Passageways Privacy Policy

Passageways Privacy Policy

Effective July 2, 2026

This update includes the following changes:

AI-Powered Features — Added a dedicated section describing OnBoard’s AI features. Included a commitment that neither OnBoard nor our AI service providers use your data to train AI models.

Enhanced Website Disclosures — Updated disclosures around cookies and sales and marketing technologies on our public-facing website, onboardmeetings.com, including tools that enable engagement with prospective customers.

EU and UK Representatives — Appointed dedicated representatives in both the European Economic Area and the United Kingdom as points of contact for data protection matters. Contact details for both representatives are available in the Contact Us section of the policy.

Passageways, Inc (“Passageways,” “we” or “our”), the provider of OnBoard and other services, values your privacy. This Privacy Policy applies to individuals who visit the Passageways public-facing website at www.onboardmeetings.com and the Passageways Help Center website at help.onboardmeetings.com (together, the “Passageways Websites”) or utilize the OnBoard web application located at app.onboardmeetings.com or its mobile applications (together, the “Platform”) (collectively, with the Passageways Websites, the “Services”).

Please review our Privacy Policy to understand how we collect and use the information you (or the entity with which you are associated) may provide to us. This Privacy Policy will be revised from time to time, so please revisit this page often to remain fully informed of our policies.

By using our Services, or voluntarily providing your information to us, you agree to the collection and use of your information as set forth in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not provide us with any information.

APPLICABILITY OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information Passageways collects or receives about you. This Privacy Policy does not apply to information collected by third party services, applications, websites, or advertisements linked to or accessible from the Services. Those third parties have their own privacy policies, and we are not responsible for their practices.

Please note that our processing of information uploaded to the Platform on behalf of our enterprise customers is governed by the terms of our agreement with the enterprise customer, rather than by this Privacy Policy. If you would like to understand how your data may be handled by one of our enterprise customers, please contact that customer directly.

HOW DO WE COLLECT INFORMATION FROM YOU?

Through Use of the Services. We collect “Personal Information” when you use the Services, including when you: (i) register for an account, (ii) use the Platform or Websites, and (iii) contact us to request information or ask questions. “Personal Information” means information that identifies you or relates to an identifiable person.

Cookie Consent. We use cookies and similar technologies on our Websites as described in this policy, including analytics tools, advertising pixels, sales and marketing technologies, and session replay technologies. Where required by applicable law, we will obtain your consent before placing non-essential cookies or activating such technologies on your device. Strictly necessary cookies, such as security and authentication cookies, are essential for the operation of our Website and do not require consent. You can manage your cookie preferences at any time using our Cookie Manager, accessible via the footer of our Websites.

Cookies and Tracking Technologies. We automatically collect certain information through cookies and similar technologies when you access our Websites, including log files, web beacons, and cookies. These are used for analytics, functionality, and remembering preferences. You can adjust settings using our Cookie Manager or browser settings; rejecting cookies may limit functionality.

Categories of Tracking Technologies. We use the following categories of cookies and similar tracking technologies on our Websites:

Strictly Necessary Cookies. Essential for basic website operation and cannot be disabled. Includes session management, security tokens, authentication, and load-balancing cookies. These cookies do not track advertising activity and do not require consent.

Analytics and Performance Cookies. Collect information about website usage (pages visited, navigation, errors) to improve our Websites. Providers: Google Analytics.

Functional and Preference Cookies. Enable personalization (language, region, display settings). Disabling may affect your experience and limit certain features on our Websites.

Advertising, Targeting Cookies, Sales Intelligence, and Pixels. Deliver relevant advertisements, measure campaign effectiveness, understand visitor engagement, limit ad frequency, and support sales and marketing activities, including identifying organizations visiting our Websites and enabling real-time sales engagement. When activated, partners may collect information including IP addresses, device and browser details, and transmit it in real time to our service providers and partners for business intelligence, visitor identification, and sales engagement purposes. We may also share hashed or otherwise protected contact information submitted through our Websites with advertising partners for conversion measurement, attribution, campaign optimization, and related purposes. Depending on how these technologies are configured, this activity may constitute a “sale” or “sharing” of Personal Information under certain state privacy laws. You may opt out of these technologies, including the visitor-identification and sales-engagement activities described above, at any time via our Cookie Manager or Do Not Sell or Share My Personal Information page.

Session Replay and Behavioral Analytics Tools. We use session recording tools that may record your interactions with our Websites, including page navigation, mouse movements, clicks, scrolling, and form inputs (excluding masked fields such as passwords). These tools transmit this information to our service providers in real time for service improvement and troubleshooting purposes. You may opt out at any time using our Cookie Manager.

Third-Party Chat Functionality. Communications submitted through our chat feature are transmitted to and processed by our chat service provider in real time. Our chat provider may also process related visitor and session information to route inquiries and operate the chat feature. By initiating a chat session, you consent to this transmission and processing. We may retain chat transcripts. Our chat provider does not use your communications for independent marketing purposes.

Social Media Features. Our Websites may include social media features (“like” or “share” buttons) from Facebook, LinkedIn, and Twitter/X. These may collect your IP address and current page. If you interact with these features or are logged into your social media account, these third parties may collect visit information per their privacy policies.

For a complete list of cookies, providers, purposes, and retention periods, see our Cookie Policy accessible through our Cookie Manager.

Third-Party Analytics and Monitoring Tools. Our Services use third-party analytics and monitoring tools to collect and analyze information about use of the Services. You can learn about Google Analytics at www.google.com/policies/privacy/partners/ and opt out at https://tools.google.com/dlpage/gaoptout. We also use application monitoring and real user monitoring tools within the Platform. For a current list of our service providers, see our subprocessor list at https://trust.onboardmeetings.com/Trust_Center.

Third-Party Data Collection. Third-party providers (including Google and Meta) may collect information about your interactions with our Websites directly through their technologies for their own purposes, including targeted advertising. You may opt out via our Cookie Manager or Do Not Sell or Share My Personal Information page.

Session Replay Data Practices. Session replay data is collected and transmitted to our service providers in real time for service improvement and troubleshooting. We do not share session replay data with third parties for independent marketing purposes. You may opt out via our Cookie Manager.

Advertising Pixels. We use advertising pixels, including the Meta Pixel. When activated, visit information (device, IP address, browser type, pages visited) may be transmitted to our advertising partners in real time. Meta uses this information in accordance with its own Data Policy. You can learn more about Meta’s advertising and how to manage your preferences within your Facebook and Instagram account settings, or by visiting Meta’s Privacy Center. You may opt out of Meta’s use of cookies and pixels by visiting Meta’s Ad Settings. You may opt out via our Cookie Manager or Do Not Sell or Share My Personal Information page.

WHAT INFORMATION DOES THE COMPANY COLLECT FROM YOU?

When you visit the Services, we automatically collect certain information through cookies, log files, and similar tools, including:

  • the domain name and browser you use to access the Internet
  • the date and time of your visit
  • the pages you visited, and how many “hits” a particular item is receiving and links “clicked”
  • the address of the web site you visited immediately prior to visiting Passageways Websites
  • your IP address (a number assigned to your computer when you use the Internet)
  • your operating system
  • non precise geolocation
  • name of your internet service provider
  • non sensitive demographic data
  • data relating to malfunctions or problems occurring when you use your computer with the Services and other customer service information
  • information about your use of the Services, and particular features thereof, and how frequently you use them. This may include, for example, activities collected through real user monitoring and session replay technology within the Platform, such as your clicks, mouse movements, scrolls, keystrokes (excluding any text content typed into password fields, which is masked), pages visited, navigation paths, and device information. This monitoring occurs within the Platform and is governed by our agreements with enterprise customers. For details, see our subprocessor list at https://trust.onboardmeetings.com/Trust_Center.

Contact With Us. When you contact us by email, chat, or through forms on the Services, you provide us with information such as your name, email address, phone number, and the content of your message.

Chat Widgets. If you use our live chat feature, your communications are transmitted to and processed by our third-party chat service provider in real time. By initiating a chat, you consent to this transmission and processing. We may retain chat transcripts. Our chat provider does not use your communications for independent marketing purposes.

Registered Users. When you register for the Platform, you or someone on your behalf provides us with information such as your name, address, phone number, and email address.

In addition, when you or other Registered Users use the Platform, certain data associated with your use of the services will be collected in addition to the general visitor data described above such as user log-in data, board role, other board service, feature usage, product settings, configuration, activity records, and associated log and metadata. Registered Users may also choose to submit additional information to the Platform, such as uploading photos or other images, or providing information about themselves in their profiles, including optional diversity-related data (e.g., how they identify with respect to gender, race, sexual orientation, or similar characteristics, if they wish to self-identify).

Professional or Employment-Related Information. We collect professional or employment-related information, such as job history and employer information, during our sales process and store it securely in our CRM. Users of the OnBoard application may voluntarily choose to provide additional information to their application profile, such as photos, images, or optional diversity-related data (e.g., how they identify with respect to gender, race/ethnicity, sexual orientation, veteran or disability status or similar characteristics). We may use this data to improve the Services and, where allowed, generate anonymized or aggregated reports. You control whether or not to provide this information; if you don’t wish for us to process this information, please do not provide it.

HOW IS YOUR INFORMATION USED?

We may use the information we receive for the following purposes based on our legitimate interests:

  • to provide and improve our Services;
  • to help identify you as a Registered User;
  • to help keep the Services safe and secure, and protect users’ rights or property;
  • to assess overall activity on the Services, including tracking interest in particular features of the Services;
  • for internal operations, including troubleshooting, diagnosing problems with servers, data analysis, testing, research and service improvement. We use such information for statistical/analytical purposes and for evaluating our Services to make them more useful to customers and to track and aggregate information. For example, we use IP addresses to monitor the regions from which Registered Users and visitors navigate the Services. We also collect IP addresses from Registered Users when they log into the Services as part of Passageways’ “Identity Confirmation” and “IP Range Restrictions” security features;
  • to monitor your use of the Services, including to enforce our Terms of Use;
  • to analyze platform usage for product development, training, security, and marketing purposes; and
  • to correspond with you regarding our Services or matters relating to use or potential use of the Services.

We may use the information we receive about you for the following purposes based on our legal obligations:

  • to store and process Personal Information for compliance with legal obligations; and
  • manage any requests to exercise data protection rights.

We may use the information we receive about you for the following purposes based on our legitimate interests, or based on your consent where required by applicable law:

  • to inform you of developments in our company or with our Services that we believe may be of interest to you. For example, if you fill out a “Contact Me” form, we will use the information provided to contact you about your interest in the Services; and
  • for products and event information purposes.

We use cookies and similar tools to personalize your use of the Services and improve your experience.

If our processing is based on your consent, you may withdraw that consent at any time by contacting us. Withdrawing consent does not affect the lawfulness of processing that occurred before you withdrew it.

We may disclose your Personal Information based on our legitimate interests to manage and develop our business:

  • with our affiliates (such as our subsidiaries) for the purposes described in this Privacy Policy;
  • with service providers who perform services on our behalf, such as website hosting, data analysis, fraud prevention, IT services, customer service, sales intelligence and engagement services, and marketing;
  • in connection with a merger, acquisition, reorganization, bankruptcy, or sale of assets, where your information may be transferred as part of that transaction, as permitted by law or contract;
  • in connection with the enforcement of terms which may govern the Services; and
  • to provide aggregate statistical information with respect to “traffic” patterns and usage of the Services to our partners or affiliates, provided that such information has been rendered non-Personal Information.

We may disclose your Personal Information to appropriate authorities for compliance with a legal obligation or legitimate interests, such as:

  • when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities (such as for potential fraud or infringement); and
  • when required by law, regulation, or legal process (such as a court order, subpoena, or government request), or when we have a good faith belief that disclosure is necessary to prevent harm, investigate illegal activity, or protect the safety of any person.

We may also disclose your information to protect someone’s safety or to comply with our legal obligations to protect our rights, property, or the safety of our users or others.

AI-POWERED FEATURES

We offer AI-powered features that help generate meeting minutes, insights, suggested action items, summaries and responses within the Platform. We use third-party AI service providers to provide these features. We do not use customer data to train AI models, and we contractually prohibit our AI service providers from doing so. These features may process certain Platform data such as meeting content, prompts, AI-generated responses, usage data, and related user identifiers. AI-generated outputs are designed to assist users and are subject to human review. Certain AI processing activities may involve temporary data storage in the United Kingdom. Processing data through AI features on behalf of our enterprise customers is governed by our agreements with those customers, including our Data Processing Agreement. If you have questions about how such features process your data, please contact us at [email protected]. For a current list of our subprocessors, including service providers that support AI features, please see our subprocessor list at https://trust.onboardmeetings.com/Trust_Center.

Selling and Sharing of Personal Information

We do not sell Personal Information in the traditional sense of exchanging information for monetary payment, but we do disclose information to certain types of advertising partners in a manner that may be considered a “sale” or “sharing” under certain privacy laws, and we allow you to opt out of such “sale” or “sharing” as described in “Your Privacy Choices.”

Requests to Opt-Out of Sale or Sharing. You may opt out of the “sale” or “sharing” of your Personal Information by visiting Do Not Sell or Share.

Browser Privacy Signals. We honor browser-based opt-out preference signals, including the Global Privacy Control (“GPC”). When we detect a GPC signal, we treat it as a valid opt-out request under applicable state privacy laws. Our Websites do not respond to “Do Not Track” (DNT) signals due to lack of a common industry standard, but you may opt out through the mechanisms described above.

THIRD-PARTY ADVERTISING ON PASSAGEWAYS WEBSITES

We use third-party advertising companies to show you ads for products and services that may interest you. These companies may use information about your visits to our Websites and other sites to deliver relevant advertisements.

Advertising companies may place cookies, pixel tags, or similar technologies on your browser to deliver personalized advertising, including sending emails based on browsing activity. Cookies may reflect de-identified data linked to information you submitted (e.g., hashed email addresses). We may share hashed or otherwise protected contact information, such as email addresses, with advertising partners for conversion measurement, attribution, campaign optimization, and related advertising purposes. In addition to our Cookie Manager, you may opt out through the Digital Advertising Alliance or Network Advertising Initiative.

We and our advertising partners use cookies to recognize you across devices (such as phone and laptop) and show personalized ads. We do not control how these third parties use your information, but they may offer opt-out choices.

Your Privacy Choices

Depending on where you live, you may have rights to access, correct, delete, or transfer your Personal Information, or to opt out of certain processing. To exercise these rights, contact us as described in the “Contact Us” section below. We will handle your request consistent with applicable law.

Our marketing emails contain links allowing you to opt-out of receiving future marketing communications. You also may opt out of receiving marketing emails from us by contacting us in accordance with the “Contact Us” section below.

Jurisdiction-specific rights are listed below.

Privacy Rights for European Union and UK Residents

Under the EU and UK GDPR, you may have the following rights regarding your Personal Information:

  • Access — You have the right to ask us for copies of your Personal Information.
  • Rectification — You have the right to ask us to rectify Personal Information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Erasure — You have the right to ask us to erase your Personal Information in certain circumstances.
  • Restriction of processing — You have the right to ask us to restrict the processing of your Personal Information in certain circumstances.
  • Objecting to processing — You have the right to object to the processing of your Personal Information in certain circumstances.
  • Data portability — You have the right to ask that we transfer the Personal Information you gave us to another organization, or to you, in certain circumstances.
  • Right to lodge a complaint — You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of your Personal Information infringes applicable data protection law.

You are not required to pay a fee for exercising these rights. To make a request, please contact us in accordance with the “Contact Us” section below. We will respond to you in the time period required by law.

Privacy Rights for U.S. Residents

A number of U.S. states have comprehensive data privacy laws which provide (now or in the future) their state residents with rights to:

  • Know — You have the right to confirm whether we process your Personal Information.
  • Access — You have the right to access certain Personal Information.
  • Delete — You have the right to request deletion of certain Personal Information.
  • Correction — You have the right to request to correct inaccuracies in your Personal Information.
  • Data portability — You have the right to ask that we transfer the Personal Information you gave us to another organization, or to you, in certain circumstances.
  • Opt-out — You have the right to opt out of Personal Information processing for: targeted advertising; sales; or profiling in furtherance of decisions that produce legal or similarly significant effects.
  • Sensitive Data Limitations — Either limit (opt-out of) or require consent to process sensitive Personal Information. Please note we limit our use of Sensitive Personal Information that we have collected about you to that which is necessary to perform the Services that we provide to you or as is otherwise legally permissible.
  • Automated Decision-Making — We do not use your Personal Information for automated decision-making that produces legal or similarly significant effects concerning you without human involvement. Our AI-powered features, as described above, are designed to assist users and generate outputs for human review, not to make autonomous decisions about individuals.

Nevada residents have a limited right to opt out of certain Personal Information sales. We do not currently sell data in a way that triggers Nevada’s opt-out requirements.

To exercise these rights, please email [email protected] or call 1-844-416-6976.

To verify your identity and protect against fraud, we may ask for additional information such as your email address, state of residency, or mailing address. If you have an account with us, we may verify your identity through your existing login credentials.

Authorized Agents. If you use an authorized agent to submit a privacy request on behalf of a U.S. resident, we may ask for proof of the agent’s authority. We may also require the resident to verify their identity directly or confirm they authorized the request.

Nondiscrimination. You have the right to be free from unlawful discriminatory treatment for exercising any of your rights under this section.

Right to Appeal. If we decline to take action on your request, you have the right to appeal our decision. To submit an appeal, please contact us at [email protected] with the subject line “Privacy Request Appeal.” We will respond to your appeal within the timeframe required by applicable law. If your appeal is denied, you may have the right to contact your state’s Attorney General or other applicable regulatory authority.

CHILDREN

This website is not intended for children and Passageways does not knowingly collect Personal Information from anyone under the age of 18 or direct the Services to anyone under the age of 18. If you are under 18, please do not use the Services or send any information about yourself to us. We do not knowingly use cookies or tracking technologies to collect data from children under 13, and our advertising and session replay technologies are not deployed in contexts where we know users are minors. If we learn that we have collected Personal Information from a child under 18, we will take steps to delete that information as quickly as possible. If you believe that a child under 18 has provided us with Personal Information, please contact us at [email protected].

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is necessary in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Cookie and Tracking Data Retention. We retain data collected through cookies and similar technologies for as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required by law. Session cookies typically expire when you close your browser, while persistent cookies remain until they expire or are deleted. For more information about specific cookies and similar technologies, please see our Cookie Manager.

PROTECTING YOUR PERSONAL INFORMATION

We implement appropriate technical and organizational measures designed to protect Personal Information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and employee training. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security. If you suspect unauthorized access to your information, please contact Passageways immediately at [email protected].

INTERNATIONAL VISITORS

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States and the United Kingdom, which may have data protection rules that differ from those of your country. For example, certain AI-related processing activities described in this policy involve temporary data storage in the United Kingdom. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

If you use our Services from the European Union, United Kingdom, or other regions with different data protection laws, your Personal Information will be transferred to the United States for storage or processing.

Your information may be transferred to a country outside of the EU/UK that is not recognized by the Secretary of State as providing an adequate level of data protection according to EU/UK standards (the full list of countries is available here). For transfers from the EU/UK to countries not considered adequate by the applicable regulatory authority, we have put in place adequate measures to protect your Personal Information, including the use of Standard Contractual Clauses approved by the European Commission and, where applicable, the UK International Data Transfer Addendum. You may request a copy of these safeguards by contacting us at [email protected].

We may also transfer your data to other countries to store and process it, fulfill your requests, and operate the Services. These countries may have different data protection rules than your home country.

POLICY MODIFICATIONS

We may update this Privacy Policy at any time, and changes take effect when posted. If we make significant changes, we will notify you by posting a notice on our website or, where required by law, by contacting you directly. We encourage you to review this policy periodically.

CONTACT US

Passageways, Inc., located at 333 N. Alabama Street, Suite 300, Indianapolis, IN 46204, is the data controller responsible for the collection, use, and disclosure of your information under this Privacy Policy. If you have questions or concerns, please email us at [email protected].

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us first at [email protected].

VeraSafe has been appointed our representative in the European Union and the United Kingdom for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union and Article 27 of the United Kingdom General Data Protection Regulation. If you are located in the European Economic Area, you may also contact VeraSafe using this contact form or via telephone at: +420 228 881 031. Alternatively, VeraSafe can be contacted at VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland.

If you are located in the United Kingdom, VeraSafe can be contacted on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form or via telephone at: +44 (20) 4532 2003. VeraSafe can also be contacted at: VeraSafe United Kingdom Ltd., 37 Albert Embankment, London SE1 7TL, United Kingdom.

DATA PRIVACY FRAMEWORK

Passageways complies with the EU-U.S. Data Privacy Framework (EU-US DPF), the UK Extension to the 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. We have certified to the U.S. Department of Commerce that we adhere to the EU-US DPF Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Passageways has also 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 in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Policy and the EU-US DPF Principles or Swiss-U.S. DPF Principles (collectively, the Principles), the Principles will take precedence. To learn more about the Data Privacy Framework, please visit https://www.dataprivacyframework.gov. You may view our self-certification on the Data Privacy Framework List.

Passageways is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. We also may be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requests.

Individuals in applicable jurisdictions may request to access their user data and HR Data, and to limit use and disclosure of this information, in accordance with the DPF Principles. To make such a request, please contact us at [email protected]. If your request involves personal information contained in user data that we process on behalf of an enterprise customer, please direct your request to that enterprise customer.

Passageways is responsible for personal information that it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. Passageways complies with the DPF Principles for all such onward transfers of personal information, including the onward transfer liability provisions.

Individuals with inquiries or complaints regarding our compliance with the DPF Principles should first contact us at [email protected]. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit our U.S.-based third-party dispute resolution provider at https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. JAMS’ services are provided at no cost to you.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Passageways also commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (“DPAs”) and the ICO and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to any unresolved complaints concerning our handling of human resources data in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

For complaints regarding DPF compliance that are not resolved by any of the other DPF mechanisms, you may have the possibility, under certain conditions, to invoke binding arbitration before a Data Privacy Framework Panel.