Privacy Policy

General

We know that your privacy is important to you, and we work hard to earn and keep your trust.  ChampionHQ, Inc (collectively with its subsidiaries, “ChampionHQ, Inc,” “Company,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”).

This Policy describes:

• The types of information we collect from you or that you may provide when you visit our website are available at: www.championhq.com, as well as any websites and blogs directly owned by ChampionHQ, Inc (collectively, our “Website”).

• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on this Website or in emails and other electronic messages between you and this Website, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by ChampionHQ, Inc or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Website (for further information, see below, “Third-party Websites”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, then please do not use our Website.  By using our Website, you agree to the terms of this Policy.  This Policy may change from time to time (see below, “Changes to this Policy”).  Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Website Terms of Use; Other Agreements

This Policy should be read in conjunction with any applicable Terms of Use, into which this Policy is incorporated by reference.

What We Collect and How We Collect It

As part of the ChampionHQ, Inc services, we store customer financial data as well as customer employee utilization information.  To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Policy.  Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). In particular, the Website may collect the following categories of Personal Information from users of the Website:

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from you. For example, when you:

• register yourself with the Website;
• review or comment on one of our products;
• submit a job application; or
• communicate with us, such as request information.

Indirectly from you. For example, through information we collect from you in the course of providing our services to you.

Directly and indirectly from activity on our Website. For example, from Website usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below.

Often, ChampionHQ, Inc collects information under the direction of its clients, and has no direct relationship with the individuals whose Personal Information it processes.  ChampionHQ, Inc collects third party information when a customer connects an integration to our platform.  This information is retained for the life of the contract, even if the integration is disconnected.

The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting ChampionHQ, Inc to request further information.  When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

Additionally, we may ask you to create a username and password that should only be known to you.  When you provide this information to us, you are no longer anonymous.  Moreover, we may receive information about you from other sources and add it to the information you have provided to us. Likewise, we may provide you with the opportunity to use integration services by logging into your existing tools. This service will authenticate your identity and provide you the option to share certain Personal Information to use with ChampionHQ, Inc.

Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to our Website.  We collect this information using automated tools that are detailed below.  These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. This information may be stored in log files. Some of the tools we use to automatically collect information about you may include:

(a) Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive.  Cookies are usually defined in one of two ways, and we may use either (or both) of them:

(1) session cookies, which do not stay on your device after you close your browser, and

(2) persistent cookies, which remain on your device until you delete them or they expire.

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings.  However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.

(b) Google Analytics. The Website sends aggregated non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance.  For more information on how Google Analytics supports the Website and uses information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.

(c) Web Beacons. A Web Beacon is an electronic image.  Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior.  If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails.  We may also use them to track if you click on the links and at what time and date you do so.  Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Website.  This information is only collected in aggregate form and will not be linked to your Personal Information.  Please note that any image file on a webpage can act as a Web Beacon.

(d) Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link.  The tracking is accomplished through a redirection system.  The redirection system allows us to understand how the link is being used by email recipients.  Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you.  This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

(e) Third-party Websites and Services. We work with a number of service providers of marketing communications technology.  These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide.  The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing.  For example, we may collect data where our banner advertisements are displayed on third-party websites.

(f) Behavioral Targeting and Re-Targeting. We partner with third parties to either display advertising on our Website or to manage our advertising on other websites.  Our third-party partner may use technologies such as cookies to gather information about your activities on this Website and other websites in order to provide you advertising based upon your browsing activities and interests.  If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt out by sending an email to privacy@championhq.com.  Please note this does not opt you out of being served ads.  You will continue to receive generic ads.

How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• providing the information, products and services you request;
• satisfying the services agreements we execute with our clients;
• security, credit or fraud prevention purposes;
• providing you with effective customer service;
• providing you with a personalized experience when you use this Website;
• contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• contacting you with information and notices related to your use of this Website;
• inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
• better understanding your needs and interests;
• improving the content, functionality and usability of this Website;
• improving our products and services;
• improving our marketing and promotional efforts; and

• any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

Duration. The length of time ChampionHQ, Inc intends to retain Personal Information, including sensitive information is for as long as reasonably necessary to carry out ChampionHQ, Inc’s intended business purpose for such information.

How We Disclose Your Information

We do not sell or lease your Personal Information to any third party.  We may disclose your Personal Information to a third party for a business purpose. When we disclose your Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.

In the preceding twelve (12) months, we may have disclosed the following categories of Personal Information for one or more business purposes:

• Identifiers;
• Internet or other network activity information; and
• Professional/employment information.

We may disclose your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates; and
• Third-party vendors who provide services that enhance our Website, products and services to you (such as vendors for credit card processing, advertising and marketing and customer support).

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:

Legal Reasons.

• We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
• To respond to duly authorized information requests from law enforcement or other governmental authorities;
• To enforce our agreements, policies, or the Terms of Use;
• To investigate and prevent security threats, fraud, or other malicious activity; or
• To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or ChampionHQ, Inc employee.

Sale of Business or Merger. There are circumstances where ChampionHQ, Inc may decide to buy, sell, or reorganize its business in selected countries.  Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, ChampionHQ, Inc will ensure your information is used in accordance with this Policy.

Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertain to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information.  After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security.  We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

Information of Minors

We do not intentionally seek to gather information from individuals under the age of eighteen (18).  We do not target the Website to minors, and would not expect them to be engaging with our Website or services.  We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet.  If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

Submissions

We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, ideas, materials, blog posts, comments or other information you provide to us (collectively, “Submissions”) will be treated as non-proprietary and non-confidential. Your Submissions on or through this Website are available to others who visit this Website. In addition, we may use your Submissions in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Submissions for such purposes. Therefore, you should have no expectation of privacy with respect to your Submissions on or through this Website. You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Submissions comply with our Terms of Use or other applicable agreements. All terms and conditions of our Terms of Use apply to Submissions on or through this Website. In particular, your Submissions must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission.

Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates.  Our Website may link to third-party websites and services, such as Facebook, Twitter, and LinkedIn. For example, if you click on an advertisement on this Website, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them.  Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

Your Rights Under State Law

California

• Shine the Light law.  Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.
• Do Not Track Signals.  Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising.  Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.
• WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” Personal Information, as those terms are defined under the California Consumer Privacy Act of 2018, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information.

Your Consumer Rights.

If you are a California, Colorado, or Virginia consumer, as defined by the California Consumer Privacy Act of 2018 (the “CCPA”), the California Privacy Rights Act (“CPRA”),  the Colorado Privacy Act (“CPA”) or the Virginia Consumer Data Protection Act (“VCDPA”), respectively, you may be afforded additional rights with respect to your “Personal Information” as that term is explicitly defined under the CCPA, CPRA, CPA, and VCDPA.  Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. You may exercise each of your rights as identified below, subject to our verification of your identity.

1. Access.  You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
2. Correction.  You can correct what personal data our Website database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.
3. Prohibit Data Sharing.  When applicable, you may prohibit the sharing of your Personal Information. In your request, please explain how you wish us to prohibit the sharing of your Personal Information, and which categories of third parties you want to prohibit from receiving your Personal Information.  When such prohibitions are not possible to provide our services to you, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy.
4. Portability.  Upon request and when possible, we can provide you with copies of your Personal Information.  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy
5. Deletion.  You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.  Where applicable, we will ensure such changes are shared with trusted third parties.
6. Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
7. Non-Discrimination. If a California, Colorado, or Virginia data subject exercises his or her rights under applicable state law, including the CCPA, CPA, and VCDPA, we shall not discriminate against that resident by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
8. Exercising your rights. If you are a California, Colorado, or Virginia resident who chooses to exercise the rights listed above, you can:

1. Submit a request via email at privacy@championhq.com; or
2. Mail us at 830 Massachusetts Ave Suite 150 Floor 3, Indianapolis, IN 46204

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information.  If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

For Website Users or Visitors Outside of the United States

To provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours.  Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

For Website Users or Visitors in the European Union (“EU”)

Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR.  For the purposes of this Policy, ChampionHQ, Inc operates as a data controller.  Any personal data we collect from you is processed in the United States and under the terms of this Policy.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing.  You may always withdraw your consent to our use of your personal data as described below.  We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

The Data Processor is:

NAME: ChampionHQ, Inc, Inc.

ADDRESS: 830 Massachusetts Ave Suite 1500 Floor 3, Indianapolis, IN 46204

EMAIL ADDRESS: privacy@championhq.com

You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:

• Access. You may email us at privacy@championhq.com to request a copy of the personal data our Website databases currently contain.
• Automated Processing and Decision-Making.  You may email us at privacy@championhq.com to request that we stop using your personal data for automated processing, such as profiling.  In your email, please explain how you wish us to restrict automated processing of your personal data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
• Correction or Rectification. You can correct what personal data our Website database currently contains by accessing your account directly, or by emailing us at privacy@championhq.com to request that we correct or rectify any personal data 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 information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
• Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to privacy@championhq.com.  In your email, please explain how you wish us to restrict processing of your personal data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
• Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to privacy@championhq.com.  When such objections are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
• Portability. Upon request and when possible, we can provide you with copies of your personal data.  You may submit a request via email to privacy@championhq.com.  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent.  Where applicable, we will ensure such changes are shared with any trusted third parties.
• Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Website by notifying us via email at privacy@championhq.com.  Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email.  Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data.  Where applicable, we will ensure such changes are shared with trusted third parties.
• Erasure. If you should wish to cease use of our Website and have your personal data deleted from our Website, then you may submit a request by emailing us at privacy@championhq.com.  Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted.  Where applicable, we will ensure such changes are shared with trusted third parties.
• Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below.  If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.

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Representative
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

• European Union (EU)
• United Kingdom (UK)

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://prighter.com/q/12324654971

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Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  However, we can never promise 100% security.  You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password.  If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.

Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through this Website. We are continually improving and adding to the features and functionality of this Website along with the products and services we offer through this Website. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

How to Contact Us

We value your opinions and welcome your feedback.  To contact us about this Policy or your Personal Information, please contact us by email at privacy@championhq.com or by mail at 830 Massachusetts Ave Suite 1500 Floor 3, Indianapolis, IN 46204.