Goodbay is in the business of providing solutions that enable our Customers to meet their business goals. We offer business process and customer support outsourcing solutions, along with consulting services. We commit to putting Customers first is to ensure that Customer Personal Information that our Customers entrust to us, including sensitive personal information, is safeguarded, and that the privacy of our Customers’ End Users is respected.
Goodbay’s privacy practices are developed in accordance with applicable legislation relating to privacy and information security, which may include, but is not limited to the EU General Data Protection Regulation (Regulation (EU) 2016/679), as nationally implemented, supplemented, amended and replaced from time to time (“GDPR”), the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Children’s Online Privacy Protection Act of 1998 (“COPPA“) the Video Privacy Protection Act of 1988, the Health Insurance Portability and Accountability Act of 1996 (“HIPAA“), the Fair Credit Reporting Act (“FCRA“), the Cable Television Protection and Competition Act of 1992, and a variety of provincial and state privacy laws, all together the “Applicable Privacy Laws”.
Goodbay is committed to ensuring that our privacy practices comply with the Applicable Privacy Laws as well as with our contractual commitments. Our commitment to our Customers is that we will work with them to protect privacy in all our service offerings.
Scope, Application and Definition
Scope and Application:
Customer is defined as customer or potential customer of Goodbay who is a business, enterprise, or other organization.
Customer Personal Information has the definition given to it in the “What Personal Information Do We Collect?” section below.
Personal Information is defined as any information relating to an identified or identifiable natural person.
End User is defined as Customers’ products or services, or clients, or customers of Customers.
Personal Information We Collect
For us to provide services to Customers, we collect and process the following Personal Information (“Customer Personal Information”):
- End User Information
This is Personal Information that relates to End Users and that is entrusted to Goodbay by Customers for Goodbay to provide services to Customers which may be used by or otherwise affect the End Users.
Such Personal Information consists of amongst others:
Names; telephone numbers; email addresses; mailing addresses; information for account management (such as usernames and passwords); IP addresses; behavioral information (such as preferences, habits, interactions, feedback, needs and problems); financial information (such as credit card numbers, bank account names and details and account histories); and special categories of data (such as personal health data).
- Customer Contact Information
This is Personal Information that we gather from Customer representatives at various stages of our relationship with Customers, such as when Customers contact us to learn information about our services, and when we continue to work with Customers to provide custom-made solutions to their requirements.
Such Personal Information consists of, among others:
Names; telephone numbers; email addresses; mailing addresses; information for account managment (such as usernames and passwords); IP addresses; and financial information (such as credit card information, payment information; including bank account names and details).
How We Use Customer Personal Information
We use Customer Personal Information for the following purposes:
- To communicate with Customers throughout their relationship with Goodbay;
- To understand End User and Customer needs and preferences;
- To provide services that are tailored to Customers’ and End Users’ requirements;
- To ensure that our services continue to be responsive to Customers’ and End Users’ requirements, including by providing technical support and training, and improve processes;
- To promote or sell products or services to Customers and End Users, in accordance with any applicable marketing or telemarketing legislation;
- To bill Customers and process Customer payments;
- To investigate and resolve incidents and Customer or End User complaints;
- To further our business goals, such as to perform audits, data analysis, fraud monitoring, and prevention, to improve or modify our services, to identify trends, to determine the effectiveness of our promotional campaigns and to operate and expand our business activities;
- To meet any regulatory or legal requirements.
We May Disclose Customer Personal Information
- Third Party Service Providers
We may disclose Customer Personal Information to certain service providers that we use to provide us with services, such as information technology services, payment processing services, SAAS-based applications, consulting, auditing and related services.
Where we enter into a relationship with any service provider or subcontractor, we will have contracts in place with such service provider or subcontractor, in order to ensure that Customer Personal Information is protected in accordance with Applicable Privacy Laws.
- Group Companies
We may disclose some Customer Personal Information between our group companies; including companies in other countries, inside or outside the United States, in order to ensure that we are dedicating the appropriate group resources to Customer requirements, as well as for certain of our business purposes, such as for accounting, regulatory compliance and internal record keeping.
- Monitoring of security compliance – We monitor the security implementation of partners and group companies to ensure that they maintain the same level of security compliance. This is supported by internal and external reporting.
There may be certain legal reasons for disclosing Customer Personal Information:
- To protect our operations and rights;
- To enforce our terms and conditions and contracts with Customers;
- To protect the safety and rights of our Customers and End Users;
- To comply with enforcement actions by regulators, court orders or any other legal proceedings;
- To seek any remedies available to us or limit damages that we may suffer;
- To respond to requests from governmental and public authorities, including public and governmental authorities outside of Customers’ countries of establishment;
- To comply with any other relevant applicable laws from time to time, including applicable laws outside of Customers’ countries of establishment, inside or outside of the United States.
- Executive Responsibility
Protecting privacy is an integral part of our services and all members of Goodbay’s executive team have a responsibility to oversee and enable compliance with Goodbay’s privacy policies and procedures within their own areas of responsibility.
- Employee Accountability
- Commitment to Accountability
Goodbay is responsible to our Customers for Customer Personal Information in Goodbay’s custody. Goodbay acts as a Data Processor (as such term is defined in the GDPR) for its Customers, which means that it processes Customer Personal Information on behalf of its Customers in order to provide services to those Customers.
- Goodbay’s Privacy Contact
Goodbay has appointed Data Protection contacts to manage data privacy compliance in its United States and India based operations. They may be contacted at: firstname.lastname@example.org
Cookies and Consent
Limitation of Processing of Customer Information
Goodbay receives Customer Personal Information from its Customers and End Users and collects Customer Personal Information from other individuals or entities on behalf of its customers.
Accuracy; Retention; Safeguards
Goodbay does not verify the accuracy of Customer Personal Information when it is received from a Customer.
Goodbay relies on its Customers to ensure the accuracy of the Customer and End User Personal Information that has been supplied to Goodbay in order for Goodbay to provide services for its Customers.
Goodbay will take appropriate steps to maintain the integrity of the Customer Personal Information and will ensure that appropriate safeguards are in place to protect any Customer Personal Information in its custody.
Goodbay has a policy respecting records retention and an associated retention schedule and will keep Customer Personal Information only as long as it remains necessary or relevant for the purposes of providing services to Customers and in accordance with the terms and conditions of the contractual agreement with the Customer.
Goodbay maintains an information security governance program to protect Customer Personal Information.
Goodbay, in compliance with its security policy, employs security measures appropriate to the sensitivity of the information in an effort to protect Customer Personal Information against such risks as loss or unauthorized access, disclosure, theft, copying, use, destruction or modification.
Goodbay’s security measures include but are not limited to the following:
- Using appropriate administrative, physical and technical security controls designed to prevent and detect unauthorized access to Customer Personal Information;
- Limiting access to Customer Personal Information to a need-to-know basis and applying the principles permission level access control;
- Requiring secure disposal of any media containing Customer Personal Information;
- Identifying and assessing reasonably foreseeable risks to the integrity, confidentiality or availability of Customer Personal Information that we hold and taking reasonable steps to mitigate those risks through the implementation of safeguards;
- Testing of our overall security program.
Openness; Incident Management: Individual Access
Openness Concerning Policies and Practices
Goodbay has developed a comprehensive incident readiness and response plan designed to identify the cause, extent, and nature of an incident involving Customer Personal Information and to allow timely reporting to the Customer in accordance with Applicable Privacy Laws and our contractual terms.
Goodbay will provide reasonable assistance to our Customers to investigate and assist in the reporting of the incident to regulatory authorities or other required parties to prevent or minimize any loss or harm arising from such incident.
Unless we specifically contract to do so as part of the provision of services to a Customer, Goodbay will not generally respond directly to access requests or inquiries of End Users. We will instead make reasonable efforts to direct inquiries and access requests made by End Users to the appropriate Customer.
Customers should advise End Users to consult Customers’ own privacy policies to familiarize themselves with their rights under Applicable Privacy Laws.
For the purposes of the GDPR, Goodbay shall be the data processor in respect of Customer Personal Information and the relevant Customer shall be the data controller.
Goodbay maintains procedures for responding to all questions or complaints about Goodbay’s handling of Personal Information. These can be forwarded on a confidential basis to our Privacy Office at email@example.com.