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Disclo Privacy Policy

This Privacy Policy was last updated on October 29, 2024 

Overview

Welcome to Disclo! Disclo streamlines the workplace accommodation process, ensuring that employers and employees collaborate in a compliant, safe, and confidential environment. In support of this mission, we provide a hosted platform and related software and tools, including the Disclo web application (the “Services”). 

Disclo is committed to protecting the personal information of those we work with globally. We operate in many different countries and regions. This Privacy Policy sets out the privacy principles and procedures we adhere to globally, but specific laws may apply to you based on the country or region in which you are located.

Disclo has adopted a global approach on privacy with the intent of providing individuals with strong privacy protections regardless of where they reside. We recognize and implement high standards for privacy rights compliance on a global scale.

This Privacy Policy explains who we are, how we collect, use, and share personal information about you and how you can exercise your privacy rights. This Privacy Policy also describes our privacy practices regarding the personal information we collect from individuals in the usual course of business, including when you:

• Interact with us on our website (“Site”); visit our social media pages; receive communications from us; or register for, attend and/or otherwise take part in any of our events, webinars, toolkits, workshops, or contests (collectively “Visitors”); and
• Register to or otherwise use any of our Services as an employee of one of our Clients (collectively “Users”).

“You” may, depending on the context, be a Visitor or a User of the Services.  

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. By registering on this Site, submitting any information to Disclo on our Site or by otherwise accessing or using any of our Services, you agree to the terms of this Privacy Policy and consent to the policies and practices it describes.

Disclo as a Service Provider

Disclo’s Services enable employers (our “Client”) to manage the workplace accommodation process for its employees. Disclo processes personal information as part of providing the Services only according to our Client’s instructions (as defined in our Client agreements). If you have questions about personal information you have entered into the Services used by one of our Clients (i.e. your employer), or want to exercise any of your rights regarding your personal information, our Client contract requires that we redirect your inquiry back to that Client (i.e., your employer).  

Disclo is not responsible for the privacy or security practices of our Clients, which may differ from those set out in this privacy policy. Please review the relevant Client’s privacy policy to understand more about their data processing activities.

Your Rights and Preferences

Disclo allows you to exercise your privacy rights and manage how we use your personal information.

Privacy and data protection laws in different geographic regions give individuals certain rights in relation to their personal information. We conduct our privacy practices according to this Privacy Policy and the relevant laws of the geographic regions in which we interact with you. Disclo encourages you to become familiar with our privacy practices and to contact us to learn more about your privacy rights and how we collect and use your personal information. Unless we specifically disclose otherwise, you understand that we may use any of your collected personal information for any of the purposes described in this Privacy Policy (as permitted by applicable law).

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How We Collect Personal Information

We collect information that relates to you and your interactions with Disclo.

When used in this Privacy Policy, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual (“data subject”), and includes “personal data” or “personal information” as defined in applicable data protection laws. Data that cannot be associated with you, such as aggregated, de-identified, or anonymized information (“Anonymous Information”), is not personal information.

Personal Information Collected and Processed on Behalf of Our Clients

The Services require an interactive process with an exchange of personal information between the Client and/or, its employees, and Disclo. We endeavor to collect only that information necessary to the Services we provide and to share this information only with those that are necessary to the workplace accommodation process.

1. Information you Provide to Us:

(i) Visitors

‍When a Visitor to our Site contacts us and/or registers for information, content or an event sponsored by Disclo, we will collect certain personal information so that we may fulfill the Visitor’s request or keep in touch with them in connection with our sales and marketing activities (always in accordance with a Visitor’s marketing preferences). The personal information we collect include:

• Identifiers, such as your name and business e-mail address;
• Professional or employment-related information, such as company name, job level, functional role and title;
• Inferences, such as your contact preferences; and
• Any other information you provide to us when completing our forms or when you interact with us in the context of troubleshooting and support.

(ii) Users

‍If you are a User, you (or your employer’s administrator) may provide certain personal information to us through the Services. The personal information we collect may include:

• Name
• Email
• Phone Number
• Mailing Address
• Social Security Number
• Account log-in credentials (such as your email or username and password when you sign up for an account with us and the unique User ID assigned to you in our systems)
• Medical information
• Marketing information (such as your contact preferences)
• Troubleshooting and support data, which is data you provide or we otherwise access in connection with support queries we receive from you
• Billing information (including your credit card numbers and associated identifiers, billing address and background information, but only where you pay for the Services)
• Other information about actions you perform through our Services and that you upload or provide during your use of our Services

Disclo collects such information from you in order to conduct business globally, including providing you with access to our Services, improving your experience, communicating with you in connection with or regarding our Services, and to enhance and improve our Site and operations based on insights we are able to obtain from your information. If you choose not to provide certain personal information, we may not be able to provide you with requested Services, or information.

2. Information We Collect Automatically:

Disclo may automatically collect some usage information when you interact with us. We use cookies and other tracking technologies to automatically collect technical information, such as URL, cookie data, IP address, device type, unique device IDs, device attributes, network connection type (e.g., WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, operating system, and Services information. Please see the section on cookies below for more information.

In some (but not all) countries, including countries in the European Economic Area (“EEA”), UK and Switzerland, this information is considered ‘personal data’ under data protection laws. 

Information We Collect from Third Parties

We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application or site, such as a social networking site, we may collect information about you from that third-party site that you have made public via your privacy settings. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business and Services.

How We Use Personal Information

We may process personal information for the following business and commercial purposes, and if you are a resident in the EEA or UK, on the legal basis identified below:

• To provide and operate the Services for our Clients and its employees, including the Site, in reliance on our legitimate business interest;
• To give you the ability to participate in the interactive features of our Services when you choose to do so;
• To respond to your inquiries, comments, feedback or questions;
• To send administrative information to you, for example, information regarding the Services, and changes to our terms, conditions, and policies;
• To analyze how you interact with our Services;
• To maintain, modify, and improve the content and functionality of the Services and identify usage trends; 
• To develop new products and services, and expand our business activities in reliance on our legitimate interests;
• To prevent fraud, criminal activity, or misuses of our Services, and to ensure the security of our IT systems, architecture and networks; 
• To provide you with direct marketing communications in accordance with your preferences (see “Marketing” below);
• To plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, billing (if any), registration, and to connect you with other event attendees, to perform any contract with you, or to the extent necessary for our legitimate interests in fulfilling your requests to attend any such events;
• To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties; and
• To enable us to conduct our business generally, such as notifying our insurers, quality assurance, internal teaching and data processing and handling and in connection with any potential sale of our business and for other purposes which are reasonably necessary in connection with our normal functions and activities.

Marketing: If you opt in to our marketing, we may use your personal information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers.You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us at support@disclo.com If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.

How We Share Personal Information

We will only share your personal information as we describe in this Privacy Policy. Parties with whom we may share your personal information, pursuant to any applicable agreements, include:

Vendors and Service Providers:

To assist us in meeting business operations needs and to perform certain services and functions, we may share personal information with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services. Pursuant to our instructions, these parties will access, process or store personal information  in the course of performing their duties to us.

Business Transfers:

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.

Legal Requirements:

If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of Users of the Services, or the public, or (v) protect against legal liability.

Anonymous Information:

We may de-identify or aggregate your information, alone or in combination with information from other individuals. Such Anonymous Information is not personal information, will not contain personal information, and may be shared freely by us.

With Consent:

Other than as set out above, we may also share your personal information and your other information for additional purposes with your consent or at your direction.

No Sale of Personal Information (CCPA):

Disclo does not sell personal information to third parties.  Dislco is not a data broker and does not offer or disclose personal information on the open market, nor does Disclo share personal information with third parties for their direct marketing purposes. 

Cookies and Similar Tracking Technologies

We use cookies and other related technologies to receive and store certain types of information whenever you interact with us or use our Services through your computer or mobile device.

Cookies. A “cookie” is a piece of information sent to your browser by a website you visit. We may use and allow others to use cookies, web beacons, pixels, local shared objects, device identifiers, and other similar technologies ("Cookies”) to collect information about you. We use this information to improve your experiences when you interact with us. You have control over some of the data we collect from Cookies and how we use it. You may learn more about Cookies and how to manage them at https://www.allaboutcookies.org/

Google Analytics. We use cookies served by “Google Analytics, a web analytics tool, to help us analyze and better understand your use of the Services and enhance your experience when you use the Site. Further information on how Google collects and uses this data can be found at www.google.com/policies/privacy/partners/. You can opt-out of all Google supported analytics within the Services by visiting https://tools.google.com/dpage/gaoptout. 

“Do Not Track” Setting. Like most other companies, Disclo is not currently configured to respond to browser "Do Not Track" signals because, at this time, no formal "Do Not Track" standard has been adopted.

Links to Other Websites 

The Services may contain links to other websites not operated or controlled by Disclo, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the Services and visiting your account profile page.

You may also send us an email at support@disclo.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

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Children’s Privacy and Age Limitations for the Platform

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Our Services are not directed to children who are under the age of 18. Disclo does not knowingly collect personal information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided personal information to Disclo through the Services please contact us and we will endeavor to delete that information from our databases.

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The Services are intended for use by persons aged 18 or older, and by your use of the Services you affirm that you are at least 18 years of age and are fully able and competent to enter into and accept the terms set forth in this Privacy Policy.  

Data Retention

We will retain your personal information for as long as is necessary to fulfill the services that you have requested, comply with any laws or regulations, resolve disputes, and enforce our agreements, unless we receive a verified request under an applicable privacy law for earlier deletion of such personal information. Where permitted under applicable law, Disclo may retain your data longer for a legitimate business interest where business benefit is not outweighed by your personal rights and freedoms. Data entered into the Services and processed on behalf of our Clients as a service provider or processor is retained in accordance with any applicable agreement between Disclo and its Clients.

Security

We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. Our program includes appropriate administrative, technical and physical safeguards, procedures and practices to protect personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, we cannot guarantee its absolute security. Any transmission of your information to us is at your own risk. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or third party websites.

Your Privacy Rights

Depending on your location, your jurisdiction, and applicable law, you may have the rights below with regard to your personal information. Please note, however, that the rights described below are not absolute and, depending on applicable law or in certain cases, may be subject to conditions or limitations.

Also please note: if your personal information has been submitted to us by or on behalf of our Client (your employer) and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Client directly. ‍For more information on how your employer uses your personal information, please see your employer’s privacy policy. 

Your data protection rights generally may include: 

• The right of access, or the right to know, means that you have the right to request that we disclose what personal information we have collected, used and disclosed about you. If you are located in California, under the CCPA (if applicable) you have the right to request to know:some text
  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected, used, and/or disclosed about you;
  • The categories of sources from which we have collected personal information about you;
  • Business and/or commercial purposes for collecting and disclosing your personal information; and
  • The categories of third parties with whom your personal information has been disclosed or shared.

• The right of deletion means that you have the right to request that we delete personal information collected or maintained by us, subject to certain exceptions. 
• The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights. Disclo will not discriminate against an individual for exercising any rights under the CCPA (if applicable) or any other applicable privacy law, including, but not limited to, (a) denying goods or its professional services, (b) charging different prices or rates (including discounts/penalties) not directly related to the value provided to Disclo for personal information, or (c) suggesting an individual will receive a different rate/price or level of quality of goods/professional services.
• The right to opt-out, if you are located in California under the CCPA (if applicable), means you can opt-out of the sale or certain sharing of your personal information by submitting a request via your employer or to support@disclo.com. Note that Disclo does not sell personal information, though in certain instances Disclo does share personal information as described in this Privacy Policy.
• Through your employer or via support@disclo,com, you can also ask that Disclo correct or update your personal information; object to the processing of your personal information; ask to restrict processing of your personal information or request the portability of your personal information. In response to a request, we will ask to verify your identity if we need to, and to provide information that helps us to understand the request better. If we do not comply with the request, whether in whole or in part, we will explain why.
• While you cannot opt out of service-related emails if you are an account holder, as this is an essential part of the Services, you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or by contacting us at support@disclo.com.
• Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent via your employer or via support@disclo.com at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about the collection and use of your personal information. For more information, please contact your local data protection authority.
• Disclo does not engage in any automated decision making with your personal information.

Changes to Our Privacy Policy

We reserve the right to change or update this Privacy Policy from time to time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. We will notify you about material changes in the way we process personal information by posting the most current version of this Privacy Policy on our Site and we may also advise you of changes via our Services or by other communication channels, such as by email, newsletters or community post. Please review any changes carefully.

Your continued use of the Services and/or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means, if applicable, will constitute your: (a) acknowledgement of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us via email at support@disclo.com, or via regular mail at Disclo Inc., 8 The Green, Suite # 8372, Dover, DE 19901.

International Data Transfers

Your personal information may be transferred to, and processed in, the United States and in any other country where Disclo or its affiliates, subsidiaries or third party service providers maintain facilities or personnel. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). We follow applicable data protection laws when transferring personal data. If you are resident in or a visitor from the EEA, United Kingdom or Switzerland, we will protect your Personal Information when it is transferred outside of such locations by processing it in a territory which the European Commission has determined provides an adequate level of protection for Personal Information; or otherwise implementing appropriate safeguards to protect your Personal Information, including through the use of Standard Contractual Clauses or another lawful transfer mechanism approved by the European Commission.  

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