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PRIVACY NOTICE

Body


PROTECTING YOUR PERSONAL INFORMATION

UKG Inc., comprised of Ultimate Software, Kronos, and their respective
subsidiaries (collectively, “UKG”, “we” and/or “us”) are committed to protecting
the privacy of the individuals who visit our website (“Visitors”) and
individuals who use UKG’s Services (“Users” and/or “you”) as an employee or
applicant of UKG or one of its customers.


SCOPE

This Privacy Notice (“Notice”) describes UKG’s privacy practices in connection
with the use of UKG’s websites, products, services, and any associated
applications (“Services”). The Notice also provides information about the
choices you have regarding the collection or use of your Personal Information
(“PI”) and the rights provided to you, including the ability to access or update
information about you.

WHAT DOES THIS NOTICE COVER?

The Notice applies to PI provided or collected through the use of UKG’s Services
by customers, employees, job applicants and/or website visitors. For purposes of
this Notice, PI means information collected by UKG, relating to an Identified or
Identifiable natural person. 

WHICH PRIVACY NOTICE IS APPLICABLE?

Our Customer’s Notice applies when you:

 * Use a customer-branded sign-on page; and
 * Are an applicant creating a profile or applying for a position with our
   customer.

This Notice applies when you:

 * Use a UKG-branded sign-on page; and
 * Are an applicant creating a profile or applying for a position with UKG.

LINKS TO NON-UKG WEBSITES

UKG’s websites might contain links to third-party sites for your convenience
and/or information. When you access those links, you leave UKG’s website and are
redirected to a third-party site.  UKG does not control third-party sites.  The
privacy practices of third parties might differ from UKG’s privacy practices. 
We do not endorse or make any representations about third-party websites.  When
you share PI with third-party websites, the third-party processing is not
covered by this Privacy Notice. We encourage you to review the privacy policy of
any website or company before sharing PI with them.


SOURCES OF PERSONAL INFORMATION

INFORMATION WE COLLECT:

UKG collects PI from several different sources, including:

 * Directly from a website visitor, prospects, customers, applicants, or
   employee;
 * Directly or indirectly from website visitors, customers, vendors, service
   providers or other third parties; and
 * From your use, visit or activity on any of our websites or products.

Please review each of the sections below to learn more about how UKG collects
PI, and what PI is collected. 

WEBSITE VISITORS

How Do We Collect Personal Information?

UKG collects PI about a website visitor when the visitor visits our website and
when the visitor chooses to provide PI. For example, we collect information when
you visit our website and when you contact us via our website, provide your
email, phone or other similar information, such as the information that you
provide when you sign up for a webinar. 

What Is collected?

The PI collected from a website visitor includes:

 * Name;
 * Company;
 * Job Title;
 * Address;
 * Phone Number; and
 * Email Address.

CHILDREN

We do not knowingly collect PI from children under the age of 13. If you are
under the age of 13, please do not submit any PI to UKG. If you have reason to
believe that a child under the age of 13 has provided his/her PI to UKG, please
contact us in accordance with Section 14 of this Notice, and we will endeavor to
delete that information from our databases.

UKG JOB APPLICANTS AND EMPLOYEES

How Do We Collect Personal Information?

UKG collects PI about a job applicant when an application for employment with
UKG is completed. Additionally, UKG collects information about individuals who
create a profile on our website, regardless of whether or not an application is
completed.

If hired by UKG following an application, additional information is collected
during the onboarding process and throughout the employment relationship. We may
also collect information that you have voluntarily made public and/or shared on
publicly visible accounts, such as social media platforms.

What Is collected?

The PI collected from an applicant or employee of UKG includes, but is not
limited to:

 * Personal Identifiers (Name, Address, Age, Date of Birth, Social Security
   Number);
 * Professional or Employment-related Information (Employment Record, Salary);
 * Education Information; and
 * Personal/Professional Contact Information.

CUSTOMERS’ INFORMATION (AND THE INFORMATION OF THEIR EMPLOYEES AND JOB
APPLICANTS)

How Do We Collect Personal Information?

When using our products and services, our customers are solely responsible for
determining what PI is collected regarding their employees or job applicants.
UKG processes information solely at the direction of its customers and has no
direct relationship with the individuals (our customers’ employees and
applicants) whose PI we process. 
The information may be collected through our SaaS solution, by members of our
support team who provide support to customers, or by subprocessors engaged by
UKG to provide you with the Services. For employees of customers who use Kronos
terminals with a biometric or finger scanning device for employee timekeeping,
please see the Biometric Data Privacy section of this Notice.

What Is collected?

The PI processed by UKG on behalf of our customers varies, but includes
information such as name, company name, address, email address, time and
attendance and schedule information, and Social Security Numbers. Please contact
your employer or the company with whom you applied to learn more about the
information they collect for use with UKG’s products and services. 

MOBILE APPLICATION USERS

How Do We Collect Personal Information?

UKG collects PI about a user of our mobile application when the user chooses to
provide such information. We also collect information about you through the use
of mobile analytics software.

What Is Collected?

Our mobile application may record information concerning how often you use the
application, the events that occur within the application, aggregated usage,
performance data, your location, the type of device used, and from where the
application was downloaded. We do not link the information we store within the
analytics software to any PI you submit within the mobile application.

WEBSITE ACTIVITY, COOKIES AND OTHER TRACKING TECHNOLOGIES

How Do We Collect Personal Information?

UKG collects information through the use of website tracking software, as well
as from your use or activity on any of our websites, utilizing cookies and other
tracking technologies.

What Is Collected?

The website tracking software automatically captures technical information that
is stored in our server’s log files. For example, when you visit our websites,
We and our partners store and access non-sensitive information from your device,
such as cookies or a unique device identifier, and process PI such as your IP
address, device manufacturer and model, the type of browser being used, the web
pages visited, and the amount of time spent on our website.

To learn more about our use of Cookies and other tracking technologies, please
visit our Cookies and Other Tracking Technologies section. 

SOCIAL MEDIA FEATURES AND WIDGETS

How Do We Collect Personal Information?

Our websites may include social media features, such as video links, “Like”
buttons, and widgets such as “Share” buttons or interactive mini-programs, and
may set a cookie to enable the feature to function. Social media features and
widgets may be hosted by a third party or hosted directly on our websites. Your
use and interactions with these features are at your discretion, and are
governed by the privacy policy of the companies providing them.

What Is collected?

These features may collect your PI such as your IP address and which website
page you are visiting. 


USE OF PERSONAL INFORMATION


WHY WE USE YOUR PERSONAL INFORMATION:

UKG uses PI for several purposes, including:

 * To communicate with you regarding our products and/or services;
 * To fulfill the purpose(s) for which the information was collected/provided,
   including providing contractually-obligated products and/or services;
 * To improve our website, products and services, through testing, research,
   analysis and product development;
 * For security purposes, such as to prevent unauthorized access or disclosure,
   to maintain data accuracy, to protect the confidentiality, integrity and
   availability of your PI and to allow only the appropriate use of your PI; and
 * To comply with all applicable legal obligations.

Please review each of the sections below to learn more about how we use your PI.

WEBSITE VISITORS

How Do We Use Your Personal Information?

The PI you provide when using our website will be used in accordance with this
Privacy Notice. We use your PI to fulfill requests for information about our
products and services and to enable you to register and participate in events
that we sponsor (including webinars).  

UKG JOB APPLICANTS AND EMPLOYEES

How Do We Use Your Personal Information?

We use PI of our job applicants and employees for legitimate human resource
business purposes, such as:

 * Payroll administration;
 * Filling open employment positions;
 * Maintaining accurate benefits records;
 * Complying with governmental reporting requirements;
 * Performance management;
 * Provision of company network access;
 * Authentication of individuals; and
 * Security, health and safety management.

CUSTOMERS’ INFORMATION (AND THE INFORMATION OF THEIR EMPLOYEES)

How Do We Use Your Personal Information?

We use your PI to provide you with services, which UKG is contractually obliged
to provide to you, to improve these services or communicate with you about our
products or services. For employees of customers who use UKG terminals with a
biometric or finger scanning device for employee timekeeping, please see the
Biometric Data Privacy section of this Notice.

WEBSITE ACTIVITY, COOKIES AND OTHER TRACKING TECHNOLOGIES

How Do We Use Your Personal Information?

In order to improve the content and format of our site, UKG uses website
tracking software to automatically capture technical information that is then
stored in our server’s log files.  UKG and its partners also utilize cookies and
other tracking technologies to measure the preferences of our website visitors,
analyze trends, administer the website, track users’ movements around the
website, and to gather demographic information about our user base as a whole.
Please visit our Cookies section below to learn more. 

MOBILE APPLICATION

How Do We Use Your Personal Information?

UKG uses mobile analytics software to allow us to better understand the
functionality of our Mobile Software on your phone. We do not link the
information we store within the analytics software to any PI you submit within
the mobile application.  


DISCLOSURE OF PERSONAL INFORMATION

We do not sell PI to third parties. Please review each of the sections below to
learn more about how we might disclose your PI.

AFFILIATES AND SUBSIDIARIES:

We might share your PI with our Affiliates and Subsidiaries in order to deliver
a product or service or complete a task that you requested.  

THIRD PARTIES (VENDORS/SERVICE PROVIDERS):

We might engage with third parties (vendors and/or service providers) in order
to deliver a product or service (or perform certain functions such as enhancing
and/or delivering our product and service offerings) or complete a task that you
requested.  

We have contracts with third-party providers (vendors and/or service providers)
to perform certain functions on our behalf, and only at our direction. Our third
parties are bound by confidentiality agreements, only have access to your PI to
the extent necessary to provide these contracted services and are only permitted
to process your PI in accordance with our instructions (and for the purposes we
disclose).

ADDITIONAL DISCLOSURES

UKG might disclose your PI if we in good faith believe that such action is
necessary to:

 * Comply with the law or with legal process;
 * Protect and defend our rights and property;
 * Protect against misuse or unauthorized use of our website;
 * Protect the personal safety or property of our users or the public (among
   other things, this means that if you provide false information or attempt to
   pose as someone else, information about you may be disclosed as part of any
   investigation into your actions).

Other than as stated in this Privacy Notice, we will endeavor not to release
your PI to unknown or unaffiliated third parties, and we will not
cross-reference your PI with that of any other customer or entity.
 


TRANSFERS OF PERSONAL INFORMATION

INTERNATIONAL TRANSFERS

UKG complies with the EU General Data Protection Regulation regarding the
transfer of PI from the EU to the U.S.  For transfers of PI originating in the
EU to UKG for processing by UKG in a jurisdiction other than a jurisdiction in
the EU, the EEA, or the European Commission-approved countries providing
‘adequate’ data protection, UKG agrees it will (a) provide at least the same
level of privacy protection for PI originating in the EU as required under the
U.S.-EU and U.S.-Swiss Privacy Shield frameworks; or (b) use the form of the
Controller-to-Processor Standard Contractual Clauses (“SCCs”) currently
approved. To facilitate cross-border transfers, such as between the EU,
Switzerland, and the United Kingdom and the U.S., we rely on other mechanisms
such as Standard Contractual Clauses (SCC) to ensure that appropriate privacy
protections and safeguards for personal information are in place.

To learn more about how UKG complies with the Schrems II caselaw, please refer
to UKG’s Transfer Risk and Impact Statement.

PRIVACY SHIELD

UKG complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S.
Privacy Shield Framework (Privacy Shield) as set forth by the U.S. Department of
Commerce regarding the collection, use, and retention of personal information
transferred from the European Union, the United Kingdom and/or Switzerland, as
applicable. UKG has certified to the Department of Commerce that it adheres to
the Privacy Shield Principles with respect to such information. To learn more
about the Privacy Shield program, and to view our certification, please visit
the Privacy Shield website.

UKG is responsible for the processing of PI we receive, defined as any operation
or set of operations which is performed upon PI, whether or not by automatic
means, such as collection, recording, organization, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, blocking,
erasure or destruction, it receives, under the applicable Privacy Shield
Framework, and, on occasion, subsequently transfers to a third party acting as
an agent on its behalf.  UKG complies with the Privacy Shield Principles for all
onward transfers of PI from the European Union, the United Kingdom and/or
Switzerland, including the onward transfer liability provisions.

With respect to PI received or transferred pursuant to the Privacy Shield
Frameworks, UKG is subject to the regulatory enforcement powers of the U.S.
Federal Trade Commission.  In certain situations, UKG may be required to
disclose PI in response to lawful requests by public authorities, including to
meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website,
you may invoke binding arbitration when other dispute resolution procedures have
been exhausted.

APEC

UKG’s privacy practices, described in this Privacy Notice, comply with the APEC
Cross Border Privacy Rules System (CBPR).  The APEC CBPR system provides a
framework for organizations to ensure the protection of Personal Information
transferred among participating APEC economies.  More information about the APEC
framework can be found here.


RETENTION OF PERSONAL INFORMATION

UKG will only retain PI for the length of time necessary to fulfill the
purpose(s) for which the information was collected or as required or permitted
by applicable laws, (including the resolution of disputes) and in accordance
with our customer contracts.


COOKIES AND OTHER TRACKING TECHNOLOGIES


WHAT ARE COOKIES?

A cookie is a small amount of data which our website stores on your computer,
and which we can later retrieve. The cookie cannot be read by a site other than
ours. As discussed in our section on Use of Your PI, we use cookies for a number
of administrative purposes, including to store your preferences, allowing us to
provide website visitors with a better experience.

HOW CAN YOU MANAGE THE USE OF COOKIES?

UKG Privacy Center: When you visit our website, you can make choices about our
usage of cookies, by navigating to the bottom of our website and clicking
“cookie consent choices” or by clicking “Learn More” on the pop-up banner. You
also have the option of viewing our existing partners and authorizing or
blocking their collection and use of your PI.

MANAGING FLASH COOKIES

To manage Flash cookies, please click here.

MANAGING COOKIES THROUGH YOUR BROWSER

You can monitor our use of cookies on your computer by setting your Web browser
to inform you when cookies are set, or you can prevent the cookies from being
set entirely. The “help” portion of the toolbar on most browsers will tell you
how to prevent your browser from accepting new cookies, how to have the browser
notify you when you receive a new cookie, or how to disable cookies altogether.
Please understand that if you disable the use of cookies on your computer, you
may be unable to access certain portions or services on our websites. 

ADVERTISING AND ANALYTICS COOKIES

We work with third parties to manage our advertising on other sites. These third
parties might use cookies or other similar technologies to provide you
advertising based upon your browsing activities and interests. We use standard
Google Analytics for general site analytics. To learn more about how Google uses
data from sites that use their services, click here. 

We have also implemented the following Google Analytics Advertising features for
our paid advertising:

 * Google Display Network Impression Reporting;
 * Google Analytics Demographics and Interest Reporting; and
 * Integrated services that require Google Analytics to collect data for
   advertising purposes, including the collection of data via advertising
   cookies and identifiers.

If you wish to opt-out of the Google Analytics Advertising features that we use,
click here.


BIOMETRIC DATA

As previously stated, UKG does not collect or control customer employee data.
For customers who use UKG terminals with a biometric or finger scanning device,
the collection of customer employee finger scan data is undertaken and
controlled by the customer. Our customers collect such employee data through
their use of the finger scanning devices and related software, and either store
the data at the customer controlled site or on secure space (in accordance with
applicable law) made available by UKG in a cloud environment for that purpose.

This data is used by the customer for employee verification in connection with
its employee timekeeping purposes. Such data consists solely of templates
created from mathematical algorithms, not fingerprints. Customer employee finger
scan data, or templates as described above, may be among the customer employee
data collected or stored by UKG customers.

A copy of UKG’s data security policy applicable to the secure space on which
customers can store employee data can be accessed at: www.kronos.com/security.
UKG has put reasonable measures in place to minimize its access to customer
employee finger scab data from its customers. On the rare occasions when UKG
accesses customer employee finger scan data (e.g. for technical support), it is
done pursuant to a customer’s instruction, and subject to strict handling
procedures, and UKG permanently destroys such data promptly after the specific
purpose for accessing the data has been satisfied. Customers are responsible for
destroying customer employee finger scan data that they collect, control,
possess or store. Any questions regarding customer biometric or finger scan
employee data, including any applicable retention schedule or destruction
process, should be directed to the appropriate employer.


DATA SUBJECT RIGHTS

UKG will take reasonable steps to ensure that all PI of UKG employees, job
applicants and website visitors is accurate and complete for the intended use.
As previously stated, we will only use PI in ways that are consistent with the
purposes for which it was collected, as required or permitted by law, or as you
might subsequently authorize.

In accordance with all applicable law, we enable you to exercise some or all of
the following rights regarding our collection, use, and sharing of your PI:

 * Access the PI we maintain about you;
 * Update or correct any inaccurate or incomplete PI about you;
 * Request that we delete your PI;
 * Object to or restrict the processing of your PI;
 * Receive the PI you have previously provided to UKG, in a machine-readable
   format, allowing you to transfer that PI to another company at your
   discretion;
 * Not be subject to a decision based solely on automated processing, including
   profiling, which produces legal effects concerning you or similarly
   significantly affects you; and
 * File a complaint directly with the relevant Supervisory Authority about how
   we process your PI.

EXERCISING YOUR RIGHTS

To protect your privacy and security, we take reasonable steps to verify your
identity, before granting access to your PI. Please follow the instructions
below based on your relationship with UKG, and provide the requested information
to allow us to adequately address your request.  We will respond to your request
within a reasonable timeframe.

If you are a resident of California, please review our CCPA Notice here.

WEB VISITORS

If you are a Non-California resident and would like to request access to your
Personal Information, and/or request erasure (right to be forgotten) of PI
previously provided, please click here.

UKG JOB APPLICANTS AND EMPLOYEES

If you are a current or former employee or you previously applied for employment
with UKG (including Ultimate Software, Kronos, and their respective
subsidiaries), and reside in the European Union, Switzerland or the United
Kingdom, and would like to request access to your PI, and/or request erasure
(right to be forgotten) of PI previously provided, you may submit your request
via email at privacy@ukg.com.

For current and previous UKG employees, please indicate the right you are
exercising. In order to verify your identity, your request must include the
following:

 * Your full name and email address associated with your profile;
 * Your preferred contact number; and
 * Your hire date, which can be found by current or former employees (up to one
   year following termination) within your profile, or on your offer letter. We
   require your hire date to be provided in the MM/DD/YY format.

If you previously applied for employment with UKG, please indicate the right you
are exercising. In order to verify your identity, your request must include the
following:

 * Your full name and email address associated with your profile;
 * Your preferred contact number; and
 * The number of employment opportunities you have applied for with UKG, as well
   as the Job Title and Job Code associated with each application, which can be
   found in your profile, under the Applications tab.

OUR CUSTOMER’S JOB APPLICANTS AND EMPLOYEES

When processing PI on behalf of a customer, UKG has no direct business
relationship with the individuals whose PI it processes (applicants or employees
of our customers). 

If you are a current or former employee or job applicant of one of UKG’s
customers, please contact your employer/former employer/company you applied with
directly to exercise your rights relating to your PI. As a processor, UKG does
not respond to requests from our customer’s applicants or employees unless that
customer is no longer in business.

DENIAL OF REQUESTS

UKG may deny a request relating to a Data Subject’s individual rights as
permitted by applicable law. UKG will endeavor to timely notify you regarding
any decision and reason(s) for denial.

DISPUTE RESOLUTION

In accordance with this Notice, UKG will investigate and attempt to resolve
complaints and disputes regarding the use and disclosure of your PI.
Additionally, UKG agrees to cooperate with Data Protection Authorities within
the European Union and the Federal Data Protection and Information Commissioner
in Switzerland, or authorized representatives for disputes specific to Human
Resource information received from the European Union, the United Kingdom and
Switzerland. 

Any privacy-related dispute or concern that is still unable to be resolved to
your satisfaction shall be handled in accordance with applicable dispute
resolution procedures through our U.S.-based third party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

We strongly encourage you to raise any complaints you may have with regard to
this Privacy Notice and/or our activation of this Notice to us prior to
proceeding to the arbitration procedure described in the prior paragraph.


SECURITY

To prevent unauthorized access or disclosure, to maintain data accuracy, and to
allow only the appropriate use of your PI, UKG utilizes physical, technical, and
administrative controls and procedures to safeguard the information we collect.

To protect the confidentiality, integrity, availability and resilience of your
PI, we utilize a variety of physical and logical access controls, firewalls,
intrusion detection/prevention systems, network and database monitoring,
anti-virus, and backup systems. We use encrypted sessions when collecting or
transferring sensitive data through our websites.

We limit access to your PI and data to those persons who have a specific
business purpose for maintaining and processing such information. Our employees
who have been granted access to your PI are made aware of their responsibilities
to protect the confidentiality, integrity, and availability of that information
and have been provided training and instruction on how to do so.


ENFORCEMENT AND VERIFICATION

UKG will periodically assess its operations to validate compliance with this
Privacy Notice.

When we have knowledge that one of our employees or third parties is using or
disclosing PI in a manner contrary to this Privacy Notice, we will take
reasonable steps to prevent or stop the use or disclosure. We hold our employees
and third parties accountable for maintaining the trust that our customers place
in us.


CHANGES TO THIS PRIVACY NOTICE

This Notice describes our current PI protection policies approved on October 1,
2021. UKG reserves the right to modify or amend this Notice at any time
consistent with applicable laws.  We encourage you to periodically review this
page for the latest information on our privacy practices.


CONTACT INFORMATION

At any time, you may contact UKG with questions or concerns about this Privacy
Notice at privacy@ukg.com.

Written responses may also be submitted to:

Ultimate Kronos Group
Attention: VP Deputy General Counsel
900 Chelmsford St.
Lowell, MA 01851

Those residing in the EU may contact our Data Protection Officer (DPO) via email
at privacy@ukg.com. The DPO also serves as UKG’s representative in Europe and is
located at:

Ultimate Kronos Group
Attention: Data Privacy Officer
53 rue d’Hauteville
75010 Paris, France

UKG will respond to all correspondence within a reasonable timeframe, including
as required by applicable law.


CALIFORNIA RESIDENTS - CHANGES TO THIS PRIVACY NOTICE

The California Consumer Privacy Act (“CCPA”) provides certain privacy-related
rights to California residents. Please click here to learn more about UKG’s
privacy practices and compliance with the CCPA.




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