At Gainwell our commitment to privacy goes beyond the minimum legal and regulatory requirements. We strive for best-in-class data protection and privacy management, which requires a sound data privacy governance structure and an effective data privacy compliance and best practices program to ensure we meet ever-changing and increasingly-complex regulatory standards and all contractually agreed privacy obligations.
Gainwell’s Global Privacy and Data Protection Office has strategic and operational responsibility for this program, which is adequately resourced and appropriately organized to ensure the policies and compliance processes, technology and physical controls and security we rely upon to govern the collection, use, storage and transfer of personal data all over the world meets statutory and regulatory requirements. Therefore, our approach is to coordinate the contribution of several corporate disciplines – including ethics and compliance, legal, human resources, and information and physical security – to achieve our “best in class” data protection and privacy management objectives.
Collection of Personal Information
Personal information is any information that personally identifies an individual or from which an individual could be identified. This may include a name, address, telephone number, email address and other private personal attributes.
Gainwell collects, uses, stores and transfers (collectively “processes”) personal information to manage its relationship with its customers, employees, business partners and other third parties (“covered individuals”) and better serve covered individuals by personalizing their experience and interaction with Gainwell. Such processing is done in compliance with applicable laws, including appropriate notice and consent, along with required filings with data protection authorities, where required.
Gainwell may collect and process personal information through a variety of means, including, as examples, access to Gainwell sites or services, or other ordering channels, employment processes, during conversations or correspondence with Gainwell representatives, through purchase of goods or services or in the course of an online application.
Use of Personal Information
Fulfilling your Transaction Request
If we receive any requests related to, for example, a product or service, a callback, or specific marketing materials, we will use your personal information to fulfill your request. In this context, we may share information with others, for instance, Gainwell’s group companies and business partners, involved in fulfillment. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes subject to applicable laws and regulations.
Personalizing your Experience on our Web Sites
We may use information we collect about you to provide you with a personalized experience on our Web sites, such as providing you with content in which you may be interested and making navigation on our sites easier.
The information you provide to Gainwell, as well as the information we have lawfully collected about you indirectly, may be used by Gainwell for marketing purposes. We will offer you the opportunity to opt-in to Gainwell using your information in this way. You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you may receive, or by contacting Gainwell directly at email@example.com.
Some of our offerings may be co-branded, that is sponsored by both Gainwell and third parties, such as Gainwell partners. If you sign up for these offerings, be aware that your information may also be collected by and shared with those third parties. We encourage you to familiarize yourself with their privacy policies to gain an understanding of the manner in which they will handle information about you. If you would like to review, rectify or request deletion of any Personal Information we have about you, you can submit a request by emailing Gainwell’s privacy office at firstname.lastname@example.org.
In connection with a job application or inquiry, whether advertised on a Gainwell Web site or otherwise, you may provide us with information about yourself, such as a resume. We may use this information throughout Gainwell and its group companies in order to address your inquiry or consider you for employment purposes.
Monitoring or Recording of Calls, Chats and Other Interactions
Certain online transactions may involve you calling us or us calling you. They may also involve online chats. Please be aware that it is Gainwell’s general practice to monitor and in some cases record such interactions for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction.
Mobile Applications and Use of Information in the Social Computing Environment
Gainwell makes available mobile applications for download from various mobile application marketplaces. Gainwell also provides social computing tools on some of its websites to enable collaboration among members who have registered to use them. These include forums, wikis, blogs and other social media platforms.
When downloading and using these applications or registering to use these social computing tools, you may be asked to provide certain personal information. These applications and tools may also include supplemental privacy statements with specific information about collection and handling practices. We encourage you to read those supplemental statements to understand how the tools and applications may process your data.
Protect the Rights and Property
We may also use or share your information to protect the rights or property of Gainwell, our business partners, suppliers, clients, or others when we have reasonable grounds to believe that such rights or property have been or could be affected. In addition, we reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights, or the rights of others, or to comply with a judicial proceeding, court order, law enforcement or legal process.
Sharing of Personal Data
Gainwell will not sell, rent or lease your personal information to others.
As a global organization with business processes, management structures and technical systems that cross borders, Gainwell may share information about you within Gainwell and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this Privacy Statement. Our Privacy Statement and our internal policies and practices are designed to provide a globally consistent level of protection for personal information all over the world. Even in countries whose laws provide for less protection for your information, Gainwell will still handle and protect your information in the manner described in this Privacy Statement.
Gainwell retains service providers, suppliers, and other alliance partners located in various countries to manage or support its business operations, provide professional services, deliver customer services and solutions, and otherwise process information on Gainwell behalf. It is Gainwell’s practice to require such service providers, suppliers and alliance partners to handle personal data and other confidential information in a manner consistent with Gainwell’s policies.
Circumstances may arise where, whether for strategic or other business reasons, Gainwell decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is Gainwell’s practice to seek appropriate protection for information in these types of transactions.
Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, law enforcement or legal process. We may also share your information to protect the rights or property of Gainwell, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.
California Consumer Privacy Act – CCPA
Gainwell is committed to the lawful treatment and confidential handling of sensitive information, including personal information about California residents, and has adopted a set of global information management policies including privacy and data protection, security, system access, information classification, and other relevant policies governing the collection, use, disclosure, transfer, retention, and deletion of information.
Gainwell as a “Service Provider” (as defined in the CCPA) confirms that it will process personal information which it retains, uses, or discloses in connection with its performance under any contract: (1) only on behalf of and for the benefit of the “Business” (as defined in the CCPA) from which it has received the personal information; (2) only in accordance with the contract and Business’s prior written instructions, if any; unless (3) as otherwise required by the CCPA. Gainwell confirms that it will not process personal information for any purpose other than for the specific purpose of performing the services specified in the contract.
Information Security, Accuracy and Retention
Security is a high priority for Gainwell and to protect the personal data and other confidential information and maintain its accuracy and integrity we have implemented appropriate administrative, technical and physical safeguards to prevent unauthorized access, use or disclosure. We require the same high standard of information security and information management of any third parties we share your data with.
We will retain personal information only for as long as legally required or permitted and in accordance with Gainwell records and information management policies. We respect your right to privacy and upon your request Gainwell will no longer use your personal information unless required to provide you services or as necessary to comply with Gainwell’s legal obligations, resolve complaints and disputes, and enforce our agreements.