WrkPlan values and respects the privacy of those who visit WrkPlan.com and the pages of its siteor use our WrkPlan software, products, and web-based services (the “Services”). This Privacy Policy addresses our privacy practices relating to visitors and users of our Sites and Services. This serves as notification regarding information collected automatically via the Sites or Services, as well as that which is affirmatively provided by Users.

If you do not want your Personal Data to be collected or processed as described in this Privacy Policy and in accordance with our privacy practices as explained herein, you should not use the Sites. If you use our Services and have questions regarding the treatment of Personal Data, you should contact WrkPlan Support and consult the terms of your WrkPlan Service Agreement related to those Services.

“Personal Data” means any information that, by itself or in combination with other information, identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person, including, based on applicable Privacy Laws, a consumer or household. While this Privacy Policy uses the term Personal Data, it shall be read to encompass similar terms of art, such as Personal Information and Personally Identifiable Information, depending on jurisdiction. This does not include anonymized, aggregated, statistical, or non-personally identifiable data resulting from the use of the Sites and Services. See the Personal Data Categories Chart at the end of this document for more detailed information.

“Privacy Laws” refers to the applicable legislation, statutory instruments, and any other enforceable laws, codes, regulations, or guidelines regulating the collection, transfer, processing, use, and disclosure of, and/or rights to Users’ Personal Data based on their governing jurisdiction, including, in particular: (i) the California Consumer Privacy Act and its implementing regulations, as amended from time to time (the “CCPA”)

How we use Personal Data

WrkPlan uses information about Users, including Personal Data, for a variety of purposes, including

1. To enable you to use our Sites or Services;
2. To monitor usage and analyze statistical information related to our Sites or Services;
3. To supply information regarding your Services upon your request;
4. To respond to your comments, questions, and requests;
5. To carry out our obligations and enforce rights arising from our contractual relationship with you;
6. To improve and maintain the security, performance, and operational efficiency of our Sites or Services;
7. To provide customer support;
8. To send communications regarding Services or information related thereto; and/or
9. For any other purpose with your consent.

When you visit the Sites, WrkPlan has collected a limited amount of Personal Data based on your internet connection.

The categories and extent of Personal Data customers choose to collect and store in their individual WrkPlan system database(s) is largely at the customer’s discretion and varies based on the specific Services provided, the engagement and scope of Services requested, and/or any configurations or customizations undertaken on your behalf in accordance with the terms of your Services Agreement. Customers should contact WrkPlan Support for more information.

a. Data Integrity

You are responsible for the accuracy of the information you provide to WrkPlan. WrkPlan will use reasonable efforts to maintain the accuracy and integrity of such information and update it, as appropriate. WrkPlan will not maintain data any longer than necessary for the purposes stated without your consent unless legally required. b. End-User Personal Data

As part of using the Services, you may enable access to your end-users (as governed by the terms of your Services Agreement). WrkPlan collects Personal Data on behalf of our customers in order to provide the Services and has no direct relationship with your end-users whose Personal Data may be processed in connection with the provision of those Services. You are solely responsible for establishing policies for and ensuring compliance with applicable Privacy Laws relating to the collection of Personal Data from your end-users. Therespective standard obligations of Customers and WrkPlan are set forth in your Services Agreement.

c. Automated Collection

WrkPlan collects log files, domain names, and IP addresses of site visitors and system Users for statistical purposes, to measure use, to improve the content or responsiveness of the Sites, or to customize the content or layout of the Site for individual Users. WrkPlan may also aggregate this information to identify traffic patterns for the Sites. This data helps WrkPlan understand how Users consume information on the Site and interact with the Services with the ultimate goal of building an experience that improves WrkPlan’s processes and priorities in accordance with User needs. Access to this data is restricted to those who administer WrkPlan’s network and Sites. WrkPlan may use and disclose this data to third parties only in connection with monitoring our networks for security purposes, in response to legal process or law enforcement inquiries, to control any abuses of the Sites, or to address identified violations of any contractual provision entered into between you and WrkPlan.

In addition, most web browsers contain cookies, but also provide controls that allow you to block or delete them. You have the ability to accept or decline cookies from the Sites at any time by modifying the settings in your web browser. Certain Site and Service features require cookies to function. Please be aware that if you choose to block cookies, you may not be able to access or use those features and preferences that are dependent on cookies.

d. Processing of Personal Data

WrkPlan’s legal basis for collecting and using Personal Data will depend on the Personal Data concerned and the specific context in which WrkPlan collects it.

e. However, WrkPlan will normally collect Personal Data with your consent, to perform a contract (for example, when providing Services), or where the processing is in WrkPlan’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, WrkPlan may also have a legal obligation to process Personal Data or may need to do so in order to exercise, establish, or defend legal claims.

f. The personal data that customers choose to enter for their employees and their business connections is for their accounting, billing, timekeeping, and personnel management and is not used by WrkPlan except for Support as requested by the customer.

g. If WrkPlan asks you to provide Personal Data to comply with a legal requirement or to perform a contract, WrkPlan will make this clear at the relevant time and advise whether the provision of Personal Data is mandatory or not (as well as the possible consequences, if any, if you do not provide that Personal Data).

4. Confidentiality and Security of Personal Data

Security is one of WrkPlan’s highest priorities. WrkPlan takes commercially reasonable and appropriate steps to protect Personal Data transmitted from you to the Sites and in connection with the Services and to protect such data from loss, misuse, or unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no internet transmission is ever 100% secure or error-free. In particular, email may not be secure and therefore special care should be taken when deciding what information is sent to WrkPlan via email. Where you use passwords, ID numbers, or other special access features, it is your responsibility to safeguard them.

We make commercially reasonable efforts to reduce the risk of data breaches and have dedicated controls and procedures in place for such situations, along with the procedures to make notifications to the relevant supervisory authorities and data subjects (where applicable).

Face Recognition Data

Collection of Face Recognition data is at the option of the customer organizations using the WrkPlan. WrkPlan makes no use of this data other than to authenticate the end user’s access to his/her personal timesheet. Face data is purged when the employee status is changed to Terminated.

Disclosure/Onward Transfer of Personal Data

Any Personal Data provided to WrkPlan will be used for WrkPlan’s business purposes only and only disclosed on a need-to-know basis or as required by law. When WrkPlan provides Personal Data to third parties used to deliver or support specific Services to you, our agreements with these third parties do not permit them to use Personal Data outside the scope of fulfilling those Services nor allow them to further disclose your Personal Data.

WrkPlan’s business partners are independent third parties that are otherwise not affiliated with WrkPlan. Any relationship you elect to enter into with a partner for additional products and services is directly between you and that third party.

User Rights to Personal Data

WrkPlan collects and processes Personal Data consistent with the disclosures in this Privacy Policy. Depending on applicable Privacy Laws, you may have the right to request WrkPlan disclose certain information to you and/or about our collection and use of your Personal Data. You may have the right to object to or request access to your Personal Data, to restrict the processing of your Personal Data, or to have your Personal Data transferred, corrected, or deleted. You may also have the right of portability with respect to your Personal Data. However, you should note that these rights are not absolute and, depending on the type of information affected, WrkPlan may be permitted, or even required by law, to refuse your request. In all events, upon receipt of a valid, verifiable request, WrkPlan will explain its position in detail.

These rights are applicable to WrkPlan customers and do not extend to customers’ employees or business connections whose personal data may be contained in the customer’s WrkPlan database.

The CCPA permits California consumers (as defined under Cal. Code Regs. tit. 18, § 17014) to request certain information regarding WrkPlan’s disclosures of Personal Data and compliance with the CCPA. Depending on the circumstances of your relationship with WrkPlan, the disclosure may extend over the previous twelve (12) months. California consumers should submit their requests as described in Contact Us. It is important to note that WrkPlan is required under the CCPA to verify your identity in order to respond. WrkPlan will respond to verifiable requests within a reasonable period of time after receipt.

a. Marketing

Based on applicable Privacy Laws, WrkPlan may separately ask you to opt-in to receive promotional and/or marketing communications. At any time, you can manage your communication preferences via the Email Preference Center or you may unsubscribe from receiving such communications by utilizing the “unsubscribe” or opt-out feature within the communication. Requests to unsubscribe from WrkPlan communications may also be made by contacting WrkPlan via the methods indicated in Contact Us.

b. Selling of Personal Data

WrkPlan’s disclosures of Personal Data to its affiliates, third-party service providers, partners, or subprocessors do not qualify as “sales” within the scope and meaning of the CCPA as the disclosures are necessary to perform the business purpose under your Services Agreement or facilitate business communications and/or transactions between the parties. WrkPlan does not exchange “covered information” (as defined under the Nevada Statute) for monetary consideration to any person or entity for the purpose of licensing or selling the covered information.

c. Personal Data Collection Based on Consent

If WrkPlan collects and processes Personal Data with your consent, you can withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of any processing WrkPlan conducted prior to your withdrawal, nor will it affect processing of Personal Data conducted in reliance on lawful processing grounds other than your consent.

d. Concerns

Under the CCPA, you may also submit inquiries or concerns about WrkPlan’s collection and processing of your Personal Data. In addition to those methods noted in Contact Us, California consumers may contact WrkPlan via our toll-free number 1-866-826-3399, to submit your request or inquiry.

e. Non-Discrimination under CCPA

WrkPlan will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, WrkPlan will not:

1. Deny goods or Services;
2. Charge different prices or rates for goods or Services;
3. Provide a different level or quality of goods or Services; or
4. Suggest that you receive a different price or rate for or a different level of quality of goods or Services. The CCPA requires that we disclose to you that WrkPlan may offer and you may consent to receive certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive offered must reasonably relate to the value of your Personal Data and will contain written terms that describe the program’s material aspects. You may revoke your consent to participate or receive such financial incentives at any time.

Privacy Policy Changes

This Privacy Policy is current as of the Effective Date set forth above. WrkPlan reserves the right to change this Privacy Policy from time to time, consistent with Privacy Laws, principles, and/or technical requirements. Unless such changes afford greater protections to your privacy interests, or you otherwise consent, such changes will apply only to Personal Data received after the Effective Date of such change. You should refer to this Privacy Policy regularly, as it will be updated from time to time.

Contact Us

If you have any questions about this Privacy Policy or if you wish to submit a request pursuant to User Rights to Personal Data customers should contact WrkPlan Support for additional information and assistance.