal to privacy@workstream.us.

YOUR PRIVACY RIGHTS IN CANADA

This section applies to residents of Canada whose Personal Information we collect.

Cross-Border Transfers. Your Personal Information may be transferred to, stored, and processed in the United States and other countries where Workstream or its service providers maintain facilities. These countries may have different data protection laws than Canada. By using our Services or providing us with your Personal Information, you consent to such transfers, storage, and processing.

Your Rights Under PIPEDA: Under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws, Canadian residents have the right to:

Access: Request access to your Personal Information in our possession or control.
Correction: Request correction of your Personal Information if it is inaccurate or incomplete.
Withdrawal of Consent: Withdraw your consent to our collection, use, or disclosure of your Personal Information, subject to legal or contractual restrictions.

Accountability: We are responsible for Personal Information in our possession or control, including information that we transfer to third parties for processing. We use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

To Exercise Your Rights: To exercise your privacy rights under Canadian law, please contact us using the methods described in the "CONTACT US" section above. We will respond to your request within 30 days or as required by applicable law.

Workstream Privacy Policy