Last updated: February 28, 2023
This Privacy Policy ("Policy") describes how we at Remote collect, protect, and use the Personal Data you ("User", "you," or "your") may provide on the remote.com website and within any of our products or services (collectively, "Website" or "Services").
Remote is made up of a number of legal entities which we use as infrastructure to provide our Services. However, for data protection purposes the entities in control of all Personal Data processed in connection with our Website and Services are:
collectively referred to as "Remote", "we," "us," or "our".
This Privacy Policy applies to the following Data Subjects: Users of the Website, including Customers, Partners, Contractors and Employees and also all visitors of remote.com with whom Remote does not have a contractual relationship. Depending on Data Subject category and country of residence this Policy may from time to time be supplemented by additional policies issued by us and other parties which will be notified to you separately. For example, Personal Data about Employees and Contractors hired by any of our local legal entities can be co-controlled by these local entities and, where required by law, an additional policy will be notified to you in case the local entities engage in Personal Data processing not covered in this Policy.
We commit ourselves to the highest standard for data protection and privacy. Due to our global footprint, we are subject to several data protection regulations and as a guiding principle, we apply the strictest regulation to protect your data and privacy globally. This results in a broad set of rights and choices made available to you.
The terms "Personal Data", "Data Processing", "Data Subject", "Data Controller and "Data Processor" have the same meaning as under Regulation (EU) 2016/679 - the General Data Protection Regulation ("GDPR").
Remote may collect your Personal Data through our communication and your usage of our products and services. Personal Data can be directly provided by you or indirectly collected by us (i.e. from your interactions, use, and experiences with our products).
| Data you give | Data we collect | When |
|---|---|---|
| You participate in our promoted programs or giveaways | ||
| You subscribe to our blog | ||
| You browse pages of our website | ||
| You opt-in for marketing messages | ||
| You receive an email from us | ||
| You select someone to be hired on your behalf | ||
| You request information from us | ||
| You engage in a meeting with our team | ||
| You participate in our promoted events | ||
| You create an account in our platform | ||
| You allow our partners to share your data |
| Category | Description | Data Type |
|---|---|---|
| Contact | Information that facilitates communication | Email and physical address, telephone number |
| Location | Information about an individual's location | Country, IP address |
| Identifying | Information that can identify a specific individual | Depending on the Data Subject - Name, government-issued ID, profile picture, birthdate |
| Financial/Account | Information that identifies an individual's financial account or about an individual's remuneration | Bank accounts, salary, benefits |
| Professional | Information about educational or professional career | Role |
| Emergency contact | Information about emergency contact | Name, surname and contact details of emergency contact |
| Social | Information about social status | Marital status and number of dependants |
| Communication | Information communicated to or from an individual | Email conversations and the personal data that you might freely share with us in the communications. |
| Special category data | Sensitive Data | Biometric data in the form of face scans for our identity verification process (KYB and KYE) Health data - e.g. disability, pregnancy, absence due to sickness, etc. |
| What we do | Lawful Basis for processing | Data Subjects | Personal Data |
|---|---|---|---|
| Identity verification by means of face screening (processing of biometric sensitive data) | Processing is necessary for reasons of substantial public interest | Employees | Special category data, Identifying |
| Administration, performance and termination of the employment agreement (i.e. paying out salaries and providing benefits) | Performance of a contract | Employees | Communication, Professional, Financial/Account, Identifying, Location, Contact |
| Legally required purposes (i.e. managing time off and sick days, pension and retirement administration, tax reporting, establishing and exercising legal claims in connection with the employment relationship) | Compliance with a legal obligation | Employees, Job applicants | Communication, Social, Emergency Contact, Professional, Financial/Account, Identifying, Location, Contact |
| Administration, performance and termination of the contractual relationship between Remote and the Client | Performance of a contract | Customers, Contractors | Communication, Professional, Financial/Account, Identifying, Contact |
| Conduct integrity screenings | Performance of a contract | Contractors | Professional, Identifying, Location |
| Assistance with the drafting, negotiating, and execution of the contract between the contractor and the Client | Performance of a contract | Customers, Contractors | Communication, Professional, Financial/Account, Identifying, Location, Contact |
| KYB checks | Compliance with a legal obligation | Customers, Customer’s UBO(s) and directors | Professional, Financial/Account, Identifying, Location, Contact |
| Create user accounts | Performance of a contract | Customers, Employees, Contractors | Contact, Identifying, Location, Financial/Account, Professional |
| Hire employees | Performance of a contract | Customers, Employees | Special category data, Communication, Social, Emergency Contact, Professional, Financial/Account, Identifying, Location, Contact |
| Payment and management of contractor invoices on behalf of the Customer | Performance of a contract | Contractors, Customers | Contact, Financial/Account, Professional, Communication |
| Recording of conference video calls | Consent | Customers | Communication, Contact |
| Identify you and help you solve issues related to the usage of our services | Performance of a contract | Customers, Employees, Contractors | Contact, Communication |
| Notify you of any changes to our services | Performance of a contract | Customers, Partners | Contact, Communication |
| Contact you to improve our services and customer experience | Legitimate interest (service improvement) | Customers, Employees, Contractors, Partners | Contact, Communication |
| Direct Marketing | Consent | Data Subjects who gave their explicit consent | Contact, Communication, Location, Professional |
| Share your business information with our partners when you attend a promoted event | Consent | Customers, Employees | Contact, Communication, Location |
| Send you marketing material about our company (newsletters, blogposts, webinars, prizes, etc.) | Legitimate interest (service promotion) | Customers, Partners | Communication, Professional, Contact |
| Reporting marketing campaign activities (i.e. understanding how many leads our marketing campaigns were able to convert) | Legitimate interest (service promotion) | Customers | Communication, Location, Professional |
| Aggregating pseudonymised personal data and reporting anonymised salary data for the purpose of compensation benchmarking in various industries and geographies | Legitimate interest (service improvement) | Employees, Contractors | Financial/Account |
| Reaching out to Customers and candidates for the purpose our recruitment services | Legitimate interest (providing additional services to Customers in the field of recruitment and reaching out to candidates who may be interested in roles that our clients recruit for) | Customers, Employees, Contractors, | Communication, Professional, Contact |
| Disclosing Personal Data to third parties | See 'Personal Data Disclosures' below | See 'Personal Data Disclosures' below | See 'Personal Data Disclosures' below |
Under the GDPR, we need to have a lawful basis to legally process your Personal Data. For the described Data Processing, we rely on the following legal grounds:
Although restricting access to certain data might affect your experience, you can always make changes, such as:
You may exercise any rights related to the Personal Data we collect via the "Help” button in the lower right corner of your dashboard if you are a registered user or via this form if you are not a registered user. We will then verify your identity and respond to your inquiry without undue delay within 15 days of receipt of the request.
That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension, together with the reasons for the delay.
We note that where requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may refuse to act on the request. In such cases Remote shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.
Find below a summary list of your rights and how you can exercise them:
| Right to | Description | Additional information |
|---|---|---|
| Access | You can access the personal data we hold about you directly on your user profile. If you need additional information regarding: - the data categories we process - the purposes of the data processing - retention period - to whom we disclose personal information - any other information about your data, please use the "Help" button in the lower right corner of your dashboard if you are a registered user, or via this form if you are not a registered user. | Please let us know what kind of data you would like to access. |
| Rectification | You can update most of the personal data we hold about you directly on your user's profile. Please keep in mind that some personal data, such as financial data, may be restricted from modification on the platform to avoid processing errors. If you need to modify a restricted field, please use the "Help" button in the lower right corner of your dashboard. | Please let us know: - the fields to update - the old data values to be replaced - the new data values - evidence of the new data values as applicable |
| Data Portability | You have the right to receive, upon request, your Personal Data that you have provided to us for purposes of Data Processing in a portable and machine-readable format. We can export and send a Json file containing all personal data we have collected. | If you would like us to send your information, please reach out to us through this form. |
| Object processing | In the event that the processing of your personal data by us is alleged to be carried out in the public interest or for the purpose of the legitimate interest pursued by us, you have the right to object to it by asserting specific reasons relating to your particular situation. If you object, we will not further process your Personal Data unless we can demonstrate that our continued processing of your Personal Data is premised on compelling legitimate grounds which override your interests, rights and freedoms affected by our continued processing of your Personal Data, or because your Personal Data serves to assert, exercise or defend legal claims. Any such objection does not affect the lawfulness of the processing activities carried out prior to your objection being communicated to us. To exercise your right, please use the "Help" button in the lower right corner of your dashboard if you are a registered user, or via this form if you are not a registered user. If your objection is related to receiving marketing communications or our newsletter, please hit the unsubscribe link on the communication you no longer wish to receive. | If the data has no other purpose except within the process to which you rightfully object, we will delete that data. |
| Restrict processing | You can restrict your data from being processed if: - we processed or will process inaccurate personal data - you believe that we processed your personal data unlawfully - we don't need to process your personal data, but we need to keep it to allow you to establish, exercise, or defend a legal claim - you exercised your right to object processing, but we are still validating your request | Let us know why you want us to restrict your data processing. |
| Erasure (right to be forgotten) | Under the following circumstances you may request that we erase (delete) your Personal Data without undue delay: - in case your Personal Data is no longer needed for the purposes for which it was collected; - if you have withdrawn your consent and there is no other legal basis for the processing of your Personal Data; - if you have filed an objection to our processing of certain of your Personal Data and there are no overriding legitimate reasons for continued processing such personal data; - if your Personal Data is being processed unlawfully; - if your Personal Data must be deleted in order to fulfil a legal obligation. Please note that the Right to Erasure does not apply when the processing of your personal data is necessary for the compliance with a legal obligation Remote is subject to, or for the establishment, exercise or defence of legal claims. | Use this form and state the reason for your deletion request. We will reply to you to confirm we have deleted your account or to let you know why we are unable to fulfill the request. |
| Lodge a complaint | If you believe that we are not processing your data in a lawful way under the GDPR or if you are not satisfied with any response we provide, you may lodge a complaint with a relevant data protection authority. | Please let us know your complaint and we will look into it. You always have the right to complain at your local Data Protection Authority, if you are not satisfied with our handling of your complaint. Under certain conditions, you may be able to invoke binding arbitration for complaints regarding Privacy Shield compliance. Please check here https://www.privacyshield.gov/article?id=G-Arbitration-Procedures |
We comply with the EU's General Data Protection Regulation. Data protection is ensured by encryption and security measures throughout the lifecycle of your data.
In order to provide, maintain, improve, secure and promote our Services, Remote needs to disclose Personal Data to third parties. All Personal Data in scope of this Policy is shared within the Remote corporate group and is hosted on Amazon Web Services. This section provides further details about the specific disclosures we make to other third parties.
Certain Personal Data may be disclosed to our suppliers who help us run our business. Our suppliers may process Personal Data on our behalf solely in accordance with our instructions and pursuant to a written agreement. For example, we use suppliers for web-hosting, secure cloud storage, video conferencing, analytics, email delivery, customer relationship management, web fonts and other services. We also use suppliers such as social media companies and search engines in order to promote our Services.
Certain Personal Data may be disclosed to other suppliers who also help us run our business but act as controllers. These suppliers process Personal Data in accordance with their own privacy policies, however in any case, our contracts with such suppliers require them to comply with applicable data protection law when processing any Personal Data they receive from us. These suppliers include financial institutions, lawyers or notaries, licensed auditors assisting or supervising us in connection with our compliance obligations, HR and payroll providers, identity verification service providers and others.
Personnel files, such as employment and contractor agreements,payslips information about sick leave, ID and RTW verification outcomes and other information you upload on the platform may be disclosed to Customers upon request. Our contracts with Customers require them to comply with applicable data protection law when processing any Personal Data they receive from us.
Various authorities such as regulators, tax authorities, law enforcement agencies, courts of law and others may require us to produce information that may include Personal Data about you. What Personal Data is included depends on each request.
Our platform integrates with other SaaS products such as applicant tracking systems (ATS) and human resource information systems (HRIS) through our application programming interface (API). We partner with such SaaS providers to make it easier for their clients to access our services and for our clients to access their services. More information about the different use cases of our API is available here: https://remote.com/platform/remote-api#overview-partnerships.
When partner systems integrate with our platform, they are able to pull personal data we store upon a customer request. This means that when Customers integrate Remote with other SaaS systems they use Remote will send Employee and Contractor data to the requesting Customer via the partner SaaS system.
If we sell or buy any assets or business, we may disclose Personal Data about you to the prospective seller or buyer of such business or assets. Conversely, if we are acquired by another business, Personal Data about our customers will be transferred to the buyer.
We would be happy to address any specific queries you may have about the Personal Data we disclose to third parties. We have tried our best to outline all relevant disclosures in this section, however, disclosures depend on many factors. If you need more specific information, please contact us using the contact details provided in this Policy.
Remote operates at a global level and therefore Personal Data may need to be transferred to countries outside of where it was originally collected.
When we transfer your Personal Data to a third country, we will ensure that this transfer complies with applicable laws. We share Personal Data with countries located outside the EU and the EEA, on the basis of EU Standard Contractual Clauses. For transfers out of other jurisdictions operating transfer restriction regimes, we take additional steps to ensure compliance with local law.
In accordance with applicable data protection laws, we do not store your Personal Data for longer than needed for the purposes of the respective processing activity. The relevant retention periods depend on the national legislation of the country you are based in.
If the Personal Data is no longer required for the performance or enforcement of contractual or legal obligations, we will delete it regularly, unless its further temporary storage is still necessary to:
For more detailed information about the retention periods of the Personal Data that Remote processes, you can request a copy of our Retention Policy via the 'Help' button in the lower right corner of your dashboard if you are a registered user or via this form if you are not a registered user.
The Website and our mobile app “Remote: Global Employment” use "cookies" and similar technologies, such as pixel tags and software development kits, to help personalize your online and in-app experience. A cookie is a text file that is placed on your hard device by a web page server or a mobile app. For detailed information about cookies and which types of cookies we use, please read our cookie policy.
To learn more about cookies and how to manage them, visit internetcookies.org.
While Privacy Shield is no longer a valid mechanism for data transfers from the EU, it is still a valid commitment toward certain data privacy requirements for companies that participate in it. Remote participates in the Privacy Shield and has committed to comply with its principles. Organizations’ continued participation in the EU-U.S. Privacy Shield demonstrates a serious commitment to protect personal information in accordance with a set of privacy principles that offer meaningful privacy protections and recourse for individuals.
Remote 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/.
Remote commits to cooperate with the panel established by the EU data protection authorities (DPAs), the Swiss Federal Data Protection, or the Information Commissioner. EU, Swiss, and UK individuals can contact EU DPA, the Swiss Federal Data Protection, or the Information Commissioner as applicable. Please find the contact details of the EU DPAs here.
Remote is responsible for the collection and processing of data it may receive under the Privacy Shield Framework, including subsequent transfers to third parties Remote engages that act on our behalf. Remote complies with the Privacy Shield Principles of all transfers of data in the EU.
The Federal Trade Commission has jurisdiction over Remote Technology, Inc.’s compliance with the Privacy Principles. Failing to follow the Privacy Shield principles could result in U.S. FTC enforcement measures for Remote.
We do not knowingly collect any Personal Data from persons under the age of 18. If you are under the age of 18, please do not submit any Personal Data through our Website or Service.
If you have reasons to believe that a person under the age of 18 has provided Personal Information to us through our Website or Service, please contact us via the "Help" button in the lower right corner of your dashboard if you are a registered user or via this form if you are not a registered user.
We reserve the right to modify this Policy relating to the Website or Services at any time, effective upon posting of an updated version of this Policy on the Website. You can find the date of our last update at the top of the document.
Depending on your region we may have to offer some additional information. Please find below any additional provisions applicable to you:
If you are a Consumer (defined as an individual “who is in the State for other than a temporary or transitory purpose” or an individual “who is domiciled in the State who is outside the State for a temporary or transitory purpose.” under the CCPA) or a Workforce Member (Consumers who are our employees, applicants, independent contractors, and other types of workers) , we need to provide you additional information about how we process your personal information and how we protect your rights.
You can find the types of personal information we collect about you in the section "Types of Personal Data" we collect of our privacy policy, but since California regulations have specific terms, please find below the correct applicable terms:
Under the California regulations, the following personal information is considered sensitive and requires additional disclosure:
To learn more about categories of sources from where and how we obtain personal information, please read the section "When and how we collect data" from this policy, but in short names and email addresses are provided to us by our clients and then we ask Consumers and Workforce Members to upload all other information necessary for onboarding.
To learn more about how we use the personal information we collect, please read the section "How we use your Personal Data" from this policy.
In this context, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.
Under Californian laws, this concept of sale would only apply to Remote for instance, when Remote hosts a webinar with a partner and share the attendee's list with them.
Remote will only share your data with your consent. You can withdraw your consent whenever you wish.
Opt-out to the sale of personal information (DO NOT SELL MY PERSONAL INFORMATION)
Where the disclosure of personal information is made in exchange for monetary or other valuable consideration, California residents have the right to opt-out of such disclosure under certain limitations. To exercise your right to request access or delete your personal information under California law, please follow the instruction in "Data subjects rights".
Click on the "Do not sell my personal information" button to exercise your right. We will save your opt-out for a minimal period of 12 months.
If you are not satisfied with the information in our privacy policy, you have the right to request that we disclose to you:
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
The information will be delivered electronically in an easily usable format to enable you to easily transmit the information to another entity – provided that this is technically feasible.
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used for compliance and other legal reasons, to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights, etc.).
If no exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.
Providing your personal information for surveys, marketing, or other purposes, is optional. Your refusal to provide your information for these purposes will not have any impact on the entering into or performance of the contract. When requested under Data Protection Laws, we will collect your prior consent before proceeding to process your personal information for these purposes.
To exercise any of the above or other rights under California law, or to contact us with questions and concerns about this privacy notice and our practices, contact us via the "Help" button in the lower right corner of your dashboard if you are a registered user or via this form if you are not a registered user.
If you are an authorized agent seeking to exercise rights on behalf of a California consumer, contact us at the email above and attach a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity before completing your rights request.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
If you cannot submit a verifiable request, you can request a person registered with the California Secretary of State to act on your behalf.
You can submit a maximum number of 2 requests over a period of 12 months.
We will respond to your request free of charge within 45 days of its receipt. In some cases, we may need to take up to 90 days to fulfill your request, if your request needs additional time to be fulfilled will explain to you the reasons why and when do we expect to fulfill your request.
If your request is manifestly unfounded or excessive we may charge you a reasonable fee, or refuse to act on the request. Remote may also need to deny your request if we have a legitimate reason to do so. In such cases, we will communicate our choices and explain the reasons behind them.
We will need to share your personal information for “business purposes” with service providers. We share this information to provide our services and products, like web hosting and security, payment purposes, customer support services, delivering marketing messages, or advertisements.
We may share your personal information with competent authorities for complying with the law, and also some personal information such as business contacts can be shared with third parties for "commercial purposes". This sharing may include information related to Identifiers like name and email. To know more about the recipients of your data, please reach out to us via the "Help" button in the lower right corner of your dashboard if you are a registered user or via this form if you are not a registered user.
If you want to know more details regarding the receipt and sharing of personal information with third parties you can read the sections "How we use your Personal Data" and "Personal Data Disclosure" of our privacy policy.
We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.
Our services are not directed at children under the age of 16. Therefore, we don't knowingly share the personal information of minors under the age of 16 years without appropriate consent, as required under the California Consumer Privacy Act (CCPA).
The provisions contained in this section apply to all Users who are located in Brazil, according to the "Lei Geral de Proteção de Dados" (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the Privacy Policy.
This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD). Our Data Protection Officer is Emanuel Velho and you can contact him via the "Help" button in the lower right corner of your dashboard if you are a registered user or via this form if you are not a registered user.
Please check the sections “What is "legal basis"?” and "How we use your data" for more information on the legal basis we use for processing your Personal Data.
If you have any additional questions regarding our legal basis for processing please contact us via the "Help" button in the lower right corner of your dashboard if you are a registered user or via this form if you are not a registered user.
Please read the section "Types of data we collect", to check the types of data we collect from you.
If you have any additional questions regarding the types of data we collect, please contact us via the "Help" button in the lower right corner of your dashboard if you are a registered user or via this form if you are not a registered user.
To find out why and when we process your personal information, you can read sections "When and how we collect data" and "How we use your data". If you have any questions about why do we process your data, please contact us via the "Help" button in the lower right corner of your dashboard if you are a registered user or via this form if you are not a registered user.
We assure you that you will never be discriminated against by exercising your rights. Please refer to section "Data Subjects rights" to understand how you can exercise your rights. We note, however, that where requests are manifestly unfounded or excessive, in particular because of their repetitive character, Remote shall (i) bear the burden of demonstrating the manifestly unfounded or excessive character of the request; and (ii) refuse to act on the request, indicating the factual or legal reasons that prevent the immediate adoption of the measure.
The rights of the data subjects under the LGPD differ a little from the rights under the GDPR. Thus, please see below the rights you have over your personal data under the LGPD:
You can also lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies.
In the event you wish to exercise your right to access your personal data or to confirm the existence of the processing, please let us know that you are performing this request under the LGPD and whether if you wish a simplified or complete disclosure. If you opt for the complete disclosure, please note that it might take up to 15 days to fulfill your request.
Please be aware that are allowed to transfer your personal information outside of the Brazilian territory when the transfer:
We have a Data Protection Officer (DPO) who monitors our compliance with the General Data Protection Regulation (GDPR), other data protection regimes and policies of Remote in relation to the protection of Personal Data and privacy.
For inquiries or requests about this Policy, please reach out to us via the 'Help' button in the lower right corner of your dashboard if you are a registered user or via this form if you are not a registered user.