Privacy Policy

WorkMarket Online Privacy Statement

Effective Date: October 5, 2018

This Privacy Statement explains how WorkMarket, an ADP Company ("WorkMarket" or "our" or "we") uses and discloses personal data that we collect from individuals, including business and client contacts, freelancers, and other consumers (users) who visit The WorkMarket Platform which includes all websites associated with WorkMarket (including all domains and sub-domains of www.workmarket.com), all application programming interfaces (APIs), and all applications and communication tools provided by WorkMarket ("The WorkMarket Platform").

This Privacy Statement also incorporates ADP's Binding Corporate Rules ("BCR") Privacy Code for Business Data (the "Business Code"), which includes information about how ADP processes and protects personal data of our business and client contacts, freelancers, and consumers (users). For more information on the Business Code, please click on Business Code Overview here: https://www.adp.com/privacy.aspx. If you have additional questions about privacy or this Privacy Statement, please contact our Privacy Team at [email protected].

ADP also has a Global Data Privacy Policy that applies to all ADP companies worldwide, including WorkMarket. An overview of our Privacy Program for ADP Clients is located here: https://www.adp.com/privacy.aspx.

1. Types of Personal Data

This Privacy Statement explains our practices with regard to personal data collected by WorkMarket for its own business purposes.

Personal data is any information that can be used to identify, locate, or contact a natural person.

Some examples of personal data include your name, username, mailing address, telephone numbers, email address, geographic location, user profile information, customer account information, financial and tax information, or other information about how you use The WorkMarket Platform.

Personal data also includes other information that may be associated with your personal data.

2. How WorkMarket Collects Personal Data & Categories of Personal Data Collected

In most cases, we collect personal data directly from you.

We will ask you for personal data when you interact with us, such as registering on The WorkMarket Platform; setting up an account as a freelancer, contractor, or employee; making a purchase; signing up to receive marketing communications,or providing services, goods, or products. We may also collect additional information from third party data suppliers who enhance our files.

WorkMarket collects the following categories of personal data directly from you: First Name, Last Name, e-mail address, password, login, Address, Business Name, Bank account information, US Tax Identification Number (TIN ), Tax Information (only for Canada-based freelancers), Date of Birth (on IRS Form W-8BEN), Foreign Tax Identifying Number (on IRS Form W-8BEN), Photo, Geo-tracking data, Government ID (such as a driver's license), Skills and qualifications, interests, IP address.

Cookies and Other Tracking Tools. If you interact with us through The WorkMarket Platform, we use cookies and other technological tools to collect information about your device and your use of The WorkMarket Platform.

We treat this information as personal data when it is associated with your contact information.

For more information about cookies and other technologies, please see the section Cookies and Other Data Collection Technologies below.

Location Information. When you enable, or grant permission to use, the GPS/geo-location feature of the WorkMarket Platform through your mobile device, WorkMarket may access and process your location data to provide you platform functionality, including providing such information to actual or potential Clients and other Users of the WorkMarket Platform, finding work near you on the public marketplace, and checking in and out of a work assignment. You may choose to turn off the GPS/geo-location feature, but doing so may impact the functionality of the WorkMarket Platform and all features may not be available to you.

3. How WorkMarket uses Personal Data

The WorkMarket Platform creates efficiences in managing and delivering labor and services by allowing users to match their respective needs. WorkMarket uses your personal data to provide the WorkMarket services, such as managing payments, invoicing, tax reporting, customer service, account management support, and to provide other services related to your relationship with WorkMarket.

WorkMarket also uses your personal data for the following business purposes:

(a) Business purposes for processing personal data pertaining to business and client contacts. personal data pertaining to professionals with whom WorkMarket has a business relationship may be processed as needed:

(1) To initiate, assess, develop, maintain, or expand a business relationship, including negotiating, contracting, and fulfilling obligations under contracts;

(2) For due diligence regarding the individual's qualifications and eligibility for the relationship, including verifying the identity, qualification, authority, and creditworthiness of the professional and obtaining publicly-available information from third parties (such as publicly-available sanction lists from screening companies);

(3) To send transactional communications (such as requests for information, responses to requests for information, orders, confirmations, training, and service updates);

(4) For account management, accounting, finance, and dispute resolution purposes (such as accounts receivable, accounts payable, account reconciliation, cash management, or money movement) and for consolidated management and reporting;

(5) To assure quality control and to enforce company standards and policies;

(6) For risk management and mitigation, including for audit and insurance functions, and as needed to license and protect intellectual property and other assets;

(7) For security management, including monitoring Individuals with access to the website, applications, systems, or facilities, investigation of threats, and as needed for any data security breach notification;

(8) To anonymize or de-identify the personal data.

(b) Business Purposes for processing personal data pertaining to freelancers and consumers and other individuals. Personal data pertaining to consumers and other individuals may be processed as needed:

(1) To provide the information, product, or service requested by the individual, and as would be reasonably expected by the individual given the context in which the personal data was collected, and the information provided in the applicable privacy statement given to the individual (such as for personalization, remembering preferences, or respecting individual rights);

(2) For due diligence, including verifying the identity of the individual, as well as the eligibility of the Individual to receive information, products, or services (such as verifying age, employment, or account status);

(3) To send transactional communications (such as requests for information, responses to requests for information, orders, confirmations, training materials, and service updates);

(4) To manage the individual's account, such as for customer service, finance, and dispute resolution purposes;

(5) For risk management and mitigation, including for audit and insurance functions, and as needed to license and protect intellectual property and other assets,

(6) For security management, including monitoring Individuals with access to the website, applications, systems, or facilities, investigation of threats, and as needed for any data security breach notification; and

(7) To anonymize or de-identify the personal data.

(c) Business-necessary processing activities. WorkMarket may process personal data as needed (i) to protect the privacy and security of the personal data it maintains, such as in connection with advanced security initiatives and threat detection; (ii) for treasury operations and money movement activities; (ii) for compliance functions, including screening Individuals against sanction lists in connection with anti-money laundering programs; (iv) for business structuring activities, including mergers, acquisitions, and divestitures; and (v) business activities, management reporting, and analysis.

(d) Development and improvement of products and/or services. WorkMarket may process personal data to develop and improve WorkMarket's products and/or services, and for research, development, analytics, and business intelligence.

(e) Relationship management and marketing. WorkMarket may process personal data for relationship management and marketing. This purpose includes sending marketing and promotional communications to individuals who have not objected to receiving such messages as may be appropriate given the nature of the relationship, such as product and service marketing, investor communications, Client communications (e.g., HR compliance alerts, product updates, and training opportunities and invitations to ADP events), customer satisfaction surveys, supplier communications (e.g., requests for proposals), corporate communications, and WorkMarket news.

WorkMarket uses your personal data for secondary purposes such as:

4. Why and How Personal Data is disclosed by WorkMarket

WorkMarket does not provide your personal data to third parties for their own marketing purposes. We limit our sharing of your personal data to:

We may also use and disclose information about you that is not personally identifiable. For example, we may publish reports that contain aggregated, anonymized, and statistical data about our clients. These reports do not contain information that would enable the recipient to contact, locate or identify you. These reports also do not contain identifiable company information.

5. Cookies and Other Data Collection Technologies

When you visit, use The WorkMarket Platform, or receive digital communications from us, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.

For example, when you visit our website, we place cookies on your device. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the "help" section of your browser to learn about cookie preferences and other privacy settings that may be available.

WorkMarket also uses Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. We use Flash Cookies for security purposes and to help remember settings and preferences similar to browser cookies, but these are managed through a different interface than the one provided by your web browser. To manage Flash Cookies, please see Adobe's website at http://kb2.adobe.com/cps/526/52697ee8.html or visit www.adobe.com. WorkMarket does not use Flash Cookies or similar technologies for behavioral or interest-based advertising purposes.

Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.

We collect many different types of information from cookies and other technologies. For example, we collect information from the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the Internet Protocol ("IP") address assigned to the device you use to connect to the Internet. An IP address is a unique number that devices use to identify and communicate with each other on the internet. We may also collect information about the website you were visiting before you came to WorkMarket and the website you visit after you leave our website.

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without reference to personal data. For example, we use information we collect about website users to optimize our website and to understand website traffic patterns. In some cases, we do associate the information we collect using cookies and other technology with your personal data. This Privacy Statement applies to the information when we associate it with your personal data.

WorkMarket has relationships with third party advertising companies to place advertisements on this website and other websites, and to perform tracking and reporting functions for this website and other websites. These third party advertising companies may place cookies on your computer when you visit our website or other websites so they can display targeted advertisements to you. These third party advertising companies do not collect Personal Data in this process, and we do not give Personal Data to them as part of this process. This Privacy Statement does not cover the collection methods or use of the information collected by these vendors. For more information about third party advertising, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org. You may opt out of being targeted by many third party advertising companies by visitingwww.networkadvertising.org/consumer/opt_out.asp or http://preferences.truste.com/truste/.

Although our website currently does not have a mechanism to recognize the various web browser Do Not Track signals, we do offer Individuals choices to manage their preferences that are provided in the previous sections above. We do expect our third party advertising companies to use reasonable efforts to respect browser Do Not Track signals by not delivering targeted advertisements to website visitors whose browsers have a Do Not Track setting enabled. However, we understand that some companies do not have this capability today. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/.

WorkMarket uses Google Analytics as a third party vendor. For information on how Google Analytics uses data, please visit "How Google uses data when you use our partners sites or apps", located at http://bit.ly/2jXZ13Y.

6. Mobile Applications

WorkMarket offers the Application that allows you to access your account, interact with us online, and receive other information via your mobile device. Personal data collected by WorkMarket via our mobile applications is protected by the terms of this Privacy Statement.

7. Communication Preferences

You may limit the information you provide to WorkMarket. You may also limit the communications that WorkMarket sends to you. To opt-out of emails, simply click the link labeled "unsubscribe" at the bottom of any email we send you.

Please note that if you are currently receiving services from WorkMarket and you have decided to opt-out of emails, this will not impact the messages we send to you for purposes of delivering such services.

If you have questions about your choices or if you need assistance with opting-out, please contact us via email to [email protected]. You may also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.

8. Access, Correction, Erasure, and Other Individual Rights

WorkMarket respects your right to access, correct, and delete your personal data, or object to the processing of your personal data. If you have an online account, you may log into your account to access update, or delete the information you have provided to us. Additionally, you may contact [email protected] to request access to your data, and to exercise any of the individual rights afforded to you by ADP's Business Code, or by applicable data protection laws and regulations. You may also write to us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and detailed information about the changes you would like to make. WorkMarket will respond to requests as soon as possible and in accordance with applicable data protection laws.

9. Automated Decision Making/Profiling

In some instances, our use of your personal data may result in automated decisions being taken. Automated decisions mean that a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without human review. For example, we may use your personal data to match you with companies looking to engage freelancers. These actions/automated decisions are necessary to provide you with our Services and related support. We have implemented measures to safeguard the rights and interests of individuals whose personal information is subject to automated decision-making.

When we make an automated decision about you, you have the right to contest the decision, to express your point of view, and to require a human review of the decision. You can exercise this right by contacting the Global Data Privacy and Governance Team at [email protected].

10. Information Security

WorkMarket is committed to maintaining the appropriate organizational, technical, and physical controls to protect personal data entrusted to WorkMarket. These controls protect personal data from anticipated threats and hazards and unauthorized access and use. WorkMarket will strive to provide security that is proportional to the sensitivity of the personal data being protected. Additional information about ADP's Global Security Organization may be found at http://www.adp.com/trust.

You should also take steps to protect yourself, especially online. When you register at The WorkMarket Platform, choose a strong password, and do not use the same password that you use on other websites. Do not share your password with anyone else. WorkMarket will not ask you for your password in an unsolicited phone call or in an unsolicited email. Also remember to sign out of the website and close your browser window when you have finished your work. This is to ensure that others cannot access your personal data and correspondence if they have access to your device.

11. Data Retention

WorkMarket will retain your personal data for as long as necessary for the purposes for which the personal data is processed. WorkMarket follows a Global Records Information Management ("RIM") Policy and has established records retention schedules for all types of personal data that WorkMarket processes. Personal data is retained in accordance with the records retention schedules to ensure that records containing personal data are retained as needed to fulfill the applicable business purposes, to comply with applicable laws, or as advisable in light of applicable statutes of limitations.

When the retention period has expired, records containing personal data will be securely deleted or destroyed, de-identified, or transferred to archive, in accordance with ADP's RIM Policy.

12. International Data Transfers

WorkMarket is headquartered in the United States of America. Your personal data may be accessed by or transferred to the United States or elsewhere in the world in accordance with the ADP Business Code.

13. Privacy Statements of Third Parties

This Privacy Statement only addresses the use and disclosure of information by WorkMarket. Our Suppliers, Business Partners, and other Third Party websites that may be accessible through The WorkMarket Platform have their own privacy statements and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by third parties prior to providing them with information or taking advantage of an offer or promotion.

14. Job Applicants

If you have applied for employment with WorkMarket, the personal data submitted with your job application will be added to our recruitment system and used for recruitment and other customary human resources purposes in accordance with the ADP Applicant Privacy Statement.

15. Individuals Located in the European Economic Area

In addition to the rights already listed in this Privacy Statement under Section 8 and Section 9, you also have the right to data portability. A data protection officer for the European Economic Area ("EEA") has been appointed and can be reached at [email protected]. You may reach the data protection officer via mail at the address below.

Data Protection Officer - EMEA
ADP Europe SAS
31 Avenue Jules Quentin
92000 Nanterre
France

16. Changes to this Privacy Statement

From time to time, we may update this Privacy Statement to reflect new or different privacy practices. We will place a notice online when we make material changes to this Privacy Statement.

17. ADP Group Companies bound by this Privacy Statement

For a listing of ADP Group Companies bound by this Privacy Statement and the Privacy Code for Business Data, please click www.adp.com/privacy/pdf/A2CoBDC.pdf

18. How to Contact Us

Please contact us if you have questions, or comments. You may reach us via email at [email protected], or via mail at address below. If you send us a letter, please provide your name, address, email address, and detailed information about your question, comment, or complaints.

WorkMarket
Global Data Privacy and Governance Team
MS 325
One ADP Boulevard
Roseland, NJ 07068-1728 USA

19. How to Lodge a Complaint

If you believe that WorkMarket has not handled your personal data properly or that it has breached its privacy obligations, under any applicable data protection laws or the Business Code or of applicable law, you may file your complaint in writing to the address above, or via email, to the Global Data Privacy and Governance Team at [email protected]. The Global Data Privacy and Governance Team will investigate each complaint and notify you within a reasonable timeframe of the outcome of the investigation. If you are not satisfied by the resolution WorkMarket proposes, you may lodge a complaint in accordance with the provisions of the Business Code.