Privacy Policy

Effective Date: July 2nd, 2024 

At WorkStep, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy. 

Remember that your use of WorkStep's Services is at all times subject to our Terms of Service, as may be updated or amended from time to time, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Service. 

You may print a copy of this Privacy Policy by clicking here. 

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon material changes, we will alert you to any such changes by placing a notice on the WorkStep website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our website available at https://workstep.com/ (the “Site”) and the services, features, content or applications offered by Workstep Inc. (“we”, “us” or “our”) (together with the Site, the “Services”). “Personal Data” means any information that identifies or relates to an identifiable individual or could be used to identify a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. Some of our Services are provided to Company Customers pursuant to a SaaS Agreement (such as our our Workstep employee engagement offering) (“Workstep Platform”). Please contact your employer if you have any questions about how your Personal Data is treated by them. 

Categories of Personal Data We Collect

This chart details the categories of Personal Data we collect if you visit our website, sign up for our marketing materials, request a demo, or otherwise engage with us before becoming a Workstep customer. 

Category of Personal Data

Examples of Personal Data We Collect

Categories of Third Parties To Whom We Disclose this Personal Data:

Contact Data
  • First and last name
  • Organization 
  • Email
  • Phone number
  • Timezone
  • Language preference
  • Service Providers
  • Analytics Partners
  • Advertising Partners
  • Parties You Authorize, Access or Authenticate

Device/IP Data
  • IP address
  • IP-address-based location information
  • Device ID
  • Domain server
  • Type of device/operating system/browser used to access the Services
  • Analytics Partners
  • Advertising Partners 
  • Service Providers

Web Analytics
  • Web page interactions
  • Referring webpage/source through which you accessed the Services
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and the Services
  • Service Providers
  • Advertising Partners 
  • Analytics Partners

This chart details the categories of Personal Data that we collect and have collected over the past 12 months in connection with our Workstep HIRE job network offering (please note that HIRE is not currently offered in Canada):

Category of Personal Data

Examples of Personal Data We Collect

Categories of Third Parties To Whom We Disclose this Personal Data:

Contact Data
  • First and last name
  • Email
  • Phone number
  • Timezone
  • Language preference
  • Service Providers
  • Analytics Partners
  • Advertising Partners
  • Parties You Authorize, Access or Authenticate

Profile Data 
  • Login information
  • Service Providers

Device/IP Data
  • IP address
  • IP-address-based location information
  • Device ID
  • Domain server
  • Type of device/operating system/browser used to access the Services
  • Analytics Partners
  • Advertising Partners 
  • Service Providers

Web Analytics
  • Web page interactions
  • Referring webpage/source through which you accessed the Services
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and the Services
  • Service Providers
  • Advertising Partners 
  • Analytics Partners

Consumer Demographic Data
  • Age / date of birth
  • Home address
  • Gender
  • Service Providers
  • Parties You Authorize, Access or Authenticate

Professional or Employment-Related Data
  • Academic institution and degree information
  • Resume
  • Job title
  • Job history
  • Skills
  • Eligibility to work in the US
  • Job search preferences (such as schedule, commute, and wages
  • Service Providers
  • Parties You Authorize, Access or Authenticate

Categories of Data Considered “Sensitive” Under the California Privacy Rights Act as amended by the California Privacy Rights Act

  • Race or ethnic origin
  • Personal data revealing citizenship or immigration status
  • Veteran status
  • Disability status
  • Service Providers
  • Parties You Authorize, Access or Authenticate

Inferences Drawn From Other Personal Data Collected
  • Inferences related to your job candidacy 
  • Service Providers
  • Parties You Authorize, Access or Authenticate

Other Identifying Information that You Voluntarily Choose to Provide

  • Identifying information in emails, letters, texts, or other communication you send us
  • Video and audio content to the extent you choose to engage with us on a video conference
  • Responses to job application or profile questions
  • Service Providers
  • Parties You Authorize, Access or Authenticate

With respect to the Workstep Platform, we may collect Personal Data on behalf of and as determined by our Company Customers, including responses to surveys that we provide on their behalf. In connection with the Workstep Platform, below are categories of Personal Data we collect and have collected in our role as a data controller over the past 12 months:

Category of Personal Data

Examples of Personal Data We Collect

Categories of Third Parties To Whom We Disclose this Personal Data:

Contact Data 
  • First and last name
  • Email
  • Phone number
  • Time zone
  • Language preference
  • Service Providers
  • Advertising Partners 
  • Analytics Partners
  • Company Customer
  • Parties You Authorize, Access or Authenticate

Profile Data 
  • Login Information 
  • Service Providers

Device/IP Data
  • IP address
  • IP-address-based location information
  • Device ID
  • Domain server
  • Type of device/operating system/browser used to access the Services
  • Service Providers
  • Advertising Partners
  • Analytics Partners

Web Analytics
  • Web page interactions
  • Referring webpage/source through which you accessed the Services
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and the Services
  • Service Providers
  • Analytics Partners
  • Advertising Partners

Other Identifying Information that You Voluntarily Choose to Provide

  • Identifying information in emails, letters, texts, or other communication you send us
  • Video and audio content to the extent you choose to engage with us on a video conference
  • Responses to job application or profile questions
  • Service Providers
  • Advertising Partners
  • Analytics Partners
  • Business Partners
  • Parties You Authorize, Access or Authenticate

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

Our Commercial or Business Purposes for Collecting Personal Data

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CCPA regulations and we do not collect or process sensitive personal information with the purpose of inferring any characteristics about California residents.

How We Disclose or Transfer Your Personal Data

We disclose or transfer your Personal Data to the categories of service providers and other parties listed in this section. If you are in the US, depending on state laws that may be applicable to you, some of these disclosures or transfers may constitute a “share” or “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

Company Customers/Employers or Prospective Employers

Legal Obligations

We may disclose any Personal Data that we collect to third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above. 

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a prospective of completed merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it to third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could be used to identify you.  

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, serve advertisements, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). 

We use the following types of Cookies:

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work. 

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking here. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union or United Kingdom, respectively.

For more information about the Cookies we use in connection with the Services, you can access our current list of Cookies and Cookie providers using the Cookie Preferences link in the Site footer or on the My Account page.

Session Replay Technology

We may use session replay technology in order to identify and resolve customer issues, to monitor and analyze how you use our Services, to better understand user behavior, and to improve our Services. By continuing to use the Services, you consent to the use of session replay technology.

Information About Interest-Based Advertisements

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services and on other websites. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.  Users in the United States should visit the US Digital Advertising Alliance website https://digitaladvertisingalliance.org/ and Users in Canada should visit the Digital Advertising Alliance of Canada’s website http://youradchoices.ca/choices.

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal or contractual obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

Personal Data of Children

As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data from or about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@workstep.com.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Except as otherwise specified below, please see the “Exercising Your Rights” section for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@workstep.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data disclosed to each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Personal Data Sales and Sharing Opt-Out and Opt-In

In this section, we use the terms “sell” and “share” as they are defined in the CCPA. We may sell your Personal Data, subject to your right to opt-out of these sales.

We may sell or share your Device ID and Web Analytics data via Cookies to Advertising Partners and Analytics Partners. Our use of Cookies is further described in the “Tracking Tools, Advertising and Opt-Out” section above. Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Certain third parties that provide these Cookies may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” and/or “share” of information and California residents have certain rights when a business “sells” or “shares” Personal Data with third parties, including for purposes of cross-contextual behavioral advertising. We may also sell your Profile or Contact Information (specifically, your name and email address) with Advertising Partners for the purpose of generating leads or otherwise marketing our services to you. 

You can opt out of these sales and the sharing of Personal Data by following the instructions in this section.

In the past 12 months, we have sold or shared the foregoing categories of Personal Data for the following business or commercial purposes:

You have the right to opt-out of the sale or sharing of your Personal Data. You can opt-out using the following methods:

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale or sharing of your Personal Data for at least 12 months. To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Exercising Your Rights Under CCPA

To exercise the rights described in this Privacy Policy, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your name and email address), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@workstep.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@workstep.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

European Union and United Kingdom Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. WorkStep will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@workstep.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Examples of these legitimate interests include (as described in more detail above):

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties. 

EU and UK Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@workstep.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.  

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through WorkStep and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to WorkStep in the U.S. and will be hosted on U.S. servers, and you authorize WorkStep to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

Canada Data Subject Rights and Additional Information

Personal Data We Collect and Use

WorkStep makes the Workstep Platform offerings available to its Company Customers (employers) in Canada and processes Personal Data through this offering on behalf of and in the course of providing Services to such customers. If you have any questions regarding the personal information we process on behalf of one of our customers, we encourage you to first contact the customer directly and/or review their applicable privacy policy. If you signed-up to receive marketing communications from one of our customers and now wish to unsubscribe, please contact the customer directly.

We rely on our Company Customers to ensure that their use of our Services complies with their obligations under applicable privacy laws, and to provide all necessary notice and consents. Except as set out in this Privacy Policy, we do not collect or use personal information from our customers for any purpose other than to provide Services on behalf of our Company Customers.

Canada Data Subject Rights and Choices

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@workstep.com. Please note that in some circumstances, we may not be able to fully comply with your request due to exceptions under applicable law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.  

If we receive a request from an individual to access or update personal information we maintain on behalf of a Company Customer, we will direct that individual to the relevant customer. We will assist our Company Customers wherever possible in responding to individual access requests.

If you have signed-up or otherwise receive our email marketing communications, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Information” section below. Please note that you may continue to receive transactional or account-related communications from us. To withdraw your consent to our use of non-essential cookies, including interest-based advertising, please see “Tracking Tools, Advertising and Opt-Out”.

Sharing of Personal Data 

We and our service providers (including affiliates) may access, store and otherwise process Personal Data outside of Canada (including, for residents of the province of Quebec, outside of Quebec), including in the United States, or other foreign jurisdictions, where we or our service providers are located.

We and our Canadian, US and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. 

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we or our service providers collect, use and disclose your Personal Data or your choices and rights regarding such collection, use and disclosure, please do not hesitate to contact our Vice President of Finance at privacy@workstep.com.

If you are located in the EU or UK, you may use the following information to contact our EU or UK-Based Member Representative: