BASE® Privacy Statement

Effective as of November 14, 2023

BASE® and its affiliates' (collectively referred to as "BASE®", "we", "us") take its data protection responsibilities seriously. This Privacy Statement explains who we are, how we collect, use and share personal information about you, and how you can exercise your privacy rights. It applies to all individuals who access our website(s), engage in our products and/or services ("Services"), or who participate in our recruitment activities. We recommend that you read this Privacy Statement in full to ensure you are fully informed.

The BASE® entity responsible for your personal information will be the member of BASE® that originally collects your information. This will be explained at the point at which your personal information is first collected by the BASE® entity, for example where you or the business you work for engages us to provide a service or where we engage you to provide a service to us.

You might find external links to third party websites on our website. This Privacy Notice does not apply to your use of a third party site.

What We Do

BASE® provides employee benefit plan administration and compliance solutions. You can find out more about BASE® at About BASE® | BASE® (baseonline.com) or by Contacting BASE® directly.

Collection and Uses of Your Personal Information

"Personal information" is any information that can be used to identify an individual, and may include name, address, email address, phone number, login information, or payment information.

We collect and use information about you if you:

  • Use one of our website(s) or online services
  • Purchase or received one of our services
  • You are identified as a potential customer
  • Work with us as a business partner
  • Apply for employment with BASE®

Use of our website(s) or online services

The personal information that we may collect about you when you visit our websites broadly falls into the following categories:

  • Information you provide voluntarily: We collect personal information that you provide voluntarily through our websites, for example when completing online forms to contact us. The information we collect about you may include some or all of the following:
    • Name and job title
    • Company or Organization
    • Contact information, including email address and telephone number(s)
    • Information pertinent to fulfilling our Services to you; and
    • Any other personal information that you voluntarily choose to provide to us.

If we ask you to provide any other personal information not described above, the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point that you are asked to provide it.

  • Information that we collect automatically: When you visit our websites, we may collect certain personal information automatically from your device. Specifically, this information may include information such as: your IP address, device type, unique device identification number, browser-type, broad geographic location (e.g., country or city-level location) and other technical information. We may also collect information about how your device has interacted with our websites, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our websites, where they come from, and what content on our websites is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our websites to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained in our Cookie Notice.

We will use this information in the following ways and where we are satisfied that we have an appropriate legal basis to do so. Our uses broadly fall into the following categories:

  • Providing our websites: We process your personal information to perform our contract with you for the use of our websites and to fulfill our obligations under applicable terms of use/service. Where we have not entered into a contract with you, we base the processing of your personal information on our legitimate interest to operate and administer our websites and to provide you with the content you access and request (e.g., to download content from our websites);
  • Providing necessary functionality: We process your personal information to perform our contract with you for the use of our websites. Where we have not entered into a contract with you, we base the processing of your personal information on our legitimate interest to provide the necessary functionality required during your use of our websites;
  • Developing and improving our websites: We process your personal information to analyze trends and to track your usage of and interactions with our websites to the extent it is necessary for our legitimate interest in developing and improving our websites and providing our users with more relevant content, or where we seek your valid consent;
  • Promoting the security of our websites: We process your personal information by tracking the use of our websites, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the websites, systems and applications and in protecting our rights and the rights of others;
  • Assessing and improving user experience: We process device and usage data, which in some cases may be associated with your personal information, in order to analyze trends that assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the website, or where we seek your valid consent;

Purchase or receive one of our services or a business partner

When you engage our Services, we collect and use personal information which is necessary for the performance of those Services. The majority of the personal information we collect and use to provide our Services is supplied voluntarily by our customers and business partners. Because of this, if you are a customer or business partner of BASE® then it will be generally obvious to you what personal information we collect and use. This information broadly falls into the following categories:

  • Basic information such as your name, the company you work for, your position and your relationship to a person;
  • Contact information such as postal address, email address and telephone number(s);
  • Financial information (such as bank account information, tax registration information, billing details) in order to manage and process any payments you make to us;
  • Information held by credit references agencies and fraud prevention agencies, in order to assess any application for your use of our services;
  • Identification and background information provided by you or collected as part of our business validation process; and
  • Information and feedback you provide to us about our products and services in order to continuously improve the products and services.

We will use this information in the following ways and where we are satisfied that we have an appropriate legal basis to do so. These uses broadly fall into the following categories:

  • Providing our services: We process your personal information to perform our contract with you for the use of our Services and to fulfill our obligations under applicable terms of use/service. Where we have not entered into a contract with you, we base the processing of your personal information on our legitimate interest to operate and administer our Services;
  • Providing necessary functionality: We process your personal information to perform our contract with you for the use of our services. Where we have not entered into a contract with you, we base the processing of your personal information on our legitimate interest to provide the necessary functionality required during your use of our services;
  • Developing and improving our services: We process your personal information to analyze trends and to track your usage of and interactions with our Services to the extent it is necessary for our legitimate interest in developing and improving our Services and providing our users with more relevant service offerings, or where we seek your valid consent;
  • Assessing and improving user experience: We process device and usage data, which in some cases may be associated with your personal information, in order to analyze trends in order to assess and improve the overall user experience to the extent it is necessary for our legitimate interest in assessing and improving our Services offering, or where we seek your valid consent;
  • Promoting the security of services: We process your personal information by tracking the use of our Services, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the Services, systems and applications and in protecting our rights and the rights of others;
  • Managing user registrations: If you have registered for an account with us, we process your personal information by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
  • Handling contact and user support requests: If you fill out a "Contact Me" web form or request customer support, or if you contact us by other means including via a phone call, we process your personal information to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
  • Managing event registrations and attendance: We might process your personal information to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, to perform our contract with you;
  • Managing contests or promotions: If you register for a contest or promotion, we process your personal information to perform our contract with you. Some contests or promotions have additional rules containing information about how we will process your personal information;
  • Managing Payments: If you have provided financial information to us, we process your personal information to verify that information and to collect payments to the extent that doing so is necessary to complete the transaction and perform our contract with you;
  • Reviewing compliance with applicable usage terms: We process your personal information to review compliance with the applicable usage terms in our customer's contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms;
  • Displaying personalized advertisements and content: We might process your personal information to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our websites or, where necessary, to the extent you have provided your prior consent;
  • Complying with legal obligations: We process your personal information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.

Potential customer

We collect information directly, from other members of the BASE® group, and from other third-party lead providers about organizations who might like to hear from us or receive our products and services. We will only do so in accordance with your preferences and as described in this Privacy Statement.

The information we may collect falls broadly into the following categories:

  • Basic identification and contact information (such as your name, telephone number, gender, national ID number, and email address) in order to fulfill any order, provide our Services and manage your account;
  • Demographic information such as your age and information about your occupation;

We will use this information in the following ways and where we are satisfied that we have an appropriate legal basis to do so. Our uses broadly fall into the following categories:

  • Identifying customer opportunities: We process your personal information to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their users' experiences;
  • Registering office visitors: We process your personal information for security reasons, to register visitors to our offices and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices and our confidential information against unauthorized access;
  • Sending marketing communications: We will process your personal information to send you marketing information, product recommendations, and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions, or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent;

Apply for employment with BASE®

BASE® collects information from and about candidates in connection with available employment opportunities at BASE®. This information may include resumes, identification documents, academic records, work history, employment and references. BASE® uses your personal information to match your skills, experience and education with specific roles.

Your Choices and Rights

BASE® respects your rights in knowing what personal information we have about you and how that information is collected, used and shared. You may request we disclose what personal information we have and to access, make corrections to, or delete your personal Information and make choices about the kinds of marketing materials you receive (or choose not to receive marketing from BASE® at all).

We may ask you for additional information to verify the request, confirm your identity and for security purposes, before disclosing the personal information request to you. We reserve the right to charge a fee where permitted by law.

You can exercise your rights by using one of the methods in the Contact Us section. We will send a confirmation once we receive your request that might include any verification instructions and provide further information on how your request will be addressed. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. The method we use to verify your request will depend on the type and sensitivity of the personal information. We may need more information to verify the request if there is a risk of harm to you by unauthorized access or deletion of the information. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Access, Correction or Deletion of Your Information

If you would like to correct or update your personal information, or to request access to or deletion of your personal information, you may contact us by using one of the methods listed in the Contact Us section below including your name, email address, account identification, and purpose of the request. If you request a change to or deletion of your personal information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion). Some of your information may also remain within our systems and other records where necessary for compliance with applicable law.

At your request and where the law requires us to do so, we will confirm what personal information we hold about you. You may also have a legal right to obtain a copy of your personal information. You can make such a request by making a written request in one of the ways described in the Contact Us section below. We may charge a processing fee for this service where permitted by law and we will require verification of the request and evidence of your identity before fulfilling your request.

Advertising and Marketing Choices

We give you many choices regarding our use and disclosure of your personal information for advertising and marketing purposes. You may access or update your contact details and modify your communication preferences by using one of the following methods in the Contact Us section below. You can ask us to stop sending email marketing, by following the 'unsubscribe' link found on all email marketing message we send you. Please also note that if you choose not to receive marketing from us, we may still send you communications related to your BASE® Services, such as information about a security update, billing issue or product delivery. Some advertising content is delivered through the BASE® Services' (including our website) use of cookies and related tracking technologies. Our Cookie Notice includes more information on BASE's use of such technologies and how you can modify or reject their use.

Finally, you have a right not to receive discriminatory treatment for the exercise of your privacy rights.

For California Consumers, you have a right to designate an authorized agent to make a request on your behalf.

Sharing Your Personal Information

We may disclose your personal information with third parties for the purposes of operating our business, delivering, improving, and customizing our Services, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent.

We may share your personal information in the following ways with the following categories of third-parties:

  • Within BASE® and any of our global affiliates for the purpose of data processing or storage,
  • With service providers, authorized third-party agents, or contractors to provide a requested service or transaction.
  • With BASE® business partners or vendors so that they may share information with you about their products or services. To opt-out of BASE® sharing with third parties for their marketing purpose, you may contact us by using one of the methods listed in the Contact Us.
  • In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.
  • In response to a request for information by a competent authority if we believe disclosure is in accordance with or is otherwise required by any applicable law, regulation, or legal process.
  • With law enforcement officials, government authorities, or other third parties as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of BASE®, its business partners, you, or others; or as otherwise required by applicable law.
  • In aggregated, anonymized, and/or de-identified form, which cannot reasonably be used to identify you.
  • If we otherwise notify you and you consent to the sharing.

Sale of Personal Information

BASE® does not sell Personal Information to third parties for a business or commercial purpose.

Security

We intend to protect the personal information entrusted to us and treat it securely in accordance with this Privacy Statement. BASE® implements reasonable physical, administrative, and technical safeguards designed to protect your information from unauthorized access, use, or disclosure. For example, we encrypt certain sensitive personal information such as credit card information when we transmit such information over the Internet. We also contractually require that our suppliers protect such information from unauthorized access, use, and disclosure. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal information you provide to us.

Retention of Personal Information

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Privacy Statement. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements. In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Use of Cookies and other Web technologies

As mentioned above, we collect information from your visits to our websites and your use of BASE® services and our software products, to help us gather statistics about usage and effectiveness, personalize your experience, tailor our interactions with you, and improve our products and services. Do this through the use of cookies, pixel tags, and similar technologies. Please refer to our Cookie Notice for more information on our use of cookies and similar technologies, how you can manage cookies and how we respond to Do Not Track signals.

Forums and Chat Rooms

If you participate in a discussion forum, local communities, or chat room on a BASE® website, you should be aware that the information you provide there (i.e. your public profile) will be made broadly available to others, and could be used to contact you, send you unsolicited messages, or for purposes neither BASE® nor you have control over. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. BASE® is not responsible for the personal information or any other information you choose to submit in these forums. To request removal of your personal information from our blog or community forum, contact us at privacy@baseonline.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

How to Contact Us

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us using the contact details below. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by data protection laws.

Updates to this Privacy Statement

This statement may be amended from time to time to keep it up to date with legal requirements and how business is operated. Please regularly check for the latest version of this notice. If significant changes to this Privacy Statement are made, you will be informed by notice via website or by email.