Why personal information about You will be collected. 2
Personal information about You that will be collected. 2
How personal information about You will be used. 3
Third parties with whom Your personal information may be shared. 4
Your rights as a citizen of the European Economic Area (EU) under GDPR.. 5
Who to contact to exercise Your rights as an EU citizen under GDPR.. 6
Your rights as a California resident under CCPA.. 6
Who to contact to exercise Your rights as a California resident under CCPA.. 7
Why personal information about You will be collected
You (defined in this Privacy Notice as “You” or “Your”) have been invited to participate in [Program Name] (defined in this Privacy Notice as “the Program”) sponsored by [BIW Client Name] (defined in this Privacy Notice as “Sponsor”). This Privacy Notice also references Sponsor's provider, BI WORLDWIDE (defined in this Privacy Notice as “BI WORLDWIDE”). If you choose to participate in the Program, then Sponsor and BI WORLDWIDE have a legitimate interest in the collection of your personal information to operate the Program.
BI WORLDWIDE designed and administers the Program for Sponsor, a [Type of program: rewards and recognition, training, travel, etc.] program through which BI WORLDWIDE promotes engagement of participants on Sponsor's behalf in [Describe type of activity such as: online training, self-improvement, rewarding excellence]. If applicable, the Program may allow participants to earn certain branded award points (defined in this Privacy Notice as “Award Points”) which can be redeemed for merchandise, experiential, and/or travel awards using an on-line awards catalog linked to the Program website which is [program URL https://] (the on-line awards catalog and Program website are collectively defined in this Privacy Notice as “the Website” or “the Program Website”.
The Program and the Website are owned and operated on the Sponsor's behalf by BI WORLDWIDE, with headquarters located at 7630 E. Bush Lake Road, Minneapolis, MN 55439, and/or BI Worldwide Ltd, with headquarters located at 1 Vantage Court, Newport Pagnell, Buckinghamshire MK16 9EZ.
Personal information about You that will be collected
Sponsor and BI WORLDWIDE may already possess personal information about You that may be combined with additional personal information that is collected from You by BI WORLDWIDE to administer the Program.
Sponsor will provide to BI WORLDWIDE and/or BI WORLDWIDE will collect and use personal information that You provide to BI WORLDWIDE directly through this Program, as applicable, when You:
- complete forms, or communicate with BI WORLDWIDE or Sponsor in person, by phone, e-mail, fax, on-line or chat
- register to use the Program Website
- enter details of activities or performance completed in connection with the Program
- participate in Program activities such as competitions, learning opportunities, promotions or surveys
The following types of personal information will be collected and processed by the Program:
Internal note: Delete personal information types from the following list that will not be used by this program's client website, and add any missing type of personal data collected by this program's client website.
[Participant employee ID number, name, personal or business street address, personal or business phone number, personal or business email address, employee performance, date of birth, gender, bank account details, credit card number, passport number, social security number/national identity number, device IP address, video/photos, race, religion, ethnicity, nationality, health data, sexual orientation, political/philosophical beliefs, trade union membership, criminal record check results, credit check results].
Collection, processing, and storage of personal information are required to operate and administer the Program. BI WORLDWIDE is under contract withSponsor to operate and administer the Program which requires BI WORLDWIDE to receive data from Sponsor and/or otherwise collect personal information from You.
- BI WORLDWIDE will not share Your personal information with any third party companies for any company's marketing purposes unrelated to the purpose of the Program.
- BI WORLDWIDE will not sell Your personal information to any third parties.
You have the choice to not provide the personal information necessary to participate in the Program. If You choose not to provide the personal information requested, You may not be able to participate in, or receive any benefit(s) provided by the Program.
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Personal information is saved for the length of time that is required for BI WORLDWIDE to operate and administer the Program as defined within a written contract or data protection agreement between BI WORLDWIDE and Sponsor.
How personal information about You will be used
Sponsor and BI WORLDWIDE respect the privacy of Your personal information and will not share Your personal information with third parties except as necessary to operate the Program and related purposes. BI WORLDWIDE administers the Program on behalf of Sponsor and Sponsor will be sharing Your personal information with BI WORLDWIDE. Any personal information You provide via the Website will be processed by BI WORLDWIDE on Sponsor's behalf, but BI WORLDWIDE is under contract to assure Your personal information and data privacy rights are protected.
Your personal information will only be used for the intended purpose(s) for which it was collected, or for closely related purposes in conjunction with the Program.
Your personal information will be used by BI WORLDWIDE only as directed by Sponsor to the extent required to:
- allow You to participate in, and receive benefits of the Program
- allow Sponsor to achieve the intended results of the Program
- assure You are provided with the Program content which is relevant to You
- notify You about changes to the Program Website or related services
- perform research and analysis on Your performance or engagement with Sponsor and/or Sponsor's industry per direction from Sponsor
- analyze and improve the Program
Personal information You choose to post, share, upload, or make available via the Program may be visible to others who use the Program.
When it is necessary to share personal information from the Program with a third party, Your personal information will be properly protected, only the minimum personal information required will be shared, and it will be shared only on a need-to-know basis.
Your personal information may be shared:
- with the Sponsor of the Program and with BI WORLDWIDE to administer the Program
- with other companies within the Sponsor's corporate group
- with Your employer (and its management staff). If Sponsor is your employer, then personal information processed in connection with the Program (including information regarding the performance of your duties as an employee) may be provided to Sponsor for employment related purposes. This information could form part of your employer's personnel record, and could be considered when evaluating the performance of your work. For further information, please see Sponsor's employee handbook.
- with Sponsor's and/or BI WORLDWIDE's suppliers and sub-contractors in conjunction with the Program
- with another business if Sponsor is involved in a takeover or merger with that business
- if Sponsor is under a legal duty to disclose Your information (for example, as required by law enforcement or a court order)
- if Sponsor or a third party (including BI WORLDWIDE) must enforce a contract
- if Sponsor or a third party (including BI WORLDWIDE) must protect the rights, property, or safety of You or anyone else
- with providers of analytics services as described in the next paragraph
Sponsor and/or BI WORLDWIDE will collect the following types of information and use analytics services to help make improvements to the Program and/or the Website, or to troubleshoot problems:
- personal information – the IP address assigned to the device You use to access the Website (an IP address is a unique number assigned to your device when you use the internet)[, add any other type(s) of personal data used by the program for analytics here and convert to black text] and any phone number You use to call BI WORLDWIDE's customer service number
- technical information – browser type and version, time zone setting, browser plug-in types and versions, operating system, and device type
- performance information – information about Your use of the Program Website or performance in the Program, including the date and time You connect, the pages of the Website You view, how long it took to display each page You viewed, errors, and the length of time You spent on certain pages
- [additional analytics usage – add any additional specific language describing how analytics will be used by the specific client program if not covered above, and convert to black text]
Your personal information is securely stored within [Country where the application database is stored].
Your personal information for purposes of shipping, mailing or delivery (name, address, e-mail and phone number) will be transferred to the country or region where you reside as required to permit physical delivery of Program communications.
[Add any additional descriptions of international transfers of personal information here using the following format: Your personal information (<lorem, ipsum>) will be transferred to <Country> for the purpose of <lorem ipsum>.]
Internal note: If this client program website will be transferring personal data between countries for reasons other than shipping, delivery, or mailing physical client program communication materials, BIW must obtain prior written authorization from the BIW client, and the BIW data privacy office must review and approve the data being transferred, reason for transfer, and method(s) used for transfer.]
If it is necessary to transfer Your personal information outside of the country in which it is stored, the Sponsor and BI WORLDWIDE take steps to make sure adequate levels of privacy protection in line with applicable data protection laws are in place. These privacy protection measures are contractually required of all parties involved in the transfer.
Third parties with whom Your personal information may be shared
Internal note: If this program’s client website does not share any personal data with any third party, then delete this entire section (including the section header line above), and then Update the Table of Contents so it no longer lists this section and updates page numbers.
Internal note: Delete or add each category of third party processor to be used by this program. Examples of typical categories are listed in red text below. Add any additional categories as applicable using the same format used by the examples in red text.
Your personal information is not shared with any third parties unless it is required to administer the Program. If your information is shared with a third party, the type of third party is listed below.
- This Program includes self-registration for travel or an event, so an Event Registration provider will receive some of Your personal information.
- This Program includes the option to use a Mobile App named [insert mobile app name here] to participate in the Program using Your mobile device. If You choose to use the Mobile App, then the Mobile App provider will receive some of Your personal information.
- This Program includes travel via airlines, so an Airline Booking provider will receive some of Your personal information.
Internal note: Add or delete the Data Privacy Office contact information for each applicable BIW third party that will be receiving personal data from this program's client website. A typical list might include one or more the examples in red text below. If you use any of the examples listed, convert them to black text.
If You have any questions or concerns related to how Your data is used by the Event Registration provider Cvent, You should provide your name and contact information via email to: privacy@cvent.com
If You have any questions or concerns related to how Your data is used by the Event Registration provider Lenos, You should complete their online form located here:
https://digital.lenos.com/corp/LenosContact2017/Privacy-Form/privacy
Internal note: The Lenos link listed above is subject to change, so please verify the link is still the correct one to use if this is applicable to this client program.
If You have any questions or concerns related to how Your data is used by the [insert mobile app name here] provider, You should send an email with your name and contact information to: [insert mobile app provider privacy office email address here]
If You have any questions or concerns related to how Your data is used by the Airline Booking provider, You should send an email with your name and contact information to: dataprotection@Amadeus.com
Internal note: End of section to delete if this program's client website does not share any personal data with any third party.
Your rights as a citizen of the European Economic Area (EU) under GDPR
The Sponsor and BI WORLDWIDE respect Your rights to access and control Your personal information which include:
1) Right to information – This right provides You with the ability to ask Sponsor what personal information about You is being processed and the rationale for such processing.
2) Right to access – This request provides You with the right to see or view Your own personal information that is being processed, as well as to request copies of Your personal information.
3) Right to rectification – This right provides You with the ability to ask for modifications to Your personal information if You believe that Your personal information is not up to date or accurate.
4) Right to withdraw consent – This right provides You with the ability to withdraw previously given consent for processing of Your personal information for a specific purpose. Your request would then require the Sponsor to stop the processing of Your personal information that was based on the consent provided earlier.
5) Right to object – This right provides You with the ability to object to the processing of Your personal information. Normally, this would be the same as the right to withdraw consent, if consent was appropriately requested and no processing other than legitimate purposes is being conducted. However, a specific scenario would be when You ask that Your personal information not be processed for certain purposes while a legal dispute is ongoing in court.
6) Right to object to automated processing – This right provides You with the ability to object to a decision based solely on automated processing. Using this right, You may ask that Your input (for instance, a questionnaire You completed) to be reviewed manually, because You believe that automated processing of Your responses may not consider Your unique situation.
7) Right to be forgotten – Also known as right to erasure, this right provides You with the ability to ask for the deletion of Your personal information. This will generally apply to situations where You no longer participate in the Program. It is important to note that this is not an absolute right, and also must take into consideration the Sponsor's rights.
8) Right for data portability – This right provides You with the ability to ask for transfer of Your personal information. As part of such request, You may ask for Your personal data to be provided directly to You, or transferred to another data controller or data processor other than Sponsor or BI Worldwide. When doing so, Your personal information must be provided or transferred in a machine-readable electronic format.
Who to contact to exercise Your rights as an EU citizen under GDPR
Under applicable EU data protection laws, the Sponsor is an independent “Data Controller” of Your personal information.
If You have any questions or concerns related to how Your personal information is used bythe Program, You should contact [BIW Client Name] directly by sending an email with your name and contact information to [BIW Client Name]'s Data Privacy Office: [Client Privacy Office Email Address]
Internal note: Add the client's Data Privacy Office e-mail address to this program's client website Data Map spreadsheet (located under the GDPR Data Maps shared directory).
If You are not happy with the response you receive from any of the data protection officers you have contacted, or You believe that protection of Your personal information or privacy rights have been infringed, You should contact Your European Union, United Kingdom, or other state or country's Data Protection Authority (DPA) or the Swiss Federal Data Protection and Information Commissioner, as applicable. You can search for Your country's DPA by entering the name of your country combined with the words “data protection authority” or “privacy office” into an Internet search page such as www.google.com.
Your rights as a California resident under CCPA
The California Consumer privacy Act of 2018 (CCPA) was written with the goal to assure the right of every California resident (Consumer) to control certain uses of their personal information by giving them an effective way to control their personal information, by ensuring the following rights:
- The right to know what personal information is being collected about them.
- The right to know whether their personal information is being sold or disclosed (and to whom).
- The right to say "no" to the sale of their personal information.
- The right to access their personal information.
- The right to equal service and price, even if they exercise their rivacy rights.
Under the CCPA, Consumers have the right to request that a company in possession of their personal information disclose to the Consumer the following:
- The categories of personal information the company has collected about the Consumer.
- The categories of sources from which the Consumer's personal information is collected.
- The company's reason, or purpose, for collecting or selling the Consumer's personal information.
- The categories of third parties with whom the company shares the Consumer's personal information.
- The specific pieces of the Consumer's personal information the company has collected or shared with a third party.
Under the CCPA, Consumers also have the right to request that a company in possession of their personal information delete the personal information pertaining to the Consumer.
- This includes deletion of any copies of the Consumer's personal information that have been sold or disclosed to any third parties.
Who to contact to exercise Your rights as a California resident under CCPA
Please be aware that [BIW Client Name] is required to respond to a consumer request only once during any calendar year, that not all information sharing is covered by the California Privacy Rights requirements, and only information sharing that is covered will be included in [BIW Client Name]'s response.
To make such a request You can either:
In your request, please attest to the fact that You are a California resident and provide Your current California address.
