Terryberry (“we”) are committed to safeguarding the privacy of our website visitors and registered users of the 360Recognition, Awardchoice, and Give a WOW platform; this Notice sets out how we will treat your personal data when we act as the processor of that data and when its processing is governed by the EU General Data Protection Regulation (GDPR).

Summary

Definitions
What personal data do we collect?
Cookies and other tracking technologies we use
Why we use collected information
Lawful grounds
Sharing of collected information
Security of collected information
Transfers of collected information
Retention of your personal data
Changes to this notice
Third party websites
Access to your personal data
Your rights
Contact us

Definitions

We use the term “personal data” to refer to any information collected or processed by or in connection with this website or the platform that directly or indirectly identifies you or factors specific to you, such as your name, IP address or user preferences.
Below we describe “lawful grounds” for processing your personal data. These lawful grounds (sometimes also referred to as “legal basis”) are the justification under GDPR for the processing of your personal data. If there is no lawful ground for processing your personal data, neither we nor anyone else is permitted to access or process your personal data.

What personal data do we collect?

We may collect, store and use the following kinds of information and personal data (“Collected Information”):
(a) information and personal data about your visits to and use of this website and our platform. We collect personal data about your computer and your visits to this website or the platform, including your IP address, geographical location, browser type, referral source, length of visit and number of page views, all of which are also Collected Information.
(b) information about any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our goods or services.

The data subjects to whom the Customer Personal Data relates will be primarily individual Employees employed by Customer and who are entitled to participate in and benefit from the Reward Program.

The types of Customer Personal Data which Terryberry may process when hosting the Site and providing the Program Services will include:

• Employee name, including preferred name;
• Job title;
• Email address;
• Date of birth/birthday;
• Start date;
• Award qualification date;
• Cost centre name;
• Department;
• Home address;
• Business address;
• Address for delivery of Rewards;
• Telephone number;
• Line manager name;
• Line manager address;
• Employee number/ID;
• Length of service;
• Reward Points;
• Award value;
• Profile picture
• Payment data, including billing address;
• Such other personal data as may be collected by Customer from the Employee and provided to Terryberry from time to time or which is otherwise uploaded, inputted, stored, transmitted and/or otherwise communicated to or via the Site.

(c) information that you provide to us for the purpose of registering with us on the website or platform and/or subscribing to our website services and/or email notifications. We collect first and last name, email address, and phone number for these purposes.

Cookies and Other Tracking Technologies We Use

We use cookies on this website. A cookie is a text file sent by a web server to a web browser, and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

We may send one or more cookies which may be stored by your browser on your computer. The information we obtain from cookies is part of the Collected Information. Our advertisers and service providers may also send you cookies.

Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.) This will, however, have a negative impact upon the usability of many websites, including this one.

To improve our services and this site, we may retain third party service providers to operate this site and help us monitor, collect and analyze information regarding your interactions with this website and data you input, including through the use of such providers’ cookies on your computer.

For more information about cookies and other tracking technologies we use, please see our Privacy Policy here.

Why we use collected information

Collected Information, including personal data, will be used to:
(a) administer and improve this website’s and the platform’s usability;
(b) improve your browsing experience by modification and replacement of text, images, videos, links to increase relevance to the visitor;
(d) send to you marketing and other communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you by post or, where you have specifically consented, by email or similar technology.

(e) to provide other companies with statistical information about our users. Information we provide to other companies will not identify any individual user.

Lawful grounds

If you are a registered platform user, the lawful ground for processing your personal data is your employer’s need to allow you to perform your employment contract or otherwise allow you to perform your duties in connection with the clinical trial. If you do not provide personal data to us you may be in breach of your employment contract as you may not be able to perform your assigned functions.

If you are a registered platform user, or a website user, the lawful ground for processing your Collected Information is our legitimate interest in understanding how users interact with this website and the platform, and in promoting our products and services.

Sharing collected information

We may share Collected Information about you:

(a) to enable our third party subprocessors to provide data center hosting services, database hosting services, dialer infrastructure services, email sync services, and to enable our third party processors to provide sales and marketing operations services;
(b) to the extent that we are required to do so by law;
(c) in connection with any legal proceedings or prospective legal proceedings;
(d) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
(e) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Security of collected information

We will take reasonable precautions to prevent the loss, misuse or alteration of your personal data. Data transmission over the Internet is inherently insecure and we cannot guarantee the security of data sent over the Internet.  We will store all the personal data you provide or that we collect about you on our secure servers.

You are responsible for keeping your passwords confidential. We will not ask you for your passwords.

Transfers of Collected Information

We are located in the United States. By submitting your personal data via this website or the platform, will transfer your personal data to us.

Retention of your personal data

We retain your personal data until data is requested to be purged from our systems by an authorized member of your organization.

Changes to this notice

We may update this privacy policy from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.

Third party websites

The website contains links to other websites. We are not responsible for the privacy policies of third party websites or such site operators’ actions including the collection or use of your personal data.

Access to your personal data

If you use this website, upon request, Terryberry will grant you reasonable access to your personal data and allow you to correct, amend or delete information that is demonstrated to be inaccurate or incomplete. See Contact Us.

If you are a platform user, we depend on you to update and correct your personal data to the extent necessary for the purposes for which that data was collected, such as contact information you provide so that we can provide you invoicing information.

Your rights

You are entitled to have any inadequate, incomplete or incorrect personal data corrected (that is, rectified).

You also have the right to request access to your personal data (including receiving a copy thereof) as well as additional information about the processing.

If we ever process your personal data on the lawful ground of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Further, you are entitled to have your personal data erased, under certain circumstances.

As from May 25, 2018, you also have the following additional rights:

• Data portability – if ever we rely (as the lawful ground for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party (such as your employment contract), and the personal data is processed by automatic means, you have the right to receive all such personal data which you have provided us in a structured, commonly used and machine-readable format, and also to require that it be transmitted to another controller where this is technically feasible.
• Right to erasure – you are entitled to have your personal data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where personal data is unlawfully processed, provided that applicable law does not provide otherwise.
• Right to restriction of processing – you have the right to restrict the processing of your personal data (that is, allow only its storage) where:
• you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy;
• where the processing is unlawful but you do not want us to erase the personal data;
• where we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defence of legal claims; or
• where you have objected to processing justified on legitimate interest lawful grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.

Where your personal data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.

• Right to object to processing (including profiling) based on legitimate interest grounds – where we rely upon legitimate interests to process personal data, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal data for the establishment, exercise or defense of legal claims, or applicable law requires otherwise.
• Right to object to direct marketing  (including profiling) – you have the right to object to our use of your personal data for direct marketing purposes (including profiling).

You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law.

You may contact us if you wish to exercise any of your rights in respect of your personal data processed in this website or the platform.

Contact us

To exercise your rights, or if you have any questions about this GDPR Data Privacy Notice or our treatment of your personal data, please send us an email at privacy@Terryberry.com or by post to Terryberry, 2033 Oak Industrial Dr. N.E., Grand Rapids, MI  49505.

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your Personal Information. EU or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us at:

Dan Egan
Terryberry
2033 Oak Industrial Dr. N.E.
Grand Rapids, MI  49505
Or at: Privacy@Terryberry.com

Under certain conditions, which are described in greater detail on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.