Dwellworks General Privacy Policy 
 

Effective Date: May 25, 2018 

Updated: November 01, 2023 

This General Privacy Policy (this "Policy") governs the way Dwellworks, LLC and its US based subsidiaries manage and process Personal Data collected in the delivery of relocation services in the European Economic Area (“EEA”) (which includes the member states of the European Union (“EU”) plus the United Kingdom, Iceland, Liechtenstein, and Norway) or Switzerland that is subsequently transferred to the United States, as well as Personal Data that is collected in the process of delivering relocation services elsewhere in the world, including within the United States. Dwellworks, LLC is a Delaware limited liability company with its headquarters located at 1317 Euclid Avenue, Cleveland, Ohio 44115. The other Dwellworks companies are wholly owned subsidiaries of Dwellworks, LLC. 

 

This Policy applies to: 

  • Dwellworks, LLC; 
  • Dwellworks Destination Services, LLC; 
  • Dwellworks Property Advising Services, Inc; and 
  • Dwellworks Property Advisors, LLC dba Station Cities; (together referred to as "Dwellworks"). 

For all other purposes, this Policy applies to all affiliated entities of Dwellworks including:  

  • Dwellworks SAS; 
  • Dwellworks Sarl; 
  • Dwellworks GmbH; 
  • Dwellworks Relocation Services Ireland Limited; 
  • County Homesearch International Limited; 
  • Dwellworks Hong Kong Limited; 
  • Dwellworks Canada, Inc.; 
  • Dwellworks Costa Rica Ltda.; 
  • Dwellworks Mexico S. de R.L. de C.V.; 
  • Dwellworks Australia Pty. Ltd.; 
  • Dwellworks Netherlands B.V.; 
  • Dwellworks Netherlands II B.V.; 
  • Dwellworks Living Pte. Ltd; and 
  • Dwellworks Real Estate Property Management (Shanghai) Co. Ltd. 

 

Purpose and Scope

This Policy lays out the general data protection principles utilized by Dwellworks and general rights granted to you under Data Privacy Laws. For more specific information regarding your data and rights, please see our Privacy Notices. If you are a California resident, you may have additional rights under the CCPA.  

Due to the global nature of the mobility industry and Dwellworks’ business operations, the transfer of personal data across national borders may occur.  Dwellworks respects and strives to protect the privacy of its supply chain partners and transferees. Personally identifiable information and sensitive personal data that identifies or describes a living person (hereinafter “Personal Data”) which is collected, used, or disclosed by or on behalf of Dwellworks is protected in accordance with the laws of the countries in which Dwellworks operates.  

This Policy applies to Personal Data of transferees and to Personal Data of any other individuals (such as business contacts and supply chain partners) other than employees (including applicants for employment and former employees) of Dwellworks (“you”). This Policy also applies to Personal Data received by Dwellworks in any format, including electronic, paper, or verbal.  

For the purposes of the General Data Protection Regulation (EU 2016/679) (“GDPR”) in the European Union, UK Data Protection Act 2018 (“UK GDPR”), California Consumer Privacy Act (“CCPA”), and any other applicable data privacy law (together, “Data Privacy Laws”), Dwellworks will be a “Data Processor” of Personal Data relating to transferring individuals which is obtained and processed in the course of providing relocation services to its corporate customers. Dwellworks will be a “Data Controller” of Personal Data relating to its supply chain partners and relating to transferring individuals which is obtained and processed in the course of providing relocation services directly to such transferring individuals. 

Types of Data Collected

Personal Data collected by Dwellworks is limited to information necessary to conduct business.  Personal Data collected includes but is not limited to: name, address, government identification number (i.e., social security number, national identification number, tax payer identification number, passport information, driver's license), date of birth, phone number, email address, Office of Foreign Assets Control (“OFAC”) information, financial information and bank account information. 

Notice & Disclosure of Personal Data

Dwellworks will inform individuals about the purposes for which it (in its own capacity or on behalf of a corporate customer, where relevant) collects and uses Personal Data, the types of third parties or agencies to which it discloses such information, and the choices which Dwellworks (in its own capacity or on behalf of a corporate customer, where relevant) offers to limit the use and disclosure of Personal Data. 

The sharing of Personal Data by Dwellworks with its network of third-party suppliers of relocation-related services is necessary for the purpose of providing relocation services to its customers and their transferring employees. We may disclose your Personal Data to third parties, as reasonably necessary for the purposes described above or as otherwise directed or consented to by you, including but not limited to: 

  • To any Dwellworks company for the uses and purposes set out above;   
  • To our intermediaries, advisers, and business partners for the purposes of fulfilling our contractual obligation to you (for example, to deliver our Services and to arrange services for you);   
  • To third party service providers such as entities providing customer service, email delivery, auditing and other services;   
  • If we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence; and   
  • In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).  

When Dwellworks sends or receives Personal Data from its subsidiaries, affiliates or other organizations in a country not covered by an adequacy decision or the DPF, we rely on standard contractual clauses as our mechanism to safeguard the transfer.  

Choice

Dwellworks offers individuals the opportunity to opt out of disclosing their Personal Data to a third party or to consent to the use of the information by Dwellworks for a purpose other than which it was originally collected or subsequently authorized.  For sensitive data (which includes health data and other types of data classified as special categories of personal data under Data Privacy Laws), Dwellworks offers individuals the opportunity to affirmatively and explicitly consent to the disclosure of the information to a third party or to the use of the information by Dwellworks for a purpose other than which it was originally collected or subsequently authorized. 

Onward Transfer

Dwellworks will only transfer Personal Data to a service provider, vendor or other third party acting as a processor (or sub-processor) of Personal Data for Dwellworks where that party has provided assurances that it provides at least the same level of privacy protection as is required by this Policy, including implementing standard contractual clauses where applicable.  Where Dwellworks becomes aware that a party is using or disclosing Personal Data in a manner contrary to this Policy, Dwellworks will take reasonable and appropriate steps to prevent or stop the use or disclosure of that Personal Data. 

On occasion, Dwellworks may be required to share personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

Security

Dwellworks takes reasonable steps to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. These precautions include but are not limited to password protections and multi-factor authentication for online systems, encrypting Personal Data, and restricting access to Personal Data to the legal department or to their relocation consultant for transferees. Individuals who have access to Personal Data are aware of their responsibilities to protect the security, confidentiality and integrity of the information. 

Data Subject Rights

Under Data Privacy Laws, Personal Data is protected by legal rights, which include individuals' rights to request access to or amendment of their Personal Data, to request erasure of their Personal Data, to object to processing of their Personal Data, to require restriction of processing of their Personal Data, to request the transfer of their Personal Data to another party or to withdraw consent at any time where Dwellworks are relying on consent to process such Personal Data. Where Dwellworks is a data controller, Dwellworks will respond to any request from an individual to exercise any such right within one month. Where Dwellworks is a data processor, Dwellworks will forward any request from an individual to exercise any such right to the relevant data controller (being the applicable corporate customer). 

Under Data Privacy Laws, individuals shall have the right to make a complaint about Dwellworks' use of their Personal Data to a relevant supervisory authority for data protection matters. If you would like to exercise your rights under Data Privacy Laws, please complete the form located in the “Contact Us” section. 

Transferees can access their Personal Data and can correct or amend it if it is inaccurate or incomplete.  Subject to applicable data protection laws, Dwellworks reserves the right to deny or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to the individual’s privacy. Any Dwellworks transferee or other individual that wants to review or update their Personal Data can do so by contacting us using the information below. 

Data Integrity 

Dwellworks will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Dwellworks will take reasonable steps to ensure that Personal Data is reliable, complete, accurate, and current. All transferees or other individuals are asked to inform human resources or their consultant respectively immediately in the event of changes in Personal Data. 

Enforcement, Verification, & Dispute Resolution 

Associates and supply chain partners who violate Data Privacy Laws may be subject to potential civil and/or criminal liability. Dwellworks conducts periodic reviews of its privacy practices to verify adherence to this Policy and the DPF Principles. This Policy may be updated occasionally to reflect changes to Dwellworks’ privacy practices. 

Transferees and others whose Personal Data is handled by Dwellworks should contact Dwellworks if there is reason to believe that the security of their Personal Data has been compromised.  Dwellworks will investigate and attempt to resolve complaints regarding use and disclosure of Personal Data.  Where necessary under applicable data protection laws, Dwellworks will report any misuse or other personal data breach to the relevant regulatory authorities. 

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Dwellworks commits to refer unresolved complaints concerning our handling of Personal Data received in reliance on Data Privacy Framework to the International Centre for Dispute Resolution – American Arbitration Association (“ICDR-AAA”) alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from Dwellworks, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of ICDR-AAA are provided at no cost to you. A binding arbitration option will also be made available to the individual in order to address residual complaints not resolved by any other means. The Federal Trade Commissions (“FTC”) has jurisdiction over Dwellworks’ compliance with the Data Privacy Framework. 

Declarations Regarding the Data Privacy Framework 

For the purposes of this Policy, references to "Data Privacy Framework" or “DPF” shall be references to the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework, all as applicable, and references to "DPF Principles" shall be references to the applicable privacy principles contained within the Data Privacy Framework.  

Before sharing Personal Data concerning a resident of the EU, UK, or Switzerland with a third party, Dwellworks will verify that the third party holds Personal Data in a manner consistent with this Policy, and certifies compliance with the European Union, United Kingdom, and Switzerland's data protection laws and with the Data Privacy Framework requirements. In particular, Dwellworks will ensure that Dwellworks will only transfer such Personal Data to third parties (i) in countries that have been deemed to provide an adequate level of protection for personal data by the proper governing bodies; (ii) to third parties who have signed specific contracts approved by the proper governing bodies which give Personal Data the same protection it has in the EU, UK, or Switzerland; or (iii) to third parties based in the United States if they are also part of the Data Privacy Framework.  

Dwellworks complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Dwellworks has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  Dwellworks has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/ 
  
Dwellworks' participation in the Data Privacy Framework applies to all Personal Data that is received from the European Union, United Kingdom (and Gibraltar), and/or Switzerland.  

Dwellworks is accountable for Personal Data that it receives under the Data Privacy Framework and subsequently transfers to a third party, as described in the DPF Principles. In particular, Dwellworks remains responsible and liable under the DPF Principles for onward transfers of Personal Data to third-parties, and if the third-party agents that it engages to process the Personal Data on its behalf do so in a manner inconsistent with the DPF Principles, unless Dwellworks proves that it is not responsible for the event giving rise to the damage.  

Contact Us 

If you have any questions or comments about this Notice or wish to exercise your rights privacy rights, please do not hesitate to contact us at: 

Phone: +1 800 399 2626 

Portal: Data Subject Access & Erasure Request  

Email: [email protected]

Data Protection Officer Germany: www.datenschutz-stalla.de

Data Protection Officer EU/UK: [email protected] 

EU/UK Representatives: [email protected]   

Postal Address:  

Dwellworks, LLC 

Attn: Compliance Department 

1317 Euclid Avenue 

Cleveland, Ohio 44115 USA 

 

Dwellworks will respond to complaints or inquiries within a reasonable time but in any event, no later than one month after such complaint or inquiry.