Effective: May 25, 2018

Scope of this Privacy Policy

We at Mobility Empowered (collectively, “Mobility Empowered”, “We”, “Us”, or “Our”) recognize the importance of protecting the privacy of personal data ("Information") collected by us and that transferred to us for processing on behalf of our customers. This Privacy Policy describes what Information we gather, how we use it, how we protect it, your rights with regard to your personal data and how you can access and update this information. Please note that this website and any related service portals are owned and operated by Mobility Empowered and is licensed to Solana Accommodations, Inc to conduct their business operations.

Our Privacy Policy and, as applicable, the agreement between us and your employer comprise the entire agreement governing access to and use of our websites (www.mobilityempowered.com, employee.mobilityempowered.com, www.solanaempowered.com, employee.solanaempowered.com, www.bristolempowered.com, and employee.bristolempowered.com) owned and operated by Mobility Empowered, and our relocation management, talent mobility, temporary housing and assignment management services (“Services”).

If your employer entered into an agreement with us, then you represent that you are an authorized user of our websites and the Services, and will abide by the terms of that Agreement. Information obtained and shared with you through this website or our mobile applications is our confidential information unless expressly indicated otherwise. Information may be requested/collected from you or your employer to enable the delivery of our services, to operate our business and to make the experience of using this site faster and more effective.

By using this web site, you consent to the terms of our Privacy Policy and to Mobility Empowered’s processing of Information for the purposes stated above, as well as those explained where Mobility Empowered collects Personal Information on our websites, service portals or within our mobile applications. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU CANNOT USE OUR WEBSITES, OUR SERVICE PORTALS OR OUR MOBILE APPLICATIONS. Should our Privacy Policy change, we intend to take every reasonable step to ensure that these changes are brought to your attention by posting all changes prominently on our websites, service portals and within our mobile applications for a reasonable period of time.

The above listed websites are hosted by servers in the United States, and, as such, these websites are governed by United States law. If you are located outside of the United States, your personal Information will be transferred to the United States. By using one or more of these websites or our Services, you acknowledge and agree to this Privacy Policy and the collection, use, and disclosure of your personal data by Mobility Empowered as outlined in this Privacy Policy.  If you do not agree with the terms described in this Privacy Policy, please do not use these websites or the Services, or submit any personal data. Your continued use of the websites, the Services and/or submission of personal data will be deemed your conclusive acceptance of our Privacy Policy and consent to the transfer of personal data to the United States and to its storage, processing, and use there in accordance with this Privacy Policy and United States law.

Collection, Use and Sharing

We collect and use personal data to enable delivery of our Services, to operate our business and improve performance of our websites.

To deliver our Services to you, the personal data we may collect and use include your name, telephone number, address, email address, employment information and IP address. We may also collect and use more “sensitive” personal information such as bank account number, government issued identifiers such as Social Security number, driver’s license number, an individual’s geolocation or historical precise geolocation information. Such personal data may be collected when you provide it to us through our websites, service portals, mobile applications, over the phone, through email, in support tickets or online chats or by mailing it to us; however we also may collect personal data about you from your employer or other third parties, such as our suppliers who provide Services to you. The personal data collected will be used only to communicate with you and to help us provide Services to you in accordance with our client agreements. As necessary for these purposes, we may share your personal data with your employer, our suppliers providing Services to you and among the companies within the Mobility Empowered family.

To facilitate the delivery of our Services, we engage and use suppliers in many countries throughout the world.  The location of the suppliers that will assist us in providing our Services to you will depend on the particulars of your assignment or relocation. These suppliers are given access only to the personal data, if any, that is needed to provide the specific service for which we contract them to provide for you. They are contractually bound to protect the confidentiality and security of your personal data; further, they must agree to limit the use of your personal data for the purpose intended in providing the service and are prohibited from doing anything with your personal data that we have not authorized them to do. Finally, they are required to treat your personal data in a manner consistent with this Privacy Policy.

In the event of a merger, dissolution, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal data as set forth in this Privacy Policy. This policy shall be binding upon Mobility Empowered and its legal successors in interest.

We are required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas. We also may disclose personal data about you as required or permitted by law.

We will retain your personal data in a form that identifies you only as long as necessary to provide you with our Services or as required by our contractual arrangements, data retention policies, to resolve disputes or by legal requirements.

In some cases, Mobility Empowered acts solely as a processor of the Information at the direction of our customer. In those instances, an individual who seeks access to, or who seeks to correct, amend, or delete inaccurate Information should direct his query to Mobility Empowered and Mobility Empowered will review with the client (the data controller) and respond within a reasonable timeframe.

Business Marketing & Newsletters

We may collect personal data consisting of name and business contact information from our clients, prospective clients, and our suppliers for use in providing and/or marketing our Services. In addition, if you ask to be subscribed to any of our marketing communications, we will collect your personal data solely for purposes of periodically sending to you via e-mail the summary of articles, multimedia and other content bringing you insights into the issues impacting global talent mobility strategies in today’s companies, Mobility Empowered company announcements, new products and services, features and updates to which you subscribed.  If you decide you no longer wish to receive those e-mails, you may unsubscribe by using the link found in the emails or by contacting us at privacy@mobilityempowered.com

Correcting/Updating Your Information

We are committed to keeping your personal data accurate and up-to-date. If you are a current customer and have registered for online access through one of our websites or mobile applications, you may be able to update personal data such as: your address, telephone number, email address, user name and password. If you are unable to access or make changes to the information you have provided to us online, you may contact us in order to do so.  We will take reasonable steps to comply with your request.

Third-Party Websites

Our websites, service portals and mobile applications may contain links to third-party websites. These internet websites may have their own privacy policies or no policy at all. We are not responsible or liable for the independent privacy policies or the privacy practices of those third-party websites. In addition we are not responsible or liable for any actions related to the use and disclosure of personal information by these third-party websites. The inclusion of any link does not necessarily imply that we endorse the third party company, its Internet site, or any services that it may promote.

Tracking Technologies

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to conduct research, analyze trends in the aggregate for internal audits and third-parties, generally to improve our services, and administer the site. By accessing and using the websites, you consent to the processing of data about you by the automatic data collection technology company set forth below in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the websites and/or the Services.

Cookies

Technologies such as cookies or similar technologies are used by Mobility Empowered and our marketing partners and analytics providers. These technologies are used in it. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. Cookies cannot be used to collect sensitive information about your computer or data residing on your computer. Most major websites use this technology and most browsers are set up to accept them.

We use cookies for session control and for authentication. Users can control the use of cookies at the individual browser level. If you reject or disable cookies, you may still use our site, but your ability to access and/or use some features or view content on our websites may be limited.

Collection of personal data from Children

This website is not directed toward children. We do not knowingly collect or post any information, including personal data, from children including those under the age of 13. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our policy by instructing their children never to provide personal data through the websites or the Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal data to us, please contact us, and we will endeavor to delete that information from our databases.

Data Security

We restrict access to your personal data only to those of our employees, agents and suppliers who have a “need to know” and based on the Services we or they are providing to you.  We maintain reasonable physical, electronic and procedural safeguards designed to protect personal data. Our external suppliers and others that we do business with are contractually bound to us to provide at least the same level of privacy protection and security as is required by this Privacy Policy. We regularly review our security standards and procedures as well as those of our suppliers to protect against unauthorized disclosure or use of or access to your personal data.

Compliance

Mobility Empowered and the companies within the Mobility Empowered family, comply with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Mobility Empowered has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

Mobility Empowered is responsible for the processing of personal Information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Mobility Empowered complies with the Privacy Shield Principles for all onward transfers of personal Information from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal Information received or transferred pursuant to the Privacy Shield Frameworks, Mobility Empowered is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, Mobility Empowered may be required to disclose personal Information 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://www.jamsadr.com/eu-us-privacy-shield. Where applicable for employee matters, in the context of employment relationship, and employee data that Mobility Empowered processes in its role as a service provider, Mobility Empowered commits to cooperation with the panel of the EU Data Protection Authorities (DPAs), the state or national data protection authority where the employee works or the Swiss Federal Data Protection and Information Commissioner (FDPIC), as applicable, to investigate unresolved complaints.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. Once arbitration is invoked, in some cases the individual may lose the option to seek relief for the same claimed violation in another forum.  For more information about binding arbitration please visit: http://www.commerce.gov/privacyshield/

Changes to Our Privacy policy

Mobility Empowered reserves the right to amend or change this Privacy Policy at its sole discretion. If we decide to change this Privacy policy, we will post those changes on our websites in a timely manner. By accessing these websites or using the Services after we make any such changes to this Privacy policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of your personal data is governed by the policy in effect at the time we collect such data. Please refer back to this Privacy Policy on a regular basis.

Who to Contact

For questions or complaints regarding this Privacy Policy or our privacy practices, or to exercise any of your rights with regard to your personal data, please contact:

By email:	privacy@mobilityempowered.com
By mail:	Privacy Officer Mobility Empowered LLC 1604 E 4th Ave Tampa, FL USA 33605
By phone:	+1-833-273-5663

We will respond to your request within a reasonable timeframe, but in no event later than 45 days.