OnShift Website Privacy Policy

What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and share information about you in accordance with this Policy.

Information You Provide to Us

Personal Information is any information that can be used to individually identify you from a larger group, such as data including, but not limited to, your:

• first and last name,
• email address,
• telephone number,
• state/region,
• company/organization name,
• job title,
• job level (e.g., Supervisor, Manager, Consultant, etc.),
• job role (e.g., Finance, Human Resources, Information Technology, etc.), and
• comments or messages provided in free text boxes.

When you provide us with Personal Information, we may combine that Personal Information from other data we have collected about you to learn more about you and to provide additional services. For example, your Personal Information may be included to update user profiles, provide services to follow-up on your prior questions or requests, and supplement existing marketing and sales promotional lists.

You may provide us Personal Information when you:

• request information,
• provide requested services,
• update your user profile,
• schedule a demonstration,
• apply for a job,
• subscribe to our emails, and
• register yourself with our Website.

The information that you provide in each case will vary.

Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using our Website. Some of the tools we use to automatically collect information about you may include:

• Cookies. A “cookie” is a small data file transmitted from a website to your computer’s hard drive. Cookies are not used to run programs or deliver viruses to your computer. Instead, we use cookies to help you personalize your online experience. One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize pages on our Website, or register for a subscription service, a cookie helps us to recall your specific information on subsequent visits. When you return to the Website, the information you previously provided can be retrieved, so you can easily use the customized features.

Cookies are usually defined in one of two ways, and we may use both of them:

(1) session cookies, which do not stay on your computer after you close your browser, and
(2) persistent cookies, which remain on your computer until you delete them or they expire.

We may use the following categories of cookies on our Website.

1. Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested, such as maintaining a record of your downloaded items, cannot be provided.
2. Performance Cookies. These cookies collect anonymous information on how people use our Website to help us understand how you arrive at our site, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
3. Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.
4. Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. These cookies remember the websites you visit and that information is shared with other parties.

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.

• Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
• Third-Party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.
• Digital Fingerprinting. We, along with our trusted third-party partners, may use digital fingerprinting technology to create a profile of your device using its features (such as operating system, screen size, plugins, IP addresses, time zone location, and other related characters of the device) to create a trackable profile for that device. In some cases, this profile may effectively pseudonymize the device’s user. We may use this pseudonymized profile in an effort to collect inferences related to activities when visiting certain websites.

The Website may send aggregated, non-Personal Information to HotJar for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance and better understand how our users interact with our Website.

The Website may send aggregated, non-Personal Information to third parties to conduct technical and statistical analysis on the Website’s performance and the behaviors of Website visitors. These parties may use technologies similar to cookies, including local storage and browser fingerprinting to monitor and track Website visitor engagement on this Website and across other websites. 

The Website may send aggregated, non-Personal Information to Google Analytics and Hubspot for the purpose of providing us with the ability to conduct technical and statistical analysis of the Website’s performance. For more information on how Google Analytics and Hubspot support our Website and use information sent from the Website, please review each company’s respective privacy policy available at https://policies.google.com/technologies/partner-sites and https://legal.hubspot.com/privacy-policy.

Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When you initially make contact with us, such as through requesting a white paper or requesting a demonstration of a product, we will add your information to our communications list. If we provide subscription-based services, such as email newsletters, we will always allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed to the service.

You may opt-out of receiving communications from us at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you might affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

Should you have any questions about your Personal Information, please e-mail us at privacy@onshift.com.

Information of Minors

We do not actively seek to gather information from individuals under the age of eighteen (18). We do not target our Website to minors, and would not expect them to be engaging with our websites or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• Assisting you with items such as personalized experiences, facilitation of product usage, and enforcement of Terms of Use.
• Preventing malicious activity and providing you with a secure experience.
• Providing service and support for services you request.
• Providing marketing communications that are effective and optimized for you.
• Keeping you up-to-date with the latest benefits available from us.
• Preventing unwanted messages or content.
• Measuring the performance of our marketing programs.
• Contacting you about services and offers that are relevant to you.

Duration: The length of time we intend to retain the Personal Information we collect from you, including any sensitive information, is for as long as reasonably necessary to carry out our intended business purpose for such information.

How We Share Your Information

OnShift will never sell or share your personal data, including your phone number, unless (a) you consent, (b) as necessary to provide the services you purchased from OnShift; provided that the recipient of such authorized disclosure shall be prohibited from using your personal information for any reason other than as expressly authorized; or (c) as follows:

• Responding to duly authorized information requests from law enforcement or other governmental authorities.
• Complying with any law, regulation, subpoena, or court order.
• Investigating and helping prevent security threats, fraud, or other malicious activity.
• Enforcing or protecting the rights and properties of OnShift or its subsidiaries.
• Protecting the rights or personal safety of OnShift’s employees.

By providing a telephone number to us, you are consenting to be contacted by SMS text message. Message & data rates may apply. You can reply STOP to opt-out of further messaging.

Third-Party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Website may link to third-party websites and services, but these links are not endorsements of these sites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or site and providing any information.

Your Rights Under State Law

California

Pursuant to California Civil Code Section § 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.

Other than as disclosed in this Policy, the Website does not track any users over time and across third-party websites to provide targeted advertising. Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.

Your Consumer Rights

Some state laws in the United States provide consumers with additional rights with respect to their personal information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018 (the “CCPA”) as amended by the California Privacy Rights Act, the Colorado Privacy Act (“CPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). Any personal information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you reside in a state that provides additional rights with respect to your personal information, you may exercise each of your rights as identified below, subject to our verification of your identity.

1. Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
2. Correction. You can correct what personal data our Website database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.
3. Limit Use and Disclosure of Sensitive Personal Information. If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
4. Portability. Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
5. Deletion. You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.
6. Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
7. Non-Discrimination. If a data subject exercises his or her rights under applicable state law, including but not limited to the CCPA, CPA and VCDPA, we shall not discriminate against that data subject by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
8. Exercising your rights. If you are a data subject that has rights under applicable state law, including but not limited to the CCPA, CPA and VCDPA, who chooses to exercise the rights listed above, you can:

1. 1. Submit a request via email at privacy@onshift.com; or
   2. Call us at 1-800-385-1494 to submit your request.

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.  

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

International

We do not warrant or represent this Policy or the Websites’ use of your Personal Information complies with the laws of any jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

For Website Visitors in the European Union (“EU”)

Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR. For the purposes of this Policy, we operate as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Policy.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

The Data Controller is:

NAME: ShiftKey, LLC

ADDRESS: 1621 Euclid Avenue, Cleveland, OH 44115

EMAIL ADDRESS: privacy@onshift.com

You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:

• Access. You may email us at privacy@onshift.com to request a copy of the personal data our Website databases currently contain.
• Automated Processing and Decision-Making. You may email us at privacy@onshift.com to request that we stop using your personal data for automated processing, such as profiling. In your email, please explain how you wish us to restrict automated processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
• Correction or Rectification. You can correct what personal data our Website database currently contains by emailing us at privacy@onshift.com to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
• Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to privacy@onshift.com. In your email, please explain how you wish us to restrict processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
• Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to privacy@onshift.com. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
• Portability. Upon request and when possible, we can provide you with copies of your personal data. You may submit a request via email to privacy@onshift.com. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.
• Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Website by notifying us via email at privacy@onshift.com. Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
• Erasure. If you should wish to cease use of our Website and have your personal data deleted from our Website, then you may submit a request by emailing us at privacy@onshift.com. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.
• Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.

Safeguarding the Information We Collect

We take reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your Personal Information. If you believe your Personal Information has been compromised or accessed without authorization, please notify us immediately.

Changes to this Policy

If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block. You can get to this page from our Website by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at:

Chief Marketing Officer, OnShift
1621 Euclid Avenue #1500
Cleveland, OH 44115

1-800-385-1494

privacy@onshift.com

Last Revised: November 19, 2024