HR Connect
Privacy Policy

EMR (USA Holdings) Inc. and its related companies in the United States (“Company”, “we”, “our”, or “us”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing HR services to you (our “Services”) and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

• Through the Services.
• In communications, including email, text, chat, and other electronic messages, between you and the Services.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party that does not link to this policy; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Services.

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

The Personal Data That We Collect or Process

“Personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address, social security number, or any other identifier we may use to contact you online or offline).

The types and categories of personal data we collect or process include:

• Account and contact information, including name, address (such as home address, work address, or other address), email address, phone number, username, and other contact information you provide us. Demographic information, including your age, gender, income level, education, or family or marital status.
• Health data
• Location information.
• Content and information you elect to provide as part of your profile.
• Images, voice recordings, and videos collected or stored in connection with the Services.
• Identity document information, such as Social Security and driver’s license numbers.

Some of the information identified above may be considered sensitive data under certain laws. If required under applicable law, we will collect and process sensitive personal data only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information.

We also collect:

• Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.

If we combine or connect non-personal statistical with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Collect Your Personal and Other Data

When you Provide Information to Us i.e. (when you apply for a job with Us, during your employment).

We collect information about you when you interact with our Services.

How we process your Data

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with the Services and any contents, features, information, products, or services that we make available through the Services.
• Provide you with notices about your employment with the Company, including notices regarding benefits enrollment.
• Improve our Services, including by analyzing your information and creating aggregated data derived from your information) to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when Services updates are available and about changes to any products or services we offer or provide though them.
• Fulfill any other purpose, with your consent.
• In any other way we may describe when you provide the information.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

• Estimate our audience sizes and usage patterns.
• Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.
• Speed up your searches.
• Recognize you when you return to our Services.
• Any types of enquiries that may be handled through SMS, such as HR support requests, benefits enquiries, PTO questions, and HR system assistance etc.

SMS Communications

When you choose to receive SMS communications from HR Connect, we collect and process your mobile phone number and any information required to deliver and manage those communications.

SMS communications may be used for HR-related purposes, including HR support requests, benefits enquiries, PTO questions, HR system assistance, and other employment-related communications.

SMS opt-in consent and related messaging data will not be sold, shared, rented, or disclosed to third parties for marketing, advertising, promotional, or other commercial purposes. SMS opt-in information is used solely to provide the requested messaging service and to comply with applicable legal and regulatory requirements.

Data sharing with third parties

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

• To fulfill contractual, legal, regulatory requirements, and ensure compliance.
• For any other purpose disclosed by us when you provide the information.
• For any other purpose we deem necessary to deliver HR services to you. With your consent.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers/members, or others.
• SMS messages and associated personal data may be processed and stored by service providers acting on our behalf solely for the purpose of delivering and supporting the HR Connect messaging service. SMS opt-in consent data and phone numbers collected for SMS communications will not be shared with third parties for marketing or promotional purposes.
• No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All categories of data excluding text messaging originator opt-in data and consent information may be shared where permitted by law and as necessary to provide HR services. Text messaging originator opt-in data and consent information will not be shared with any third parties under any circumstances, including with the individual's consent for marketing or promotional activities.

This addresses both compliance findings:

• Privacy policy includes a no-share clause for SMS opt-in data.
• Removes/improves the consent-based sharing language so that SMS opt-in data is never shared, even with employee consent.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data. The Company complies with all applicable laws.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

SMS Terms and Conditions

By providing your mobile phone number and opting in to receive SMS messages from HR Connect, you consent to receive employment-related text messages regarding HR enquiries, benefits administration, PTO requests, HR system support, and other HR services.

Message frequency may vary based on your interactions with HR Connect.

Message and data rates may apply.

You can opt out at any time by replying STOP to any message. For assistance, reply HELP or contact AskHR@emrgroup.com.

Consent to receive SMS messages is not a condition of employment.

SMS opt-in data and consent information are not shared with third parties for marketing or promotional purposes.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “last updated” date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Contact Information

To ask questions or comment about this privacy policy or our privacy practices, contact us at: AskHR@emrgroup.com.