O.C. Tanner Privacy Notice
Last updated: January 11, 2023
Your privacy is important to O.C. Tanner, and we value being transparent about how we process your personal information. This Privacy Notice (“Notice”) is intended to help you understand what information we process, why we process it, and the rights you have concerning your personal information.
In this Notice the terms “O.C Tanner,” “we,” ”us,” and “our” refer to O.C. Tanner and its affiliated entities.
Applicability of this Notice
This Notice applies to your business interactions with O.C. Tanner and use of our websites www.octanner.com, www.accumulate.com.au, www.thanks.com, or any other website where this Notice is posted (the “Websites”). O.C. Tanner’s products and services may be subject to separate privacy policies or notices that apply to you (e.g., if you participate in an employee recognition program administered by your employer). This Notice is not applicable to any such products or services. This Notice applies only to the personal information that O.C. Tanner processes in connection with your business interactions with O.C. Tanner and use of the Websites.
Personal information we process and purpose of processing
Depending on how you use the Websites or otherwise interact with O.C. Tanner, we may process the following personal information:
We will only process your personal information for the purposes for which we collected it. If we need to process your personal information for a new purpose, we will provide notice to you (and if required by law we will ask for your consent).
You are not required to provide personal information to us and you will not be subject to automated decision-making that significantly affects you or produces an adverse legal effect.
If we receive deidentified information, or deidentify your personal information, we commit to maintain and use such information in deidentified form and will not attempt to reidentify the information.
How we collect your personal information
In most cases, we collect personal information directly from you (when you voluntarily submit it via the Websites or other interactions with O.C. Tanner). We may also collect personal information automatically from you when you visit the Websites.
O.C. Tanner is committed to protecting your personal information. We implement appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure.
Basis for processing
We process your personal information in accordance with applicable law, including for legitimate business purposes, or where the processing is necessary to comply with a legal obligation, for our legitimate interests, to protect your vital interests, or with your consent (if required by applicable law).
Disclosures to subprocessors and other parties
Your personal information may be disclosed to O.C. Tanner’s third-party service providers that facilitate the administration of the Websites or an event hosted or promoted by O.C. Tanner.
We may also disclose personal information to O.C. Tanner’s lawyers, accountants, or other professional advisors. Where required by law or order of a court, we may disclose your personal information to an administrative agency or government tribunal. This includes in response to legal processes and lawful requests by public authorities.
Storage of personal information and cross-border transfers (overseas disclosures)
Depending on where you are located, your personal information may be transferred to O.C. Tanner in the United States (cross-border transfer or overseas disclosure), where the data protection laws may not be considered as protective as the laws of the country in which you reside. However, we implement appropriate security measures and adopt necessary data processing and transfer agreements to ensure your personal information is adequately protected.
We will only keep your personal information for as long as necessary to fulfill the purposes for which we collected it, or as necessary to resolve disputes.
To determine the appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
Depending on where you are located, you may have certain rights concerning your personal information, including the right to access, restrict the processing of, object to the processing of, correct, update, rectify, and receive a copy of (data portability) your personal information; or request that we erase or delete your personal information. You may also have the right to lodge a complaint with a supervisory or regulatory authority.
Some or all of the rights listed above may not apply to you or may be subject to limitations, depending on applicable law. To exercise these rights, please contact firstname.lastname@example.org
You may also opt-out of receiving email communications from us about new products, features, or other services by clicking the “Unsubscribe” link at the bottom of the communication, or by following the opt-out instructions included in the communication.
If you are a California resident, you may have additional rights under the California Consumer Protection Act (CCPA) and California Privacy Rights Act (CPRA), including the right to (i) know the categories of personal information collected about you; (ii) know the source of the personal information collected about you; (iii) correct inaccurate information; (iv) limit the use and disclosure of sensitive personal information; and (v) request that we delete your personal information. Some of these rights may be subject to limitations. We will not discriminate against you for exercising these rights. For information about how to exercise these rights, please visit the “Your Rights” section of this Notice.
California law requires that we tell you whether we collect any personal information that is described in California Civil Code Section 1798.80(e), which includes personal information, such as name, contact information, physical characteristics, credit card or billing information, and health or medical information. We collect personal information described in Section 1798.80(e). This information is already described in the “Personal information we process” section above.
We do not “sell” or “share” (as those terms are defined in the CCPA and/or CPRA) your personal information or sensitive personal information. This Notice describes the categories of personal information we collect, the sources of that information, the purpose for collection (which includes for “business purposes" under the CCPA and/or CPRA), the categories of third parties to whom personal information is disclosed, and our deletion and retention policies. If you have questions or would like to exercise your rights under the CCPA or CPRA, please contact email@example.com
The Websites are not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13.
Cookies and tracking technologies
Cookies are small text files which are placed on your computer or device when you visit a website or mobile application. Pixels, clear gif’s, and other tracking technologies operate similarly. The term “cookies” in this Notice refers to all files that collect information in this manner.
Certain web browsers may allow you to enable a “do not track” option that sends signals to the websites you visit indicating that you do not want your online activities tracked. This is different than blocking cookies as browsers with the “do not track” option selected may still accept cookies. We currently do not honor “do not track” signals. If we do so in the future, we will update this Notice accordingly.
Revisions to this Notice
We may update or revise this Notice due to changes in applicable laws or regulations, or because of changes to our processing activities. We will notify you of material changes that affect your personal information. You can see the last time this Notice was updated by checking the “last updated” date listed at the top of this Notice.
If this Notice appears in a language other than English, and there is a question or concern regarding interpretation or meaning, we will refer to the English version, available here. The English version will also resolve any conflicts of interpretation between the translated versions.
If you have questions, comments, or complaints regarding this Notice, you may contact our Data Protection Officer as described below:
O.C. Tanner Company
Attention: Data Protection Officer
1930 South State Street
Salt Lake City, Utah 84115
Phone: 1 (385) 301 2140