This Privacy Notice applies to the mobile application branded as “VialtoGuide” powered by Relocity (the “Tool”) and should be read together with the Vialto Privacy Statement and the Relocity Privacy Policy. In the event of any conflict between this Privacy Notice and the Vialto Privacy Statement or Relocity Privacy Statement, the terms of this Privacy Notice shall prevail.
This Privacy Notice will help you understand what Personal Data is collected through your use of the Tool, why this Personal Data is being collected and what is being done with this Personal Data when you use the Tool. For purposes of this Privacy Notice, “Personal Data” means information that identifies or could reasonably be used to identify an individual, including “personal data,” “personal information,” “personally identifiable information,” or an equivalent term, in each case as defined by applicable privacy laws.
This Privacy Policy does not apply to any third party applications or technologies that integrate with the Tool, or any other third party products, services, or businesses (“Third Party Services”). While using the Tool, you may be directed to a third party website via links or other references, which may take you to that third party website (“Third Party Websites”). This Privacy Policy does not apply to any data collected from you or provided by you to Third Party Services or Third Party Websites. You should review such Third Party Services’ or Third Party Websites’ privacy policies (and such other terms and conditions) to determine how your Personal Data will be used before sharing your Personal Data in connection with Third Party Services or through Third Party Websites.
“Vialto” refers to one or more of the entities or partnerships within the Vialto Partners network consisting of (i) affiliated entities; and (ii) other entities operating as part of the Vialto Partners network, each of which is a separate legal entity. “Relocity” refers to Relocity, Inc., which is the entity that develops, owns and operates the Tool.
The Tool is being made available to you pursuant to a separate agreement between Vialto and your employer (your “Employer”) that governs delivery, access, and use of the Tool (the “Client Agreement”). Your use of the Tool may also be subject to your Employer’s policies, as applicable. If you have any questions about your Employer’s policies or practices, please contact your Employer directly. Neither Vialto nor Relocity is responsible for the privacy or security practices of your Employer, which may differ from those set forth in this Privacy Policy.
Privacy and data protection laws in certain jurisdictions differentiate between the “controller” (or a similar term for the entity that determines the purposes and means of the Processing of Personal Data) and the “processor” (or a similar term for the entity that follows documented instructions of the controller) of Personal Data. In general, with respect to the Initiation Data (as defined below), your Employer acts as the controller for any Initiation Data that your Employer makes available to Vialto, and Vialto acts as a processor with respect to such Initiation Data. Where Vialto acts as a processor of such Initiation Data, Relocity is acting as a sub-processor of that Initiation Data.
With respect to the Operational Data and Community Data (each as defined below), Relocity is acting as the controller. In the event Vialto Processes any Operational Data, Vialto would be acting as an independent controller for such Processing of the Operational Data.
The Tool provides you with streamlined lump-sum management, cost savings opportunities and comprehensive resources in connection with your relocation. Your Personal Data processed in the Tool is used in order to provide
you with access to and use of the Tool, and for the other purposes, and pursuant to the legal bases, described in the Vialto Privacy Statement and the Relocity Privacy Policy, as applicable.
Neither Vialto nor Relocity sells or shares for cross-contextual behavioral advertising any Personal Data collected in connection with the Tool.
The categories of Personal Data processed by the Tool include the following (collectively, the “Initiation Data”):
This data is collected either (i) directly from you via the Tool, or (ii) directly from your employer.
Within the Tool, you may opt-in to the “Community” feature, which is an in-app forum that allows you to communicate and share experiences or information with other employees within your company who also have access to the Tool (the “Other Employees”). If you decide to opt-in to the Community, then your name will be visible in the directory to the Other Employees. If you opt-out, then your name will not be included in the directory and you will not have access to the Community feature (unless you subsequently opt-in). Any Personal Data you choose to disclose through your use of the Community feature (the “Community Data”) will be governed by, and subject to, the terms of the Relocity Privacy Policy.
Relocity may also process other categories of Personal Data generated through the operation, hosting, maintenance, monitoring, security, and administration of the Tool, including usage data, metadata, log data, diagnostic data, technical data, cookie or device data, and other similar information required for security, performance, service integrity, fraud prevention, or internal analytics (collectively, the “Operational Data”). For more information, please refer to the Relocity Privacy Policy.
To the extent that Personal Data has been deidentified, aggregated or otherwise rendered anonymous in such a way that you or your device are no longer reasonably identifiable, such information will be treated as non-Personal Data and the terms of this Privacy Notice will not apply.
The scope of what qualifies as special or sensitive category Personal Data will be determined by applicable data protection law, but may include, without limitation, information that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation, criminal records and/or financial account information. The Tool does not intentionally collect any special or sensitive category Personal Data from you, and the Tool’s intention is not to process such information. Neither Vialto nor Relocity will be responsible or liable for any losses or damages you or another individual may experience due to your disclosure of sensitive or special category Personal Data in connection with your use of the Tool where such data is not expressly solicited by Vialto or Relocity.
Your Personal Data collected through the Tool may be accessed by the following persons/teams:
The access rights detailed above may involve transferring Personal Data from and to various jurisdictions in which Vialto (Vialto office locations are listed at https://vialtopartners.com/) and / or Relocity operates. Each of Vialto and Relocity will process your Personal Data in the Tool in accordance with applicable law, regulations and professional standards applicable to such party.
Vialto and / or Relocity may also transfer or disclose your Personal Data to third-party service providers (and their subsidiaries and affiliates) who are engaged to support internal ancillary processes, including IT infrastructure. Additional information on the categories of recipients that Vialto or Relocity, as applicable, may disclose Personal Data to are indicated in the Vialto Privacy Statement and the Relocity Privacy Policy, as applicable.
This Privacy Policy does not apply to any Personal Data collected from you or provided by you to Third Party Services or Third Party Websites, and you should review such Third Party Services’ or Third Party Websites’ privacy policies (and such other terms and conditions) to determine how your Personal Data will be accessed or shared. For avoidance of doubt, if you elect to use Third Party Services or Third Party Websites from Vialto, this Privacy Policy does not apply to such Third Party Services or Third Party Websites, and you should review the privacy policies (and such other terms and conditions) made available to you in connection with such Third Party Services or Third Party Websites.
Any Initiation Data provided to Vialto by your Employer directly will be governed by Vialto’s data retention policies and procedures. Such information will be retained for as long as necessary for the purposes described in this Privacy Policy and the Vialto Privacy Statement, and in accordance with any contractual obligations under the Client Agreement. Your Personal Data may be held for longer periods where required by law, regulation or other professional obligations or in order to establish, exercise or defend legal rights.
Any Personal Data uploaded by you into the Tool, or otherwise collected directly by the Tool, will be processed and retained in accordance with Relocity’s data retention policies and procedures and the Relocity Privacy Policy. Relocity retains Personal Data for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide the Tool and related services, and to comply with law, regulation, and other professional obligations.
Each of Vialto and Relocity has appropriate measures in place designed to protect the confidentiality and security of information it obtains in the course of its business. Access to such information is limited, and policies and procedures are in place that are designed to safeguard the information from loss, misuse and improper disclosure.
For more information about Relocity’s security measures applicable to the Tool, please visit: https://trust.relocity.com/.
You provide Personal Data at your own risk. Unfortunately, no data transmission over the internet is guaranteed to be 100% secure, and we cannot guarantee that unauthorized access, hacking, data losses, or other breaches will never occur. If you believe your privacy has been breached, please contact us immediately at privacy@vialto.com.
You are responsible for safeguarding your user account and password.
You may have certain data subject rights under applicable privacy law in relation to the Personal Data we process about you, including (without limitation) the right to access, modify or remove your Personal Data. Please refer to the Vialto Privacy Statement and the Relocity Privacy Policy for more information on what data subject rights may be applicable to you under applicable privacy law.
If you seek to exercise any of your data subject rights with respect to the Initiation Data, you should direct your inquiry to your Employer as the controller of such information.
If you seek to exercise any of your data subject rights with respect to the Operational Data or Community Data, you should direct your inquiry to Relocity (at privacy@relocity.com) as the controller of such information. More information about how data subject rights can be exercised with respect to such data can be found in the Relocity Privacy Policy.
If you are concerned about an alleged breach of privacy law or any other regulation in connection with your use of the Tool, please contact us at privacy@vialto.com or via your Vialto representative. Vialto will investigate your matter and provide information about how it will be handled and resolved. If you are not satisfied with how Vialto resolved your matter, you have the right to complain to your country’s data protection authority. You can also refer the matter to a court of competent jurisdiction.
Certain Vialto and Relocity entities in countries outside the European Economic Area (EEA) have appointed a representative in the EU to act on their behalf if, and when, they undertake data processing activities to which the EU General Data Protection Regulation applies. For further information and the contact details of Vialto’s representatives, please contact privacy@vialto.com. For further information and the contact details of Relocity’s representatives, please contact privacy@relocity.com.
Vialto reserves the right to modify, update or other amend this Privacy Notice at any time and for any reason, in which case you will be notified through the Tool.
If you have additional questions or concerns, contact your usual Vialto representative or privacy@vialto.com.