Privacy Notice

HUMANSCALE PRIVACY POLICY

Last Updated: January 25, 2023

Table of Contents

Who Is This Policy For And What Does It Cover

This Privacy Policy (“Policy”) explains how Humanscale Corporation, Humanscale International Holdings Ltd., and subsidiary, parent and affiliated companies (collectively, “Humanscale” or “us”) collect, use, and disclose Personal Information about you through our websites and other online products and services (collectively, our “Services”), when you interact with us on social media, or when you otherwise interact with us. This Policy also explains related rights and choices you have.

You may see other privacy notices when we collect your Personal Information for certain purposes. Those notices supplement this Policy. 

We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review this Policy whenever you access our Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

What is Personal Information?

When we say “Personal Information,” we mean information that can reasonably be linked to a particular individual or their household. Generally speaking, your Personal Information includes your unique identifiers (full name, phone number, email address, user name, etc.), and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you. 

“Non-Personal Information,” on the other hand, has been anonymized, aggregated or de-identified such that it cannot reasonably be linked to a particular individual or their household.

Personal Information We Collect And How We Collect It

Information You Provide to Us

When you purchase our products or services or open an account with us, we ask you to provide certain information such as your name, email, account password, address, phone number, mailing address, and payment information. We also collect information when you participate in any interactive features of our Services, fill out a form, participate in a contest or promotion, take a survey, attend an event we host, interact with us at a trade show, webinar, apply for a job, communicate with us via third party social media sites, request customer support, or otherwise communicate with us.

If you apply for a job with us, we will collect your contact details, other Personal Information that you provide as part of your job application (including your resume and our application form), details of assessments that we perform or that you provide to us, information that you provide at interviews, recordings of video interviews, and any personal data provided to us about you by your references.

Information About Your Use of Our Services

When you access or use our Services, we automatically collect information about you, including:

• Log Information: We collect log information about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address, your city or general geographic location and the page you visited before navigating to our Services.  
• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Information Collected by Cookies and Other Tracking Technologies:  We use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see “Your Choices” below.

Information We Collect from Other Sources

We may obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from our resellers and dealers, business partners, advertising networks, social media platform and networks, and service providers.

If you apply to a job opportunity with Humanscale, we may collect information that is publicly available on third party websites or through third party vendors such as current and previous employers, education information, licenses, associations, professional references.

With your consent, we may seek employment references, carry out background checks, including collection of criminal background, credit history and motor vehicle records, and seek other confirmatory information about you. Please only provide the details of employment references and other third parties if they have given you permission.

How We Use Personal Information

We use the information we collect to provide, maintain, and improve our Services, such as to deliver products you order, maintain and service accounts, process and fulfill orders and transactions, process payments, provide financing and to customize your shopping experience with us.  We may also use the information we collect to:

• Send you technical notices, updates, security alerts, support and administrative messages and to respond to your comments, questions and customer service requests;
• Communicate with you about products, services, offers, and events offered by Humanscale, our resellers and dealers, and others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage and activities in connection with our Services;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Humanscale and others;
• Personalize and improve our Services and provide advertisements, content or features that match user profiles or interests;
• Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
• Contact you about your job application or alternative career opportunities within Humanscale, assess your suitability for the role to which you are applying, or seek your feedback about our recruitment process;
• Comply with our legal obligations; and
• Carry out any other purpose described to you at the time the information was collected.

We may use Non-Personal Information for any purpose.

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Humanscale and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit the Digital Advertising Alliance, or if you are in the European Economic Area (“EEA”), please visit the European Interactive Digital Advertising Alliance.

Google Analytics

We use or may use third-party analytics services, such as Google Analytics or Facebook Pixels, to evaluate your use of the Site, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information related to the Site. Google Analytics is a web analytics service provided by Google, Inc., (“Google”). Google Analytics places cookies on your computer to help the website analyze how users use the Site. The information generated by the cookie about your use of the site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of the website, compile reports on website activity for website operators and provide other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information regarding Google Analytics, please visit Google's website and pages that describe Google Analytics, such as https://policies.google.com/privacy?hl=en.

HOW WE DISCLOSE PERSONAL INFORMATION

We will not share Personal Information except in the following circumstances:

• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf. For example, we use iCIMS, Inc. to operate the recruitment pages on our website as our processor. Please note that iCIMS will also act as independent controller when it anonymises your information and uses it for its own purposes. Please see iCIMS' privacy notice and data processing addendum for more information;
• For ergonomic assessments, including ergoIQ, with your employer as necessary to implement workstation improvements;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Humanscale or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among Humanscale and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
• With your consent or at your direction.

We may also share Non-Personal Information with third parties for any purpose.

SOCIAL SHARING FEATURES

Our Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa.  Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

DATA RENTION

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for as long as we have an ongoing relationship with you, for legitimate business purposes, or as otherwise required by law or legal process.

TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

Humanscale Corporation is based in the United States and has operations around the world. We process and store information in the United States, Germany, and other countries. When we transfer your personal data, we take steps to ensure that your personal data receives an adequate level of protection.

YOUR CHOICES

Managing Personal Information

You may update, correct or delete information about you at any time by logging into your online account, if applicable.  You may also request to update, correct or delete information about you by emailing us at privacy@humanscale.com or, if you are a resident of the European Economic Area, UK, or Switzerland, at euprivacy@humanscale.com. Please note that we may retain certain information as required or authorized by law or for legitimate business purposes.  We may also retain cached or archived copies of information about you for a certain period of time.

COOKIES

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. You may also adjust your cookie preferences by visiting our privacy preference center here. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Universal Opt-Out Signals

We recognize the Global Privacy Control (GPC) as a universal opt-out signal. If your browser sends a GPC signal, our site will honor it as a request to opt-out of cookies that might allow third parties to track your activity across different sites or applications. You can learn more about GPC here: https://globalprivacycontrol.org/ 

Your browser may offer a Do Not Track (DNT) setting. If you turn that setting on, your browser sends a signal to websites indicating that you don’t want to be tracked over time or across third party sites. We don’t currently respond to DNT signals because there is not a common understanding of how to process them or a consensus on what “tracking” means.

Promotional Communications

You may opt out of receiving promotional emails or text messages from Humanscale by following the instructions in those communications or by logging into your online account. If you opt out, we may still send you non-promotional communications, such as those about your account, orders you place, or our ongoing business relations.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA, UK AND SWITZERLAND (TOGETHER, EUROPE)

The following additional information is for individuals in Europe.

Lawful Basis for Processing

 We process your personal data on the following lawful basis:

• We need to use your personal data to perform our responsibilities under our contract with you, for example to deliver products that you ordered from us, or prior to entering into a contract with you, for example when you apply for a job vacancy.
• We have a legitimate interest in processing your personal data. For example, if you are a customer, we may process your personal data to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
• We have your consent to do so. For example, if you are not a customer, we may seek your consent to send you marketing communications. 
• We need to comply with the law or establish, exercise or defend legal claims.

Data Subject Requests

You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. You also have a right to information about matters set out in this notice. For example, you may contact us for further details about our retention policy and international data transfers. If you would like to exercise any of these rights, you may contact us as indicated below. You may also correct your personal data by logging into your online account or by emailing us at euprivacy@humanscale.com.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

How do we secure your personal data?

We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of the personal data we hold. We also seek to ensure our third-party service providers do the same.

We will endeavour to use the least amount of personal data as is required for each purpose. We will employ pseudonymisation and anonymisation techniques, where appropriate. Our staff will access your personal data on a “need to know” basis.

Job Applicants in Europe

When you apply for a role with Humanscale, the personal data that you provide will be held and processed by or on behalf of Humanscale for the purpose of assessing your suitability for the role you have applied for and for business administration purposes. 

All information requested as part of your application is mandatory and regrettably we will be unable to process your application in the absence of this information.

Humanscale recruitment is managed in the first instance by our Recruitment team based in the USA who support our leadership teams internationally by sourcing applicants for vacant roles and assisting with the shortlisting of candidates, the scheduling of interviews and the presentation of offers to successful candidates. We enter into standard contractual clauses to safeguard your personal data in respect of international data transfers.

We will generally retain your application details for 12 months, unless longer retention is necessary to complete the selection process, follow your instruction, comply with the law or to establish, exercise or defend legal claims.

CALIFORNIA RESIDENTS

This section makes additional disclosures to California (“CA”) residents (i.e., “consumers”), and describes rights they have under the California Consumer Privacy Act of 2018, as amended (the “CCPA”).  This disclosure does not reflect our processing of California residents' Personal Information where an exception under California law applies. If you work for us, please see our Privacy Notice to California Employees, available from Human Resources, which describes how we collect, use and disclose your Personal Information in connection with your role as our employee or independent contractor. You can learn more about the CCPA here:  https://oag.ca.gov/privacy/ccpa

• CA Personal Information Collected. Consistent with the "Collection of Information" section above, we have collected the following categories of Personal Information about California residents within the past 12 months:
  • Identifiers, such as name, address, email address, cookie ID or other unique device identifier
  • Personal information as defined under the California safeguards law, such as contact information and financial information;
  • Commercial information, such as payment or transaction information;
  • Internet or network activity information, such as browsing history and interactions with our website;
  • Inferences drawn from any of the Personal Information listed above to create a profile about an individual's preferences and characteristics, for example;
  • Professional or employment-related information, such as your employment history (if you apply for a job with us);
  • Education information, such as degree obtained (if you apply for a job with us);
  • If you receive an offer of employment from us, background check information and information that the CCPA defines as “Sensitive Personal Information,” including social security, driver’s license, state identification card, or passport number.
• Sources of CA Personal Information. We collect Personal Information from CA residents using the sources disclosed in the "Collection of Information" section above.
• Uses and Disclosures of CA Personal Information. We use and disclose Personal Information as described in the "Use of Information" and "Sharing of Information" sections above.
• “Sale” or “Sharing” of CA Personal Information. Under the CCPA, you have the right to request to opt-out of the “Sale” of your Personal Information (which the CCPA defines very broadly to include some arrangements that do not involve the exchange of data for money) and the “Sharing” of your Personal Information with third parties (which the CCPA defines as sharing for purposes of cross-site targeted advertising). In the past 12 months, we have Sold or Shared the following categories of Personal Information (to the categories of recipients listed):
  • Identifiers (to analytics and advertising partners)
  • Personal information as defined under the California safeguards law (to analytics and advertising partners)
  • Internet activity information (to analytics and advertising partners)

We do not knowingly Sell or Share the Personal Information of minors under 16 years of age.

• Data Retention. We keep your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). We may remove personal information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, we may delete personal information from our database at any time and without providing any reason.
• Rights to Request to Know, Delete or Correct. As a California resident and subject to certain exceptions, you have the right to request more information about how we process your Personal Information (“Request to Know”), and to correct and/or delete your Personal Information.
• Right to Limit Use and Disclosure of Sensitive Personal Information. If a business collects sensitive personal information* for the purpose of inferring characteristics about you, you have the right to request that the business limit its use and disclosure of your sensitive Personal Information to that use and disclosure which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods and services.  Humanscale does not collect Sensitive Personal Information for the purpose of inferring characteristics about you.

*The CCPA’s definition of Sensitive Personal Information includes: social security number; driver’s license or state identification number; complete account log-in credentials; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email and text messages (unless the business is the intended recipient of the communication); genetic data; biometric information; health information; and information concerning sex life or sexual orientation.

• Right to Non-Discrimination.  You will not be penalized for exercising your rights under the CCPA.

How to Exercise Your CCPA Rights With Humanscale

To request to opt-out of the Sale or Sharing of your Personal Information, click on the “Do Not Sell or Share My Personal Information” link at the bottom of our website’s homepage.

To request to Know, Delete or Correct, you may email us at privacy@humanscale.com or call us toll-free at (800) 400-0625. We will undertake to verify that the individual making the request is the individual or an authorized representative about whom we have collected Personal Information by matching the identifying information that the individual has provided with the Personal Information maintained by us or through the use of a third party service provider. You can designate an authorized agent to make an Access, Deletion or Correction request under California law on your behalf in certain circumstances. If you use an authorized agent for this purpose, we may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request on your behalf. If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with California law. If we deny your request, we will explain why.

VIRGINA RESIDENTS

Virginia residents who interact with a business in a consumer context (as opposed to a business-to-business or employment context) have certain rights under Virginia’s Consumer Data Protection Act (“CDPA”), including:

• To confirm whether or not a business is processing the consumer’s Personal Information and to access such Personal Information;
• To correct inaccuracies in the consumer’s Personal Information;
• To delete Personal Information provided by or obtained about the consumer;
• To obtain a copy of the consumer’s Personal Information that the consumer previously provided to the business in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another business without hindrance (if the data is processed by automated means)
• To opt out of the processing Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling in furtherance of decisions that produce legally or similarly significant effects concerning the consumer.

How to Exercise Your CDPA Rights With Humanscale

To opt-out of targeted advertising on our Services, please visit our privacy preference center here.

To exercise other rights under CDPA, please submit a request to privacy@humanscale.com. After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it.

If we decline to act on your request, you have a right to appeal. To submit an appeal, please contact us at privacy@humanscale.com. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reason for the decision. If your appeal is denied, you can contact the Virginia Attorney General to submit a complaint at Office of the Virginia Attorney General, 202 North Ninth Street, Richmond, VA 23219.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at:

Humanscale Corporation

5675 DTC Blvd

Suite 100

Greenwood Village,

CO 80111

+1 800 400 0625

Humanscale International Holdings Ltd.

DA Industrial Estate

Poppintree, Finglas

Dublin 11

Ireland

+353 (0)1 858 0910