O.C. Tanner Privacy Notice

‍Last updated: January 29, 2025

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.

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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.

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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:

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Information processed	Purpose of processing
Identifiers: Your name, Internet Protocol (IP) address, and contact information, including email address, telephone number, and shipping address.	To contact you, to deliver or display adds (see the Cookie Section of this Notice for more information), to measure your interest in various services or special offers, and to inform you about new products, features, or other services that may be of interest to you. To conduct surveys and research regarding O.C. Tanner’s products or services. To seek voluntary feedback from you. To facilitate your participation in an O.C. Tanner event. To fulfil the purpose for which you provided such identifiers.
Professional or Employment Related Information: Information related to your employment, including position or title.	To tailor messages and content that may be of interest to you and conduct surveys and research regarding O.C. Tanner’s products or services.
Commercial Information: Payment card information and purchase history or other commercial information connected to O.C. Tanner’s products, services, or events.	To facilitate your participation in an O.C. Tanner event or the use of O.C. Tanner’s products or services (please note that we use third-party payment processors, so we do not store or retain payment card information).
Physical Characteristics or Descriptions: Content such as messages, comments, photos, videos, and other information.	To provide you with information you have requested, or use such content in promotional materials related to O.C. Tanner’s products, services, or events.
Internet or other Network Activity: Information about your use of the Websites, including the type of device used to access the Websites, operating system, web browser, cookies and similar technologies, traffic logs, mobile network information, and referring web pages.	To improve the Websites, maintain the integrity and security of the systems used to administer the Websites, to facilitate the user experience, and deliver content to you. To provide you more relevant O.C. Tanner advertisements and content on non-O.C. Tanner websites (see the Cookies section of this notice for more information).
Device Data: Information about the language or country configuration of the device you use to access the Websites.	To deliver content via the Websites that align with the size and resolution of the device you use to access the Websites and align (to the extent possible) with your language preferences set on your device.

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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.

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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.

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Security measures

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.

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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).

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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.

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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.

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Retention

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.

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Your rights

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 privacy@octanner.com

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.

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California Residents

If you are a California resident, you may have additional rights under the California Consumer Protection Act (CCPA) and California Privacy Rights Act (CPRA). For more information on those rights, please see our California Privacy Rights Disclosure.

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Children

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.

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Cookies and tracking technologies

We may process your personal information when we use cookies and similar technologies. In general, cookies are used to measure how you interact with a website, display content and ads, and remember you and your preferences when you return to a website. Other technologies, like web beacons, pixels, and embedded scripts are used for similar purposes. For more information about how we use cookies and similar technologies when you visit the Websites, please see our Cookie Policy.

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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.

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Translated Versions

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.

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Contact us

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
Email: privacy@octanner.com
Phone: 1 (385) 301 2140

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