Privacy Policy

Revised December 14th, 2023

Introduction

MovePlus Inc. and its affiliates (“MovePlus”, “we” “us” or “our“) is committed to protecting and maintaining the privacy of personal information it collects and processes.

MovePlus provides a Global Talent Mobility platform (“Platform”) that empowers HR teams to effectively deploy, manage, assess and engage employees across the world. We enable businesses to deliver mobility as part of a broader talent strategy, encompassing traditional relocations and assignments, – with a focus on enhanced employee experiences. MovePlus keeps companies and employees engaged and compliant wherever their work happens.

This privacy notice (“Notice”) describes MovePlus’s role and privacy practices as they pertain to accessing information about MovePlus via our Websites, or events offered by or related to MovePlus or in engaging MovePlus or using our Platform (together, the “Services”).

This Notice distinguishes between the following activities:

MovePlus Visitors and Attendees. This relates to people who visit MovePlus’s Websites (“Visitors”) as well as companies and people who register to attend MovePlus’s corporate events (“Attendees”). MovePlus acts as a Controller of such data.

Agreements with Customers
This relates to any business contact details of personnel at a company that enters into an Agreement (“Customer“) relevant to entering into or administering delivery, of the Services (the “Agreement”) or to the extent necessary for communicating information about the Services under the Agreement and in managing MovePlus’s invoicing and accounts. MovePlus acts as a Controller of such information. The MovePlus local entity with which you contract will also be a Controller.

MovePlus Platform
This relates to confidential or proprietary information of Customers submitted to the Platform through the Customer Agreement (collectively, “Customer Data”). The Customer (g., your employer or another entity or person) that entered into the Agreement controls the Customer-MovePlus instance of the Services and any associated Customer Data. Additional terms related to privacy may be addressed in the applicable Agreement related to you or your company’s use of the Services. In this case, MovePlus acts as a service provider to the Customer and MovePlus’s Customer is the Controller. Any access to Customer Data by MovePlus is only to the extent permitted and directed by MovePlus’s Customer in order to support the Customer-MovePlus instance of the Services. Privacy Notice does not apply to any third-party applications or software that integrate with the Services (“Third Party Services”), or any other third-party products, services or businesses.

Websites Covered

This Notice applies to the Websites that link to this Notice and the Services, including, but not limited to: https://moveplusmobility.com (collectively referred to as “MovePlus Websites”).

Information We Process

When you use MovePlus’s Services or otherwise engage with us, we may process from or about you, information by which you can be identified either directly or indirectly (“Personal Information“) which may include the following.

MovePlus Vistors and Attendees

MovePlus may collect and receive Visitor and Attendee information, in a variety of ways.

- Contact Information– Information such as your name, company title, role, email and/or postal address that for example, you provide if you fill in any forms such as a ‘contact us’ form or if you submit a question or otherwise correspond or engage with us, including by email or phone.
- Event Information– When you register for or attend a corporate event or webinar, MovePlus will ask you to provide basic Attendee contact information, including your name, company, title, email address and information about the event registered for and or attended (“Attendee Information”).
- Usage Information– Information relating to your online visit:- Technical information – such as your Internet Protocol (IP) address used to connect your device to the internet, information about your device, browser type and version, time zone setting, operating system and operating platform.- Activity information – including the Uniform Resource Locators (URL), clickstream (including the date and time), information viewed or searched for, page response times, download errors, length of visits to certain pages, content interaction information.- Cookies – as described within our cookie consent management tool and as further set out below

Agreements with Customers

- Contact Information (as described above).

MovePlus Platform

- User Information – Customers or its employees granted access to the Services (“Authorized Users”) and who submit Customer Data to the MovePlus – Customer instance of the Platform.
- Usage Information – Where you use the Services under the Agreement the Platform collects Usage Information as described above, in addition to user login information.

Customer Data – Any Personal Information submitted through the Platform is at the discretion of the Customer and under their control. Such data may include Customer employee contact and role details, placement information, documentation required under immigration laws, payroll and compensation information and talent management records. It may also include, but not be limited to, other personal identifiers such as date of birth, tax or social security number, driver’s license number, or financial account details. MovePlus is not responsible for the authenticity of information submitted by Customer or Authorized User while using the Platform.

Purposes for Processing

MovePlus processes Personal Information from or about you in the following ways:

MovePlus Visitors and Attendees
- Unless we are required to obtain your consent, we will use this information in our legitimate interests where we have considered that these interests are not overridden by your rights to:
  – Ensure content is presented in the most effective manner for and your device,
  – Provide any information you request from us, including in responding to any queries you have submitted,
  – Administer our Websites and Services for internal operations, including troubleshooting, data analysis, testing and statistical purposes,
  – Keep our Websites and Services safe and secure,
  – Analyze the effectiveness of our social media channels and advertising we serve,
  – Register you for events and administer your attendance,
  – Participate in a focus group, and
  – Allow you to participate in interactive features when you choose to do so.
- With your consent, where required, to send you our marketing communications and deliver cookies, including updates leading up to and following an event, and when providing more information to you regarding MovePlus and our selected partners. Every marketing email you receive from us will have instructions on how to update your contact information or manage your communication settings, including the option to opt-out of further marketing emails.

Agreements with Customers
- Take steps to enter into any Customer contract or uphold our obligations arising out of a Customer contract, in particular:

– To administer the Customer account under the Customer contract
– Keep a record of the account, including receipt of payments
– Notify you of changes to our Services.

MovePlus Platform

When you log in to the Platform, the Platform stores information that you or your Employer (our Customer) submits and uses. While in some cases you can make certain information private to you, by default your information is available to other Authorized Users of the Customer based on their role permission configuration selections enabled by your employer. Any access to Customer Data by MovePlus personnel is only to the extent authorized by the Customer in order to support the functioning of the Customer-MovePlus instance of the Services and as outlined in our Agreement between MovePlus and your company.

Aggregated data

MovePlus may aggregate the metadata and Usage Information of you with regards to the MovePlus Websites and/or Services so that the results are non-personally identifiable with respect to you (“Aggregated Anonymous Data”). MovePlus may use the Aggregated Anonymous Data:

for its own internal statistical analysis
to develop and improve the Services, and
to create and distribute reports and other materials regarding use of the Services. To be clear, MovePlus does not have the right (or ability) to publicly identify you as the source of any Aggregated Anonymous Data.

A Cookie is a small piece of information that a website and online service can store via your Internet access device for later retrieval. MovePlus uses Cookies and other similar technologies in our Websites and Services that help us collect Information. When you use our Services or visit our Websites, any of them may place a Cookie within the memory of your internet access device.

Cookies enable you to be remembered when using that device and can be used to manage a range of features and content as well as storing searches and presenting personalized content. They allow us to distinguish you from other Visitors or Authorized Users and helps you to receive a good experience. Cookies also allow us to secure access-controlled areas of our Websites and Services.

A number of Cookies we use last only for the duration of your online session and expire when you close your browser. We may also use permanent Cookies or server-side constructs to help us track use of our Services by Authorized Users, such as the number and frequency of visits to our pages and which parts of our Services are visited.

We use these Cookies and other technologies on the basis that they are necessary for the performance of a contract with you or because using them in in our legitimate interests (where we have considered that these are not overridden by your rights and, where required, where you have consented to their use. More information about the Cookies we use and the choices available to you is available within our cookie consent management banner and tool

Our Disclosure of Personal Information

MovePlus will not sell, license, trade, or rent your Personal Information. MovePlus will not otherwise disclose your Personal Information except as described within this Notice and within the Agreement. In this regard we may share Personal Information with:

A member of the MovePlus Group
Which means our affiliates, our ultimate holding company and its subsidiaries, who support our processing of Personal Information.
Business Partners
We may share Personal Information with partners of MovePlus in connection with Services that these individuals or entities perform with us, provided that these agents, contractors or partners are restricted from using said information in any way other than to the extent necessary to provide Services.
Organizations acting on our behalf
We may share Personal Information with third-party service providers (e.g., email service providers, analytics services, data infrastructure hosting storage and processing facilities) to let them perform business functions for us or on our behalf, subject to appropriate safeguards. We do not permit our service providers to use Personal Information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
To Comply with Laws or Enforce our Rights
We may also disclose Personal Information we receive if required by law, such as to comply with a subpoena, or similar legal process, or in response to a government request. We also may be required to disclose Personal Information in response to a lawful request by public authorities in efforts to meet national security or law enforcement requirements. To protect and defend the rights, property or safety of MovePlus or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues, we may disclose Personal Information to relevant parties.
During a Change to MovePlus’s Business
We may disclose Personal Information in connection with any merger, acquisition, debt financing, sale of company assets, or other business transaction in which data could be transferred to third parties as one of our business assets subject to the terms of the Privacy Notice.
With Consent
Additionally, we may share your Personal Information with third parties when we have your consent to do so, including as indicated in the event registration form when registering for a MovePlus event to which you may specifically opt-in to share your Personal Information with MovePlus event partners. If you choose to share your Personal Information with MovePlus event partners by opting in to do so at event registration, your Personal Information will be subject to applicable business partners’ respective privacy statements. Customers determine their own policies and practices for the sharing and disclosure of Personal Information of its Authorized Users, and MovePlus does not control how they or any other third parties choose to share or disclose Personal Information.

As a company with affiliates and Websites hosted in the US Personal Information will be processed in the United States when you engage with our Services as a Visitor or Attendee or in the case of Customer Data where our support for the functioning of the Customer-MovePlus instance of the Services may include support provided by MovePlus from the United States. In cases where this involves a transfer of Personal Information outside of Europe, we will take steps to implement appropriate legal safeguards, for example, implementing standard contractual clauses where appropriate.

Choice

Where permitted in our legitimate interest, or subject to your consent, where required by law, MovePlus may contact you with our newsletter or promotions by email.

When you receive newsletters or promotional communications from us, you may “opt-out” by following the unsubscribe instructions provided in emails you receive from us or by contacting us directly at the contact information below.

How we protect Personal Information

Personal Information we process is stored on our secure servers. While MovePlus Services are typically accessed via single sign on, where you have been given (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

How long we keep Personal Information

We will retain your Personal Information for as long as your account is active or as needed to provide you Services. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our Agreements.

We may also retain aggregate information for research purposes and to help us develop and improve our Services. You cannot be identified from aggregate information retained or used for these purposes.

Updating Your Personal Information

Depending on from where or how you access our Services (such as a Visitor or Attendee), you may have the right under certain circumstances to:

Be provided with a copy of your Personal Information held by us;
Request your data be corrected or erased;
Request that we restrict the processing of your Personal Information (while we verify or investigate concerns with this information for example);
Object to further processing of your Personal Information, including the right to opt-out of further marketing (as mentioned in the ‘Choices’ section above) or to withdraw your consent where the processing of your Personal Information is based upon consent; and
Request that your provided Personal Information be moved to a third party.

You may email us at info@moveplusmobility.com We will respond to your request within 30 days, when permitted or required by law.

Where you accessing our Services in Europe and your request is not satisfactorily resolved by us, you may approach your local EU data protection authority (see https://commission .europa.eu/law/law-topic/data-protection/data-protection-eu_en or for those in the UK, the data protection authority is the Information Commissioner.

If you are an Authorized User of a Platform Customer, you can view your Personal Information by accessing the profile feature of the Platform. Should you need to modify, remove, or delete the Personal Information you provided, such requests should be directed to the MovePlus Services administrator at your company, where he/she can send an email to info@moveplusmobility.com or use the “feedback” or “help” button available in those Services.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to: management@moveplusmobility.com