This Privacy Statement explains how ADP, Inc. and the ADP Group Companies listed under section 17 of this Statement, (hereinafter “we”), use and disclose Personal Data that we collect from Individuals who visit our websites and otherwise engage with us in business activities. This Privacy Statement also incorporates ADP’s Binding Corporate Rules (BCR) Privacy Code for Business Data, which includes detailed information about how ADP processes data of our Business Contacts and the commitments we have made to protect that data. For more information on the BCR, please click on ADP Privacy Code for Business Data Overview towards the bottom of this webpage. If you have additional questions about privacy please contact us at Privacy@ADP.com.
For information on how ADP protects the Personal Data we process for Clients, please see the ADP Privacy Statement for Client Employees, found towards the bottom of this webpage.
1. Types of Personal Data
This Privacy Statement explains our practices with regard to Personal Data collected by ADP for its own Business Purposes. Personal Data is any information that can be used to identify, locate or contact you. Some examples of Personal Data include your name, username, mailing address, telephone numbers, email address, geographic location, creditworthiness, customer account information, or other information about how you use ADP websites and applications. Personal Data also includes other information that may be associated with your Personal Data.
2. How ADP collects Personal Data
In most cases, we collect Personal Data directly from you. We will ask you for Personal Data when you interact with us, such as registering on our websites, signing up to receive a newsletter, making a purchase, signing up to receive marketing communications, or to provide ADP with services, goods or products. We may collect additional information from Third Party data suppliers who enhance our files and help us better understand our contacts.
3. How ADP uses Personal Data
ADP uses your Personal Data for the following Business Purposes:
(a) Business Purposes for Processing Personal Data pertaining to Professionals. Personal Data pertaining to Professionals with whom ADP has a business relationship may be processed as needed:
(1) To initiate, assess, develop, maintain, or expand a business relationship, including negotiating, contracting, and fulfilling obligations under contracts;
(2) For due diligence regarding the Individual’s qualifications and eligibility for the relationship, including verifying the identity, qualification, authority, and creditworthiness of the Professional and obtaining publicly-available information from Third Parties (such as publicly-available sanction lists from screening companies);
(3) To send transactional communications (such as requests for information, responses to requests for information, orders, confirmations, training, and service updates);
(4) For account management, accounting, finance, and dispute resolution purposes (such as accounts receivable, accounts payable, account reconciliation, cash management, or money movement) and for consolidated management and reporting;
(5) To assure quality control and to enforce company standards and policies;
(6) For risk management and mitigation, including for audit and insurance functions, and as needed to license and protect intellectual property and other assets;
(7) For security management, including monitoring Individuals with access to ADP’s websites, applications, systems, or facilities, investigation of threats, and as needed for any Data Security Breach notification; and
(8) To anonymize or de-identify the Personal Data.
(b) Business Purposes for Processing Personal Data pertaining to Consumers and other Individuals. Personal Data pertaining to Consumers and other Individuals with whom ADP has a business relationship may be processed as needed:
(1) To provide the information, product, or service requested by the Individual, and as would be reasonably expected by the Individual given the context in which the Personal Data were collected, and the information provided in the applicable privacy statement given to the Individual (such as for personalization, remembering preferences, or respecting Individual rights);
(2) For due diligence, including verifying the identity of the Individual, as well as the eligibility of the Individual to receive information, products, or services (such as verifying age, employment, or account status);
(3) To send transactional communications (such as requests for information, responses to requests for information, orders, confirmations, training materials, and service updates);
(4) To manage the Individual’s account, such as for customer service, finance, and dispute resolution purposes;
(5) For risk management and mitigation, including for audit and insurance functions, and as needed to license and protect intellectual property and other assets,
(6) For security management, including monitoring Individuals with access to ADP’s websites, applications, systems, or facilities, investigation of threats, and as needed for any Data Security Breach notification; and
(7) To anonymize or de-identify the Personal Data.
(c) Business-necessary Processing activities. ADP may process Personal Data as needed (i) to protect the privacy and security of the Personal Data it maintains, such as in connection with advanced security initiatives and threat detection; (ii) for treasury operations and money movement activities; (ii) for compliance functions, including screening Individuals against sanction lists in connection with anti-money laundering programs; (iv) for business structuring activities, including mergers, acquisitions, and divestitures; and (v) business activities, management reporting, and analysis.
(d) Development and improvement of products and/or services. ADP may process Personal Data to develop and improve ADP’s products and/or services, and for research, development, analytics, and business intelligence.
(e) Relationship management and marketing. ADP may process Personal Data for relationship management and marketing. This purpose includes sending marketing and promotional communications to Individuals who have not objected to receiving such messages as may be appropriate given the nature of the relationship, (or who have opted into such messages in those jurisdictions where opt-in consent is required), such as product and service marketing, investor communications, Client communications (e.g., HR compliance alerts, product updates, and training opportunities and invitations to ADP events), customer satisfaction surveys, supplier communications (e.g., requests for proposals), corporate communications, and ADP news.
ADP uses your Personal Data for Secondary Purposes such as:
- Disaster recovery and business continuity, including transferring the information to an Archive
- Internal audits or investigations
- Implementation or verification of business controls
- Statistical, historical, or scientific research
- Dispute resolution
- Legal or business counseling
- Compliance with laws and company policies
- Insurance purposes
4. Why and How Personal Data is disclosed by ADP
ADP commits to not provide your Personal Data to Third Parties for their own marketing purposes. We limit our sharing of your Personal Data to:
- ADP Group Companies, which will only use your Personal Data for the purposes listed above.
- Our service providers, who are bound by law or contract to protect your Personal Data and only use your Personal Data in accordance with our instructions.
- Our business partners, but only to the extent you have purchased product or service from such partner, interacted with such partner, or otherwise authorized the sharing. For example, if you are referred to ADP from a business partner website, we may provide that partner with your contact information and certain economic and financial information, such as bank account information, to validate the referral. We may also provide your contact information to companies that offer complementary products and services if you request information about these solutions.
- Enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will also disclose Personal Data when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.
Please note that we may also use and disclose information about you that is not personally identifiable. For example, we may publish reports that contain aggregated, anonymized, and statistical data about our Clients. These reports do not contain information that would enable the recipient to contact, locate or identify you. These reports also do not contain identifiable company information.
5. Cookies and Other Data Collection Technologies
When you visit our website or use our mobile applications, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs, and web beacons. For example, when you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.
ADP also uses flash cookies (also known as local stored objects) and similar technologies to personalize and enhance your online experience. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. We use flash cookies for security purposes and to help remember settings and preferences similar to browser cookies, but these are managed through a different interface than the one provided by your web browser. To manage flash cookies, please see Adobe’s website at https://adobe.ly/2Kn1NL2 or visit www.adobe.com. ADP does not use flash cookies or similar technologies for behavioral or interest-based advertising purposes.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.
We collect many different types of information from cookies and other technologies. For example, we collect information from the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the Internet Protocol (IP) address assigned to the device you use to connect to the Internet. An IP address is a unique number that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to ADP and the website you visit after you leave our site. .
In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without reference to Personal Data. For example, we use information we collect about website users to optimize our websites and to understand website traffic patterns. In some cases, we do associate the information we collect using cookies and other technology with your Personal Data. This Privacy Statement applies to the information when we associate it with your Personal Data.
ADP has relationships with Third Party advertising companies to place advertisements on this website and other websites, and to perform tracking and reporting functions for this website and other websites. These Third Party advertising companies may place cookies on your computer when you visit our website or other websites so they can display targeted advertisements to you. These Third Party advertising companies do not collect Personal Data in this process, and we do not give Personal Data to them as part of this process. This Privacy Statement does not cover the collection methods or use of the information collected by these vendors. For more information about Third Party advertising, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org. You may opt out of being targeted by many Third Party advertising companies by visiting http://bit.ly/2Ig9IgT or http://preferences-mgr.trustarc.com/.
Although our websites currently do not have a mechanism to recognize the various web browser Do Not Track signals, we do offer Individuals choices to manage their preferences that are provided in the previous sections above. We do expect our Third Party advertising companies to use reasonable efforts to respect browser Do Not Track signals by not delivering targeted advertisements to website visitors whose browsers have a Do Not Track setting enabled. However, we understand that some companies do not have this capability today. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/.
ADP uses Google Analytics as a Third Party vendor. For information on how Google Analytics uses data, please visit “How Google uses data when you use our partners sites or apps”, located at http://bit.ly/2jXZ13Y.
6. Mobile Applications
ADP offers mobile applications that allow you to access your account, interact with us online, and receive other information via your mobile device. Personal Data collected by ADP via our mobile applications is protected by the terms of this Privacy Statement or our Privacy Statement for Client Employees, as applicable.
7. Communication Preferences
You may limit the information you provide to ADP. You may also limit the communications that ADP sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. Additionally, you may opt-in or opt-out of communications by navigating to the Global Preference Center at http://subscribe.adpinfo.com/.
Please note that if you are currently receiving services from ADP and you have decided to opt-out of promotional emails, this will not impact the messages we send to you for purposes of delivering such services.
If you have questions about your choices or if you need assistance with opting-out, please contact us via email to Privacy@ADP.com. You may also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.
8. Access, Correction, Erasure, and Other Individual Rights
ADP respects your right to access, correct, and delete your Personal Data, or object to the processing of your Personal Data. If you have an online account, you may log into your account to access update, or delete the information you have provided to us. Additionally, you may contact Privacy@ADP.com to request access to your data, and to exercise any of the individual rights afforded to you by ADP’s Privacy Code for Business Data, or by applicable data protection laws and regulations. You may also write to us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and detailed information about the changes you would like to make. ADP will respond to requests as soon as possible and in accordance with applicable data protection laws and regulations.
9. Information Security
ADP is committed to maintaining the appropriate organizational, technical, and physical controls to protect Personal Data entrusted to ADP. These controls protect Personal Data from anticipated threats and hazards as well as unauthorized access and use. In each case, ADP will strive to provide security that is proportional to the sensitivity of the Personal Data being protected, with the greatest effort being focused on protecting Sensitive Personal Data and other Personal Data whose compromise could result in substantial harm or inconvenience to the Individual. Additional information about ADP’s Global Security Organization may be found at https://www.adp.com/about-adp/data-security.aspx.
Please note that you should also take steps to protect yourself, especially online. When you register at ADP websites, choose a strong password, and do not use the same password that you use on other sites. Do not share your password with anyone else. ADP will never ask you for your password in an unsolicited phone call or in an unsolicited email. Also remember to sign out of the website and close your browser window when you have finished your work. This is to ensure that others cannot access your Personal Data and correspondence if others have access to your computer.
10. Data Retention
ADP will only retain your information for as long as necessary for the Purposes for which the Personal Data is processed. ADP has implemented a Global Records Information Management (RIM) Policy and has established records retention schedules for all types of Personal Data that ADP processes. Personal Data is retained in accordance with the records retention schedules to ensure that records containing Personal Data are retained as needed to fulfill the applicable Business Purposes, to comply with applicable laws, or as advisable in light of applicable statutes of limitations. When the retention period has expired, records containing Personal Data will be securely deleted or destroyed, de-identified, or transferred to archive, in accordance with ADP’s RIM Policy.
11. International Data Transfers
ADP is headquartered in the United States of America. Your Personal Data may be accessed by or transferred to our Group Companies and Suppliers in the United States or elsewhere in the world in accordance with the ADP Privacy Code for Business Data, found towards the bottom of this webpage.
12. Privacy Statements of Third Parties
This Privacy Statement only addresses the use and disclosure of information by ADP. Our Suppliers, Business Partners, and other Third Party websites that may be accessible through our ADP.com website have their own privacy statements and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by Third Parties prior to providing them with information or taking advantage of an offer or promotion.
13. Forums, Product Reviews and Other Public Areas
14. Job Applicants
If you have applied for employment with ADP, the Personal Data submitted with your job application will be added to our recruitment system and used for recruitment and other customary human resources purposes in accordance with our ADP Applicant Privacy Statement.
15. Individuals Located in the European Economic Area
In addition to the rights already listed in this Privacy Statement under Section 8, you also have the right to data portability, as well as the right to be notified of automated decision making or profiling related to your Personal Data. A Data Protection Officer for the European Economic Area has been appointed and can be reached at DataProtectionOfficer.ADPEMEA@adp.com You may reach the Data Protection Officer via mail at the address below.
Data Protection Officer - EMEA
ADP Europe SAS
31 Avenue Jules Quentin
16. Changes to this Privacy Statement
From time to time, we may update this Privacy Statement to reflect new or different privacy practices. We will place a notice online when we make material changes to this Privacy Statement.
17. Group Companies bound by this Privacy Statement
For a listing of Group Companies bound by this Privacy Statement and the Privacy Code for Business Data, please click www.adp.com/-/media/adp/privacy/pdf/A2CoBDC.pdf
18. How to Contact Us
Please contact us if you have questions, or comments, at Privacy@ADP.com. You may reach us via mail at address below. If you send us a letter, please provide your name, address, email address, and detailed information about your question, comment, or complaints.
ADP Global Data Privacy and Governance Team
One ADP Boulevard
Roseland, NJ 07068-1728 USA
19. How to Lodge a Complaint
If you believe that ADP has not handled your Personal Data properly or that it has breached its privacy obligations, under any applicable data protection laws or the ADP Privacy Code for Business Data or of Applicable Law, you may file your complaint in writing to the address above, or via email, to the Global Data Privacy and Governance Team at Privacy@ADP.com. The Global Data Privacy and Governance Team will investigate each complaint and notify the Individual within a reasonable timeframe of the outcome of the investigation. If you are not satisfied by the resolution ADP proposes, you may lodge a complaint in accordance with the provisions of the ADP Privacy Code for Business Data.