LAST UPDATED: SEPTEMBER 21ST, 2022
We at Gentle Transitions Minnesota (“GTMN”), recognize the importance of protecting the privacy of personal and/or sensitive information collected about our client’s, relocating transferees, and others with whom we do business. We know privacy is important to you and it is extremely important to us. Below outlines how we keep your personal information private and secure and how we use personal information to provide you better experience.
Protecting The Privacy Of Personal Information
It is our intention to provide an understanding about how we collect information and the use we make of it in the course of the services we provide. The use of information collected through our services shall be limited to the purpose of providing the services for which either our clients or relocating transferees have engaged GTMN.
GTMN acknowledges that you have the right to access your personal information. GTMN has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their questions to your employer. If requested to remove data, we will respond within a reasonable time frame.
GTMN collects information under the direction of your employer. If you are a transferee of one of our clients and would no longer like to be contacted, please contact your employer that you interact with directly. We may transfer personal information to other suppliers that help us provide our service to you. Transfers to subsequent third parties are covered by the service agreements with our clients.
Personal Information GTMN Collects
Your employer will provide us with personal information about you and your dependents who are eligible to receive employer-approved relocation and/or assignment management benefits. This information is provided via a controlled access electronic authorization form. Personal information contained in this form includes: names, addresses, telephone numbers, email addresses and benefit eligibility instructions. We supplement this information by communicating directly with you and/or your dependents in an effort to customize services to meet your needs. We may also receive personal information from suppliers who assist us in providing services to you and your dependents. We offer you choices with respect to the use and disclosure of your personal information, while drawing to your attention the limitations this may place on GTMN and suppliers in terms of provision of services to you.
On our public website, https://gentletransitions.net/, users are not required to provide any information. Data that is captured is opt-in only and is limited to the following data that is provided by users on forms and information requests on our website, blog and social media outlets. Standard web traffic tracking includes IP addresses, and non-personal information related to that IP address. This information is in no way linked to any personal information and remains completely anonymous and used for site administration only.
When And How GTMN Discloses Your Information
We share your personal information with our employees, our affiliates, and our network of suppliers in order to deliver the relocation services that we have been engaged to provide. Information that we share with our employees is distributed strictly on a need-to-know basis. We will provide personal information to our affiliates if you, or your employer, have selected them as the supplier-of-choice. Personal information will be shared with external suppliers who are assisting us in providing services to you. These suppliers include, for example, moving companies, temporary housing facilities, mortgage originators, real estate brokers, destination service companies, visa & immigration service providers, etc. each providing essential parts necessary to facilitate the relocation services we deliver to you. We require these suppliers to protect the confidentiality of your personal information and to limit their use of such information to delivery of the requested services. We also exchange personal information with your employer to enable them to monitor our performance and to update their employee records.
We may also disclose Information as required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, to any other third party with your prior consent to do so.
Regarding the use of my information
GTMN is an “Opt In” organization. GTMN will only use your personal information to deliver services which your employer has authorized. You may deny the use of your personal information at any time; however, GTMN may be unable to provide services to you. If you have any questions, please contact your Relocation Consultant or Privacy@CorpRelo.com or contact us by postal mail at the contact information listed below.
Upon request GTMN will provide you with information about whether we hold any of your personal information. In case your Information (such as postal code or e-mail address) changes, you can request to correct, update, or remove the Information that you give us. We also will give you the opportunity to control the communications we direct at you. Please send you request to your GTMN Relocation Consultant or Privacy@CorpRelo.com. We will respond to your request to update, correct, or delete your personally identifiable information within a reasonable timeframe.
How GTMN Protects Your Information
GTMN is committed to protecting the personal information you share with us. GTMN uses a combination of industry-standard security technologies, procedures, and organizational measures to protect against the loss, misuse, and unauthorized access of your personal information under our control. To accomplish this, we take the following steps:
We employ internal access controls to ensure that the only people who see your information are those with a need-to-know basis.
We train all personnel on our privacy and security measures.
We physically secure the areas where we hold hard copies of the information we collect.
We regularly back up the information we collect to insure against loss.
We use technical controls to secure the information we collect online as appropriate, including but not limited to: encryption, firewalls, and password protections.
We cannot ensure or warrant the security of any information you transmit to us by email, and you do so at your own risk. No method of transmission over the internet, or method of electronic storage, is 100% secure; therefore, we cannot guarantee its absolute security. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org
User Data Supplementation
We may receive information about you from other sources, including publicly available databases of third parties from whom we have purchased data, combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
We will retain personal data we process on behalf of our clients for as long as needed to provide services to our client and your Information for as long as your account is active or as needed to provide you services. In the event you cease to be a transferee for any reason, we will continue to maintain your information consistent with the privacy policies and practices that apply to our clients. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Use Of Tracking Technologies
We use Google Enhanced Conversions to track leads from Google Ads. You can read their Customer Data Policies here, and Google's Ads Data Processing Terms here.
Log Files – As is true of most web sites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
California Consumer Privacy Act
Under the California Consumer Privacy Act, California residents have the right to:
- Request that a business delete any personal information about the consumer which the business has collected from the consumer.
- Request that a business that collects personal information about the consumer disclose to the consumer, free of charge, the following:
- The categories of personal information that it has collected about that consumer.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom the business shares personal information.
- The specific pieces of personal information it has collected about that consumer.
- Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose disclose, free of charge, to the consumer:
- The categories of personal information that the business collected about the consumer.
- The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal was sold, by category or categories of personal information for each third party to whom the personal information was sold.
- The categories of personal information that the business disclosed about the consumer for a business purpose.
Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.
You may submit a request under the California Consumer Privacy Act through the following methods:
You may call us toll-free at 1-866-450-2707.
You may e-mail us at Privacy@CorpRelo.com.
To submit a request, we are required to verify your identity. Please be prepared to provide us with your address, phone number, email address and employee ID. We will match the personal information that you provide to us with personal information that we already maintain about you in order to verify your identity. We may also need to contact you to confirm your request.
You may also designate an authorized agent to make a right to know or deletion request on your behalf. To use an authorized agent, you as the California resident must provide the agent with written authorization, including the verification information above. In addition, the agent will be required to verify their own identity with us. We may deny a request from an agent that does not submit proof that they have been authorized by the you to act on your behalf.
We may not be able to honor each request that we receive, but if we are unable to do so, we will respond to let you know our reasons. We will not discriminate against you if you choose to exercise any of your rights as described in this section.
Purposes and Legal Bases for Processing Personal Information
GTMN collects your personal information to provide our products and services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. We will collect and process your personal information as necessary for the performance of a contract to which you are a party or because we have another legitimate interest in doing so relating to our business purposes arising from your relationship with us. We may also seek your prior consent or rely on some other lawful basis to process your personal information.
Our legitimate interests include but are not limited to:
Provide you with the products and services you request, view, engage with, or purchase;
Communicate with you regarding your account or transactions with us; and
Operate, understand, optimize, develop, or improve our sites, applications, products, services, and operations.
Rights of Users Located in the EU
If you use this website and are located in the EU, EAA, or Switzerland, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.
The right to access. You have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.
The right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
The right to erasure. You have the right to ask us to erase your personal information in certain circumstances, including your personal information to be erased to comply with a legal obligation under EU or member state law.
The right to restrict processing. You have the right to ask us to restrict the processing of your personal information in certain circumstances, including: (i) when the accuracy of the personal information is brought into question, or (ii) when we no longer need the personal information for purposes of the processing, but require such personal information for the establishment, exercise, or defense of a legal claim.
The right to data portability. You have the right to ask that we transfer the personal information you gave us from one organization to another or give it to you.
The right to lodge a complaint with the supervisory authority. If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
The right to withdraw consent. If GTMN obtains your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of information.
Automated decision-making. To the extent that GTMN engages in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.
To exercise these rights please contact us using the Contact Information below. For your protection, we may need to verify your identity before responding to your request. If we refuse a request, we will provide you a reason as to why.
Links To Third Party Websites
Changes To This Policy
Who Can I Contact At GTMN
If you have any questions regarding this privacy statement or the practices, please contact your Relocation Consultant or Client Services. You may also contact us in the following ways:
By email at Privacy@CorpRelo.com
By phone at 1 469-568-5900
By mail at:
ATTN: PRIVACY OFFICE
CORPORATE RELOCATION INTERNATIONAL
1432 WAINWRIGHT WAY
CARROLLTON, TX 75007
UNITED STATES OF AMERICA
Please explain your complaint or dispute in as much detail as possible. We will investigate as soon as possible and respond within a reasonable timeframe.