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WorkAbility Privacy Policy (U.S.)

Safeguarding your privacy is important to us. WorkAbility is committed to maintaining your
trust by protecting personal information that we collect and use.

If you live or are based in the United States, this Privacy Policy (“Policy”) describes how
WorkAbility Companies Inc. and its affiliated companies and subsidiaries (“WorkAbility”, “we” or
“us”) collect, use, and disclose your personal information in connection with any website,
application, or other service that refers to or links to the Policy (collectively, our “Services”).

Please read the Policy carefully before you use our Services. You should not use our Services if
you are not comfortable with what is stated below, and your continued use of Services
constitutes consent to the practices we describe in this Policy and the use and sharing of your
information as provided herein.

If you live or are based anywhere else, please refer to our Privacy Policy (Outside the United
States). When the text of this Policy is available in multiple languages, the English version is the
authoritative version, except where prohibited by applicable law.

Information We Collect

We collect various types of personal information in connection with the Services, namely:
● information you provide us directly;
● information we collect about your device(s) and your use of our Services, including
through cookies, web beacons, and other internet technologies; and
● information we obtain from third-party sources.

Personal Information You Provide Us Directly

We collect various types of information and content that you provide us directly. For example,
in order to enroll as a member or to access some of our Services, you will be requested to
provide us with your name, telephone number, email address, postal address, and where
applicable company or organization name. We also collect other content and information that
you provide us directly, including the content and information you may add to your member
network or other community profile and photographs or other information or documentation
you submit or provide us and the communications that you transmit through our networks. We
collect billing and payment information you provide when you access some of our Services or
purchase products and services. We also collect information that you provide us when you
participate in our surveys, sweepstakes or events. If you do not provide us with the requested
information, we may be unable to deliver you the Services in full.

To the extent that you disclose to us any personal information of another individual, we assume
that you have obtained such individual’s consent for the disclosure of such personal
information as well as the processing of the same in accordance with the terms of this Policy.

Information About Your Device(s) and Your Use of the Services

We collect information about how you use our Services and, depending on the access
permissions you have chosen for your device, other information, as specified below, from and
about the computers, phones, and other devices where you install or access our Services. We
use standard internet technologies, such as cookies and web beacons, to collect information
about your computer or device and your online activity, as explained in more detail in the
section on cookies.

The information we collect in this respect is:
● your browser type and operating system;
● IP address and device identifiers;
● your browsing behavior on our Services, such as the amount of time spent viewing our
online Services and the links you click within our online Services;
● websites you visit before or after our websites;
● whether you have opened or forwarded our e-mails or connected to offers or links that
we send you; and
● your general or specific geographic location, such as through GPS, Bluetooth or WiFi
signals to the extent permitted by the settings of your devices.

If you use our internet connection, networks, telecommunications systems or information
processing systems, your activity and any files or messages on those systems may also be
monitored by WorkAbility at any time, in accordance with applicable law, for purposes of an
investigation or to ensure compliance with company policies.

Information From Third-Party Sources

We obtain information about you from your company or organization, including when they may
create or supplement your profile for you in the member network. You can review and amend
this profile at any time. For further details, see below .
We also receive information about you from publicly and commercially available sources and
other third parties as permitted by law. We may combine this information with other
information we receive from or about you, where necessary to provide the Services you
requested.

Use of Personal Information

We use the personal information that we collect as necessary and appropriate for the following
purposes:
● To provide our products and services. We use your personal information to provide you
with the products, services, and features that you or your company or organization have
requested; to respond to inquiries we receive from you or your company or
organization; to verify your identity; in connection with a transaction that you or your
company or organization has initiated; to deliver notifications and other operational
communications; and for troubleshooting.
● To improve our products and services and to analyze how users navigate and use our
products and services and individual features.
● To manage the performance of our products and services.
● For audit and reporting purposes, to perform accounting and administrative tasks, and
to enforce or manage legal claims.
● To deliver advertising and promotional communications. For example, we may
periodically contact you with offers and information about our products, services,
features, and events; to send you newsletters or other information about topics that we
believe may be of interest; to conduct online surveys; and to otherwise promote our
products, services, features, and events. We also may deliver targeted advertisements
to you, both on and off the Services.
● For security and to protect, enforce, or defend legal rights, privacy, safety or property,
whether our own or that of our employees or agents or others, and to enforce
compliance with WorkAbility policies and to comply with applicable law and government
requests.

Sharing of Personal Information

We disclose your personal information in the following circumstances to the following parties:
● Among WorkAbility companies. Our services are provided by affiliates of WorkAbility
Companies Inc. depending on where you are located and the services you use.
WorkAbility shares personal information with those affiliates for the purposes
mentioned above. These affiliates use your information in accordance with this policy.
● Our Community. Our Services include online and offline member communities, forums
and networks that allow you to share and connect with others. We make this possible
for WorkAbility members by creating a profile for new members that contains your
name and the name of your company or other organization. This profile is created
automatically and is accessible to other members of the forum or network, some of
which include all WorkAbility members. You can supplement your profile by adding
additional information about yourself and your company or organization and by posting
content and comments and you may be able to share your profile with a broader
audience.
● Service Providers. We rely on third-party service providers to perform a variety of
services on our behalf. For example, we may rely on service providers to host data and
platforms, fulfill our product and service requests and answer your questions, send
e-mails on our behalf, process payment card or other transactions, and analyze data to
improve our products and services.
● Other Parties When Required by Law and as Necessary to Provide and Protect Our
Services. There may be instances when we disclose your information to other parties:
○ to provide you with the services you or your company or organization request,
such as a disclosure of your information to a landlord in connection with a lease
agreement, or to auditors or consultants;
○ to comply with the law or respond to legal process or a request for cooperation
by a government entity or law enforcement;
○ to detect, suppress, and prevent fraud or verify and enforce compliance with the
policies governing our Services; or
○ to protect our rights, property, and safety or that of any of our respective
affiliates, business partners, customers or employees and where otherwise
required by law.
● Other Parties in Connection with a Corporate Transaction. We will disclose your
personal information to an acquirer in the event we sell or transfer all or a portion of a
business or assets to that third party, such as in connection with a merger or in the
event of a bankruptcy reorganization or liquidation.
● Third-Party Partners, With Your Consent. We may request your consent to share
personal information about you with third parties so that they may provide you with
special offers, promotional materials, and other materials that may be of interest to
you.
● Other Parties at Your Company’s or Organization’s Direction. In addition to the
disclosures described in this Policy, we may share information about you with third
parties when your company or organization requests such sharing. For example, we
periodically may partner with third parties to make products or services available to
individual members or participating companies and organizations. If you or your
company or organization requests to participate, we may share your information with
the relevant third party in connection with the requested product or service.
● Aggregated and Non-Personal Information. We also share with third parties information
in a manner that does not identify particular individuals, for example, information that
has been aggregated with other records.
Our Services contain links to other sites that we do not own or operate. We provide links to
these third-party sites as a convenience to our members. They are not intended as an
endorsement of or referral to the linked services. The linked services are subject to their
separate and independent privacy statements, notices, and terms, which we recommend you
read carefully. The collection, use, and disclosure of your personal information will be subject
to the privacy policies of the third party and not this Policy.

Third Parties That Provide Content or Functionality on Our Services

We also partner with certain third parties to collect, analyze, and use some of the personal
information described in this Policy. For example:
● Third-parties that provide features and functionality on the Services by means of
plug-ins. Even if you do not click on or interact with social networking services or other
plug-ins, they may collect information about you, such as your IP address and the pages
that you view.
● Advertising providers help us and our advertisers provide advertisements on our
Services or elsewhere, including advertisements that are targeted based on your online
behavior, and analytics companies help us measure and evaluate the usage of our
services.
● Other content providers may offer products and services on our Services and may
operate contents, sweepstakes, or surveys on our Services.

These third parties collect or receive certain information about your use of our Services,
including through the use of cookies, web beacons, and Internet technologies and this
information may be collected over time and combined with information collected across
different websites and online services.

Some of these companies participate in industry-developed programs designed to provide
consumers choices about whether to receive targeted advertising. Please visit the websites
operated by the Network Advertising Initiative and the Digital Advertising Alliance to learn
more.

Information Security

We have in place various procedures to safeguard your information. Although we take such
steps to protect your information, no security program is foolproof and thus we cannot
guarantee the absolute security of your personal or other information.

Reviewing and Updating Your Information

In accordance with applicable law, you may have the right to access, update, or correct
inaccuracies in your personal information in our custody and control, subject to certain
exceptions prescribed by law. If you would like to access, review, or update your information,
please e-mail privacy@workability.works.

Accessing, Reviewing, and Updating Your Personal Information

To the extent provided for under applicable law, you may have the right to access your personal
information and to update or correct inaccuracies in your personal information in light of the
nature of our certain aspects of the services.

If you would like to exercise any of these rights, please send an e-mail to
privacy@workability.works.

International Transfers

The Services are headquartered in the United States. Please be aware that information you
provide to us or that we obtain as a result of your use of the Services may be collected in your
country and subsequently transferred to another country in accordance with applicable law. By
using the Services, you consent to the collection, international transfer, storage, and processing
of your information.

Your California Privacy Rights

You may opt out of having your personal information shared with third parties for those third
parties’ direct marketing purposes by e-mailing privacy@workability.works.

Some web browsers may transmit “do-not-track” signals to the websites and other online
services with which a user communicates. There is no industry standard that governs what, if
anything, websites should do when they receive these signals. We currently do not take action
in response to these signals. If and when a standard is established and accepted, we may revisit
our policy on responding to these signals.

California residents who are registered members or users of the Services and are under the age
of 18 may be entitled under California law to request and obtain removal of content and
information that they themselves post on the Services. You may request such removal by
emailing us at privacy@workability.works. In your request, please provide a description of the
material that you want removed and information sufficient to permit us to locate the material,
including your name, email address, year of birth, mailing address (including city, state, and zip
code) and the subject line “California Removal Request.” Please note that your request does
not ensure complete or comprehensive removal of the material. For example, materials that
you have posted may be republished or reposted by another user or third party.

Collection of Information From Children

The Services are not directed to children under the age of 16 and we do not knowingly collect
personal information from anyone under the age of 16. Persons over 16 but under 18 years of
age should ask their parents for permission before using the Services or sending any
information about themselves to anyone over the Internet.

Changes to This Privacy Policy in the Future

Privacy laws and guidelines are part of a constantly changing environment. We reserve the
right, at our discretion, to change, modify, add, or remove portions of this Policy at any time.
We encourage you to review this Policy periodically to ensure that you are aware of our current
privacy practices, although we may also elect to notify you by e-mail or by posting something
on some or all of our online Services. Your continued use of our Services following any changes
signifies your acceptance of these changes.

Questions or Comments

If you have any questions or comments regarding our Policy, please contact us at:
Privacy Director,
WorkAbility
1431 Ogden St
Denver CO 80203
Email: privacy[at]workability[dot]works
Effective Date: April 1 2018

Cookies, Web Beacons, and Other Internet Technologies

We, as well as certain third parties that provide content and other functionality on our Services,
may use cookies, web beacons and other similar technologies on our online Services.

Cookies

A cookie is a small file that may be stored on your computer or other device. A cookie enables
the entity that put the cookie on your device to recognize it across different websites, services,
devices, and browsing sessions.

When you use a web browser to access the Services, some browsers may allow you to
configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is
sent. Click the “Help” menu of your browser to learn more about how to change your cookie
preferences. The operating system of your device may contain additional controls for cookies.
Please note that disabling cookies may affect your ability to access and use certain features of
the Services.

Web Beacons

Web beacons and similar technologies are small bits of code, which are embedded in web
pages, ads, and e-mail, that communicate with third parties. We may use web beacons, for
example, to count the number of users who have visited a particular web page, to deliver or
communicate with cookies, and to understand usage patterns. We also may include web
beacons in e-mails to understand whether messages have been opened, acted on, or
forwarded.

Other Technologies

There are other local storage and Internet technologies, such as Local Shared Objects (also
referred to as “Flash cookies”) and HTML5 local storage, that operate similarly to the cookies
discussed above in that they are stored on your device and can be used to store certain
information about your activities and preferences across different services and sessions. Please
note that these technologies are distinct from cookies, and you may not be able to control
them using standard browser tools and settings. 

How We Use These Technologies

Our websites use these technologies for the following general purposes:
● Administering and improving our Services, including helping us measure and research
the effectiveness of our content, features, advertisements, and other communications.
For example, we measure which pages and features website visitors are accessing and
how much time they are spending on our webpages. We may include web beacons in
e-mails, for example, to understand whether messages have been opened, acted on, or
forwarded.
● Storing your sign-in credentials and preferences so that you don’t have to enter those
credentials and preferences every time you log on to a Service.
● Helping us and third parties provide you with relevant content and advertising by
collecting information about your use of our Services and other websites.
Please see “Use of Information” for details about how we use the information that we collect.
By continuing to use the Services, you consent to our use of cookies, web beacons, and other
Internet technologies as described above.

Personalized Advertising and Opting-Out

Your online privacy is important, so we offer the following options for controlling the targeted ads you receive. Opting-out of this type of advertising through the below methods will not prevent you from seeing general web ads, however those ads will be less relevant because they will not be tailored to your interests.

Web browser: You can opt-out of receiving personalized ads sent by us by clicking on the blue icon that typically appears in the corner of the ads you see and following the instructions provided or by clicking here.

Please note that opting-out is browser-specific and relies on an “opt-out cookie”, if you delete your cookies after having opted out, you will need to opt-out again using the link above.

Cross Device Opt-Out: In some cases we may link multiple browsers or devices to you. If you opt-out on a browser or device and we have more linked to you, your opt-out decision will be extended to your other linked browsers. There could be some cases where you are still being tracked in a different browser or device we have not linked, and where you are being treated as a different user.

Opt-out for mobile devices: To opt-out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:

iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting.

For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Select Ads > Enable “Opt out of interest-based advertising”.

You can also request that we stop email marketing to you. You can use the unsubscribe link in our marketing emails or contact hello@workability.works.

Dated: April 1, 2019