Blue Marble Global Payroll (also referred to as “we” or “us”) recognizes that users may have concerns about privacy issues as they navigate the Internet. This Privacy Policy applies to the information we collect on our website, http://www.bluemarblepayroll.com (the “Site”), and it explains how we collect, use, disclose and secure such information.

As described below, Blue Marble participates in the U.S.-Swiss Safe Harbor and the U.S.-E.U. Privacy Shield programs. With the exception of those sections of this Privacy Policy, this Privacy Policy only applies to the personal information that we collect online; it does not apply to the personal information we collect on behalf of our customers related to our payroll data aggregation service; such personal information is subject to our customer’s privacy policy and practices, and we will collect and process this information only as instructed or permitted by our customer. In such cases, our client is the data controller and Blue Marble is the data processor.

U.S.-Swiss Safe Harbor Program

Blue Marble Payroll complies with the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information obtained from Switzerland and has self-certified its adherence to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement with the U.S. Department of Commerce. To learn more about the Safe Harbor program, and to view Blue Marble Payroll’s certification, please visit http://www.export.gov/safeharbor.

Please e-mail any comments or questions regarding our safe harbor compliance to privacy@bluemarblepayroll.com. If you have a complaint regarding the use of your personal information that cannot be resolved with us directly, you may contact the JAMS using the procedures at http://www.jamsadr.com/safe-harbor-claim.

U.S.-E.U. Privacy Shield Program

Blue Marble Payroll complies with the U.S.-E.U. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information obtained from European Union member countries. Blue Marble Payroll has certified that its processing of personal information from E.U. member countries is in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (the “Principles”). You may view our certification here: https://www.privacyshield.gov/list. Blue Marble Payroll is subject to the investigatory and enforcement authority of the Federal Trade Commission.

Information We Process. We collect information from and about individuals in the E.U. in accordance with the Privacy Shield principles. Specifically, we collect the following categories of information from our customers, including prospective customers: contact information and payment information. We process this information for the purposes described in in the Use of Information section below.

We also collect and process personal information about E.U. individuals as a data processor on behalf of our customers, which includes: name, government identifier (as required), salary information, age of date of birth, financial information (e.g., bank account information for purposes of processing payroll), employer data, and other information as supplied by our customer or otherwise required by law for payment processing. The scope of information that we collect may vary based on the particular customer and/or country in which the customer is based. We use personal information we receive from our customers for the process of providing services to our customers as well as for purposes required by law, such as in response to a valid request from law enforcement. We also use data in the aggregate for analytics purposes, e.g., evaluating the use of our services as well as for product improvement).

Accessing Personal Information. The Privacy Shield Principles provide individuals located in the E.U. whose personal information we process with the right to access their personal information in order to review, correct, amend or delete information processed under the Principles. Employees of Blue Marble’s E.U. customers who would like to access their personal information may log in and update their profile or may email us at privacy@bluemarblepayroll.com.

E.U. individuals whose personal information we process on behalf of a Blue Marble customer (as a data processor) should first contact the Blue Marble customer, who is the controller of your personal information, to access their personal information; Blue Marble will work with its customers to provide individuals the necessary access about what personal information is processed.

Transfers to Third Parties. As described in the How We Share the Information We Collect section below, to provide our services to our customers, we transfer personal information that we receive about E.U. persons to third parties (our service providers, law enforcement, and other third parties as set forth below) in the United States. We contractually require third parties located outside of the E.U. to which we transfer personal information to provide the same level of protections as the Principles. We do not transfer personal information to a third party for its own marketing purposes. Blue Marble Payroll remains responsible for the personal information we receive and transfer under Privacy Shield.

In accordance with our legal obligations, we may also transfer, subject to a lawful request, personal information to public authorities for law enforcement or national security purposes.

Contacting Us, Complaints and Dispute Resolution. E.U. individuals who have questions or complaints about how we process their personal information may contact us at privacy@bluemarblepayroll.com. We will work to resolve your issue and respond no later than 45 days after receipt.

If you are unable to resolve the issue directly with us, you may file, free of charge, a complaint with our independent dispute resolution provider JAMS located in the United States. For more information about JAMS dispute resolution process or to file a complaint, please visit https://www.jamsadr.com/eu-us-privacy-shield.

Individuals may also submit complaints through their local Data Protection Authority (DPA). We will work with the Department of Commerce to resolve any complaints forwarded by a DPA. Finally, if we are unable to resolve any complaints through any of the above methods, an E.U. individual may invoke binding arbitration in accordance with the Privacy Shield Framework.

Information Collected

Generally, we collect the following types of information about the users of our Site, including registration information, as well as usage and related information that we collect automatically.

Information We Collect Directly. Users may visit our Site without registering, but you must register to use any of the personalized services. To register you must submit your name, e-mail address and contact information, as well as additional information. You must also create a login and password. We also collect information from users via contact and other forms on the Site, and allow users to sign up to receive information and emails from us.

Information We Collect Automatically. We automatically collect certain types of information whenever a visitor interacts with the Site. For example, we collect certain “traffic data” and related data, including a visitor’s IP address, referring URL, page view and other interactions with the Site (including date and time stamps, and time spent on our Site), the number of and frequency of visitors to our Site and other usage information. This information helps us determine which parts of the Site visitors find most valuable as well as how we can continually improve the services we provide.

Use of Information

We use your information to provide our services and as described below.

  • Customer Service. To contact users regarding their account status, to respond to inquiries, and for other customer service-related purposes.
  • Marketing. In accordance with local requirements, to contact customers about special promotions, product release notices, and other information we think may be of interest to customers.
  • Optimization and Personalization. To tailor the content and information that we may send or display, to offer location customization (where permitted by applicable law), personalized help and instructions, and to otherwise personalize your experiences on out Site.
  • Improve and Analyze Services. To assess how customers use our services, to improve our services, and to develop new products and services.

In addition, we may use aggregate and de-identified information for various other marketing, research and analysis purposes.

How We Share the Information We Collect

We may share your information as follows:

  • Service Providers. We may disclose the information we collect from you to third party vendors, service providers, or agents who perform functions on our behalf.
  • Business Transfers. If we are acquired by or merge with another company, or if substantially all of our assets are transferred to another company (including as part of bankruptcy proceedings), we may transfer the information we have collected from you to the other company.
  • In Response to Legal Process. We may disclose the information we collect in order to comply with the law, a court orders, subpoenas or other legal process.
  • To Protect Us and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our terms of use or this privacy policy, or as evidence in litigation in which we are involved.

In addition, we may share aggregate or de-identified information about users with third parties for marketing, research or similar purposes.

Cookies and Tracking Technologies

We use “cookies” and other tracking technologies (e.g., clear GIFs) on our Site to collect usage and related information about Site visitors. A cookie is a small file that your Web browser places on your computer’s hard drive to identify you as a user. You may disable and erase cookies through your browser. To do this, consult the help features in your browser. However, if you disable cookies, some Site features (e.g., login) will not function properly.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Third-Party Analytics. We may use automated devices and applications, such as Google Analytics, along with other analytic means, to evaluate usage of our Site and services. We use these tools to help us improve our Site and services, including the performance and user experiences for each. These third-party devices and applications may use cookies and other tracking technologies to perform their services. Such third parties may combine the information that we provide about you with other information that they have collected. This privacy policy does not cover such third parties’ use of data they collect or obtain.

Do-Not-Track. Currently, our Site does not honor browser Do-Not-Track signals. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third-Party Ad Network section.

Third-Party Ad Networks

We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice PageConsumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

Marketing Choices

We may send promotional or informational emails to you as permitted by applicable law. You may opt-out of such emails by following the opt-out instructions contained in the e-mail or by emailing us at privacy@bluemarblepayroll.com. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional and marketing emails, we may still send you e-mails about your account or any services you have requested or received from us.

Access and Correction

To access or amend your registration information, log in and update your profile or you may email us at privacy@bluemarblepayroll.com.

Links to Other Sites

Our Site may contain links to third-party websites. These links are provided solely as a convenience to users and not as an endorsement by Blue Marble Payroll of the contents on such third-party websites. We are not responsible for the content of linked third-party sites and do not make any representations regarding the content or accuracy of materials on such third-party websites.

Security

We use systems and procedures to safeguard the personal information we collect. However, as no protection measure is 100% secure, we cannot guarantee against unauthorized or illegal access, disclosure, modification, or loss of data.

Questions

If you have any questions about our privacy practices or if you believe that Blue Marble Payroll has not handled your personal information properly, you may also contact Blue Marble Payroll’s Privacy Office at privacy@bluemarblepayroll.com. If you are not satisfied with the resolution of your inquiry, you may bring a complaint before JAMS, as part of the Jams International Safe Harbor Program, http://www.jamsadr.com/safeharbor/.

Privacy Policy Updates

We may update this privacy policy in the future. If we make a material change to this privacy policy that affects how we use and disclose personal information previously collected form you, we will endeavor to notify you by posting notice of the new Privacy Policy on our Site, or by email, if you have provided us with an email address. Any updated privacy policy will be posted to our Site at http://www.bluemarblepayroll.com/privacy-policy.

Last Updated: 09/23/2016