Privacy Notice

Date Updated: May 14, 2018

Introduction

Velocity Global is committed to maintaining your trust by protecting your personal data. This Privacy Notice explains how we collect, use, share and protect personal data. It also describes the choices available to you regarding the use of your personal data. For purposes of this Privacy Notice, the terms “Velocity Global,” “we,” “us” and “our” shall refer to Velocity Global, LLC and its domestic and international subsidiaries. As you review this Privacy Notice, keep in mind that it applies to all Velocity Global services that do not have a separate privacy policy or that link to this Privacy Notice, which we call the “Services.”

Velocity Global is committed to ensuring that your privacy is protected, and to the extent possible by Velocity Global, that your personal data is secure. Velocity Global shall process your personal data in a transparent and lawful way. Any personal data you provide when using our website located at velocityglobal.com and any other website operated by us from which you are accessing this Privacy Notice (each a “Site”) and our Services will only be used in accordance with this Privacy Notice. Please read this Privacy Notice carefully to understand our policies regarding your personal data. If you do not agree with this Privacy Notice, your choice is to not use our Site and Services. You are responsible for ensuring we have an up-to-date, active and deliverable email address for you and for periodically visiting our Site for changes and updates.

What is Personal Data?

For individuals covered by the General Data Protection Regulation (GDPR), personal data is any information relating to an identified or identifiable natural person. For individuals not covered by GDPR, Velocity Global defines personal data as data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, government issued identification information, education information, payroll information, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

Information That We Collect

Velocity Global processes your personal data to ensure the efficiency and effectiveness of our Services and products, particularly with regard to the following services, each an example of a Service:

  • Professional Employer Organization (PEO)
  • Recruiting – Talent Acquisition
  • Immigration
  • Payroll
  • Consulting Services

Unless otherwise required, we do not collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of genetic data, biometric data in order to uniquely identify a person or data concerning health or sex life and sexual orientation.

How We May Collect Personal Data

We and our service providers may collect personal data in a variety of ways, including:

  • Through the Services: We may collect personal data through the performance of the Services.
  • Offline: We may collect personal data from you offline, such as when you contact customer service or attend our events.
  • From Other Sources: We may receive your personal data from other sources, such as public databases, joint marketing partners, social media platforms and from other third parties.

Data You Provide To Us

We collect and use the personal data you provide directly to us. This data is collected in various online and physical forms and throughout our business relationship.

General and PEO
Contact Data
Financial/Billing Data
Unique Personal Identifiers
Demographic Data
Medical for health benefits only

Recruiting
In addition to the above
Education
Previous Employment
Social Networking Data

Immigration
In addition to the above
Immigration Data

Payroll
In addition to the above
Payroll Data

Consulting Services
This type of engagement is tailored to your needs so the data collected can vary greatly. If we collect personal data during these engagements we will use proper collect and use methods.

Other ways you provide data to us
If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

When you download an e-book, checklist or other content from either our Site or another social media platform, we will collect your name and e-mail address, as well as any other content included in form, in order to send you materials relating to such content.

When you participate in one of our surveys, we may collect additional profile information.

We may also collect personal data at other points in our Site that state that personal data is being collected.

We do not process the following types of data
User generated data (photos, music, text)
Legal data
Data on or about children

Data We Collect Automatically

Velocity Global and our service providers automatically collect information about you when you access our Site. Here are examples of the ways we collection information automatically.

Tracking Technologies

Cookies are small amounts of data that are stored in separate files within your computer’s Internet browser. Cookies are accessed and recorded by the web-sites you visit, and by the companies that show advertisements on these web sites, so that they can recognize the same browser. For more information regarding cookies, please see our cookie policy below.

Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small strings of code that provide a way for us to deliver a small graphic image (usually invisible) on a web page or in an email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed.

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this application, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Google AdWords conversion tracking is an analytics service provided by Google that connects data from the Google AdWords advertising network with actions performed on this Site.

To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

Cookie Policy

Our Site uses cookies to distinguish you from other users of our Site. A cookie is a small file of letters and numbers that we will put on your computer if you agree. This helps us provide you with a good experience when you browse our Site, and also allows us to improve our Site and Services.

We use cookies:
  • which are essential to make our Site work; and
  • help us to improve it by giving us some insight into how the Site is being used.

We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent cookies can be removed by following Internet browser help file directions.

About our cookies:
Cookie Description Links for more information
Convert Pro Used to identify and distinguish users, as well as for analytics and conversion tracking. https://www.convertplug.com/pro/
DoubleClick Used for analytics, monitoring, and conversion tracking. https://support.google.com/ds/answer/2839090?hl=en
Facebook Used to identify and distinguish users, as well as for analytics, targeting, and conversion tracking. https://www.facebook.com/policies/cookies/
Google Analytics/Google Tracking Used to identify and distinguish users, as well as for analytics, targeting, and conversion tracking. https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
https://policies.google.com/technologies/types
LinkedIn Used to identify and distinguish users, as well as for analytics, targeting, and conversion tracking. https://www.linkedin.com/legal/cookie-policy
Microsoft/Bing Used to identify and distinguish users, as well as for analytics, targeting, and conversion tracking. https://advertise.bingads.microsoft.com/en-us/resources/training/universal-event-tracking
HubSpot Used to identify and distinguish users, and remember form field values, as well as for analytics, targeting, and conversion tracking. https://knowledge.hubspot.com/articles/kcs_article/account/hubspot-cookie-security-and-privacy
Wistia Used to track user behavior in videos and to remember where users left off in a video. https://wistia.com/product/hubspot

Use Of Data

We collect and use personal data to ensure we provide you with informative and timely sales and marketing material. During our engagements, we collect personal data so that we fulfil our obligations of the Services.

  • The personal data we collect during the onboarding process for the External Employees (EE) is used to fulfil the contractual obligations of the services for which the EE applied.
  • Any personal data collected to assist with the immigration process is obtained as necessary to fulfill contractual and legal obligations.
  • The payroll data collected is used to comply with all tax and legal obligations.
  • When you apply for an EE position with us, we keep your resume on file because we have a legitimate interest in being able to help you find the perfect position.
  • Additional information collected by us is used to provide a service to both our clients and the EEs. We are the conduit which ties them together and jointly have a contractual and legitimate interest in this information.
  • Some information is collected for Velocity Global’s internal use and to improve our operations. We will obtain consent from users before collecting this type of information.
  • When you download an e-book, checklist or other content from either our Site or another social media platform, the download is part of a series of information and it is in our legitimate interest to provide you with additional emails and marketing materials pertaining to the downloaded materials so that you have the most accurate and up to date information. If you choose not to continue to receive such information, we make it very easy for you to opt-out of these emails.
  • If you register for one of our webinars, we may share your personal data with the co-presenter(s) of the webinar as stated in the registration form of the webinar.
  • In some cases, we use sub-processors to process your personal data.

Communication

We contact you by the email that you have on file with us.  We send transactional emails to individuals with whom we have a business relationship; these are emails regarding our services and you may not opt-out of these emails.  These types of emails provide information to you about any changes that we make that will affect you.   We send marketing emails which contain promotional material about our services and you may opt-out of these emails.  These emails provide valuable information about how we can better serve you or new features that can help you.  If there is a concern regarding your personal data, we will contact you when required to do so by law. To do this, we will use the email address on file for you.

If for any reason you think there is a problem, please let us know by either contacting your Account Manager or by email Privacy@VelocityGlobal.com.

Third Party Sharing

General Sharing

We may share information internally within our family of companies or with third parties for purposes described in this policy. Information collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside of the EEA for the purposes as described in this policy. We utilize standard contract clauses approved by the European Commission, adopt other means under European Union law, and ensure there is a legal basis to process the personal data to legitimize data transfers from the EEA to the United States and other countries.

Sub Processors

We transfer information to vendors, service providers, and other partners who globally support our business, such as providing technical infrastructure services, analyzing how our Services are used, measuring the effectiveness of ads and services, providing customer service, facilitating payments, or conducting academic research and surveys. These partners must adhere to strict confidentiality obligations in a way that is consistent with this Privacy Notice and the agreements we enter into with them. Here are examples of some of the ways we use sub processors to process your personal data.

  • We use third party Software-as-a-Service (SaaS) and other vendors to help us process personal data.
  • We use third party email hosting services to send email.
  • We use third party customer relationship management tools to help with management of business related data.
  • We use third party billing and credit card merchant systems to process payments.
  • We use third party ticketing and help systems to support our customers.

We make no promises regarding the policies or business practices of other third-party websites and encourage you to familiarize yourself with their privacy policies before providing them with your personal data.

  • We may disclose your personal data to our agents or sub processes for the purposes identified above. In such cases, the agent or sub processors will be obligated to use that personal data in accordance with the terms of this Privacy Notice.
  • We will not sell, distribute or lease your personal data to third parties unless we have your permission or are required by law to do so.
  • We may disclose your personal data without your permission to the extent that it is required to do so by United States, European Union or National law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.

Data Subject Rights – Your Choice

Access to Personal Data

If we receive a Data Subject Request from an individual whose data we process on behalf of another party, we will inform them of such a request and work with both the third party and the individual to complete the request.

After we have confirmed your relationship with us and have the proper authorizations, we will provide you with information about whether we hold any of your personal data. You have the right to access the personal data we have about you and you may request that it be corrected, amended, not processed, or deleted by following the directions in this Subject Access Request Policy or by emailing Privacy@VelocityGlobal.com with the subject of Access Request.  We require all our requests to be in writing. You can download the SAR form here.  We will respond to your access request within a reasonable time, under 30 days. We may require additional information from you to allow us to confirm your identity or find your personal data.

If you believe that any personal data we are holding on you is incorrect, incomplete or shouldn’t be processed, please contact us as soon as possible, at the contact information below and we will promptly take the appropriate action.

You have the right to withdraw your consent for any marketing or sales material.  To do this, please sending an email to marketing@VelocityGlobal.com.

Profiling

We will not use your personal data for decisions based solely on automated processing if the decision produces legal effects concerning you or significantly affects you, unless you gave your explicit consent for this processing.

Security

We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate technical and organizational measures to safeguard and secure the personal data we process. No system is 100% secure and your personal data cannot be guaranteed. You must ensure you protect your username and password and do not share it with others. If, despite all our efforts, a data breach does occur, we shall do everything in our power to limit the damage. In case of a data breach which is likely to result in a high risk, and depending on the circumstances, we will inform you about remedial actions to prevent any further damage. We always inform the relevant data controller, supervisory authority or authorities without undue delay.

Data Retention

We will not store your personal data longer than necessary for the purpose for which we have processed your personal data including our legal requirements to retain data after completion of the Services. How long we retain your personal data depends on the type of data, the purpose for which we process it and the laws governing such data.

Changes To Our Privacy Notice

It is our policy to post any changes we make to our Privacy Notice on this page. In some cases, we provide additional notice of changes. If we make material changes to how we treat your personal data, we will notify you by email to the email address specified in your account and/or through a notice in the application or on the Site. The date the Privacy Notice was last revised is listed at the top of this page.

Complaints

If you have a complaint with how we have handled a SAR please let us know and we will try to fix it.  You can email the Data Protection Officer (DPO) at Privacy@VelocityGlobal.com or by calling +1 (303) 309-2894.

If you are dissatisfied with Velocity Global ’s handling of any privacy complaints, if you do not receive timely acknowledgement of your complaint, or your complaint is not satisfactorily addressed please contact the Information Commissioner’s Office in England at https://ico.org.uk/concerns/.

Special Notification for California Residents

Individuals who are residents of California and have provided their personal data to us may request information regarding our disclosures, if any, of their personal data to third parties for direct marketing purposes. Such requests must be submitted to our Marketing Department in writing at:

Marketing Department
3858 Walnut St, Suite 101
Denver, CO 80205

Such requests must include the reference Request for California Privacy Information in the subject line and in the body of the message and must include the e-mail address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted to us if not submitted pursuant to the terms set forth above.

Further Information

If you have any questions about this privacy notice or questions or complaints about the processing of your personal data by Velocity Global, please contact:

Controller:
Data Protection Officer
3858 Walnut St, Suite 101
Denver, CO 80205
303-309-2894
Privacy@VelocityGlobal.com