OnTrac Privacy Information
Privacy Documents
OnTrac Privacy Policy
The OnTrac Privacy Policy is reviewed and updated annually
Introduction
Express Messenger Systems, Inc., dba, OnTrac (together with its subsidiaries and affiliated companies, “OnTrac”)
recognizes the importance of having effective privacy protections in place and is committed to compliance with
applicable data privacy laws, regulations, internal policies and standards. These protections form the foundation of a
trustworthy company, are necessary to maintain the confidence of customers and employees and ensure the company’s own
compliance with such local laws. This Privacy Policy (“Policy”) is based on globally accepted, basic principles on
data protection.
OnTrac does not to give, sell or otherwise distribute information collected to unaffiliated third parties.
In order to respect the privacy of minors online, OnTrac services are not directed to minors less than sixteen (16)
years of age, and OnTrac does not knowingly collect, maintain or process personally identifiable information from such
minors.
If you have any questions or comments about this Privacy Policy or our practices regarding your personally
identifiable information, please contact us at privacy@ontrac.com.
Scope
This Policy applies to all employees, vendors and employees of vendors in the service of OnTrac. Individual
operating
companies may not adopt policies inconsistent with this Policy. In the event of conflicts between applicable local
laws,
rules or regulations and the Policy, OnTrac will work to find a practical solution that reconciles these
requirements.
Definitions
Customer Data
Electronic data containing Personally Identifiable Information (PII) provided by OnTrac customers on behalf of
third-party package recipients.
Personally Identifiable Information (PII)
Any information relating to an identifiable person.
Personal Information
Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be
linked,
directly or indirectly, with a particular consumer or household.
Categories of Personal Information
- Identifiers: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP)
address, email address, account name, social security number, driver’s license number, passport number, or other
similar
identifiers
- Customer records information: Name, signature, social security number, physical characteristics or description,
address, telephone number, passport number, driver’s license or state identification card number, insurance policy
number, education, employment, employment history, bank account number, credit or debit card number, other
financial
information, medical information, health insurance information
- Characteristics of protected classifications under California or federal law: Race, religion, sexual
orientation,
gender identity, gender expression, age
- Commercial information: Records of personal property, products or services purchased, obtained, or considered,
or
other purchasing or consuming histories or tendencies
- Biometric information: Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and
other
biometric data
- Internet or other electronic network activity information: Browsing history, search history, and information
regarding
a consumer’s interaction with an Internet website, application, or advertisement
- Geolocation data
- Audio, electronic, visual, thermal, olfactory, or similar information
- Professional or employment-related information
- Education information: Information that is not “publicly available personally identifiable information” as
defined
in
the California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)
De-identified data that cannot reasonably identify a particular consumer or employee does not constitute Personal
Information.
Anonymized data such that cannot identify an individual does not constitute Personal Information.
Processing
Any operation performed on Personal Information, with or without the use of automated systems, such as to collect,
store, organize, retain, archive, record, view, modify, adapt, alter, query, use, retrieve, forward, transmit or
combine
data. This also includes disposing of, deleting, erasing, destroying or blocking data. Examples include:
- Storing information in databases
- Viewing information stored on another computer or device
- Transferring information from one device to another
- Transferring information from one database to another
The transportation of physical media (documents, computers, etc.) containing Personal Information does not
constitute
Processing of that Personal Information.
Data Protection
Personal Information will be collected, recorded and used in a proper and professional manner, whether the Personal
Information is on paper, in computer records or recorded by any other means.
OnTrac is accountable for and must be able to demonstrate compliance with the following principles of data
protection.
OnTrac does not to give, sell or otherwise distribute information collected to unaffiliated third parties. We
reserve
the right, however, to provide such information to our employees, contractors, agents, and designees to the extent
necessary to enable them to perform contracted services an d certain site-related services (e.g., web hosting,
improve
site-related services and features, or maintenance services) on our behalf. In addition, we may provide personal
information to government agencies as required by law or regulation.
Fair and Lawful: When Processing Personal Information, the rights of the individual related to their Personal
Information must be protected. Personal Information must be collected and Processed fairly and lawfully.
In order to respect the privacy of minors online, OnTrac services are not directed to minors less than sixteen (16)
years of age, and OnTrac does not knowingly collect, maintain or process personally identifiable information from
such
minors.
Use of Information: Personal Information can be used or Processed only for the purpose defined at the time of
collection
and shall not be further used or Processed in any manner incompatible with that purpose.
Collection Limitation: OnTrac only collects Personal Information necessary to meet the specified purpose at the time
of
collection and only to the extent allowed by local law.
Deletion: Personal Information no longer needed for the purpose specified at the time of collection shall be deleted
according to applicable retention schedules unless it is subject to an exception from the Legal Department.
Data Quality: Personal Information should be accurate, and if necessary, kept up to date.
Security Safeguards: Personal Information must be protected using technical, managerial and physical security
measures
against risk of loss or unauthorized access, destruction, use, modification or disclosure.
Transparency: Individuals must be notified at the time of collection how their Personal Information is being used or
Processed. They must be aware of who is collecting the Personal Information, the purpose for the Processing of the
Personal Information and if third parties will Process the Personal Information, that adequate safeguards are in
place.
Individual Participation: To the extent required by local law, individuals have a right to access their Personal
Information and, where appropriate, to correct or delete it and exercise any other right provided by local law.
Security and Access
Customer Data and Personal Information is classified as confidential. Any unauthorized Processing of such data by
employees is prohibited. Any Processing undertaken by an employee that is not part of his or her legitimate duties is
prohibited. Employees may have access to Customer Data or Personal Information only as is appropriate for the type and
scope of the task in question. This requires the definition and separation, as well as implementation, of roles and
responsibilities.
Employees are prohibited from using Customer Data or Personal Information outside of the scope of their employment at
OnTrac, to disclose it to unauthorized persons or to make it available in any other way outside the permitted business
use. Supervisors must inform their employees at the start of the employment relationship about the obligation to
protect Customer Data and Personal Information. This obligation shall remain in force even after employment has ended.
Customer Data and Personal Information must be safeguarded from unauthorized access and unlawful Processing or disclosure. This applies regardless of whether data is Processed electronically or in paper form.
Employees are expected to follow the Acceptable Use and Data Classification and Handling policies. Information Security classifies all data as Confidential/Customer Data, Internal/Private or Public.
Depending
on its classification, Personal Information must be protected in accordance with the applicable Data Classification
and
Handling standard.
In the event of suspicious activity, suspected cyberattack, suspected security incident, or possible breach of
Customer
Data or Personal Information, all OnTrac employees must notify Information Security immediately to report the
incident.
Communication and Responsibilities
Telecommunications and Internet
Telephone equipment, email addresses, intranet and Internet, along with internal social networks are provided
primarily
for work-related assignments. They can be used within the applicable legal regulations and internal policies. In the
event of limited acceptable usage for private purposes, the local laws on secrecy of telecommunications and any local
telecommunication laws must be observed.
All Employees are responsible for:
- Reading and complying with this Policy and related policies, along with related documents/guidelines that may be
developed and maintained to implement the requirements of this Policy.
- Reporting violations of this Policy.
Management is additionally responsible for:
- Ensuring all reporting personnel understand the requirements of this Policy.
- Ensuring appropriate safeguards are in place to protect Customer Data and Personal Information.
- Providing all necessary training and/or guidance to assist with the implementation process, and for monitoring
compliance with this Policy.
Enforcement
Compliance to this policy will be verified through various methods, including but not limited to periodic
walk-throughs,
video monitoring, business tool reports, internal and external audits, and feedback to the policy owner.
This policy will be enforced by the OnTrac Executive Team. Violations may result in disciplinary action, which may
include suspension, restriction of access, or more severe penalties up to and including termination of employment.
Where
illegal activities or theft of company property (physical or intellectual) are suspected, the company may report such
activities to the applicable authorities.
OnTrac may restrict the use of its computers and network systems when presented with evidence of violation of OnTrac
policies, or federal or state laws, or when it is necessary to do so to protect OnTrac against potential legal
liability.
OnTrac Privacy Notice for California Consumers
Effective Date: January 1, 2020
This Privacy Notice for California Residents supplements the information contained in the OnTrac Privacy Policy, and
applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We
adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the
CCPA
have the same meaning when used in this notice.
Information We May Collect
Our Website may collect information that identifies, relates to, describes, references, is capable of being
associated
with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal
information"). In particular, the Website may have collected the following categories of personal information from
its
consumers within the last twelve (12) months:
| Category |
Examples |
Collected |
| Identifiers |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address,
email address, account name, or other similar identifiers.
|
Yes
|
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §
1798.80(e))
|
A name, signature, address, telephone number, insurance policy number.
|
Yes
|
Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
-
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996
(HIPAA) and the
California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
-
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act
(FRCA),
the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's
Privacy.
OnTrac obtains the categories of Personal Information listed above from the following categories of sources:
-
Directly from you. For example, from forms you complete or services we provide you.
- Indirectly from you. For example, from observing your actions on our website or from information your computer
or
mobile
device transmits when interacting with our website, among other things.
How We Use Personal Information
We may use or disclose the Personal Information we collect from you or about you to do one or more of the
following:
- To fulfill or meet the reason you provided the information.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide support and to respond to, including investigating and addressing your concerns and monitoring and
improving our responses.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other
technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website,
products,
and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental
regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for
materially different, unrelated, or incompatible purposes without providing you notice.
How We Share Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal
information for a business purpose, we enter 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 performing the contract. We may
share your personal information with the following categories of third parties:
- Service Providers
- Third parties with whom you direct us to share your Personal Information.
- Data aggregators
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, OnTrac has disclosed the following categories of Personal Information for
business purposes:
- Identifiers
- California Customer Records Personal Information categories
Sales of Personal Information
OnTrac does not sell Personal Information.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits California residents who
are
users of our website to request certain information regarding our disclosure of Personal Information to third
parties
for their direct marketing purposes. OnTrac does not disclose your Personal Information to third parties for direct
marketing purposes.
Privacy Rights for California Minors
California residents aged 16 and over may use the OnTrac website and respond to opt-in/opt-out requests as required
by the web site. California minor residents between the ages of 13 and 16 must provide OnTrac with written approval
before providing any information to OnTrac via the web site. California minor residents under the age of 13 must
have
their parent(s) or legal guardian(s) provide OnTrac with written approval before providing any information to OnTrac
via the web site. To provide written approval, please write OnTrac at:
ATTN: Legal Department
OnTrac
2501 S Price Rd Ste 201
Chandler AZ 85286
Changes to Our CCPA Employee Privacy Notice
OnTrac reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to
this privacy notice, we will post the updated notice on the Website and update the notices effective date. Your
continued use of our Website or interaction with us through other methods following the posting of changes and/or
our
directing you to the updated CCPA Privacy Notice constitutes your acknowledgment of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which OnTrac collects and uses your
information
described above and in the OnTrac Privacy Policy, your choices and rights regarding such use, or how to exercise
your
rights under California law, please do not hesitate to contact us at:
Phone: 800.334.5000
Email: privacy@ontrac.com
Postal Address:
ATTN: Privacy Department
OnTrac
2501 S Price Rd Ste 201
Chandler AZ 85286
Cookie Notice
Last update: March 2020
Introduction
The terms "OnTrac", "we", "us", or "our" refers to Express Messenger Systems, Inc., dba, OnTrac who is responsible
for
the use of cookies on the website www.ontrac.com including any (sub)pages, domains and mobile apps (hereafter
"Websites").
This document is intended to explain what cookies are, how we use them, and how you can manage them. When using
cookies,
we often collect personal data.
To learn more about the personal data we collect with cookies and how we use the personal data, please consult our
Privacy Notice. The Privacy Notice will also explain how and why we collect and use your personal data and which
rights
you can exercise in relation to the processing of your personal data.
Contact information:
ATTN: Vice President of Human Resources
OnTrac
2501 S Price Rd Ste 201
Chandler AZ 85286
privacy@ontrac.com
Overview
OnTrac uses cookies and similar technologies on our Website. This Cookie Notice applies to every visit to our
Website.
What are Cookies?
Cookies are text files sent to your computer when browsing a website ontrac.com. Cookies are most commonly used
to track activity on the site and to hold information you provide to customize your experience. The cookie is passed
back to the server when you return to the site to help the site administrator understand how the site is most
frequently
used or to provide a customized experience, for example.
Are Cookies Safe?
Yes, cookies are safe to accept. Cookies are widely used on many sites for a myriad of purposes. Accepting a cookie
does
not give the server access to your computer or any of your personal information. Under normal circumstances, cookies
cannot transfer viruses or malware to your computer. Cookies themselves are not harmful, but because they may carry
sensitive information, you should only use cookies on sites you trust to be safe and secure.
Why We Use Cookies
We use cookies for a variety of purposes, including to:
- Improve customer experience
- Help us obtain information about your visits to our Websites
- Schedule a Pickup
- Change content periodically
- Deliver communications and content specific to your interests
- Remember your preferences
- Understand how the site is used to better understand customer needs
- Understand how many people use the site to ensure efficiency and availability
- Assist in troubleshooting technical issues related to the site
Types of Cookies Used
OnTrac uses session, functional, analytical and tracking cookies.
Session cookies are temporary cookies which expire at the end of a browser session. Session cookies allow users to
be
recognized within a website so any page changes or item or data selection you make is remembered from page to page.
These cookies are required for the site to work properly and contain no Personal Information.
OnTrac uses other types of cookies to offer the best possible experience based on behavior and use patterns and to
help
improve performance and site optimization. We track visits to understand the how many individual visitors are
browsing
the site, the number of visits, the pages viewed, length of time each page is viewed, and the performance
experienced
during those visits. We gather browser and operating system information as well as IP Address with analytical
cookies.
During optional activities, like Scheduling a Pickup, PI is collected during the session. In this case, items like
first
and last name, email address, phone number, company name and reference text are collected.
Allow, Block and/or Delete Cookies
By default, browsers are configured to accept cookies. If you no longer want cookies to be stored on your device
you
can
change the settings in your browser. Each device and browser holds settings so if you have multiple devices or
multiple
browsers, you will need to change the settings on each device and in each browser.
If cookies are disabled ontrac.com will continue to work however some parts of the Websites, such as Scheduling a
Pickup, may not work.
Deleting or clearing cookies resets the information stored on your computer that allows sites to recognize you and
save
preferences. You will need to enter information into sites that was entered automatically for you based on the
information stored in the cookie.
Depending on the browser, some cookies can be accepted while others are blocked. Managing cookie settings is a
function
of the browser, use the help function or search the internet for support in managing cookies for your specific
browser.
Questions or Complaints
Questions or complaints regarding the use of cookies can be directed to OnTrac by using the contact information
provided
at the top of this Cookie Notice.
Updates to This Notice
OnTrac may update this Cookie Notice from time to time. If a change will have a serious impact, OnTrac will strive
inform you. OnTrac will publish an up-to- date Cookie Notice on our Websites at all times, indicating the last
update.
California Employee Privacy Notice
Introduction
The California Consumer Privacy Act of 2018 ("CCPA") imposes specific obligations on businesses processing
personal information of California residents. According to the CCPA, Express Messenger Systems, Inc., dba OnTrac
("OnTrac," "we" or "us") is required to provide its employees who are California
residents ("California Persons") a notice, used at or before the point of collection of such personal
information, that identifies the categories of personal information that may be collected and why OnTrac collects such
information.
This California Employee Privacy Notice ("Notice") is intended to provide California Persons with the CCPA
required notice.
Definitions
| Term |
Definition |
| Personal Information |
Information collected by OnTrac about you in the course of employment for
employment-related purposes and encompasses any information that identifies, relates to, describes, is capable
of being associated with, or could reasonably be linked, directly or indirectly, with you. |
| Process, Processed, or Processing |
Any operation or set of operations which is performed on personal information,
whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation
or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making
available, alignment or combination, restriction, erasure or destruction of personal information. |
| "Employee(s)," "You," "Your" |
An identified or identifiable natural person who is a California resident and who is
acting as an OnTrac job applicant, employee, or contractor. In this context "job applicant" refers to
any person who has submitted his or her candidacy with OnTrac; "employee" refers to any person who is
employed at OnTrac as a full-or part-time employee or temporary worker, and "contractor" means a
natural person who provides any service to a business according to a written contract. |
Personal Information We Collect About You
Listed below are the categories of personal information that OnTrac may process about employees:
- Identifiers, including real name, alias, postal address, unique personal identifiers, email, account name, social
security number, driver's license number, passport number, or other similar identifiers. In this context, a
"unique personal identifier" means a persistent identifier that can be used to recognize an employee, or a
device that is linked to an employee, over time and across different services, including, but not limited to, a
device identifier; an Internet Protocol address; cookies, beacons, pixel tags, or similar technology; unique
pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers.
- Characteristics of Protected Classifications Under California or Federal Law, including the following: race, skin
color, national origin, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy,
childbirth, breastfeeding and/or related medical conditions), gender identity, gender expression, sexual
orientation, marital status, medical condition (such as genetic characteristics, cancer or a record or history of
cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request
for family care leave, request for leave for an employee's own serious health condition, request for pregnancy
disability leave, and age.
- Internet or Other Electronic Network Activity Information, including browsing history, search history, application
access location and information regarding an employee's interaction with an internet website, application or
advertisement, time and geolocation data related to use of an internet website, application or physical access to an
OnTrac office location.
- Professional or Employment-related Information, including job-related data, maintained as part of the employment
relationship that is present in: a job application or resume; an employment contract; a contractor agreement; a
performance review; a disciplinary record; photos; biometric data, including imagery of your fingerprint, face, and
voice recordings; information from employee expenses; browsing and search history; payroll and benefits related
data; internal and external contact information; or information captured from video, audio, systems, or other forms
of monitoring or surveillance.
- Education Information, including information about an employee's educational background, such as education
records, report cards, and transcripts that is not publicly available.
- Inferences, including any information drawn from any of the personal information categories referenced above to
create a profile about an employee reflecting the employee's characteristics, psychological trends, preferences,
predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Purposes for Collecting Your Personal Information
OnTrac collects the personal information identified in section above for the reasons listed below.
| Purpose |
Description |
| Recruitment |
Gather required information to assess employment and conduct employment-related
background screening and checks. |
| Benefits Administration |
Medical, dental, optical, commuter, and retirement benefits, including recording and
processing eligibility of dependents, absence and leave monitoring, insurance, and accident management and
provision of online total reward information and statements. |
| Payroll and Expense Reimbursement |
Salary administration, payroll management, payment of expenses, to administer other
compensation-related payments, including assigning amounts of bonus payments to individuals, administration of
departmental bonus pools and administration of stock option payments. |
| Performance Reviews |
erformance appraisals, career planning, skills monitoring, job moves, promotions, and
staff re-structuring. |
| Monitor Work-Related Licenses and Credentials |
Provisioning software licenses for use in the course of an employee's work-related
responsibilities, ensuring compliance, training, examination and other requirements are met with applicable
regulatory bodies. |
| Human Resources Management Services |
Employee data maintenance and support services, administration of separation of
employment, approvals and authorization procedures, administration and handling of employee claims, and travel
administration. |
| Maintain Contact Information |
Managing your details across relevant entities within OnTrac (for example personal,
other employment, and transferring roles). |
| Emergency Assistance |
Maintenance of contact details for you, and your dependents in case of personal or
business emergency. |
| Work Eligibility |
Monitoring and ensuring compliance of employees' ability to work in the U.S. |
| Healthcare Related Services |
Pre-employment and employment-related medical screenings for return to work processes
and medical case management needs; determining medical suitability for particular tasks; identifying health
needs of employees to plan and provide appropriate services, including operation of sickness policies and
procedures; and providing guidance on fitness for travel and fitness for expatriation. |
| Safe and Efficient Work Environment |
OnTrac actions relating to disciplinary actions, and code of conduct processes and
investigations. |
| Security of OnTrac Web Sites and Internet-Connected Assets |
Hosting and maintenance of computer systems and infrastructure; management of OnTrac
software and hardware computer assets; systems testing, such as the development of new systems and end-user
testing of computer systems; training; and monitoring email and Internet access. |
| Compliance with Applicable Law or Regulatory Requirements |
Legal (local, state and federal) and internal company reporting obligations,
including headcount, management information, demographic and Health, Safety, Security and Environmental
reporting. |
Changes to Our CCPA Employee Privacy Notice
OnTrac reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to
this privacy notice, we will post the updated notice on the Website and update the notice's Effective Date above. Upon
your next visit, once the change has been posted, you will be redirected to the Privacy Notice and asked to review and
confirm it. Your continued use of our Website or interaction with us through other methods following the posting of
changes and/or our emailing or otherwise directing you to the updated CCPA Privacy Notice constitutes your
acknowledgment of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which OnTrac collects and uses your information
described above (and in the OnTrac Privacy Policy), your choices and rights regarding such use, or how to exercise
your rights under California law, please do not hesitate to contact us at:
Phone:
866.842.9505
Email:
hr@ontrac.com
Postal Address:
Human Resources
OnTrac
2501 S Price Rd Ste 201
Chandler AZ 85286
