Privacy Policy (Canada)
Our Commitment to Privacy
Via Global Ventures Talent Mobility Services Canada Inc. (“Justworks” or “us” or “we”) is committed to maintaining the security, confidentiality and privacy of your Personal Information. This Policy (the “Policy”) has been developed in compliance with applicable privacy legislation. In the event of a conflict between this Policy and applicable law, the legislation will govern.
Application
This Policy applies to the Justworks proprietary software used to onboard Canadian EOR Employees (outside of Quebec) and to manage their employment with Justworks as well as to applicable Justworks websites where Canadian EOR Employees’ data is collected (such websites and the proprietary software are collectively referred to herein as the “Platform”).
Definitions
For the purpose of this Policy, “Personal Information” means any information about an identifiable individual.
What Personal Information Does Justworks Collect?
Information collected in the onboarding process through the Platform includes, but is not limited to:
your name, home contact information, date of birth, Social Insurance Number (for income tax purposes), and information about spouses and dependents (for benefits purposes);
your contact information;
identity verification information, including identification documents or records, facial images or other biometric information;
banking and other financial information for the purpose of processing payroll and making tax remittances;
Information collected through the Platform includes, but is not limited to:
information about your device, including but not limited to IP address, browser agent, operating system type, system activity and hardware settings, for the purpose of managing operation of the Platform;
activity on the Platform such as upload, download, installation, uninstallation, start, access duration, crashes, network activity and resource consumption;
date and time stamps associated with activity;
system configuration information;
Information collected through cookies (See the section on cookies below).
Why does Justworks collect, use or disclose Personal Information through the Platform?
The Justworks Platform is used as a central hub of information to establish, manage (and where applicable) terminate the relationship with Justworks employees. Information in the Platform is used for the following, non-limited purposes:
to verify information provided by or about individuals which is necessary to manage and administer an employment relationship;
to administer the relationship with Justworks’ clients (“Clients”) and meet the contractual and business obligations of Justworks and its Clients;
to process and administer payroll and to meet related regulatory and legal requirements and to address the requests of regulators (for example, Canada Revenue Agency requirements or licensing bodies);
to maintain appropriate employee/employer communication;
to manage and protect Justworks assets and property;
to assist Justworks in any dispute involving Justworks and/or a Client and or/an employee, including with respect to bringing or defending against claims or litigation;
in the context of a business transaction, such as a purchase, transfer or sale of services or assets;
to investigate, manage and address legal matters;
generally, to manage the employment relationship; and
as otherwise required or authorized by applicable law.
Once the employment relationship has been established, you will be provided a copy of the applicable Justworks Employee Privacy Policy. This document will provide more information about how Justworks collects, uses and discloses personal information of its employees.
How does Justworks share or disclose Personal Information?
Justworks may from time to time use third party service providers (“Service Providers”) for administrative purposes, such as to prepare, submit and maintain payroll and employee benefits and to store and maintain Justworks financial and accounting records which may include Personal Information.
In order to establish the employment relationship, Justworks needs to identify you. Justworks uses a third party Service Provider, Persona, for the purpose of verification of identity. Justworks requires Persona to protect your personal information in a manner consistent with Justworks privacy and security requirements and applicable law. For more information about how Persona processes your personal information, please see a link to its privacy policy here.
Service Providers used by Justworks to store or process Personal Information for the purposes described in this Policy may be located in jurisdictions outside of your province of residence or Canada, and applicable laws in those jurisdictions might permit foreign governments, courts, law enforcement or regulatory agencies to access the information in those jurisdictions.
Justworks discloses personal information to Clients for the purposes set out above. This information will be stored by Clients in jurisdictions outside of your province of residence or Canada.
Justworks may also disclose Personal Information where required or permitted by law, including to law enforcement agencies, industry associations or regulatory bodies.
Anonymized Information
Justworks may use or disclose anonymized information (which is information that has been stripped of identifiers that can likely be used to identify an individual) to conduct research about the operation of the Platform and the services that it provides to Clients.
Cookies
We use cookies to personalize our Platform for you and to collect aggregate information about Platform usage by all of our users. A cookie is a text file that the Platform transfers to your computer’s hard drive for record-keeping purposes and to enhance the quality of your use of the Platform and our ability to understand how the Platform is used. The cookie assigns a random, unique number to your computer. Cookies are small text files that our Platform places on your browser to enable our system to recognize your computer and allow us to see how you use our Platform. The cookies we use on our Platform or website may include:
A. SESSION COOKIES
These temporary cookies expire and are automatically erased whenever you close your browser window. We use session cookies to grant our users access to content and to enable actions they must be logged in to do.
B. PERSISTENT COOKIES
These usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve the Platform for our users. For example, we may use a persistent cookie to associate you with your user account or to remember that your choices on the Platform, but this only works when cookies are enabled.
C. THIRD PARTY COOKIES
We permit limited third parties to place cookies through the Platform to provide us with better insights into the use of our Platform and to assist in important Platform functions such as authentication and security.
Retention
We will keep Personal Information used to make a decision affecting you for at least one year after using it to make the decision.
We will destroy, erase or make anonymous (to the extent permitted by applicable laws) documents or other records containing your Personal Information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose.
We will take due care when destroying your Personal Information so as to prevent unauthorized access to the information.
Accuracy & Access
We will make a reasonable effort to ensure that the Personal Information we are using or disclosing is accurate and complete. In some cases, we rely on you to ensure that certain information, such as your address, telephone number and emergency contact information is current, complete and accurate.
You have a right to access your Personal Information held by Justworks. Upon written request to Justworks at [email protected], we will provide you with access to your Personal Information under our control, information about the ways in which that information is being used and/or a description of the individuals and organizations to whom that information has been disclosed, as required by applicable law.
Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
If you demonstrate the inaccuracy or incompleteness of your Personal Information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of Personal Information is not resolved to your satisfaction, we will annotate the Personal Information under our control with a note that the correction was requested but not made.
How does Justworks protect Personal Information?
Justworks protects the Personal Information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
Questions
Any questions regarding this Policy should be directed in writing to Justworks at Privacy Officer at: [email protected]
Changes
This Policy is subject to amendment from time to time.