PERSONAL INFORMATION WE COLLECT
Personal Information is collected by Achievers when you specifically choose to provide it to us, such as when you choose to receive program information, register for events, or engage in the service offering provided by Achievers, or automatically through our Sites and related to the services we provide, subject to applicable laws as set out below.
成就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 We Collect Directly from You:
- Company and employment information;
- 演示graphic 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.
成就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
成就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:为了提供我们的服务，我们的工作网站，回复您的查询，错误和错误报告和决议，进行升级和维护;
- Customer Service and Support:向您发送重要信息，如更改条款，条件，政策和/或其他管理信息;
- Marketing and Promotions:送你，你已经签署了营销传播;
- Advertising and Referrals:为了帮助广告的第三方网站，并从合作伙伴网站的轨道转介服务;
- Analytics and Improvement:To better understand how users access and use the services, and for other research and analytical purposes, such as to evaluate and improve the services;
- 汇总和匿名信息：We may also generate aggregated, pseudonymized and/or anonymized information about users for marketing, advertising, research or similar purposes.
- 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
- 一般业务运营:Where necessary to the administration of our general business, accounting, recordkeeping and legal functions.
Purpose of Use
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 under the European Union’s General Data Protection Regulation (“GDPR”) and other applicable laws.
|使用目的（见上表）||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||我们的合法商业利益*|
|Marketing and Promotions||我们的合法商业利益*with your consent|
|Analytics and Improvement||我们的合法商业利益*|
|Aggregated and Anonymized Information||我们的合法商业利益*|
|Verify Identity and Detect Fraud||Compliance with law|
|Protect Our Legal Rights and Prevent Misuse||建立，维护和保障合法权益|
|Comply with Legal Obligations||我们的合法商业利益*|
Compliance with law
A cookie is a small text file that is placed on your hard disk by a Website. Cookies contain a unique identification number that identifies your browser, but not you, to our systems each time you visit one of our Websites. Cookies tell us which pages of our Websites are visited and by how many people. Achievers does not collect any Personal Information about you through cookies nor can a cookie carry a damaging payload (such as malware).
- 基于会话cookie - 仅用于你留在网站，当你离开这个网站过期的时间长度。
- Persistent based cookies — Are more permanent in nature and can re-used when you return to the Website from the same computer.
成就does not respond to web browser “do not track” (DNT) settings or headers with respect to Achievers public Websites. For more information about do-not-track signals, please click here (http://www.allaboutdnt.com/）。目前对DNT没有统一的行业标准已经通过，也有启用DNT设置时解释用户的意图没有一致的标准。成就需要的隐私权将继续关注政策的倡导者，技术专家，监管机构和公司试图创建一个围绕DNT浏览器技术达成共识的解释和执行标准。
We use your e-mail address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further. We may use your e-mail address to send you information about offers on products or special promotions that we believe may be of interest to you. You may choose to stop receiving our marketing emails at any time by following the unsubscribe instructions included in these emails.
成就uses images imbedded in e-mail messages called “web beacons”. Web beacons are clear images that allow Achievers to determine if a message has been opened. It also allows Achievers to determine the IP address of the user that opened it and to access any Achievers cookies. We may use this information in the aggregate to assess and improve our email messages.
Email web beacons can be disabled by turning off HTML display and displaying text only or by turning off image display while still using HTML within your email client.
HOW WE DISCLOSE PERSONAL INFORMATION WE COLLECT
成就does not sell your Personal Information to third parties.
成就是公司的黑鹰全局组的一部分，我们可能会透露我们的附属公司和子公司之间的个人信息（“Affiliates”) who provide services to us or on our behalf, as part of our business operations and administration of the Services in furtherance of the purposes set out in this Policy. Any Affiliate’s processing of your personal information is subject to this Policy.
为了确保我们有效地提供您向我们要求的信息，产品或服务，成就可与正在代表我们是谁帮助我们开展本策略确定的目的选择的服务提供商分享您的个人信息。服务供应商可能位于欧盟，美国，加拿大和其他司法管辖区。例如，我们可以与服务提供商合作，以跟踪和管理您已在网站白皮书，演示，大约成就服务提供信息等这样的服务提供商只与提供信息的请求为是必要的，这可以包括：您的邮寄地址，电子邮件地址和姓名。提供给服务供应商的信息可以为目的的规定，并受严格保密条款的前提下使用。成就表示了其个人信息可能被成就披露任何第三方符合欧洲议会的GDPR（法规（EU）六百七十九分之二千零十六和理事会27 2016年4月对自然人的保护方面the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and/or the principles in the EU-U.S. and Swiss-U.S. Privacy Shield or is subject to applicable laws or contractual provisions requiring the same level of privacy protection.
We may also disclose your Personal Information in the event of the situations below:
- If Achievers is involved in a merger, acquisition or sale of all or a portion of its assets, or in the event of bankruptcy or dissolution of our business, your Personal Information may be transferred to an acquiring business or third party, including contemplation of or related to due diligence for such business transactions, subject to any applicable restrictions under applicable laws. You will be notified by email and/or by a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
- 成就may also use, or disclose your Personal Information to third parties, if Achievers has reason to believe that using or disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; (iii) investigate security breaches or cooperate with government authorities pursuant to a legal matter; or (iv) to protect our rights, safety or property, and/or the rights, safety, and property of our clients, users of our platform, and any other persons.
- We may disclose your Personal Information for any other purpose to which you consent.
成就has internal policies in place that govern the retention of your Personal Information. Your Personal Information will be retained when you are a prospect or customer or for a reasonable time thereafter, or as required by relevant statutory, regulatory or contractual requirements. When Achievers is no longer required to retain your Personal Information, we will securely destroy your Personal Information based on our data disposal policies and relevant regulations or return the data to your employer for destruction at their request.
Except in limited circumstances, as specifically provided by applicable privacy legislation, Achievers can tell you whether we hold Personal Information about you.
成就will only refuse access to your Personal Information in those circumstances permitted and required by applicable laws or regulations. If we cannot fulfill your request, we will inform you about why we cannot comply with your request.
Withdrawal of Consent
你有合适的对象来处理(萤火虫ing profiling) based on legitimate interest grounds, where we are relying upon legitimate interests to process personal information. 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 information for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
Object to Marketing
You have the right to object to our use of your personal information (including profiling) for direct marketing purposes, such as when we use your personal information to invite you to our promotional events.
Right to Lodge a Complaint
You have the right to lodge a complaint with your supervisory authority, if you consider that the processing of your personal information infringes applicable law.
成就will conduct periodic assessments to validate its continued adherence to this Policy.
The personal information we collect from you may be transferred to, stored at or processed in other countries, including the United States or other locations outside the European Economic Area, which may not provide equivalent levels of data protection to your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
对于来自欧盟，英国（“UK”）或瑞士向美国转移，成就依赖于它的隐私保护认证（见下文）。保障措施还可以包括批准由欧洲委员会（为标准合同条款的形式可以在这里找到由欧盟委员会决定是否充足，或将在地方标准合同条款：EU Commission Standard Contractual Clauses）或其他适用的监管机构。
黑鹰网络公司及其附属公司，包括成就，与欧盟中美规定。隐私保护框架和瑞士中美。Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom (“UK”) and Switzerland to the United States in reliance on Privacy Shield.
As part of the certification made by Blackhawk Network Inc., Achievers has certified to the Department of Commerce that they adhere to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit:https://www.privacyshield.gov/。
成就is responsible for the processing of your personal information that it receives under the Privacy Shield Framework and subsequently transfers to a Service Provider. Achievers complies with the Privacy Shield Principles for all onward transfers of personal information from the EU, the United Kingdom, and/or Switzerland, including the onward transfer liability provisions. To learn more about the Privacy Shield program, and to view our certification, please clickhere。
成就will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of Personal Information in accordance with the principles contained in this Policy.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) athttps://feedback-form.truste.com/watchdog/request。We are committed to cooperating in the resolution of disputes with individuals through this process.
Under certain conditions, more fully described on thePrivacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
QUESTIONS OR CONCERNS
Attn: Privacy Office
c/o Blackhawk Network, Inc.
6220 Stoneridge Mall Road
这项政策可能会更改。请里维w it from time to time. If we make material changes to this Policy about how we process your personal information, we will post those changes on this page and revise the “Last Updated” date at the top and we will notify you by email or prominent notice on this Site prior to the change becoming effective. Where required by law, we will obtain your consent or give you the opportunity to opt out of such changes. Any changes will become effective when we post the revised Policy.