Privacy Policy

Last Updated January 20, 2020

This Privacy Policy explains how
information about you is collected, used and disclosed by Expert Consortium Ltd, a private limited company registered in Bangladesh (collectively, “ECL,” “we,” “us” or “our”) when you access or use our website (the “Site”) and our online payroll, benefits, human resource and other services (the “Service”), which are provided through the Site. By using the Site and/or the Service, you consent to the collection, use and disclosure of your information as outlined in this Privacy Policy.

Information We Collect and How We Collect It

In connection with your access to our Site and/or use of our Service, we collect and store certain information
about you. Some of this information can be used on its own or in combination with other information to identify you individually. We call that information “personal information.” We collect personal information and other information as described below:

• Information You Provide. We collect your personal information when you,
  your employer, or your employer’s accountant partner register to use the
  Service, provide information when using the Site or Service, update your
  account information, add additional services, submit information to verify
  your identity, contact us with questions or feedback, or otherwise
  communicate with us. This personal information may include your name,
  mailing address, email address, phone number, date of birth, bank account
  information, Social Security number or taxpayer identification number, and
  benefits enrollment information.
• When You Choose to Participate in Market Research
  Programs. We may collect
  information from you, including personal information, if you choose to
  participate in a market research program or survey.
• Public Information. We
  may collect information about you from public sources, such as public
  social media pages.
• Information from Third Parties. We may collect and receive information about you,
  including personal information and financial account information, from
  third parties, such as financial institutions and our service providers,
  for identity verification, fraud protection, risk assessment, providing
  the Service, and other purposes. We may collect your business or personal
  information from credit bureaus for the foregoing purposes as well. In
  addition, we may receive demographic and business industry information
  about you from third parties to help us better understand our users and to
  improve and market our Service.
• Health and Health Insurance Information. If you or your employer uses the Service to
  manage your health benefits (the “Benefits Service”), we may
  receive health information about you and your dependents in order to
  provide the Benefits Service. The health information may include
  information about your insurance carrier, insurance plan and claims you
  submit for coverage. We receive the health information (i) directly from
  you when you submit enrollment or claims information, or otherwise provide
  health information to us; (ii) from the primary policyholder on your
  benefits plan, if you are a spouse or dependent of the primary
  policyholder; (iii) from your employer; (iv) from insurance carriers; or
  (v) from other third-party administrators.
• Automatically Collected Information. We automatically collect certain usage
  information when you access the Site or use the Service, such as your
  device identifier (if using a mobile device), Internet Protocol (IP)
  address (if using a browser), operating system, browser type and the
  address of a referring site. We also automatically collect certain usage
  information through cookies and related technologies, as described below.
• Single Sign-On Information. Single Sign-On (“SSO”) allows you to sign
  in to the Service from another service you use and with which we partner.
  We will collect certain information for security purposes in order to
  verify your authorized access to the Service, including your username and
  password for the other service.

Third-Party
Software, Cookies and Other Related Technologies

We may use cookies, pixel tags, web beacons and other similar technologies to better understand how you interact with our Site, monitor aggregate usage by our users, and monitor web traffic routing on our Site to help us improve our Site or the Service. Most Internet browsers let you change the browser’s settings to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not allow cookies, you may not be able to use some or all portions or functionality of the Site or Service.

We partner with third parties to manage our advertising on other sites and to determine our Site performance.
Such partners may use cookies, pixel tags, web beacons and other related technologies to collect information about your activities on our Site and other sites so that we can (i) provide advertising that may be of interest to you, (ii) evaluate the efficacy of our marketing programs and our Site, (iii) monitor, analyze, improve and develop the Site and Service, and (iv) prevent, identify and address fraudulent or other illegal activity and security issues.
To prevent our partners from collecting your information for these purposes, you can visit http://preferences-mgr.truste.com to opt out of certain advertising networks.

We use Plaid Technologies, Inc. (“Plaid”) to collect information from financial institutions. By using our service, you acknowledge and agree that such information will be treated in accordance with Plaid’s Privacy Policy

Use of Your Information

We use information that we collect about you for the following purposes:

• to administer the Site, manage accounts and provide the Service;
• to monitor, analyze, improve and develop the Site and Service, and to create and test new Service features;
• to provide a more customized experience on the Site, Service and/or our partners’ or affiliates’ websites;
• to understand our users better;
• to validate user information provided to us for fraud and risk detection purposes;
• to determine eligibility for the Service and our partners’ programs;
• to prevent, identify and address fraudulent or other illegal activity and security issues;
• to (i) solicit feedback, (ii) respond to your or your employers’ or employers’ accountant partners’ comments, requests or inquiries, (iii) provide customer service and support, or (iv) otherwise contact you in connection with the Site or Service;
• to generate anonymized, aggregated data containing only de-identified, non-personal information that we may use to publish reports;
• for our marketing purposes, such as (i) informing you of our or our partners’ or affiliates’ products, services, features or offerings that may be of interest to you, (ii) providing you with newsletters, articles, reports, updates and announcements, as well as information about upcoming events, (iii) contacting potential customers you have referred to us via a referral program (“Referred Leads”), (iv) improving and tailoring our advertising and communications, (v) analyzing our marketing efforts, and (vi) determining your eligibility for certain programs, events and offers;
• to operate our business, which includes, without limitation, using your information (i) to process payment transactions, (ii) to manage and enforce contracts with you or with third parties, (iii) to manage our corporate governance, compliance and auditing practices, and (iv) for recruitment purposes, if you submit an application for employment with ECL;
• to (i) comply with laws, rules and regulations, including any disclosure or reporting obligations, (ii) resolve disputes with users or third parties, (iii) respond to claims and legal process (including but not limited to subpoenas and court orders) as we deem necessary or appropriate, (iv) protect our property rights or those of third parties, (v) protect the safety of the public or any person, and (vi) prevent or stop any activity which we may consider to be (or to pose a risk of being) illegal, unethical or legally actionable; and
• for any other purpose for which you, your employer, or your employer’s accountant partner expressly authorize us to use your information.

Sharing and Disclosure of Your Information

We will only share your information with the third parties listed below for the purposes described above in the
“Use of Your Information” Section, unless otherwise noted at the point of collection:

• government agencies and taxing authorities, as required to provide the Service, including but not limited to the Internal Revenue Service, state and local tax agencies, and state and federal regulatory agencies;
• insurance carriers and other third parties, as needed to carry out the Benefits Service in accordance with HIPAA requirements (which may include but not be limited to facilitating benefits plan enrollments, health care operations, consumer health, wellness, and dependent care claims, and insurance payments);
• banking and financial institutions;
• certain parties as necessary to respond in good faith to legal process (including but not limited to subpoenas and court orders);
• legal and financial advisors and auditors;
• third-party agents, partners and service providers, who (i) are only permitted to use your information as we allow (which may include contacting you on our behalf), and (ii) are required under law or contract to keep your personal information confidential; and
• the following third parties under the circumstances described below:
  • we may share business or personal information with credit bureaus, and we may share information with certain companies, banks and organizations for purposes such as fraud prevention or determining eligibility for the Service;
  • if you participate in a referral program, the referral email and referral link sent to any Referred Leads may include your first name;
  • if there is a sale of ECL (including, without limitation, a merger, stock acquisition, sale of assets or reorganization), or in the event that ECL liquidates or dissolves, we may sell, transfer or otherwise share some or all of our assets, which could include your information, to the acquirer;
  • we may share de-identified personal information with academic institutions to perform research, under controls that are designed to protect your privacy—including requiring such institutions to operate under confidentiality agreements and mandating that published findings contain only de-identified and aggregated data;
  • from time to time, we may share reports with the public that contain anonymized, aggregate, de-identified information and statistics; and
  • we may share your information with certain other third parties with whom you, your employer, or your employer’s accountant partner expressly authorize us to share your information.

We do not share information with third parties for their own direct marketing purposes. If we disclose any
protected health information (as that term is defined in 45 C.F.R. Part 160) to third parties, we will do so in accordance with the Health Insurance Portability and Accountability Act, as amended (“HIPAA”), the Health
Information Technology for Economic and Clinical Health Act, as amended (“HITECH”), and any other applicable state and federal privacy and security laws, as they may be amended from time to time.

Your Choices

Reviewing Your Information

You may review, update, or correct your personal information through your account or by contacting us at support@experts.com.bd

Promotional Communications

You may unsubscribe from marketing and promotional emails that we send to you by following the opt-out instructions contained in such emails or by unsubscribing at http://experts.com.bd/contact. If you opt out of receiving marketing and promotional emails from us, we may still need to send you emails related to your account and the Service.

Do Not Track

Our Site does not currently have the capability of responding to “Do Not Track” signals received from various
browsers.

Security

We employ administrative, physical and technical measures designed to protect your information from unauthorized access and to comply with HIPAA, HITECH and other applicable state and federal privacy and security laws. However, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed to prevent any interception or other type of misuse. We also depend on you to protect your information. If you become aware of any breach of security or privacy, please notify us immediately.

Links to Other Sites

The Site and/or Service may contain links to other sites. Any information you provide on a third-party site is
provided directly to the owner of that site and is subject to that party’s privacy policy. This Privacy Policy does not apply to such sites, and we are not responsible for the content, policies, or privacy and security practices of such sites.

Our Policy Toward Children

The Service is not directed to children under 13 and we do not knowingly collect personal information from
children under 13. However, if a child under the age of 13 is a dependent on a benefits plan covered by the Benefits Service, we may collect information about the child (solely as needed to provide the Benefits Service) from the child’s parent or legal guardian, or from insurance carriers and third-party administrators.

Notice to California Consumers

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), natural persons who are California
residents have certain rights concerning their personal information held by ECL, as described below.

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we disclose what personal information ECL collects, uses, discloses, and sells. You may submit a consumer request to know this information through our online request portal or by calling us at (732) 707-1646. In order to verify your request, we will ask you to provide your name, email address, and certain other pieces of identifying information. Once you have submitted this information and any necessary supporting documentation, we will confirm the information by reviewing it against ECL ’s records.

Below is a table indicating (i) the categories of personal information (as defined in the CCPA) we may collect
about you; (ii) the categories of sources from which that information is collected; (iii) the business and/or commercial purposes for collecting that information; (iv) the categories of third parties to whom that information is
disclosed; and (v) the business and/or commercial purposes for disclosing that information:

Category of Personal Information	Categories of Collection Source(s)	Business and/or Commercial Purpose(s) for Collection	Categories of Third-Party Recipient(s)	Business and/or Commercial Purpose(s) for Disclosing
Identifiers (e.g., name, alias, email address, mailing address, phone number, signature)	You, the consumer (e.g., when you take a survey or visit ECL’s office); third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL; an individual who has referred you to ECL; social media	Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; short-term, transient use, provided that the personal information collected for such use is not disclosed to third parties and is not used to build a profile about you or otherwise alter your experience outside the current interaction; performing services on behalf of ECL; undertaking internal research for technological development and demonstration; undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by ECL, and to improve, upgrade, or enhance the service that is owned or controlled by ECL; advancing ECL’s commercial or economic interests	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL; independent contractors of ECL	Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; short-term, transient use, provided that the personal information collected for such use is not disclosed to third parties and is not used to build a profile about you or otherwise alter your experience outside the current interaction; performing services on behalf of ECL; undertaking internal research for technological development and demonstration; undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by ECL, and to improve, upgrade, or enhance the service that is owned or controlled by ECL; advancing ECL’s commercial or economic interests
Commercial information (e.g., sales engagement history, purchase and consumption history)	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL	Advancing ECL’s commercial or economic interests	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL; independent contractors of ECL	Advancing ’s commercial or economic interests
Biometric information (e.g., photographs of office visitors for identification badges)	You, the consumer (e.g., when you visit ECL’s office)	Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; short-term, transient use, provided that the personal information collected for such use is not disclosed to third parties and is not used to build a profile about you or otherwise alter your experience outside the current interaction; undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by ECL, and to improve, upgrade, or enhance the service that is owned or controlled by ECL	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL	Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; short-term, transient use, provided that the personal information collected for such use is not disclosed to third parties and is not used to build a profile about you or otherwise alter your experience outside the current interaction; undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by ECL, and to improve, upgrade, or enhance the service that is owned or controlled by ECL
Internet or other electronic network activity information (e.g., online identifier Internet Protocol address, unique personal identifier, web history, advertising history)	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL	Advancing ECL’s commercial or economic interests	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL; independent contractors of ECL	Advancing ECL’s commercial or economic interests
Geolocation data (e.g., the location from which you’re logging in)	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL	Advancing ECL’s commercial or economic interests	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL; independent contractors of ECL	Advancing ECL’s commercial or economic interests
Professional or employment-related information (e.g., employment history, employer name)	You, the consumer (e.g., when you take a survey); third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL; social media	Undertaking internal research for technological development and demonstration; undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by ECL, and to improve, upgrade, or enhance the service that is owned or controlled by ECL; advancing ECL’s commercial or economic interests	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL; independent contractors of ECL	Undertaking internal research for technological development and demonstration; undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by ECL, and to improve, upgrade, or enhance the service that is owned or controlled by ECL; advancing ECL’s commercial or economic interests
Education information (e.g., education history)	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL; social media	Advancing ECL’s commercial or economic interests	Third-party vendors or partners (including accountant partners, product partners, business development partners, and bank partners) of ECL; independent contractors of ECL	Advancing ECL’s commercial or economic interests

Right to Request Deletion of Personal Information

You have the right to request the deletion of your personal information collected or maintained by ECL. You may submit a consumer request to delete this information through our online request portal or by calling us at (732) 707-1646. 

In order to verify your request, we will ask you to provide your name, email address, and certain other pieces of
identifying information. Once you have submitted this information and any necessary supporting documentation, we will confirm the information by reviewing it against ECL’s internal records and/or third-party databases.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have the right not to receive discriminatory treatment by ECL for exercising the privacy rights granted by
the CCPA.

ECL does not and will not sell personal information of any consumer (including personal information of minors under 16 years of age).

In order to exercise the rights described above, you may designate an authorized agent to make a request under
the CCPA on your behalf. 
Changes to this Privacy Policy

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, modify and revise our Privacy Policy from time to time. If we make any material changes to this policy, we will notify you of such changes by posting them on our Site, informing you through the Service, or
sending you an email or other notification, and we will indicate when such changes will become effective. By continuing to access or use our Site or Service after those changes become effective, you are agreeing to be bound by the revised policy.

Contact Information

Please contact us at privacy@experts.com.bd if you have any questions about our Privacy Policy and/or our privacy practices.