Privacy Policy

PRIVACY STATEMENT

The terms of this Privacy Policy were last updated and go into effect as of April 9, 2024.

This Privacy Policy applies only to https://plusrelocation.com, https://elo.plusrelocation.com, and email communications controlled by Plus Relocation Services, LLC (the “Sites”). This Privacy Policy describes how Plus Relocation Services, LLC and its subsidiaries and affiliated companies (“Plus Relocation” or collectively, “we”, “us” or “our”) collect, use and disclose personal information of visitors to our Sites, users of our online services and others to whom we expressly provide that this Privacy Policy will apply (collectively, “you” or “your”). It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

This Privacy Policy applies only to individuals who visit our Site or interact with us through e-mail. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using our Sites in any way, such as browsing or interacting with them, you acknowledge that you have read, understood and agree to be bound by the terms and conditions set forth in this Privacy Policy and the Terms and Conditions of Use. Your acknowledgement includes your consent and agreement to the manner of collection and use of information, including our uses of personal information (described below). If you do not agree with this Privacy Policy and the Terms and Conditions of Use, you may not use this Site.

THE PERSONAL INFORMATION WE COLLECT

For the purposes of this Privacy Policy, personal information is any information about or that can be linked to an identifiable individual or household.

We collect and maintain different types of personal information that you and/or your employer provide to us on a voluntary basis. This may include:

• contact and identification information, such as your real name, alias, unique personal identifier, IP address, postal address, telephone number, e-mail address, signature or other similar identifiers, and employer information;
• internet or other electronic network activity information, including, but not limited to, information regarding your interaction with the Site;
• product and service related information concerning the products and services that we provide to you or programs that we offer;
• any other information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household;
• for parties with whom we do business, credit, and financial information such as your payment methods and preferences, and billing and credit history, where applicable; and
• business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feed-back and information requested by or provided to you.

If you email us a question or request, we may use your email address to process your request and respond to your question, which may involve collecting any personal information that you choose to provide to us in your email

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information, and other information for the purpose of market analysis, resource planning, financial advisory services, and strategic planning. We may also collect information related to our media, investor and public relations activities, and information related to our interactions with financial, resource planning, regulatory, and other analysts, and advisors.

THE PERSONAL INFORMATION WE COLLECT FROM THIRD PARTIES

As a general rule, we collect personal information directly from you or through your employer or its designated representative.  We do not collect any personal information from third parties.

HOW WE COLLECT AND USE PERSONAL INFORMATION

We collect personal information from you to enable us to manage, maintain, and develop our business and operations, including:

• to establish, maintain and manage our relationship with you so that we may provide you with, products and services that have been requested;
• to perform services on behalf of you or your employer, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, and processing payments;
• to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
• to administer or otherwise carry out our obligations in relation to any agreement you or your employer have with us;
• to protect us against error, breach of contract, negligence, fraud, theft, illegal activity and damage to our goods and property;
• to alert you to updated information and other new products and services from us, or third-parties, or to forward promotional materials to you, where you have consented to receive such information;
• to complete a transaction or service requested by you or your employer;
• to respond to inquiries or requests submitted by you or your employer;
• to ensure the Sites are relevant to your needs;
• to detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• to debug to identify and repair errors that impair existing intended functionality;
• to undertake internal research for technological development;
• to help us create and publish content most relevant to you;
• to further any commercial purposes, including any purpose to advance your interests, such as by inducing you to buy, rent, lease, join, subscribe to, or provide products, goods, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction;
• to enable us to comply with applicable law or regulatory requirements; and
• any other reasonable purpose to which you consent.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

DISCLOSURE

Your personal information may be used and disclosed:

• as permitted or required by applicable law or regulatory requirements;
• to meet national security or law enforcement requirements;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of our regular reporting activities;
• to protect our rights and property;
• where the personal information is publicly available;
• during emergency situations or where necessary to protect the safety of a person or group of persons investigate fraud, or respond to a government request; or
• for any additional purposes for which we have obtained your consent.

We may disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you. Additionally, we may share your information with service providers in connection with real estate services, destination services, corporate housing, household goods shipments, language and cultural training and other ancillary relocation related services as part of your employer’s relocation benefit program.

Certain of our subsidiaries, affiliates, service providers and other parties with whom we share information under this Privacy Policy may perform activities outside of the European Union, Switzerland or the United States. As a result, your personal information may be collected, used, processed, stored, or disclosed in the European Union, Switzerland, United States, or other jurisdictions. In such cases, your information may be subject to the laws of those countries. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries.

We do not sell, transfer or disclose your personal information to any third party and we will not sell, transfer, or disclose your personal information to any third party other than for the limited purposes described in this Privacy Policy, or if we provide you with notice and a right to opt-out of such sale. We may share aggregated information that does not directly identify you.

We may disclose or transfer your personal information to third parties in connection with a corporate re-organization, merger or amalgamation, or the sale of all or substantially all of our assets, provided that the personal information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring this information.

TRACKING TECHNOLOGIES

When you visit our Site, we may automatically collect website use information, such as information about your operating system, browser type, domain name, your access times, the website that referred you to us, the Web pages you request, and the date and time of those requests. We use this information only to monitor our Site’s performance and improve our Site’s content and structure.

Plus Relocation and its partners use cookies to analyze trends, administer the Site, and track users’ movements around the Sites. You may be able to control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Sites.

As described in this Privacy Notice, Plus Relocation and/or its third parties on our digital propert(ies) may use cookies and similar tracking technologies to collect information and infer your interests for interest-based advertising purposes. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.

To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:

-Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices)

-European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu)

-Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/)

In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple’s IDFA or Android’s GAID), visit the device manufacturer’s current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http://www.networkadvertising.org/mobile-choices

SOCIAL MEDIA WIDGETS

Our Site includes social media features, such as the Facebook Like button, and Widgets, such as the “Share This” button or interactive mini-programs that run on our Site. These features may collect your Internet protocol address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it.

CALIFORNIA’S DO NOT TRACK NOTICE

We do not track our web visitors across third party websites to provide targeted advertising and, therefore, our Sites do not respond to Do Not Track (DNT) signals. We do not support Do Not Track browser settings and do not currently participate in any Do Not Track frameworks that would allow any of our Sites to respond to signals or other mechanisms from you regarding the collection of your personal information.

CONSENT AND OPT-OUT

It is important to us that we collect, use or disclose your personal information where we have your consent to do so.  Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express.  Express consent can be given orally, electronically or in writing.  Implied consent is consent that can reasonably be inferred from your action or inaction.  For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified at the relevant time.

If we seek additional information from you, beyond the information provided by you or your employer, we will seek your consent at the time that we collect any such personal information.  If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

Unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.  You may change or withdraw your consent to the collection of personal information at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to, or acquire products or services from, you or your employer.

From time to time, we communicate via email with users who request information. For example, we may use your email address to confirm a request you have made, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. If you do not wish to receive email communications from us, you may change or withdraw your consent at any time by contacting our Privacy Officer in writing using the contact information provided below.

PLUS RELOCATION’S ELO ONLINE COMMUNITY

We typically collect information under the direction of your employer or its designated representative. If you are a relocating employee of one of our clients and would no longer like communication provided by your employer using our services, please contact the employer that you interact with directly. Transfers to subsequent third parties are covered by the service agreements with your employer.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should log into their Elo^SM account or email us at elo@plusrelocation.com. If requested to  remove data, we will respond within a reasonable timeframe.

We will retain personal data we process for as long as needed to provide our services. Plus Relocation will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Users of the Plus Relocation’s Elo^SM Online Community (the “System”) opt-in to permit us to make certain information available to (i) their employer, or other third party that is sponsoring their use of the System, and (ii) service providers that provide services related to relocation, for the purpose of providing those relocation services.

System users may at any time also opt-out of receiving information from us, or from us making your information accessible through the System. If you wish to “opt-out” please email elo@plusrelocation.com.

PRIVACY POLICY REGARDING CHILDREN

Our Sites are not intended to collect personal information from children under the age of 13. We urge parents to regularly monitor and supervise their children’s on-line activities. Please contact us if you believe we have inadvertently collected personal information from a child under the age of 13, so we can delete such information.

LINKS TO OTHER WEBSITES

Our Sites may offer links to other websites that may be subject to less stringent privacy standards. If you visit one of these linked websites, you are then subject to the privacy policies and other policies of such website and are no longer protected by our policies. We are not responsible for, or able to monitor or control, the policies and practices of other companies, including with respect to their collection, use or disclosure or your personal information. You should review the privacy policies of these websites before providing them with personal information.

SECURITY

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.

Once we receive your transmission, we make reasonable efforts to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

In addition, although we obligate third parties who support our Sites and their related offers or other programs to use any personal information only for the purpose of performing their work, we do not control such third parties’ websites or other security measures.

If we learn of a security system breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Sites or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Sites. We may post a notice on our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

UPDATING OR ACCESSING YOUR PERSONAL INFORMATION

Upon request Plus Relocation will provide you with information about whether we hold any of your personal information. If you wish to obtain access to the personal information that we maintain about you, or to correct, amend, update or delete such information, please contact our Privacy Officer in writing using the contact information provided below. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavor to respond within an appropriate timeframe and, in any event, within any timeframe required by law. If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed or erased in accordance with our record retention obligations and practices. In the event, we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

CALIFORNIA CONSUMER PRIVACY ACT

Under the California Consumer Privacy Act, California residents have the right to:

• Request that a business delete any personal information about the consumer which the business has collected from the consumer.
• Request that a business that collects personal information about the consumer disclose to the consumer, free of charge, the following:
  • The categories of personal information that it has collected about that consumer.
  • The categories of sources from which the personal information is collected.
  • The business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom the business shares personal information.
  • The specific pieces of personal information it has collected about that consumer.

• Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose disclose, free of charge, to the consumer:
  • The categories of personal information that the business collected about the consumer.
  • The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal was sold, by category or categories of personal information for each third party to whom the personal information was sold.
  • The categories of personal information that the business disclosed about the consumer for a business purpose.
• Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.

You may submit a request under the California Consumer Privacy Act through the following methods:

• You may call us toll-free at 1-888-251-2825.
• You may e-mail us at privacy@plusrelocation.com.

To submit a request, we are required to verify your identity. Please be prepared to provide us with your address, phone number, email address and employee ID. We will match the personal information that you provide to us with personal information that we already maintain about you to verify your identity. We may also need to contact you to confirm your request.

You may also designate an authorized agent to make a right to know or deletion request on your behalf. To use an authorized agent, you as the California resident must provide the agent with written authorization, including the verification information above. In addition, the agent will be required to verify their own identity with us. We may deny a request from an agent that does not submit proof that they have been authorized by the you to act on your behalf.

We may not be able to honor each request that we receive, but if we are unable to do so, we will respond to let you know our reasons. We will not discriminate against you if you choose to exercise any of your rights as described in this section.

EUROPEAN UNION

This section of our Privacy Policy contains information for persons located in the European Union (“EU”), a European Economic Area (“EAA”) member state, or Switzerland. Before Plus Relocation collects any personal information from you, you are entitled under the EU General Data Protection Regulation (“GDPR”), to the information in this section of our Privacy Policy.

Purposes and Legal Bases for Processing Personal Information

Plus Relocation collects your personal information to provide our products and services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. We will collect and process your personal information as necessary for the performance of a contract to which you are a party or because we have another legitimate interest in doing so relating to our business purposes arising from your relationship with us. We may also seek your prior consent or rely on some other lawful basis to process your personal information.

Our legitimate interests include but are not limited to:

• Provide you with the products and services you request, view, engage with, or purchase;
• Communicate with you regarding your account or transactions with us; and
• Operate, understand, optimize, develop, or improve our sites, applications, products, services, and operations.

Rights of Users Located in the EU

If you use this website and are in the EU, EAA, or Switzerland, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.

• The right to access. You have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.
• The right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• The right to erasure. You have the right to ask us to erase your personal information in certain circumstances, including your personal information to be erased to comply with a legal obligation under EU or member state law.
• The right to restrict processing. You have the right to ask us to restrict the processing of your personal information in certain circumstances, including: (i) when the accuracy of the personal information is brought into question, or (ii) when we no longer need the personal information for purposes of the processing, but require such personal information for the establishment, exercise, or defense of a legal claim.
• The right to data portability. You have the right to ask that we transfer the personal information you gave us from one organization to another or give it to you.
• The right to lodge a complaint with the supervisory authority. If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of Supervisory Authorities is available here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
• The right to withdraw consent.  If Plus Relocation obtains your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of information.
• Automated decision-making.  To the extent that Plus Relocation engages in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.

To exercise these rights please contact us using the Contact Information below. For your protection, we may need to verify your identity before responding to your request.  If we refuse a request, we will provide you a reason as to why.

Right to Object to Processing

You have the right to object to the processing of your personal information that is based on legitimate interests. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us using the Contact Information below

Cross-Border Transfers of Personal Information

Personal information that you provide while in the EU, an EAA member state, or Switzerland will be transferred to the United States. The GDPR permits such transfer when necessary for the performance of a contract between you and Plus Relocation, if Plus Relocation obtains your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective of your privacy as those in your location.

Retention of Your Personal Information

We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

EU – U.S. DATA PRIVACY FRAMEWORK AND SWISS-US DATA PRIVACY FRAMEWORK

Plus Relocation Services, LLC, complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Plus Relocation Services, LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. Plus Relocation Services, LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

We are responsible for the processing of personal data it receives, under the Data Privacy Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Data Privacy Framework for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over Plus Relocation Services, LLC’s compliance with the EU-U.S. DPF and Swiss-U.S. DPF. In certain situations, Plus Relocation Services, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Plus Relocation Services, LLC commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.

CHANGES TO THIS PRIVACY POLICY

From time to time, we may revise this Privacy Policy as well as the Terms and Conditions of Use. Any revisions made will be posted within the Privacy Policy or Terms and Conditions of Use, as applicable, on the Sites and will take effect immediately as indicated by the ‘last updated’ date, unless otherwise noted. Collection and use of information from that point forward will be subject to the revised terms. If you do not agree with any revision to this Privacy Policy or Terms and Conditions of Use, you must stop using and accessing the Sites. Your continued access or use of the Sites after any such revisions are posted will constitute your acceptance of these changes. You should review the Privacy Policy and Terms and Conditions of Use from time to time for any changes. This Privacy Policy was last updated on August 1, 2023.

GOVERNING LAW / VENUE / FORUM

Unless otherwise noted in this Privacy Policy, this Privacy Policy and Terms and Conditions of Use shall be governed by the laws of the State of Minnesota and by the federal laws of the United States, excluding their conflict of laws provisions. All disputes, controversies and disagreements between the parties arising out of or related to this Privacy Policy shall be exclusively submitted for, resolved, and finally settled by binding arbitration. The arbitration shall be conducted by three (3) arbitrators exclusively in Hennepin County, Minnesota, in accordance with the Commercial Arbitration Rules of the American Arbitration Association. The Parties waive any objection that might be made on the ground that such venue may be in an inconvenient forum.