Privacy Policy

Last Updated March 2, 2022

As a provider of workforce management solutions, TreeRing Workforce Solutions, Inc (“TWS,” “we,” or “us”) respects the privacy of our clients and others who use our website, mobile application, products, and services. In connection with providing our services and operating our business and website, we process certain Personal Data, including from our Clients, prospective clients, and, for certain Clients, end-users of our products. We have adopted this Global Data Privacy Policy so that you can learn how we collect, use, and otherwise process your Personal Data. This Global Data Privacy Policy, which includes each of the sub-policies identified below, applies to the Personal Data we collect from you, including via your access to and use of the Services and, for Clients, is incorporated into and is subject to the TreeRing Workforce Solutions Terms of Service, which can be found at: https://www.treeringws.com/agreements. The Global Data Privacy Policy consists of and incorporates each of the following:

TreeRing Workforce Solutions, Inc Privacy Policy for All Personal Data Except U.S. Resident Biometric Data

With the exception of biometric data collected from U.S. residents, which is addressed separately within the Global Data Privacy Policy, this policy explains how TWS processes, uses and discloses all Personal Data it collects, including from Clients, end-users of our products (e.g., Client staff) for those Clients for whom TWS hosts data, prospective clients, and individuals who visit our website. In this Privacy Policy, you will find information regarding:

• Collection and Sources of Personal Data.
  • Personal Data We Receive Directly From You.
  • Personal Data We Host on Behalf of Clients.
  • Personal Data We Receive From Other Sources.
  • Cookies and Tracking Technologies.
• Purposes for Processing and Disclosures of Personal Data.
  • General Purposes for Processing and Disclosures of Any and All Categories of Personal Data.
  • Other Purposes for Processing and Disclosures of Specific Categories of Personal Data.
    • Personal Data We Receive Directly From You.
    • Personal Data We Host on Behalf of Clients.
    • Personal Data We Receive From Other Sources.
  • Data Sales.
  • Data Retention.
  • Protection of Personal Data.
  • International Data Transfers.
  • Your Rights & Choices.
  • Other Important Information about Our Practices.
  • Changes to This Privacy Policy.
  • Contact Us.

Collection and Sources of Personal Data.

Personal Data We Receive Directly From You.

TWS may collect the following categories of Personal Data directly from you:

1. Client Account Data. We may collect Personal Data in connection with Client management and account set-up and management, finance, dispute resolution, and for consolidated management and reporting. Client Account Data may include contact information, billing and banking information, Client account preferences and settings, and Client communications concerning the implementation and maintenance of the Services.
2. Communications Data. We may collect Personal Data that you provide when you express an interest in obtaining additional information about the Services, have questions or concerns about the Services, use our “Contact Us” or similar features, sign up for our emails or attend an event or webinar, or download certain content. Such information may include contact information such as name, job title, company name, phone number, and email address.
3. Human Resources Data. We may collect Personal Data from employees and job applicants, including contact information, social security number, background reports, job history, certain health or dietary information, payroll and banking information, and other Personal Data incident to the employment relationship.
4. Reputation & Creditworthiness Data. We may collect Personal Data in connection with performing diligence on our Clients, prospective clients, Service Providers or prospective service providers, and business partners or prospects. This data may include contact details, information concerning business practices, creditworthiness, reputation and business history, and job titles or roles.
5. Transaction and Payment Data. When you sign up for events or purchase some or all of the Services, we may require that you provide contact information such as name and address, billing information, such as billing name and address, credit card number, or bank account information.
6. Visitor Data. We may collect Personal Data from you when you visit our offices, including your name, who you are visiting, company name, and time and date of arrival and departure.

Personal Data We Host on Behalf of Clients.

TWS processes and stores Personal Data concerning Client staff on behalf of those Clients who have engaged us to do so. In particular, we process the following categories of Personal Data for Clients:

1. Profile Data. We may process general demographic data about you that you or your employer enters into the Services. Profile data may include username, password, first name, last name, address, email, phone number, job title, employee ID, taxpayer ID, gender, date or birth, hire date, termination date, language preference, payroll classification, employment classification, pay rates, work schedules, employment contracts, and labor union affiliation.
2. Service Data. We may process Personal Data collected from you in connection with using the Services, including clock-in time, clock-out time, clock-in location, clock-out location, leave requests, including vacation, sick, and other third-party defined leave reasons, leave accruals, FMLA cases, and hours worked.
3. EU Resident Special Category Data. We may collect certain “special categories” of Personal Data, as identified in the GDPR, from EU residents including photographic images, racial, or ethnic data, biometric data, physical or mental health data, and data concerning religious or other beliefs.

Personal Data We Receive From Other Sources.

We may also receive Personal Data about you from other sources, including:

1. Third-party lead providers from whom we have purchased Personal Data. We may combine this information with Personal Data provided by you. This “Lead Data” may include business contact data, social media data, and usage data (including web user behavior and IP addresses).
2. Consumer reporting agencies or other background investigation or credit check service providers in connection with our collection of Human Resources Data and Reputation and Creditworthiness Data.

Cookies and Tracking Technologies.

When you use the Services, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. For example, when you visit our website, we may place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies can contain and/or automatically collect information, such as a user identification code or IP address, which a website will use to track the pages and number of times you have visited, allowing us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. The data read from these cookies may be linked to Personal Data. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.

Cookies fall into the subcategories below.

1. Essential Cookies. Certain cookies are used for specific purposes that are essential to your secure use and navigation of our website. Without them, TWS may not be able to provide core website functions and features to you, and the website would not operate as well as you or TWS would like. These cookies collect and use information such as your server preferences, single-session data and corresponding identifier, web beacons and log files (detailed below), and other credential-related information. For EU individuals, essential cookies also help inform TWS whether you require, or have already been served, an affirmative consent request in connection with the GDPR. Essential cookies include analytics cookies, which provide us data that allows TWS to better understand its users and improve the website based on what we have learned from that data.
2. Preference Cookies. Other cookies are used to collect and process information about your preferences and similar choices in connection with the website in order to optimize your browsing. Preference cookies include social media cookies, which collect information about your social media usage and other data you may have provided in connection with such usage (if you access the website through a social media website or mobile application, you may have social media cookies). If you wish to modify or change your social media cookies, please visit and review the settings on your applicable social media account(s).
3. Advertising Cookies. To help support the Services and further tailor your experience, TWS uses Google Analytics as a third-party vendor. For information on how Google Analytics uses data, please visit “How Google uses data when you use our partners sites or apps”, located at http://bit.ly/2jXZ13Y.

We encourage you to consider keeping your cookies enabled because if you choose to disable the receipt of cookies, you may not be able to use or benefit from certain features of the website, particularly the features that are designed to personalize your experience.

Most web browsers automatically accept cookies, but generally allow users to modify their browser settings to display a warning before accepting a cookie, to accept cookies only from certain websites, and/or to refuse all cookies.

Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without reference to Personal Data. For example, we use information we collect about website users to optimize our websites and to understand website traffic patterns. In some cases, we do associate the information we collect using cookies and other technology with your Personal Data. This policy applies to the information when we associate it with your Personal Data.

Although our website does not currently have a mechanism to recognize the various web browser “Do Not Track” signals, we do offer individuals choices to manage their preferences, as described above. We do expect our third-party adverting partners to use reasonable efforts to respect browser “Do Not Track” signals by not delivering targeted advertisements to website visitors whose browsers have a “Do Not Track” setting enabled. However, we understand that some companies do not have this capability today. To learn more about browser tracking signals and “Do Not Track,” please visit http://www.allaboutdnt.org/ .

Purposes for Processing and Disclosures of Personal Data.

General Purposes for Processing and Disclosures of Any and All Categories of Personal Data In general, TWS may use and disclose any Personal Data it maintains about you as follows, pursuant to TWS’s legitimate business interests and need to comply with law:

1. To manage and mitigate risk, including for insurance functions, to ensure the proper functioning of the Services, to maintain the privacy and security of our data (such as through threat detection, disaster recovery and business continuity activities), and to conduct audits or investigations, in which case we may disclose your Personal Data to Service Providers, insurance providers, tax or financial authorities or consultants, and legal advisors;
2. As needed to assess and ensure compliance with applicable laws, legal requirements and company policies, to protect our assets (including to license and protect intellectual property) or to investigate or defend against any claims of illegality or wrongdoing (including to obtain legal advice), or in response to a court order or judicial or other government subpoena or warrant, in which case we may disclose your Personal Data to law enforcement, regulators, governmental authorities or other bodies, courts, tax authorities, insurance providers, legal advisors, and mediators;
3. In the event TWS undertakes or is involved in or contemplating (e.g., in connection with due diligence) any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, in which case we may disclose your Personal Data to buyers or purchasers (or potential buyers or purchasers) and their representatives.

Other Purposes for Processing and Disclosures of Specific Categories of Personal Data

In addition to the general purposes for processing and disclosing any category of your Personal Data, the chart below includes other purposes for which we may process specific categories of your Personal Data and to whom such data is disclosed as well as our legal bases for such processing, consistent with the GDPR.

Cookies and Tracking Technologies.

Pursuant to TWS’s legitimate business interests and/or your consent, TWS may use information obtained via Cookies and tracking technologies to personalize and optimize your browsing experience and the Services by:

• Providing you tailored content and ads;
• Enabling social media features;
• Safeguarding against spam and malware;
• Analyzing trends, traffic, and user behavior;
• Administering the website;
• Gathering demographic information about our user base as a whole;
• Tracking web and advertising analytics throughout our website and our affiliate websites;
• Remembering your preferences and voluntarily-submitted information;
• Performing location-related functionalities and analytics;
• Participating in market research; and
• to improve the Services.

TWS may disclose this information to Service Providers, including those used for website and application development and support, IT support, security and hosting, and marketing and promotions management.

Data Sales.

TWS does not and will not sell or rent your Personal Data.

Data Retention.

TWS will only retain your Personal Data for as long as necessary to fulfill the purposes for which it is processed, to comply with applicable Data Protection Laws, or as otherwise required for other legitimate legal purposes. TWS has implemented a Data Retention Policy for all types of Personal Data that TWS processes. Personal Data is generally retained in accordance with the retention schedules defined therein. When the retention period has expired, Personal Data will be securely deleted or destroyed.

Protection of Personal Data.

TWS has implemented and maintains commercially reasonable organizational, technical, and physical controls to protect Personal Data from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, acquisition or access. In each case, TWS will strive to provide security that is proportional to the sensitivity of the Personal Data being protected, with the greatest effort being focused on protecting sensitive Personal Data and other Personal Data whose compromise could result in substantial harm or inconvenience.

Please note that you should also take steps to protect your data. For example, when you register for the Services, choose a strong password, and do not share it with anyone else. TWS will never ask you for your password in an unsolicited phone call or email.

In the event TWS learns of a data security breach, TWS (potentially with the help of others such as third-party forensic investigators, legal counsel, and TWS’s insurance provider) shall investigate and document the facts relating thereto, its effects and the remedial actions taken and shall notify you within a reasonable period of time to the extent required by and in accordance with applicable Data Protection Laws.

International Data Transfers.

TWS is headquartered in the United States of America. Your Personal Data may be stored and processed by TWS in the United States and TWS may transfer Personal Data pertaining to individuals located outside of the United States to our affiliates and suppliers in the United States, as permitted by applicable Data Protection Laws. Therefore, your Personal Data may be processed outside the European Economic Area (“EEA”), and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as the EEA. In this event, we will ensure that such recipient offers an adequate level of protection, for instance by verifying that the recipient is Privacy Shield certified (TWS is self-certified – see the TreeRing Workforce Solutions, Inc Privacy Shield Privacy Policy for Data Transferred to the United States from the EU/Switzerland/UK, below), by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or by asking for your prior consent to such transfer.

Your Rights & Choices.

Communication Preferences.

TWS will send direct marketing materials if you have provided opt-in consent or if applicable Data Protection Laws otherwise permit. You have the right to opt-out of these communications. To opt-out of commercial emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. Additionally, you may opt-in or opt-out of communications by calling us at +1 (855) 861-4381. Please note that if you are currently receiving services from TWS and you have decided to opt-out of promotional emails, this will not impact the messages we send to you for purposes of delivering such services.

Review, Correction, Erasure, and Other Individual Rights.

You have the right to request a copy of the Personal Data maintained by or on behalf of TWS unless otherwise prohibited by applicable Data Protection Laws. If the Personal Data is incorrect, incomplete, or not processed in compliance with applicable Data Protection Laws or this Privacy Policy, you have the right to have the Personal Data rectified, restricted, or erased (as appropriate) subject to applicable Data Protection Law.

Additionally, you have the right to object to the processing of your Personal Data on the basis of compelling grounds related to your particular situation or in connection with any direct marketing communications. Restrictions may be lifted if they were temporary, based on certain grounds such as a dispute about data accuracy or the lawfulness of processing or if TWS is in the process of reviewing an objection request, and the basis of the restriction has been resolved. You will be notified about the removal of any such restriction via email or mail. In addition, once a restriction has been implemented, processing can only resume if you grant explicit consent or you request to lift the original restriction and there is no conflict with applicable Data Protection Laws.

You may contact us using the contact information provided in the “Contact Us” section below to request access to your data and to exercise any of the other individual rights afforded to you by applicable Data Protection Laws. TWS will receive, investigate, document, and respond to requests as soon as possible and in accordance with applicable Data Protection Laws. In cases where the request cannot be fulfilled by TWS, we will use best efforts to notify any third-party processing relevant data of the required correction and/or erasure.

In some cases, requests to delete data may be denied in accordance with applicable Data Protection Laws, including, for example, when the data is still needed for processing, where you gave consent and did not withdraw consent, where there has been a previous processing objection that has been granted, and where the data was processed lawfully or there is a not a legal requirement to delete the data. TWS may also reject the request if it needs access to the data to comply with a law, defend a legal claim or for research/historic/scientific purposes.

Individuals Located in the EEA.

In addition to the rights stated above and below, you also have the right to data portability, as well as the right to be notified of automated decision-making or profiling related to your Personal Data.

Individuals in the EEA, UK, and Switzerland

Individuals located in the EEA, UK, and Switzerland may file a complaint if they believe TWS has violated this policy or applicable Data Protection Law. Please see TreeRing Workforce Solutions, Inc’s Privacy Shield Privacy Policy for Data Transferred to the United States from the EU/Switzerland/UK for additional information concerning how you may file such a complaint. TWS’s Data Protection Officer will receive, investigate, and document each complaint and respond within a reasonable timeframe in accordance with applicable Data Protection Laws of the outcome of the investigation.

California Residents

If you are a California resident, California’s “Shine the Light” law, Civil Code sections 1798.80 – 1798.84, includes provisions for securing and disposing of Personal Data, notifying you of a breach of your Personal Data, and for responding to requests by you asking about the businesses’ practices related to disclosing Personal Data to third-parties for the third-parties’ direct marketing purposes. TWS complies with California Civil Code sections 1798.80 – 1798.84. TWS does not share your Personal Data with third-parties for the third-parties’ direct marketing purposes. For more information about your rights under California’s Civil Code sections 1798.80 – 1798.84, please visit https://leginfo.legislature.ca.gov.

Effective January 1, 2020, the CCPA provides California residents with additional rights related to data privacy.

Pursuant to the CCPA, upon making a verifiable request, California residents may:

1. request (in a format that is portable and, to the extent technically feasible, in a readily useable format that will allow you to transmit it to another entity) access to the specific pieces and categories of Personal Data that we have collected about you over the past twelve months, the categories of sources of that information, our business or commercial purposes for collecting the information, and the categories of third parties with whom the information was shared;
2. submit a request for deletion of Personal Data, subject to certain exceptions, including (without limitation) in the event that we may need to retain Personal Data to complete the transaction for which the Personal Data was collected, detect security incidents or protect against illegal activity, exercise free speech, comply with a legal obligation, or for lawful internal use compatible with the context in which the information was provided by you. If your request is subject to any exception, we may deny your request to delete your data.

Please note that you must verify your identity and request before further action is taken by us. To do so, we may request certain information from you, including a copy of a government-issued ID or other identifier.