PRIVACY POLICY

Last Updated: October 2, 2020

OVERVIEW

This Privacy Notice (commonly referred to as the “Privacy Policy” or “Notice”) explains how Achievers Corp. (together with the companies owned by and in common ownership with Achievers Corp, “Achievers”, “we”, “us” or “our”) process the Personal Information of visitors to this Website (https://www.achievers.com), users of our mobile applications, and the services and features therein (together, the “Sites”).

This Privacy Notice does not include within its scope the Achievers Platform. If you are a Member of the Achievers Platform, any data collected and processed is governed by our agreement with your employer and the Achievers Platform Privacy Notice.

You should read and understand this Privacy Notice because it constitutes the core of our obligations to you when you use this website and when you provide your Personal Information to us, either directly or through automated processes. For your convenience we have summarized several of the most important points, which are:

We collect and process your personal information in order to provide services to you, either as a direct customer of Achievers, or as a customer of one of the businesses for whom we provide services.
We also use your personal information for our own legitimate and lawful business interests, including (but not limited to): improving our websites and services, communicating information about our services through direct advertising (such as email) and indirect advertising (such as ads appearing on other websites), conducting fraud detection and prevention activities, maintaining records and communicating notices that are required by law.
We do not sell your information.
Data protection laws in your jurisdiction may provide you with rights to access or delete your personal information and this Notice provides you with instructions on how we do this. For example, if you are a resident of the European Union or the State of California in the United States, laws in those jurisdictions grant you specific rights that are discussed below in the section called “Your Rights.”
We may share your information with service providers, such as those needed to deliver our services to you, and those that provide marketing services and event communications to you , but such service providers are bound by law and contract to only use your information for the purposes we specify.We may receive your information when we function as a service provider for other companies; we are bound by law and contract to only use your information for the purposes they have specified.
We may receive your information when we function as a service provider for other companies; we are bound by law and contract to only use your information for the purposes they have specified.
This Notice applies to the Sites operated by Achievers, and covers your personal information whether provided via those channels as well as any information you might provide to us when you call, email, or send postal mail to our Customer Service.

You are strongly encouraged to read this Privacy Notice in its entirety, not just the above highlights, so that you will fully understand our commitment to responsible data governance and the protection of your personal information. Please also note that this Notice may have changed since the last time you read it, so you should make sure that you have familiarized yourself with any terms that may have changed since the last time you read it.

SCOPE OF THIS NOTICE

Who

This Privacy Notice applies to the activities of Achievers. It applies to our usage of your personal data, whether you are an individual consumer (“business to consumer”) or you are interacting with us as part of your job (“business to business”).

What

This Notice describes how we collect and process your personal information (which includes “personal data” or “personal information” as defined under applicable data protection laws) and the rights you have regarding such data.

Where

This Notice applies to our collection and processing of personal data about users of our Sites, as well as the data we collect during the course of providing our services (the “Services”). It also applies to those channels through which individuals communicate with us about our Sites and Services, whether in person, by telephone, by postal mail, email, or other means.

When

This Notice only applies to your activities on the Sites. In these instances, we may function as a Controller of your data. This means we define the purposes for which your personal information is processed, and we control the means by which your information is processed. When we act as a Data Controller, we bear the primary responsibility to you, the Data Subject, for protecting your information and honoring your rights.

When we act as a Data Processor on behalf of another Data Controller (such as your employer), we collect, use, and disclose certain personal information only under the Controller’s instruction, and our processing of your personal information is subject to their instructions and privacy policies. If you are a Member of the Achievers Platform, your employer’s privacy policies and our Achievers Platform Privacy Notice apply to our processing of your data.

Please note: Links to third-party websites are provided solely for your convenience; when you go to those sites, your experience there is subject to the privacy notices and terms of use of those third-party sites, not ours, unless you are explicitly told otherwise.

PERSONAL INFORMATION WE COLLECT

Achievers collects and uses your Personal Information primarily for the purpose of providing you with the information, products and services you have requested from us.

Personal Information is collected by Achievers when you specifically choose to provide it to us, such as when you request to receive program information, register for events, or engage in a service offering provided by Achievers. We also collect information automatically through our Sites and related to the services we provide, subject to applicable laws, as set out below.

Personal Information We Collect Directly from You

We may collect the following information from you:

Contact information, such as name, email address, mailing address, fax or phone number;
Your resume, employment and education history, name and contact details, background details, and references when you apply to job postings or contact us about employment opportunities;
Company and employment information;
Information about your business such as company name, size, or business type; and
Demographic information, such as age, gender, interests and ZIP or postal code.

Comments, Posts and Submissions

When you submit online forms, participate in surveys, contests, promotions, or sweepstakes, join online chat discussions or post on a blog, request customer support, or submit testimonials, we collect your personal information, such as contact information, and other information you choose to share. Any information you provide in a blog may be read, collected, and used by others who access it. With your consent, we may use your testimonial and your name, e.g., to display personal testimonials of satisfied customers on certain Sites and in print advertisements.

Personal Information We Collect Automatically

When you visit any Achievers Sites, we may automatically gather information about your use of the Sites through cookies, web beacons, java script, log files, pixels and other technologies which include: your domain name, browser type, browser language preference, device type and operating system, page view and links you click within the Sites, IP address, device ID or other identifier, location information, date and time stamp, and time spent on the Sites, referring URL, your activity within the Sites and device geolocation information (where permitted by your device settings). You may withdraw your consent to the processing of location-based information at any time by changing the settings on your device.

We also collect information from analytic services, to compile and analyze information derived from the use of our Services, such as aggregate usage patterns, user preferences, peak demand times, preferred content and other information.

Protecting Children’s Privacy Online

Achievers products, services and Sites are provided to employers and their employees. Our Sites are not directed to children and we do not knowingly collect personal information from children under the age of thirteen (13). We request that such individuals do not provide personal information through our Sites.

USE OF YOUR PERSONAL INFORMATION

Achievers will only collect, use, disclose, and otherwise process Personal Information for the following purposes, based on our legitimate business interests and/or compliance with law:

Provide Our Services: To provide our services, operate our Sites, respond to your enquiries, for bug and error reporting and resolution, to perform upgrades and maintenance;
Customer Service and Support: To send you important information, such as changes to terms, conditions, and policies and/or other administrative information;
Personalization: To personalize your experience on a Site or using the services, such as by tailoring the content we send or display to you in order to personalize help and instructions, and to otherwise personalize your experience using the Services;
Alerts and Required Notices: To send you messages that you have requested, such as service-related alerts and any notices required by contract or applicable law;
Marketing and Promotions: To send you marketing communications, such as information about our services and events, you have signed up to receive;
Advertising and Referrals: To assist in advertising the services on third-party websites ; to track referrals from partner websites; and share leads with referral partners;
Analytics and Improvement: To better understand how our users access and use the services, and for other research and analytical purposes, such as to evaluate and improve the services;
Aggregated and Anonymized Information: We may also generate aggregated, pseudonymized and/or anonymized information about users of our sites and apps for statistical purposes, research, for marketing, advertising, or similar purposes.
Verify Identity and Detect Fraud: To verify your identity and/or location in order to allow access to your accounts, conduct online transactions, and secure your personal information, and for risk control, fraud detection and prevention, and compliance with laws and regulations;
Protect Our Legal Rights and Prevent Misuse: To protect the services, prevent unauthorized access and other misuse, and where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Notice.
Comply with Legal Obligations: To comply with the law or legal proceedings such as when required to disclose information in response to lawful requests by public authorities, including responding to national security or law enforcement disclosure requirements; and
General Business Operations: Where necessary to the administration of our general business, accounting, recordkeeping and legal functions.

PURPOSE OF PROCESSING

In the table below, we explain the purposes for which we use and process your personal information, as well as the legal bases for such use and processing (such as those permitted under the European Union’s General Data Protection Regulation (“GDPR”) and other applicable laws).

Purpose of Use (see list above)	Legal Bases of Processing (where applicable)
Provide Our services	Necessary to enter into or perform a contract with you (upon your request, or as necessary to make the Services available)
Customer Service and Support	Our legitimate business interest*
Personalization	Our legitimate business interest*
Marketing and Promotions	Our legitimate business interest* with your consent
Analytics and Improvement	Our legitimate business interest*
Aggregated and Anonymized Information	Our legitimate business interest*
Verify Identity and Detect Fraud	Compliance with applicable laws and regulations
Protect Our Legal Rights and Prevent Misuse	Establish, defend or protect legal interests
Comply with Legal Obligations	Our legitimate business interest*
General Business Operations	Establish, defend or protect legal interests Compliance with law

Purpose of Use (see list above)

Legal Bases of Processing (where applicable)

Provide Our services

Necessary to enter into or perform a contract with you (upon your request, or as necessary to make the Services available)

Customer Service and Support