Privacy.
Last updated on April 2023
Onwards HR, Inc (“We”, “Us”, “Our”) is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you interact with our website or our platform.
Contact Details: privacy@onwardshr.com
Privacy Principles
Onwards HR follows these principles in order to protect your privacy. These principles are common in both the General Data Protection Regulation 2016/679 (“GDPR”), and the California Consumer Privacy Act (“CCPA”), applicable if you are resident of the state of California:
We do not collect any more personal data than is necessary to provide the Services.
We only use your personal data for the purposes specified in this privacy policy, unless you agree otherwise.
We do not keep your personal data if it is no longer needed.
Other than as we specify in this privacy policy, we do not share your personal data with third parties.
Onwards HR’s Services
Onwards HR is a cloud-based offboarding platform used by organizations in their capacity as employers to optimize their separation processes by centralizing, digitizing and automating tasks related to employee separations.
Controller or Processor
Onwards HR can be both a Controller and a Processor of personal data. Onwards HR will be the Controller of personal data when a Customer enters into a contract directly with us, for the processing of said Customer’s data.
In most instances, Onwards HR has no direct relationship with the data subjects, and we act solely as a data processor. Onwards HR processes personal data on behalf of Customers, according to their instructions. Our Customers decide the purposes for which they use our Platform and the means for collecting data from our platform’s features.
In the case of users who browse our website, Onwards HR will be the processor for the processing of data collected here, such as cookies.
Personal Data Received from Our Customers
The Customer is responsible for dictating what personal data is sent and received by our Platform. However, the Platform requires specific employee data in order to function properly, including full name, email address, and an employee identifier. Additional employee attributes are required to perform severance calculations and generate separation documents.
As a matter of principle, Onwards HR only requires Customers to provide the minimum amount of personal data to successfully configure the Platform to meet their requirements.
Data Collected by Our Website
Onwards HR collects data on our website allowing users to (1) access digital content, (2) register for events created by Onwards HR, (3) register for newsletters and marketing communications, and (4) request for a demo of our software. The data collected includes Name, Email Address, and Company Name. This data is collected only for the purposes of sending/accessing requested content and communications, enrolling in Onwards HR events and contacting you to set a date for the demo.
Processing Personal Data
Onwards HR processes personal data for the following purposes:
For the drafting, negotiation or signature of contracts or other agreements with you;
To reply to your website inquiries and requests as a Customer or user;
For securing and presenting our Platform; and
For the purposes determined by our Customers as data controllers and under our Customers’ instructions, explicitly established in an agreement between Onwards HR and our Customers.
Onwards HR does not process personal data for its own purposes. When we process and aggregate data derived from personal data to improve product development (i.e. usage, analytics, statistics), all data is anonymized.
Security
Onwards HR implements security standards to prevent unauthorized access, maintain data accuracy, and ensure the correct use of data. We also employ appropriate organizational measures to protect your information.
Our security and organizational standards are also applied when working with third party partners. We only contract with partners who use appropriate measures and provide sufficient guarantees to ensure the appropriate protection of the data entrusted with them.
All Onwards HR’s employees have signed a Non-Disclosure Agreement or clause in connection to their employment. We also have internal processes including continuous training and policies that are routinely reviewed and updated. Onwards HR has also defined an incident response plan in case of a technical incident.
Sharing of Personal Data
Data processed by Onwards HR is hosted and processed in various locations based on Customer. Data will be stored within specific regions of Amazon Web Services (AWS) based on Customer requirements. A detailed list of sub-processors can be provided upon request.
Retention Period
Onwards HR keeps personal data for different periods. Time periods depend on the type of information, the period of our contract with our Customers, and legal requirements regarding certain types of data, and other factors.
Onwards HR will stop processing your information when you are no longer a Customer. When Onwards HR is under no legal or contractual duty to preserve information for a longer period, Onwards HR will delete your data.
If we have to retain your information for the purposes of complying with a contractual or legal obligation of retention, Onwards HR will restrict access by specific individual or role.
Your Rights
Onwards HR has no direct relationship with the data subjects and exclusively processes an employee’s personal data on behalf of the Customers. However, you have certain rights when it comes to our processing of personal data. Onwards HR will comply with any of the following requests as it relates to Customer requests in regards to the data subjects:
Right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use personal data and your rights.
Right of access: You have the right to obtain access to personal data.
Right to rectification: You are entitled to have personal data rectified if they are inaccurate or incomplete.
Right to erasure: This right enables you to request the deletion or removal of personal data where there is no compelling reason for us to keep using it. This is not an absolute right to erasure and exceptions apply.
Right to restrict processing: You have rights to ‘block’ or suppress further use of personal data. When processing is restricted, we can still store personal data, but may not use it further.
Right to data portability: You have a right to obtain and reuse personal data for your own purposes across different services.
Right to object to processing: You have the right to object to certain types of processing.
Right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process personal data with your national data protection authority.
Right to withdraw consent: If you have given your consent to anything we do with personal data, you have the right to withdraw your consent at any time.
Right not to be subject to automated-decision making: You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal (or similarly significant) effects to you.
You can address your communications and exercise your rights by sending written communication to privacy@onwardshr.com. Please note that the request may be refused if you ask for the deletion of data necessary for the fulfillment of legal obligations.
Changes to this Privacy Policy
We reserve the right to change this privacy policy to accommodate product and service development, industry standards, or new regulations. If such changes are material in nature, we will do our best to inform you.