BrightJump Online Privacy Statement
Effective Date: June 18, 2020
Last Updated: March 5, 2021
This Privacy Statement explains how ADP (“Company” or “our” or “we”) uses and discloses personal data that (i) we collect from individuals who visit our websites and associated sub-domains located at http://BrightJump.adp.com (the “Site”) and otherwise engage with us in business activities, or (ii) we receive from our Client (your employer) as a data processor.
This Privacy Statement incorporates ADP’s Binding Corporate Rules (“BCR”) Privacy Code for Business Data (the “Business Code”), which includes information about how ADP processes and protects data of our business contacts/professionals and consumers. For more information on Business Code, or our Privacy Program, please click any of the overviews located here: https://www.adp.com/privacy.aspx . If you have additional questions about privacy or this Privacy Statement, please contact our Privacy Team at firstname.lastname@example.org .
1. Types of Personal Data
Personal data is any information that can be used to identify, locate, or contact you. Some examples of personal data include your name, mailing address, telephone numbers, email address, username and password, geographic location, user profile information, or other information about how you use the Site.
Personal data also includes other information that may be associated with your personal data.
2. How ADP Collects Personal Data & Categories of Personal Data Collected
We collect Personal Data directly from you as a data controller. We will ask you for Personal Data when you interact with us, such as registering on our Site, signing up to receive job alerts, a newsletter or marketing communications, product or services.
ADP, when acting as a data controller, collects the following categories of Personal Data directly from you: first name, last name, email address, mailing address, phone number username and password, geographic location (city or area), education, employment, skills and qualifications history, resume and IP address.
3. How ADP Uses Personal Data
ADP uses your personal data for the following business purposes:
(a) Business purposes for processing personal data pertaining to business contacts/professionals or consumers. Personal data pertaining to business contacts/professionals or consumers with whom ADP has a business relationship may be processed as needed:
(1) To send communications related to providing services (such as requests for information, responses to requests for information, confirmations and service updates);
(2) For account management, dispute resolution purposes and for consolidated management and reporting;
(3) To assure quality control and to enforce our standards and policies;
(4) For risk management and mitigation, including for audit and insurance functions, and as needed to license and protect intellectual property and other assets;
(5) For security management, including monitoring individuals with access to the Site, application, systems, or facilities, investigation of threats, and as needed for any data security breach notification; and
(6) To anonymize or de-identify the personal data.
(b) Business Purposes for processing personal data pertaining to consumers and other individuals. Personal data pertaining to consumers and other individuals may be processed as needed:
(1) To provide the information, product, or service requested by the individual, and as would be reasonably expected by the individual given the context in which the personal data was collected, and the information provided in the applicable privacy statement given to the individual (such as for personalization, remembering preferences, or respecting individual rights);
(2) For due diligence, including verifying the identity of the individual, as well as the eligibility of the individual to receive information, products, or services (such as verifying age, employment, or account status);
(3) To send transactional communications (such as requests for information, responses to requests for information, orders, confirmations, training materials, and service updates);
(4) To manage an individual’s account, such as for customer service, finance, and dispute resolution purposes;
(5) For risk management and mitigation, including for audit and insurance functions, and as needed to license and protect intellectual property and other assets;
(6) For security management, including monitoring individuals with access to the Site, application, systems, or facilities, investigation of threats, and as needed for any data security breach notification;
(7) To anonymize or de-identify the personal data; and
(8) For purposes of providing coaching, professional development, performance reviews, and employee insights, and tracking.
(c) Business-necessary processing activities. ADP may also process personal data as needed (i) to protect the privacy and security of the personal data it maintains, such as in connection with advanced security initiatives and threat detection; (ii) for treasury operations and money movement activities; (iii) for compliance functions, including screening Individuals against sanction lists in connection with anti-money laundering programs; (iv) for business structuring activities, including mergers, acquisitions, and divestitures; and (v) business activities, management reporting, and analysis.
(d) Development and improvement of products and/or services. ADP may process personal data to develop and improve ADP’s products and/or services, and for research, development, analytics, and business intelligence.
(e) Relationship management and marketing. ADP may also process personal data for relationship management and marketing. This purpose includes sending marketing and promotional communications to individuals who have not objected to receiving such messages as may be appropriate given the nature of the relationship, such as product and service marketing, investor communications, Client communications (e.g., HR compliance alerts, product updates, and training opportunities and invitations to ADP events), customer satisfaction surveys, supplier communications (e.g., requests for proposals), corporate communications, and ADP news.
ADP uses your personal data for secondary purposes such as:
- Disaster recovery and business continuity, including transferring the information to an archive
- Internal audits or investigations
- Implementation or verification of business controls
- Statistical, historical, or scientific research
- Dispute resolution
- Legal or business counseling
- Compliance with laws and company policies
- Insurance purposes
4. Why and How Personal Data is Disclosed by ADP
ADP does not provide your personal data to third parties outside of ADP Group Companies for their own marketing purposes. We limit sharing of your personal data:
- To ADP Group Companies, which use your personal data for the purposes listed in this Privacy Statement.
- To our service providers, who are bound by law or contract to protect your personal data and only use your personal data in accordance with our instructions.
- To enforce our rights, protect our property, or protect the rights, property, or safety of others; in connection with the sale, assignment, or other transfer of ADP’s business or assets, or as needed to support external auditing, compliance and corporate governance functions. We will also disclose personal data when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.
- As instructed, permitted or needed to provide the services that you have requested.
Please note that we may also use and disclose information about you that is not personally identifiable. For example, we may publish reports that contain aggregated, anonymized, and/or statistical data about our consumers. These reports do not contain information that would enable the recipient to contact, locate, or identify you. These reports also do not contain identifiable company information.
5. Cookies and Other Data Collection Technologies
When you visit our Site or receive digital communications from us, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs, and web beacons. For example, when you visit our Site, we place cookies on your device. Cookies are small text files that websites send to your computer or other internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available. Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and/or web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.
We collect many different types of information from cookies and other technologies. For example, we collect information from the device you use to access our Site, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the Internet Protocol (“IP”) address assigned to the device you use to connect to the Internet. An IP address is a unique number that devices use to identify and communicate with each other on the internet. We may also collect information about the website you were visiting before you came to the Site and the website you visit after you leave our Site.
In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without reference to personal data. For example, we use information we collect about website users to optimize our Site and to understand website traffic patterns. In some cases, we do associate the information we collect using cookies and other technology with your personal data. This Privacy Statement applies to the information when we associate it with your personal data.
Although our Site currently does not have a mechanism to recognize the various web browser Do Not Track signals, we do offer Individuals choices to manage their preferences that are provided in the previous sections above. The Site does not collect Personal Information about an individual consumer’s online activities over time and across different websites when a consumer uses the Site. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org . ADP uses Google Analytics as a third party vendor. For information on how Google Analytics uses data, please visit “How Google uses data when you use our partners sites or apps”, located at http://bit.ly/2jXZ13Y .
7. Communication Preferences
You may limit the information you provide to ADP. You may also limit the communications that ADP sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” at the bottom of the commercial email we send you.
Please note that if you are currently receiving services from ADP and you have decided to opt-out of emails, this will not impact the messages we send to you for purposes of delivering such services or as permitted by applicable law.
If you have questions about your choices or if you need assistance with opting-out, please contact us via email to email@example.com . You may also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.
8. Access, Correction, Erasure, and Other Individual Rights
ADP respects your right to access, correct, and delete your personal data, or object to the processing of your personal data. If you have an online account, you may log into your account to access, update, or delete the information you have provided to us. Additionally, you may contact firstname.lastname@example.org to exercise any additional individual rights afforded to you by ADP’s Business Code, or by applicable data protection laws and regulations. You may also write to us at the address in the How to Contact Us below. If you send us a letter, please provide your name, address, email address, and detailed information about the changes you would like to make. ADP will respond to requests as soon as possible and in accordance with applicable data protection laws.
9. Automated Decision Making/Profiling
In some instances, our use of your personal data may result in automated decisions being taken. Automated decisions mean that a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without human review. For example, we may use your personal data to match you with companies looking to hire specific types of Site users. These actions/automated decisions are necessary to provide you with our Services and related support. We have implemented measures to safeguard the rights and interests of individuals whose personal information is subject to automated decision-making.
When we make an automated decision about you, you have the right to contest the decision, to express your point of view, and to require a human review of the decision. You can exercise this right by contacting the Global Data Privacy and Governance Team at email@example.com .
10. Information Security
ADP is committed to maintaining appropriate organizational, technical, and physical controls to protect personal data entrusted to ADP. These controls protect personal data from anticipated threats and hazards and unauthorized access and use. ADP will strive to provide security that is proportional to the sensitivity of the personal data being protected. Additional information about ADP’s Global Security Organization may be found at http://www.adp.com/trust.
You should also take steps to protect yourself, especially online. When you register at the Site, choose a strong password, and do not use the same password that you use on other websites. Do not share your password with anyone else. ADP will not ask you for your password in an unsolicited phone call or in an unsolicited email. Also remember to sign out of the Site and close your browser window when you have finished your work. This is to ensure that others cannot access your personal data and correspondence if they have access to your device.
11. Data Retention
ADP will retain your personal data for as long as necessary for the purposes for which the personal data is processed or until you request that the personal data be deleted. ADP follows a Global Records Information Management (“RIM”) Policy and has established records retention schedules for all types of personal data that ADP processes. Personal data is retained in accordance with the records retention schedules to ensure that records containing personal data are retained as needed to fulfill the applicable business purposes, to comply with applicable laws, or as advisable in light of applicable statutes of limitations.
When the retention period has expired, records containing personal data will be securely deleted or destroyed, de-identified, or transferred to archive, in accordance with ADP’s RIM Policy.
12. International Data Transfers
ADP is headquartered in the United States of America. Your personal data may be accessed by or transferred to the United States or elsewhere in the world in accordance with the ADP Privacy Code for Business Data.
13. Privacy Statements of Third Parties
This Privacy Statement only addresses the use and disclosure of information by ADP. Our Suppliers, Business Partners, and other third party websites that may be accessible through the Site have their own privacy statements and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by third parties prior to providing them with information or taking advantage of an offer or promotion.
14. Changes to this Privacy Statement
We may update this Privacy Statement to reflect new or different privacy practices. We will place a notice online when we make material changes to this Privacy Statement.
15. Group Companies Bound by this Privacy Statement
For a listing of Group Companies bound by this Privacy Statement and the Privacy Code for Business Data, please click www.adp.com/privacy/pdf/A2CoBDC.pdf .
16. How to Contact Us
Please contact us if you have questions, or comments. You may reach us via email at firstname.lastname@example.org , or via mail at address below. If you send us a letter, please provide your name, address, email address, and detailed information about your question, comment, or complaints.
Global Data Privacy and Governance Team
One ADP Boulevard
Roseland, NJ 07068–1728 USA
17. How to Lodge a Complaint
If you believe that ADP has not handled your personal data properly or that it has breached its privacy obligations, under any applicable data protection laws or the Business Code or of applicable law, you may file your complaint in writing to the address above, or via email, to the Global Data Privacy and Governance Team at email@example.com . The Global Data Privacy and Governance Team will investigate each complaint and notify you within a reasonable timeframe of the outcome of the investigation. If you are not satisfied by the resolution ADP proposes, you may lodge a complaint in accordance with the provisions of the Business Code.
18. U.S. State Specific Privacy Rights
Click here for additional information regarding your privacy rights.