Website Privacy Policy

1. Information We Collect

Information You Provide to Us

We collect information that you provide directly to us when you use the Sites. For example, we collect information from you when you fill out a form on a Site, contact us in any form or medium (including via email and phone), respond to a survey, or otherwise interact with us or the Sites. The information we collect from you may include:

• Contact information, including name, email address, phone number, and physical address.

• Professional information, such as your job title and the company you work for.

• Information about your interactions with us, such as your communications with our support and sales teams.

• Information provided in responses to any surveys we may conduct.

• Any other information you choose to provide to us in connection with your use of the Sites.

Information We Collect Through Automated Means

When you use the Sites or when you interact with our ads displayed across the internet, we and our vendors may use various technologies, including cookies and similar tools, to assist in collecting certain information about your browser, device, and interactions with our Sites and ads, including but not limited to your IP address, device type and model, operating system, browser type, language, software and hardware attributes (including device IDs), referring and exiting pages and URLs, files you download, domain names, pages viewed and the order of those pages, the date and time you used the Sites, error logs, and other similar information. We may also collect technical information when you interact with emails or other communications from us (e.g., whether you opened an email). When you use the Sites, we may also collect general location information (e.g., IP address, city / state, and or postal code associated with an IP address) from your computer or mobile device.

Information We Collect from Other Sources

We may receive additional information about you (e.g., contact information, job title / role, company information, demographic information) from third parties, such as business partners, marketers, researchers, analysts, and other parties. We use this information to supplement the information we collect directly from you to derive your possible interests; provide more relevant experiences for you; connect with you about using our platform and services; and improve our products, analytics, advertising, and products.

2. How We Use Your Information

We use your information for various purposes depending on the types of information we have collected from and about you, to:

• Provide and maintain the Sites;

• Respond to your requests for information and provide you with more effective and efficient customer service;

• Contact you by email, postal mail, or phone regarding Justworks and partner products, services, surveys, promotions, special events, and other subjects that we think may be of interest to you;

• Customize the content you see on the Sites;

• Help us better understand use of the Sites and your interests and needs, including through analytics and research;

• Improve the Sites and test and create new products, features, and services;

• Advertise the Sites and our other products and services;

• Secure our Sites and resolve technical issues being reported;

• Comply with any procedures, laws, and regulations that apply to us where it is necessary for our legitimate interests or the legitimate interests of others;

• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others;

• Protect the rights, safety, and property of ourselves, the Sites, and third parties; and

• For any other lawful purpose, with your consent where required.

Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Sites with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

Aggregated/Anonymized Data. We may aggregate, de-identify, and / or anonymize information collected through the Sites so that such information does not identify you. We may use and disclose appropriately aggregated, de-identified, and / or anonymized data to any parties and for any purpose, at our discretion.

3. Legal Bases for Use of Your Information

The legal bases for using your information as set out in this Privacy Policy are as follows:

• Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the terms of service of our websites or a purchase you made).

• Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our website and applications; operate our business and our Sites; receive payments; comply with legal requirements and defend our legal rights; and prevent fraud).

• Where we have a reason to process the data in accordance with applicable laws (e.g., European Union Member State laws).

• Where we have your consent to engage in a particular processing activity.

4. Cookies and Similar Technologies

We and our vendors / service providers may use Internet server logs, cookies, tracking pixels, and other similar tracking technologies that collect information about you as set forth in the section above on “Information We Collect Through Automated Means.” Cookies are small text files that are placed on your computer or mobile device when you visit a Site. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Services. Cookies and other similar technologies track, measure, and analyze the behaviors and usage patterns on our Sites, which enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the Site pages you have visited and how you interact with those pages; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.

We may also gather information through other methods as we adopt additional technologies.

Your browser and / or device may enable you to change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. For more information, please consult your browser's “Help” section or, if you access the Sites via a mobile device, the manufacturer’s instructions. Please note that if you block, disable, or manage any or all cookies, the Sites may not function as intended and some features may be unavailable.

5. Online Analytics and Advertising

Analytics

We may use third-party web analytics services (such as those of Google Analytics) on our Sites to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. You may install the Google Analytics Opt-out Browser Add-on by clicking here to prevent Google Analytics from using your information for analytics. If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Online Advertising

We and our vendors / service providers may use the information we collect from and about you to tailor the advertising you see online. Some tailored advertising is carried out using cookies. You may be able to set your browser to refuse certain types of cookies or alert you when they are being used, as explained above. In addition, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of tailored advertising and your choices regarding having information used by companies participating in the DAA. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of tailored advertising and your choices regarding having information used by NAI members. We make no representation about the accuracy or effectiveness of these opt-out mechanisms. We do not control these opt-out links and we do not control whether our advertising partners participate in these programs.

Mobile devices often include settings to help you manage how your device collects and discloses information for advertising purposes. For more information on how to manage those device settings, please visit the Network Advertising Initiative’s mobile choice page.

Modifying your browser settings or opting out of tailored advertising via your web browser may have different results depending on the type of device or web browser you use and the version of your device operating system. Opting out of tailored advertising does not prevent you from seeing ads online; instead, the ads you see after opting out are not tailored to you based on your online behavior over time. Opting out is generally effective only on a device-by-device, or browser-by-browser basis. If you use more than one browser or device, you should opt out on each one you’ve used to access the Sites.

6. How We Disclose Your Information

We may disclose the information we collect for the following purposes:

• Affiliates and Subsidiaries. We may disclose the information we collect within the Justworks family of companies under common ownership and control.

• Vendors / Service Providers. We provide access to or disclose your information to select third parties that perform services on our behalf, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.

• Online Advertising Partners. We may disclose your information to third parties that provide advertising services (such as ad networks, ad servers, or other advertising partners) that help us advertise the Sites. For more information, see the “Online Analytics and Advertising” section above.

• Legal Compliance and Protection of Justworks and Others. We may disclose your information if we believe in good faith that disclosure is required or appropriate to comply with applicable law, regulations, or legal process; to establish or exercise our legal rights; to defend against legal claims; to seek legal representation or advice; and to enforce our legal terms, agreements, and policies, including investigating potential violations thereof. We may also disclose your information if we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; and to protect and defend the rights, property or safety of Justworks, our users, our employees, or others. This includes exchanging information with other companies and organizations for fraud protection, spam / malware prevention, and similar purposes.

• Business Transfers. We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event. If a portion or all of our assets are sold or transferred to a third party, your information may be one of the transferred business assets.

• Your Consent. If you have consented to a specific disclosure of your information, we will disclose your information consistent with your consent.

7. Retention of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time we retain information depends on the purposes for which we collect and use it and / or as required to comply with applicable laws.

8. Your Rights and Choices

You have certain rights and choices with respect to your information as further described in this section.

Your Legal Rights

Depending on where you live, applicable law may give you the right to make requests related to your “personal information” or “personal data,” as these terms are defined in applicable law (collectively referred to in this section as “personal information”). You may have the right to ask us to:

• Inform you about the types of personal information we collect or disclose about you; the types of sources of this information; the business or commercial purpose for collecting this information; and the categories of third parties to which we disclose this information (please note that this information is contained in this Privacy Policy);

• Provide you access to and / or a copy of certain personal information we hold about you;

• Correct or update personal information we hold about you;

• Delete certain personal information we have about you;

• Restrict or object to certain uses of your personal information; or

• Opt you out of the processing of your personal information for purposes of profiling that furthers decisions that produce legal or similarly significant effects, if applicable.

Please note that we do not make decisions based solely on the automated processing of your information.

Certain information may be exempt from these requests under applicable law. For example, we need certain information in order to provide the Sites to you or comply with applicable law. We may take reasonable steps to verify your identity before responding to a request. Depending on the sensitivity of the information you are requesting and the type of request you are making, this may include verifying your name and email address. If we cannot verify your identity, we may be unable to respond to your requests. As provided in applicable law, you also have the right to not be discriminated against for exercising your rights.

To exercise these rights, you can contact us using the “Contact Information” below. You may be able to designate an authorized agent to make requests on your behalf. For us to verify an authorized agent, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may verify your identity directly with you before processing the authorized agent’s request, as permitted by applicable law. We reserve the right not to respond to requests where we have no legal obligation to do so.

Depending on applicable law, you may have the right to appeal our decision to deny your request. We will provide information about making an appeal in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

Notice of Right to Opt-Out of Sales of Personal Information and Sharing / Processing of Personal Information for Targeted Advertising Purposes

As explained above, we provide certain information about you and your device and online browsing activities to third-party advertising providers for targeted advertising and related purposes, so that we can provide you with more relevant and tailored ads regarding our Sites. The disclosure of your information to these third parties to assist us in providing these services may be considered a “sale” of personal information under applicable law or the sharing / processing of personal information for targeted advertising purposes.

Depending on where you live, you may have the right to opt out of “sales” of your personal information and sharing / processing of your information for targeted advertising purposes. To opt out of our online disclosures of your information through cookies and similar technologies for purposes that could be considered “sales” or sharing / processing for purposes of targeted advertising, you can click here.

We may disclose your information to these third parties for these purposes other than through online tools such as cookies. To opt out of these disclosures of information that are subject to applicable opt-out rights, you can email us at [email protected].

Please note that if you have a legally recognized browser-based opt-out preference signal turned on via your device browser, (e.g., Global Privacy Control), we recognize such preference in accordance with applicable law.

Marketing Communications

You may instruct us not to contact you by email, postal mail, or phone for marketing purposes (e.g., contacting you about products, services, promotions and special events that might appeal to your interests) by contacting us using the “Contact Information” below. In commercial email messages, you can also opt-out by following the instructions located at the bottom of such emails. Note that it may take some time to process your request, in accordance with applicable law.

If you opt out of marketing communications, we may still use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may continue to receive certain non-promotional and service-related communications, such as those reflecting our relationship or transactions with you or informing you about updates to this Privacy Policy. Opting out of marketing communications will not halt these and any other non-promotional communications.

9. Third-Party Links and Features

The Sites may contain links to third-party features and / or websites. If you choose to use any third-party sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of any third parties or third-party websites or services. The collection, use, and disclosure of your information by such third parties will be subject to the privacy policies of the third-party websites or services, not this Privacy Policy. We urge you to read the privacy and security policies of these third parties before you provide them with your information.

10. Information for Non-U.S. Users

Please note that Justworks is located in the United States. If you are located outside of the United States, you should be aware that any information you provide to us about yourself is transmitted to us and processed in the United States and other locations where we or our vendors or third-party partners are located. Your information will be protected subject to this Policy and United States laws, which may differ from the laws in your country. By using the Sites, you acknowledge such transfers of your information to the United States and other locations where we or our vendors or partners are located.

If we provide information about you to vendors or other third parties, we will take appropriate measures to protect your information in accordance with this Privacy Policy. These measures may include signing Standard Contractual Clauses (SCCs) in accordance with European Union and other data protection laws to govern the transfers of such data. If applicable, you may lodge a complaint with the data protection supervisory authority in the country where you reside. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

11. How We Protect Your Information

Justworks takes technical and organizational security measures to protect the information provided via the Sites from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error-free. Please remember this when disclosing any information to Justworks via the Internet.

12. Children’s Privacy

Children under the age of 16 are not permitted to use the Sites, and we do not seek or knowingly collect any personal information about children under 16 years of age. If we become aware that we have unknowingly collected information about a child under 16 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

13. Additional Information for California Residents

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and / or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. Our use of third-party online advertising services, which are described in detail in the “Online Analytics and Advertising” section above, may result in the disclosure of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” or "sharing" under the CCPA.

The following chart details these activities:

For more information about each category of personal information, purpose of use, and third parties to which we disclose personal information, please see the “Information We Collect,” “How We Use Your Information,” and “How We Disclose Your Information” sections of the Privacy Policy above.

Opt Out of “Sales” and “Sharing” of Personal Information. The CCPA puts certain obligations on businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes. Because of how the CCPA defines “sale” and “sharing”, they may include allowing third parties to receive certain information for advertising and analytics purposes.

We provide certain personal information to advertising and analytics partners, as detailed in the chart above. To opt out of our online disclosures of your information through cookies and similar technologies for purposes that could be considered “sales” or “sharing” under the CCPA, please click here.

To opt out of disclosures of personal information for purposes that could be considered “sales” or “sharing” through means other than cookies and similar technologies, you can email us at [email protected].

Please note that if you have a legally recognized browser-based opt-out preference signal turned on via your device browser (e.g., Global Privacy Control), we recognize such preference in accordance with applicable law.

Other CCPA Rights. If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.

The CCPA allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.

Please see the “Your Rights and Choices” section of our Privacy Policy above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.

Retention of Your Personal Information. Please see the “Retention of Your Information” section above for information about how we retain your personal information.

California “Shine the Light” disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes.

Do Not Track (“DNT”). DNT is a privacy preference that users can set in certain web browsers. Like many websites, the Sites do not currently recognize or respond to browser-initiated DNT signals. Please note that DNT is a different functionality from the legally required browser-based Global Privacy Control signal discussed above, which Justworks does honor in accordance with applicable legal obligations.

14. Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at any time. We will make the revised Privacy Policy accessible through the Sites and update the “Last Updated” date at the top of the page, so you should review the Privacy Policy periodically for changes. If we make a material change to the Policy, we will notify you in accordance with legal requirements. By continuing to use the Sites, you confirm that you have read and understood the latest version of this Privacy Policy.

15. Contact Information

The Sites are owned and operated by Justworks, Inc . If you have any questions or suggestions with respect to this policy, or if you wish to exercise any of the data rights discussed above, you can write to us at Justworks, Inc., P.O. Box 7119, Church Street Station, New York, NY 10008-7119, call (888) 534-1711, or you can simply click on Contact Us to send us an email.