Privacy Policy

Privacy Policy

Counter Point HCM LLC (“Counter Point”, “we”, “our” or “us”) is committed to respecting your privacy.

Our goal is to provide small and mid-sized business with best-in-class payroll and human capital management services.  Many of our services are cloud-based with access via separate secure login to other sites during the provision of these services.  This Privacy Policy sets out how we collect, store, process, transfer, share and use your personal data, and which rights and options you may have in this respect.

We may collect data about users of our website; about individuals who attend events organized or hosted by us; about our clients or prospective clients (where these are natural persons) or their employees, agents and representatives; and about others who express an interest in us or with whom we carry on business (and these individuals about whom we collect data are referred to as “you” and “your” in this Privacy Policy).

Who is responsible for your personal data?

You will always have ultimate responsibility for who you provide your information to and whether your decisions are in your best interest.   As set forth in this Privacy Policy, we collect limited information from you.  Please note that for the purposes of the European Union General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation, the data controller for the data we collect in connection with our website is Counter Point HCM LLC.

Are you required to provide your personal data?

You do not have to give us any personal data in order to use most of our website, and in most instances you will purposefully provide us with your personal data. There are circumstances, however, in which we may not be able to assist you or an organization with which you are associated with unless you provide us with your personal data. For example, as the business owner we will require your personal data to associate your relationship with such company.  Your personal data may also be required for legally required compliance checks, to carry out instructions, for security and other reasons to allow you to access one of our events. In these cases, without the relevant personal data, we may be unable to assist you or your organization, and we would inform you or your organization that this is the case. We also may collect some personal data about you automatically as per below.

Which personal data do we collect?

When you use our website or when we interact with you, the personal data we collect may include (but is not limited to):

  • Contact information, such as your name, job title, postal address, including your home address, where you have provided this to us, business address, telephone number, mobile phone number, and email address.
  • Profile and usage data, including passwords to our websites or password-protected platforms or services; your preferences in receiving marketing information from us; your communication preferences; and information about how you use our websites, including the services you viewed.
  • Physical access data, relating to details of your visits to our events.
  • If you connect to us from a social network, we will collect personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list, and any other information you have agreed it can share or that the social network provides to us.
  • Special categories of personal data. In connection with the registration for and provision of access to an event, we may ask for information about your health for the purpose of identifying and being considerate of any disabilities or special dietary requirements you may have, or for public health reasons, including to meet public health requirements or health and safety laws. Your provision of this data is based on your consent and our use of it is with your consent and/or as required by law.

For our services we may also collect

  • In addition to all or some of the information listed above, information collected from publicly available sources or data sites for due diligence purposes.
  • Identification information from you or from your organization or other third parties for compliance with our legal obligations.
  • Payment data, such as data necessary for processing payments and fraud prevention, and other related billing information.
  • Other personal data regarding your preferences, opinions and comments where it is relevant to our services

How we collect your personal data

We may collect personal data about you in several circumstances and ways, including:

  • When you make an inquiry about our services or otherwise interact with us.
  • When you attend an event with us or a third party we are working with or sign up to receive notifications from us.
  • From social media sites.
  • Automatically in the ways described below.

Automatic Data Collection

Using tracking software, we automatically collect personal data about you when you access and use our websites, blogs, mobile sites, applications, sponsored content on social media sites (the “Online Information”), and information about the device you use to access the Online Information. For example, we may collect:

  • Information about how you view the Online Information (such as the pages you view, the links you click).
  • Information about your browser and usage patterns (e.g. your IP address, browser type and language).
  • Information about the device you use to access the Online Information.
  • Your access via a social media site.

We use this information to improve our Online Information and business and to help us develop new services.  Using email tracking software, we collect email traffic headers (“from”, “to” and timestamp fields) for analyzing patterns of network traffic and managing our relationships.

Third Party websites

Our websites link through to third party websites which may also use tracking devices over which we have no control. We recommend that you check the relevant third party’s privacy policies for information about tracking software which may be used.

Consent for tracking

If you continue to use Counter Point’s websites we will assume that you agree to our tracking. However, if you would prefer to change your settings, you can do so at any time – see below “Control”.

Control

If you wish to restrict, block or delete tracking on any of our websites, you can generally do this through your browser settings. These settings are usually found in the “options” or “preferences” menu of your internet browser. If you set your internet browser preferences to block tracking software, you may not be able to access all or parts of our site.

Use of your personal information

We will use the personal data listed above if and to the extent necessary to achieve the following purposes:

  • To provide services as requested by you or your organization.
  • To manage and administer you or your organization’s relationship with us, including billing and collection, marketing and support services, and taking other steps linked to the performance of our business relationship.
  • Where applicable, and only as permitted by law with respect to the specific category of personal data, to assess your application to join us as an employee or become a client.
  • To comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies.
  • To comply with court orders and to exercise and/or defend our legal rights.
  • To assist or enhance your experience at an event; for example, details of your dietary requirements.
  • To comply with our legal and regulatory obligations such as for anti-money laundering, financial and credit checks, audit requirements, fraud and crime prevention and detection, and record keeping. This may include automated checks of personal data you or your organization provide about your identity against relevant databases, and contacting you to confirm your identity, or making records of our communications with you for compliance purposes.
  • To analyze and improve our services and promote our business, such as by sending you invites.
  • To protect the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities.
  • To personalize and foster the quality of our communications and interaction with you.
  • For any other purposes related and/or ancillary to any of the above, or any other purposes for which your personal data was provided to us.

Legal justification for our use of your personal data

We may process your personal data in connection with any of the purposes set out above on one or more of the following legal grounds:

  • Because it is necessary for us to do so to perform your instructions or another contract with you or your organization.
  • To comply with our legal obligations, as well as to keep records of our compliance processes or tax records.
  • Because our legitimate interests, or those of a third-party recipient of your personal data, make the processing necessary, provided that those interests are not overridden by your interests or fundamental rights and freedoms.
  • Because you have expressly given us your consent to process your personal data.

Legal basis in detail

Marketing. We will only provide you with marketing-related information after you have, where legally required to do so, opted-in to receive those communications. If you have not opted-in to our providing you with information promoting our business, we will use your personal information for our legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms. We will give you the opportunity to opt out at any time.

Services. If we are providing you (or your organization) with services, our processing will be necessary for the performance of a contract between you or your organization and us.  Our processing is for our legitimate interests in ensuring compliance with our legal obligations or to protect our business. In all cases in which our legal basis for processing is due to our legitimate interests or those of our clients or prospective clients, we will use your personal information for our legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms.

Business partners. If you are engaged by us to provide services, or if you wish to be, our processing your personal data will be necessary for the performance of a contract, or for our legitimate interests.

We will not use your personal data for making any automated decisions affecting or creating profiles other than as described above.

Sharing and transferring your personal information

We may share your personal data with:

  • Third parties, including certain service providers we have retained in connection with the services we provide, such as lawyers, consultants, or other entities.
  • A client, if we have collected your personal data in the course of providing services to that client, and where permitted by law to others for the purpose of providing those services.
  • Third parties, on a confidential basis, to help us measure our performance and to improve and promote our services.
  • Companies providing services for money laundering and terrorist financing checks, credit risk reduction, and other fraud and crime prevention purposes, and companies providing similar services, including financial institutions, credit reference agencies, and regulatory bodies with whom such personal data is shared.
  • Courts, law enforcement authorities, regulators, government officials or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim.
  • Service providers which we engage to process personal data for any of the purposes listed above on our behalf and in accordance with our instructions only.
  • Prospective buyers of any business or assets to which we might assign or novate any of our rights and obligations; in such case we may disclose your personal data to the prospective buyer of such business or assets.

The personal information we collect may be collected, transferred to, and stored in countries outside of the jurisdiction you are in, or from the location of Counter Point, for the purposes specified in this Privacy Policy. Any international transfers of your personal data will be made pursuant to appropriate safeguards in accordance with the applicable laws and regulations. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy.

We do not sell or rent your personal information commercially to any third party except with your prior permission.

Protection of your personal information

We adopt appropriate administrative, technical and organizational measures designed to protect your personal information from the risk of disclosure, destruction, loss or accidental, unlawful and unauthorized alteration, access, disclosure and use. We require the third-party recipients identified in this notice to use similar protective measures when accessing and processing the personal information we share.

Your rights

Data protection laws provide certain rights for data subjects. Your rights will depend on the laws which apply to you and us, but you may have some or all the following rights:

  • To request details of the information we hold about you and how we process it.
  • To have the personal data we hold rectified or deleted, to restrict our processing of that information, to stop unauthorized transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organization.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above or for you to use the services offered by Counter Point. Please note that even after you have chosen to withdraw your consent, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations. If you have provided your consent and wish to withdraw your consent, please contact Counter Point at Privacy @ CounterPointHCM.com.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal data for the provision of our services.

We must ensure that your personal information is accurate and up to date, where relevant. Therefore, please advise us of any changes to your information by emailing us.

The Internet

This website may, from time to time, contain links to other websites which are outside of our control and are not covered by this Privacy Policy. We do not accept any responsibility or liability for other sites’ privacy policies. If you access other websites using the links provided, please check their policies before submitting any personal information.  Websites operated by Counter Point currently do not respond to “do not track” signals or similar mechanisms.

This Privacy Policy and revisions

We reserve the right to update and change this Privacy Policy from time to time to reflect any changes to the way in which we process your personal data or changing legal requirements. Please check back frequently to this page to see any updates or changes.

Contacting us

Questions, comments and requests regarding this Privacy Policy should be addressed to Privacy @ CounterPointHCM.com.

Last updated:  July 2023