Runway privacy policy for people data

Effective Date: November 11th, 2019

OVERVIEW

Runway Operations, LLC. and our affiliates (referred to together as “Runway”, “we”, “our”, or “us”) respect individual privacy and take the privacy of your Personal Information very seriously. As the data controller, we collect, use, and discloses your Personal Information in connection with your working relationship with us, or with your application for a working relationship with us in a manner consistent with the laws of the states and countries in which we do business.

We use your Personal Information in a manner that is consistent with the uses described in this Privacy Policy (the “Policy”), which covers the treatment of the Personal Information we receive or maintain about you. This Policy is intended to cover our collection and use of data that we obtain in the course of your relationship with us.

Runway is a community, and your use of or participation in certain Runway services may be governed by our other Privacy Policies.

When we refer to “Personal Information,” we mean any information that relates to you as a particular individual. This includes information that directly identifies you (e.g., your name, social security number or other government-issued identifier, or employee ID number), but also includes information which we have linked to those identifiers (e.g., your date of birth, telephone number, and information about your performance, all of which are linked to your name). This can also include information about devices that you use where we have linked the information collected from those devices back to you.

This Policy applies to the Personal Information we receive or maintain regarding all current and former employees; dependents and beneficiaries of an employee or former employee; contractors who are natural persons (referred to in this Policy as “contractors”); contingent workers; and job applicants (referred to in this Policy as “you”).

1.    TRANSPARENCY/NOTICE

a.    WHAT PERSONAL INFORMATION DO WE COLLECT OR PROCESS?

b.    WHAT DO WE DO WITH YOUR PERSONAL INFORMATION AND WHY IS IT PROCESSED?

c.    HOW DO WE COLLECT AND USE INFORMATION ABOUT USE OF BUILDINGS AND FACILITIES?

d.    WHAT DO WE DO WITH YOUR SENSITIVE PERSONAL INFORMATION AND WHY IS IT PROCESSED?

e.    WHAT DO WE DO WITH AGGREGATED DATA AND WHY IS IT PROCESSED?

2.    HOW DO WE SHARE INFORMATION WITH THIRD PARTIES?

a.    IS YOUR PERSONAL INFORMATION SHARED WITH THIRD PARTIES?

b.    CHOICE – YOUR RIGHT TO OPT IN

3.    WHAT RIGHTS DO YOU HAVE OVER THE PERSONAL INFORMATION WE HOLD ABOUT YOU?

4.    SECURITY – IS YOUR INFORMATION SECURE?

5.    RETENTION – HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

6.    CHANGES – WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?

7.    REDRESS – COMPLIANCE AND ACCOUNTABILITY – WHO CAN YOU CONTACT IF YOU HAVE QUESTIONS OR CONCERNS? 

1. TRANSPARENCY/NOTICE

A. WHAT PERSONAL INFORMATION DO WE COLLECT OR PROCESS?

We collect the types of Personal Information that we require in order to manage our relationship with you, from the point at which you make an application to work with us (e.g. in your application) and throughout your employment with us (e.g., through on-boarding, using our systems, and signing up for benefits).

The Personal Information that we collect and use about you includes:

·                Application information (e.g., your CV, application form, references supplied by your former employer). If you do not provide this information, we will not be able to process your application properly;

·                Right to work information (e.g., work permit / visa application information). If you do not provide this information, we may not be able to offer you a position with us;

·                Basic personal details (e.g., name, date of birth). If you are a family member of an employee, former employee, contractor or contingent worker, we may collect this information from the relevant individual you are related to;

·                Contact details (e.g., telephone number, email address, postal address). If you are a family member of an employee, former employee, contractor or contingent worker, we may collect this information from the relevant individual you are related to;

·                Information required for payroll purposes (e.g., bank account details, tax information);

·                Information related to benefit entitlements and schemes (e.g. details of participation, contributions made);

·                Information related to gender, race or ethnic origin for purposes of complying with applicable anti-discrimination or diversity legislation (where applicable);

·                Medical information, if necessary to comply with applicable laws, or in order to provide medical care to you (such as through workplace assessments and for the other purposes described below);

·                Performance related data (e.g. information about and assessments of your performance collected as part of the appraisal process);

·                Location information, including through GPS tracking technology on Runway-owned devices or other devices owned by you which you use in connection with your services to Runway.

·                Information which we need to Process in connection with disciplinary action or investigations;

·                Information about your use of our systems or information that you provide to us through the systems (e.g., information from your company email account, information posted on our website, information you submit through applications or software made available to you, information collected from you when you connect a device to our networks, or communications sent to us or through our applications, including Slack);

·                Payment information you provide for goods, services, and other transactions authorized by you;

·                Information about your office preferences (e.g., adjusting your desk height, cooling the room, starting the fan, etc.);

·                Any other information that you provide directly to us.

B. WHAT DO WE DO WITH YOUR PERSONAL INFORMATION AND WHY IS IT PROCESSED?

We use your Personal Information primarily to manage our relationship with you by providing services that help you carry out your work with us. We also use your Personal Information to help us manage our business, including management of resources and to carry out marketing, and keep our systems secure.

The purposes for which we use Personal Information include:

·                Recruitment;

·                Providing you with equipment, training and support so that you can carry out your role. We do this in order to meet applicable contractual and employment related obligations to you;

·                Providing staff training, feedback and appraisals, in order to meet our contractual obligations to you, and where not strictly required by that contract, to meet our legitimate interests in ensuring our staff are best able to carry out their roles. This may involve maintaining a personnel or service record, and may involve carrying out investigations or disciplinary procedures to protect our interests;

·                Compensation and benefits management, to ensure that you are paid and can take advantage of benefits offered by Runway and its partners. Optional benefits require your opt-in consent;

·                Organization management and administration, including management of staffing resources, financial planning, corporate compliance, internal audits and other administration. We process Personal Information in this way to meet our legitimate interests in running our business effectively, and we also use Personal Information for your benefit by taking efforts to ensure that projects are appropriately staffed;

·                Administration of absences in accordance with company and statutory leave programs, to ensure that we comply with our legal obligations (for statutory programs) or with our contractual obligations to you (for company programs beyond what is statutorily required);

·                Communications. This may include facilitating communications to and between employees and contractors, and communications with other bodies (e.g., works councils where these exist, and regulatory authorities). We use Personal Information for this purpose in order to meet our legitimate interests in managing our business, which includes ensuring that our staff are able to communicate with one another, and that we are able to communicate with our staff;

·                Information about your office preferences (e.g., adjusting your desk height, cooling the room, starting the fan, etc.) helps us tailor your work environment and other preferences to you;

·                Runway marketing activities, including marketing photos, brochures, website content, videos, social media posts, and other related marketing activities. We will only use your personal data in creating this content with your consent;

·                Compliance with legal obligations, including health and safety requirements, requests for information from government agencies, and security investigations;

·                Provision of employment references if requested by a potential employer;

·                Administering our applications, software, and systems. This is necessary to meet our legitimate interests in ensuring that our systems are secure and are fit for use;

·                Statistical and analytical purposes to understand and improve worker satisfaction and performance; and

·                Such other purposes as we may disclose to you from time to time.

C. HOW DO WE COLLECT AND USE INFORMATION ABOUT USE OF BUILDINGS AND FACILITIES?

We use automated chatbots in some internal communication networks (such as Slack) to collect feedback about your work environment (e.g. what you like, dislike; general complaints or issues; ideas; if you are having trouble finding a space; if you need to find a help desk, notary, or kombucha; how to create an account, etc.). The chatbots respond to queries submitted by you directly so that your issues can be resolved quickly. For instance, you can send a message like “where can I find the help desk?” to a chatbot, and it will tell you where it is. Chatbots will also actively listen for specific keywords or phrases, and will help us ensure that any issues with your work environment are resolved as quickly as possible. For instance, if a chatbot identifies messages like “the cold brew keg is out on the 5th floor”, it will send a notification to the appropriate team so that it can be fixed.

The information collected through the chatbots as described above are not used to monitor your work productivity or impact your performance or conduct reviews. Most of the information is held in a way that does not identify you as an individual. Where required by local law, we will take other necessary steps in compliance with local laws.

D. WHAT DO WE DO WITH YOUR SENSITIVE PERSONAL INFORMATION AND WHY IS IT PROCESSED?

Some types of Personal Information are particularly sensitive, for example information about your health, race or ethnicity (together these are referred to as categories of “Sensitive Personal Information”). We collect and use these types of information in some limited circumstances where it is necessary for us to protect your interests (e.g., to provide healthcare), where we need to do so to comply with specific legal obligations (e.g., equal opportunity or anti-discrimination legislation or employment law), or where we have your explicit consent to use it.

The purposes for which Sensitive Personal Information may be used include the following:

·                To provide occupational health assessments and determine in limited cases if you are able to work. If we do this we will make sure any health information collected is collected by a qualified medical professional and kept under their control;

·                To manage sickness absences and family/parental leave (where applicable) to meet obligations under applicable laws, for example to ensure that we pay statutory sickness pay or maternity pay correctly;

·                Compliance with equal opportunity or anti-discrimination legislation or regulations (where applicable);

·                In connection with benefits including retirement-related benefits, private healthcare and life insurance. We will use this information with your explicit consent where necessary;

·                Background checks for employment or client engagement purposes, where permitted by applicable laws; and

·                In the course of legal proceedings (including prospective legal proceedings), obtaining legal advice, establishing or defending legal claims, or otherwise where strictly necessary for the administration of justice in accordance with applicable laws.

E. WHAT DO WE DO WITH AGGREGATED DATA AND WHY IS IT PROCESSED?

We may also collect and/or generate anonymized and aggregated information from your use of Wi-Fi, applications, systems, and websites. Anonymized or aggregated information is not Personal Information since we are not able to re-identify you using any means available to us from that anonymized or aggregated information. Anonymized and aggregated information is used for a variety of functions, including to help us identify and remediate any bugs, and to improve the performance of our websites and applications. We may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

2. HOW DO WE SHARE INFORMATION WITH THIRD PARTIES?

A. IS YOUR PERSONAL INFORMATION SHARED WITH THIRD PARTIES?

We share Personal Information with certain third parties, such as suppliers, clients and advisers that perform certain services on our behalf or that receive services from us. Sometimes sharing your Personal Information with these third parties is necessary for them to perform their services or for us to provide our services to them.

We will only share your Personal Information with third parties for the purposes identified above in accordance with the Policy, or with your consent. We will endeavor to obtain assurances from each third party with whom we share your Personal Information for purposes of maintaining our relationship with you (e.g., benefits providers) that it will safeguard your Personal Information consistently with this Policy and will notify us if it makes a determination it can no longer meet this obligation. If we have knowledge that a third party is using or disclosing Personal Information in a manner contrary to this Policy, we will take reasonable steps to prevent or stop the use or disclosure.

Your Personal Information may be also disclosed or transferred to a third party in the event of any proposed or actual reorganization, sale, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our company or of any company assets (including should Runway become insolvent, enter into receivership or any similar event occur). Should such an event take place, we will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Policy.

We may also disclose your Personal Information to third parties if necessary to comply with legal obligations, for example to cooperate with regulatory authorities, law enforcement bodies, or courts, or if we believe that disclosure is necessary to protect our rights or those of a third party.

B. CHOICE – YOUR RIGHT TO OPT IN

It is our practice not to share Personal Information with third parties for non-employment related purposes. Instead, we inform you of and provide you with the option to contact providers of non-employment related benefits or opportunities and opt in at your own discretion. If you choose to contact these providers and provide them with Personal Information, that Personal Information will be used in accordance  with  the privacy  policies  of  those  third  parties.

3. WHAT RIGHTS DO YOU HAVE OVER THE PERSONAL INFORMATION WE HOLD ABOUT YOU?

You can view, and in some cases update and delete, much of the Personal Information we maintain about you. Subject to applicable law, you have other rights in relation to your Personal Information, including the right to object to our Processing of your Personal Information in some of the circumstances described above. In particular, if you have given your consent to any use of Personal Information, you can withdraw this at any time. If you withdraw your consent, however, in certain circumstances we may not be able to fulfill our contractual and employment-related obligations to you.

The additional rights you may have subject to applicable law include the rights to:

·                access a copy of any other Personal Information we hold about you;

·                update, correct, amend or delete information that is demonstrated to be inaccurate, incomplete or processed in violation of applicable law;

·                restrict our use of your Personal information in certain circumstances; and

·                receive personal information you have provided to us in a usable electronic format and transmit it to a third party (known as the right to “data portability”).

4. SECURITY – IS YOUR INFORMATION SECURE?

We will take reasonable precautions designed to protect Personal Information in our possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction. Access to our systems that store your Personal Information is restricted by means of a user ID and password that are issued only to authorized personnel. In turn, you need to prevent unauthorized access to your Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have accessed your Personal Information.

5. RETENTION – HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

The length of time we retain your Personal Information depends on the status of our relationship with you and the requirements of applicable law. We will retain your Personal Information for as long as your employment with us lasts, and for a certain period after your employment with us has ended. To determine that period, we take into account our legal and regulatory obligations (such as financial reporting obligations and equal opportunity or anti-discrimination reporting obligations) and whether we may need to retain personal information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes and/or enforce our agreements.

6. CHANGES – WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?

We may amend this Policy from time to time. If we make any material changes in the way we collect or use your Personal Information, we will notify you by sending you an email and, where required by applicable law, afford you the opportunity to consent or to opt out of any new use or disclosure.

7. REDRESS – COMPLIANCE AND ACCOUNTABILITY – WHO CAN YOU CONTACT IF YOU HAVE QUESTIONS OR CONCERNS?

If you have an inquiry or complaint regarding this Policy or the collection or use of your Personal Information, including any rights of access, ability to limit the use or disclosure of Personal Information, or to correct or delete inaccurate Personal Information, please email [email protected]

Effective Date: November 11th, 2019