Privacy Policy

If you are an individual employee or prospective employee of a ConfluxHR customer, this Notice does not apply to you. For more information on your privacy rights and your employer’s privacy practices, please refer to your employer’s privacy notices. Under applicable privacy laws, we are a Data Processor under the GDPR or a Service Provider under CPRA, and your employer is the Data Controller under the GDPR or the Business under CPRA.
If you are a ConfluxHR customer, please see Section 12 of this Notice for information on the collection, use, and sharing of Customer Data, including Personal Information.
This Notice applies to Visitors, Users, and ConfluxHR’s Prospective Employees, Employees, and Independent Contractors (“individuals” or “you”).
This Notice applies to Personal Information, as defined below, we collect to provide you with certain products and services (collectively, “Services”). This Notice does not apply to anonymized, de-identified, or aggregate information if it is not Personal Information.
This Notice describes the rights available to you regarding our use of your Personal Information (defined below). Use of Personal Information collected through the ConfluxHR Services shall be limited to the purposes of providing the Services for which the individual has engaged ConfluxHR, as described in this Notice, and otherwise with your consent. Some information provided to us that may, either alone or when connected with other information to which we may have access, individually identify you.
 

Personal Information is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household.
Below are the categories of information, including Personal Information that we may have collected or shared for a business purpose as permitted by law and depending on the Services you receive:

Visitor Information

We collect your name, address, title, company name, employer, business phone number, and email address when you contact us to register for an event, request information, or register for a free trial. We also document the services you purchase from ConfluxHR.
We collect browsing and search history, usage of, and information regarding your use of our applications or website using cookies. For more information about cookies, please see Section 5 below. This information may be used to create anonymous data to help us better understand customer preferences and needs. We draw inferences from the information we collect when you visit our website, use our app, or interact with our tools, widgets, or plug-ins.
We collect the city and state location of your device, which may include GPS-based, Wi-Fi-based, or cell-based location information. You can disable the collection of location information by our app at any time in your device location settings.
We may collect information via audio recordings of calls when you call our customer service.
We collect cookies, as managed by you, as described in Section 5 of this Notice.

User Information

Every customer identifies a user (account owner, primary contact, or secondary contact) before using ConfluxHR. We collect your name, title, business phone number, and email address. We use your information to set up the account and for service-related communications or to provide you with our newsletter when you request it.

Collection of Face data

With the user’s sole discretion, we may collect certain types of face data to provide our services. This may include photographs, facial recognition patterns, or other biometric identifiers related to an individual’s face. The data is collected directly from users through the use of our mobile application.

We retain Personal Information about you necessary to fulfill the purpose for which that information was collected and, if applicable, in accordance with your employer’s contract with us, consistent with applicable laws. For example, we generally retain information regarding our payroll services for at least ten years from the date of our last interaction/account closure/etc., in compliance with our obligations under applicable laws or for longer if required to do so according to our regulatory obligations or where we believe necessary to establish, defend, or protect our legal rights or those of others. When we destroy your Personal Information, we do so in a way that prevents that information from being restored or reconstructed.

Below are the sources from which we may receive your Personal Information:

• directly from you when you inquire about our Services
• from your device when you access our website, mobile app, and other online services
• from third parties that assist us in providing relevant Services

We may combine the Personal Information that you provide us through our website with other information we have received from you or your employer, whether online or offline, or from other sources such as from our service providers.

Required Cookies

These cookies are required for proper operation of our website and the use of our Services. For example, cookies enable you to access the website. A “persistent cookie” remains on your hard drive for an extended period. We use persistent cookies to determine from where you were referred to our website, as well as the last user ID that you used to log in. ConfluxHR may set and access ConfluxHR persistent cookies on your computer; persistent cookies are required to use the ConfluxHR® Services.
We collect only strictly necessary cookies within the ConfluxHR application.

Functional Cookies

Functional cookies allow us to analyze the usage of our site to evaluate and improve its performance. They are used to provide a better user experience on the site, such as by measuring interactions with content or remembering settings. They are also used to recognize and count the number of visitors accessing the website and see how visitors move around the site.

 Tracking Pixels

We may place tracking pixels in our Applicant Tracking System (ATS). These pixels are used for analytics purposes, including tracking statistical information around when an email sent to you is opened.

Advertising Cookies

We partner with third-party ad networks to manage our advertising on other sites and with third-party analytics companies to assist us with analyzing the use of our own website. These third-party companies use cookies, web beacons, pixel tags, and related technologies to collect information about your activities on this and other websites to provide you with targeted advertising based on your interests and to provide measurement and analytic services.
To learn more about Microsoft’s privacy practices, see privacy.microsoft.com/en-us/privacystatement; to opt-out of interest-based advertising with Microsoft, see https://about.ads.microsoft.com/en-us/resources/policies/personalized-ads.
To learn more about Google’s advertising policies, see policies.google.com/technologies/ads; for your ad settings with Google, see adssettings.google.com; and for Google’s ad personalization, see policies.google.com/technologies/partner-sites.
To learn more about LinkedIn’s privacy practices, see linkedin.com/legal/privacy-policy; to opt-out of interest-based advertising from LinkedIn, see www.aboutads.info/choices and www.youronlinechoices.eu and www.youradchoices.ca/choices.
To learn more about Twitter’s privacy practices, see twitter.com/en/privacy; to opt out of interest-based advertising from Twitter, see https://optout.aboutads.info.
To learn more about Facebook’s privacy practices, see facebook.com/policy.php; to opt out of interest-based advertising with Facebook, see http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.

We only disclose your personal information (i) at your express request or at the direction of your employer; (ii) to our partner or co-sponsor with your consent, and (iii) to our service providers for the business purpose(s) described below.
We will only use your Personal Information when the law allows us to. We may use or disclose the Personal Information listed in Section 2 of this Notice for the following purposes:

Business Purposes

ConfluxHR uses information, including Personal Information, provided by you to provide the Services and for business purposes such as:

• Processing your registration for a ConfluxHR event, request for information, or a free trial.
• Processing and fulfilling orders, billing, implementation, service improvement, research, marketing, and for other general business purposes.
• Conducting internal research to develop and demonstrate the technology.
• Keeping a record of our transactions and communications.
• Conducting audits and reporting related to transactions and interactions, including online interactions, you may have with us or others on our behalf.
• Delivering marketing communications (emails, calls, invitations, etc.) under applicable law or with your consent.
• Delivering user surveys, customized content, and analytics on our websites or app.
• Operating and improving our website, performing analytics, and improving our Services.
• Helping to protect you and us from fraud or economic loss and protecting your health, safety, or welfare.
• Detecting, analyzing, and preventing security incidents and other fraudulent or illegal activity.
• Identifying, debugging, and repairing errors in our systems, websites, or app that impair existing functionality.
• Short-term, transient use of Personal Information that is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Consent

ConfluxHR may disclose your Personal Information when you provide your consent and intentional direction. For example, when you request content or register for an event, you consent to receive marketing communications from ConfluxHR and our third-party partner or co-sponsor of that content or event. For example, you may consent to participate in marketing, product, or customer service research or user surveys.
You may always opt out of receiving marketing communications by unsubscribing or submitting a privacy rights request. Please Contact us.

Legal Proceedings.

ConfluxHR will share your information, including Personal Information, to respond to investigations, court orders, and legal processes or to investigate, prevent or act regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, violations of ConfluxHR’s Terms of Service, or as otherwise required by law. If ConfluxHR is required by law or an order of a court of competent jurisdiction to disclose your information, ConfluxHR will promptly notify you of this requirement, if permitted by the court or applicable law, so that you may seek a protective order or other appropriate relief.

Service Providers

ConfluxHR may also share Personal Information with our service providers, who help us to provide the Services such as cloud storage, security, application communications, customer support, backup, and data analytics.

Merger, Acquisition, Sales

If ConfluxHR is involved in a merger, acquisition, restructuring, or sale of all or a portion of its assets, equity, or similar transaction, Personal Information may be transferred to the acquiring person or entity, and you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of Personal Information, as well as any choices you may have regarding Personal Information. We will use reasonable efforts to direct the acquiring person or entity to use your Personal Information in a manner that is consistent with our Privacy Notice.

The security of your Personal Information is important to us. When you enter information into our systems, we encrypt the transmission of that information using secure socket layer technology (SSL).
ConfluxHR maintains a comprehensive written information security program that complies with applicable law and generally accepted industry standards. Our program includes appropriate administrative, technical, and physical safeguards, procedures, and practices to protect Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about the security on our website, the ConfluxHR® web application owned and operated by ConfluxHR, or the Services, please see our Security page and contact us.
ConfluxHR and its representatives will never request your account credentials. You should never share your ConfluxHR account information, including your username and password, with anyone else. We recommend that you use a unique password for your ConfluxHR account that is not associated with other websites. You should check your ConfluxHR account regularly to ensure that your Personal Information has not been tampered with or altered. You should only use the Services within a secure environment.
Any suspicious activity regarding your account, including automated messages or calls from parties you cannot identify, should be reported to ConfluxHR using the contact information below.

You may make certain choices regarding your Personal Information as permitted under applicable privacy laws. You may make these choices free of charge except as otherwise permitted under applicable law. We may limit our response to your requests as permitted under applicable law.

Right to Rectify or Correct

You may rectify or correct Personal Information that ConfluxHR has collected about you directly or indirectly, including Personal Information collected by a service provider or contractor on our behalf.
If you have an online account or profile with us, you may update your Personal Information by accessing your account through the website and mobile app. Alternatively, you may submit your request using our toll-free number or via our online form. Please see our Contact Information.

Right to Request Deletion

You may request that ConfluxHR delete your Personal Information, subject to certain limited exceptions. For example, we may retain an archived copy of your records consistent with applicable law to continue to provide Services or for other legitimate business purposes. We will use commercially reasonable efforts to honor your requests.
You may submit your request using our toll-free number or via our online form. Please see our Contact Information.

ConfluxHR Communications
Service-related Communications:  ConfluxHR will send a welcome email to Users for billing purposes and, at times, may send Service-related announcements. A User may not opt out of service-related emails, as this is part of the ConfluxHR® Services.

Marketing Communications: You may choose to stop receiving our newsletter or marketing emails or texts by following the unsubscribe instructions included in each of these emails or texts, or you can contact us.

Our website includes links to other websites whose privacy practices may differ from those of ConfluxHR. Our Services include links to third-party applications with privacy practices that may differ from those of ConfluxHR. If you submit information to any of those sites, your information is governed by the privacy policies that apply to those sites. We encourage you to carefully read the privacy notice of any website or application you visit.

Our website offers publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request the removal of your Personal Information from our blog or community forum, please contact us.
We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us.
Our website includes social media features, such as the Facebook Like button and widgets, the Share this button, or interactive mini-programs that run on our site. These features may collect your IP address and which page you are visiting on our site and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy notice of the company providing the features.

The following tables set out how we use and share Visitor and User Personal Information and our legal basis for doing so:

Visitors : Purpose of Processing Legal Basis

• To provide the Service to you
• Art. 6(1)(a) – Consent
• Art. 6(1)b) – Performance of a contract
• For us or our partners or co-sponsors to market our/their products and services to you
• Art. 6(1)(a) – Consent
• To comply with legal obligations
• Art. 6(1)(c) – Compliance with legal obligations

Users : Purpose of ProcessingLegal Basis

• To provide the Service to you
• Art. 6(1)b) – Performance of a contract
• To comply with legal obligations
• Art. 6(1)(c) – Compliance with legal obligations
• For more information about our GDPR compliance, please see our security profile.

Individual Privacy Rights

Your privacy rights as a Visitor or User include the following:

Right to be Informed: You have the right to be informed about the collection and use of your personal data.

Right to Access: You have the right to view and request copies of your Personal Information. If you have an online account or profile with us, you may access your Personal Information via your account through the website or mobile app.

Right, to Rectify or Correct: You have the right to update the Personal Information that ConfluxHR has collected about your directly or indirectly, including Personal Information collected by a service provider or contractor on our behalf. If you have an online account or profile with us, you may update your Personal Information by accessing your account through the website and mobile app.

Right to Request Erasure: You have the right to request that ConfluxHR erase your Personal Information, subject to certain conditions.

Right to Data Portability: You have the right to request that ConfluxHR transfer data that we have collected to another organization or directly to you under certain conditions.

Right to Restrict Processing: You have the right to request that ConfluxHR restrict the processing of your personal information under certain conditions.

Right to Withdraw Consent: You have the right to withdraw previously granted consent to process your personal information.

Right to Object to Processing: You have the right to object to ConfluxHR’s processing of your personal information under certain conditions.

Right to Object to Automated Processing: You have the right to object to decisions being made with your information solely based on automated decision-making or profiling. ConfluxHR does not currently engage in automated decision-making or profiling. If you have questions, please contact us.

Privacy Questions and Concerns
To speak with or file a complaint with our Data Protection Officer, please contact us. You may also lodge a complaint with your supervisory authority.

As discussed in Section 2 above, this Notice does not apply to individual employees or prospective employees of ConfluxHR customers. Such individuals should access the customer or employer’s privacy notice.
If you are a ConfluxHR customer or employer, this section describes how your customer Data is collected, used, and disclosed.

Customer Data collected by a ConfluxHR Customer as a Data Controller or Business

ConfluxHR customer “Data” is defined as all information provided, inputted, or uploaded to a customer database in the ConfluxHR® Service by a customer on their behalf.

Customer Data collected by ConfluxHR as a Data Processor or Service Provider

ConfluxHR may also collect customer Data, including Personal Information included in the Data, under the direction of its customers and has no direct relationship with the individuals whose Personal Information it processes. ConfluxHR may collect Personal Information that identifies, relates to, describes, references, or is reasonably capable of being associated with the customer, including location data. Note that precise location will only be collected with permission and in connection with the use of our mobile app and certain ConfluxHR® features if enabled by the customer. Customers are not required to use such features, and individuals are not required to consent to the collection of location data, but such features may not be available without location data. ConfluxHR may collect only strictly necessary or required cookies within the ConfluxHR application.

How We Use and Disclose Customer Data

ConfluxHR will not disclose customer Data except as compelled by applicable law or as expressly authorized by the customer in the Terms of Service or in writing and will only retain and use the Data for the purpose of providing the Customer with the Service or to complying with applicable laws, including:

Legal Purposes

ConfluxHR will share customer Data, including Personal Information included in Data, to respond to investigations, court orders, and legal processes or to investigate, prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, violations of ConfluxHR’s Terms of Service, or as otherwise required by law. If ConfluxHR is required by law or an order of a court of competent jurisdiction to disclose customer Data, ConfluxHR will promptly notify the customer of this requirement, if permitted by the court or applicable law, so that the customer may seek a protective order or other appropriate relief.

Service Providers

ConfluxHR may also share customer Data, including Personal Information included in Data, with our service providers, who help us to provide the Services such as cloud storage, security, application communications, customer support, backup, and data analytics. We will ensure that those service providers are obligated to protect customer Data under contract terms that are no less protective than those set out in this Privacy Notice.

Mergers, Acquisitions, Sales

If ConfluxHR is involved in a merger, acquisition, restructuring, or sale of all or a portion of its assets, equity, or similar transaction, your Data, including Personal Information included in the Data, may be transferred to the acquiring person or entity, and the customer will be notified via email and/or a prominent notice on our website of any change in ownership or uses of Customer Data, as well as any choices the customer may have regarding their Data. We will use reasonable efforts to direct the acquiring person or entity to use customer Personal Information in a manner that is consistent with our Privacy Notice.

Privacy Rights Requests

Customers are responsible for processing privacy requests from their prospective employees, employees, or independent contractors who have data in the ConfluxHR Service. If we receive the request, we will forward the request to the customer to process according to applicable privacy laws. Customers may access, correct, amend, or delete the Data without ConfluxHR’s involvement, but ConfluxHR will assist the customer as needed.

Cookies

ConfluxHR collects only required cookies within the ConfluxHR application.

Privacy Concerns and Complaints

ConfluxHR will forward any concerns or complaints from your employees to you.

We reserve the right to amend this Notice at our discretion and at any time. We will do so by updating this Notice. Amended terms take effect upon being incorporated into this Notice, and your continued use of the website or association with your employer following the posting of any changes constitutes acceptance of any updated terms. If the changes will materially affect the way we use your Personal Information in connection with Services that we have already collected, we will notify you or your employer.

You may be able to request this Notice in another language where we provide such notices in the ordinary course of business or in an alternative format if you have a disability. Please contact the Privacy Office below to request an alternative format.