WorkTango Privacy Notice: California, Colorado & Virginia

Information for California Residents

We collect Personal Data from Consumers and comply with the California Privacy Rights Act (“CPRA”). In addition to our general Privacy Policy available at https://www.worktango.com/privacy, this This California Privacy Notice applies to California residents (“Consumers,” “you,” or “your”).

For the purposes of this California Privacy Notice, “Personal Data” generally means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:

• Publicly available information;
• Deidentified or aggregated data; or
• Information otherwise excluded from the scope of the CPRA.

This Privacy Notice provides the following information to California Consumers:

• Categories of Personal Data we collect;
• Purposes for which we use Personal Data;
• Categories of Personal Data we disclose to third parties;
• Categories of third parties to which we disclose Personal Data; and
• How Consumers can exercise their rights under the CPRA:
  • The rights to access, correct, or delete Personal Data;
  • The right to obtain a portable copy of Personal Data;
  • The right to limit the use of sensitive personal data in certain circumstances; and
  • The rights to opt out of the sharing of Personal Data for behavioral advertising, sales of personal data, or certain profiling.

Categories of Non-Sensitive Personal Data

The table below outlines the non-sensitive categories of Personal Data WorkTango collects about Consumers and whether and how they are disclosed to third parties.

Categories of Sensitive Personal Data

The table below outlines the categories of Sensitive Personal Data WorkTango collects about Consumers and whether they are shared with third parties. WorkTango obtains affirmative consent from Consumers to process the Sensitive Personal Data, in compliance with applicable law.

Use of Personal Data

We use Personal Data for the purposes described above in our general Privacy Policy (see https://www.worktango.com/privacy). Personal Data may also be used or disclosed as otherwise permitted or required by applicable law.

We do not transfer Personal Data for purposes other than those permitted by our agreement with our customers (i.e., to provide our services). Individual customers may have contractual terms that vary or further restrict the permitted uses of data – those specific contracts (when more restrictive) will take precedence over this general privacy policy.

Disclosing Personal Data

We share Personal Data with the following categories of third parties:

• Processors: We use processors to securely handle Personal Data on our behalf and only on our instructions. These companies may not use your Personal Data for their own purposes, but only for the purpose of delivering our services.

Exercising Your Personal Data Rights

California Consumers have the following rights under the CPRA:

• The rights to access, correct, or delete Personal Data;
• The right to obtain a portable copy of Personal Data;
• The right to limit the use of Sensitive Personal Data in certain circumstances; and
• The rights to opt out of the sharing of Personal Data for behavioral advertising, sales of personal data, or certain profiling.

If you are a California Consumer, you can submit a request to exercise your personal data rights under the CPRA by sending an email to privacycompliance@WorkTango.com with the subject line "Privacy Rights Request". To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will use commercially reasonable efforts to verify your identity for this purpose. Any information you provide to authenticate your identity will only be used to process your rights request. Please be aware that we do not accept or process rights requests through other means (e.g., via fax or social media).

We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions.

We reserve the right to decline to process, or charge a reasonable fee for, requests from a Consumer that are manifestly unfounded, excessive, or repetitive.

Behavioral Advertising

The CPRA defines “sharing” as disclosing Personal Data to a third party for behavioral advertising, sometimes referred to as “targeted advertising.” An example of this is displaying advertisements to a consumer where the advertisement is selected based on Personal Data obtained from that consumer's activities over time and across nonaffiliated websites or online applications to predict such consumer's preferences or interests. We share some Personal Data for behavioral advertising. You can opt out of the sharing of your Personal Data for behavioral advertising by submitting a rights request as described above.

Limiting the Use of Sensitive Personal Data

The CPRA provides a right to limit some uses of Sensitive Personal Data. In particular, you may direct WorkTango not to use sensitive Personal Data except as necessary to provide goods or services you have requested. You may submit a request to limit the use of your Sensitive Personal Data by submitting a rights request as described above.

Authorized Agent Requests

The CPRA allows you to designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above. We may require verification of your authorized agent in addition to the information for verification above for Consumers and households.

Contact Us

If you have any questions or concerns regarding this California Privacy Notice, contact us as described in our general Privacy Policy (see https://www.worktango.com/privacy) above.

Last updated: May 15, 2024

Information for Virginia Residents

We collect Personal Data from Consumers as a Controller under the Virginia Consumer Data Protection Act, as amended or superseded from time to time (“VCDPA”). In addition to our general Privacy Policy available at https://www.worktango.com/privacy, this This this VCDPA Privacy Notice applies to Virginia residents (“Consumers,” “you,” or “your”).

For the purposes of this VCDPA Privacy Notice, “Personal Data” generally means information that is linked or reasonably linkable to a particular individual. However, the following categories of information are not Personal Data:

• Publicly available information;
• Deidentified data; or
• Information otherwise excluded from the scope of the VCDPA.

This Privacy Notice does not apply to the information of individuals acting in a commercial or employment context, such as job applicants to WorkTango, Inc. (“WorkTango”) or employees or contractors of WorkTango. Persons acting in those roles should review the applicable CPA Limited Privacy Notice made available by WorkTango.

This Privacy Notice provides the following information to Virginia Consumers:

• Categories of Personal Data we collect;
• Categories of Personal Data we share with third parties;
• Purposes for which we use Personal Data;
• Categories of third parties with whom we share Personal Data; and
• How Consumers can exercise their rights under the CPA:
  • The rights to access, correct, or delete Personal Data;
  • The right to obtain a portable copy of Personal Data; and
  • The right to opt out of targeted advertising, sales of personal data, or certain profiling.

Categories of Non-Sensitive Personal Data

The table below outlines the categories of Personal Data WorkTango collects about Consumers and whether they are shared with third parties.

Use of Personal Data

We use Personal Data for the purposes described above to Consumers at the time of collection, as described in our general Privacy Policy (see https://www.worktango.com/privacy). Personal Data may also be used or disclosed as otherwise permitted or required by applicable law.

We do not transfer Personal Data for purposes other than those permitted by our agreement with our customers (i.e., to provide our services). Individual customers may have contractual terms that vary or further restrict the permitted uses of data – those specific contracts (when more restrictive) will take precedence over this general privacy policy.

Sharing Personal Data

We share Personal Data with the following categories of third parties:

• Processors: We use processors to securely handle Personal Data on our behalf and only on our instructions; these companies may not use your Personal Data for their own purposes.

Exercising Your Personal Data Rights

Virginia Consumers have the following rights under the VCDPA:

• The rights to access, correct, or delete Personal Data;
• The right to obtain a portable copy of Personal Data; and
• The right to opt out of targeted advertising, sales of personal data, or profiling.

If you are a Virginia Consumer, you can submit a request to exercise your personal data rights under the VCDPA via sending an email to privacycompliance@WorkTango.com with the subject line "Privacy Rights Request". You may submit a rights request free of charge up to twice per year. To protect your privacy, you must authenticate your identity before we respond to your rights request. We will use commercially reasonable efforts to verify your identity for this purpose. Any information you provide to authenticate your identity will only be used to process your rights request.

We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. If you believe our response to your rights request is insufficient, you can appeal our decision by contacting Data Privacy Officer at privacycompliance@WorkTango.com and we will inform you of our final decision within 45 days.

We reserve the right to charge a reasonable fee for, or decline to process, requests from a Consumer that are manifestly unfounded, excessive, or repetitive.

Targeted Advertising

The VCDPA defines “targeted advertising” as displaying advertisements to a consumer where the advertisement is selected based on personal data obtained from that consumer's activities over time and across nonaffiliated websites or online applications to predict such consumer's preferences or interests. We use Personal Data for targeted advertising. You can opt out of the use of your Personal Data for targeted advertising by submitting a rights request as described above. Please be aware that we do not accept or process opt-out requests through other means (e.g., via fax or social media).

Contact Us

If you have any questions or concerns regarding this VCDPA Privacy Notice, contact us as described in our general Privacy Policy (see https://www.worktango.com/privacy) above.

Last updated: May 15, 2024