Privacy Policy

We self-certify compliance with

JUNE 2016

DATA PRIVACY AT SODEXOPASS, USA, INC.
SodexoPass USA, Inc. (“Sodexo”) is committed to protecting your data and privacy rights.  In that endeavor, Sodexo has established this Privacy Policy, which includes both Sodexo’s U.S.–European Union Safe Harbor Privacy Policy and the Web Sites’ Privacy Policy.  

UNITED STATES – EUROPEAN UNION SAFE HARBOR PRIVACY POLICY
For personal information (as defined below) of employees, consumers, clients, and customers that Sodexo receives from the European Union, Sodexo has committed to handling such personal information in accordance with the Safe Harbor Privacy Principles (“Privacy Principles”) published by the U.S. Department of Commerce.  Personal information means information about an identifiable individual and may include identifying information, such as name, address, birthdate, telephone number, e-mail address, profession or employment information, or financial information, such as credit card number.   Such personal information may be transferred from the European Union (“EU”) to the United States only through the use of a valid data transfer mechanism.  The European Economic Area (EEA) previously recognized the U.S.-EU Safe Harbor Privacy Principles as having provided adequate data protection.  The U.S.-EU Safe Harbor Privacy Principles are no longer considered a valid data transfer mechanism in the EEA.  Nevertheless, Sodexo complies with the U.S.-EU Safe Harbor Privacy Principles.  For more information about the Privacy Principles, please visit the U.S. Department of Commerce’s web site at http://export.gov/safeharbor/.  Sodexo’s Safe Harbor certification can be found at http://safeharbor.export.gov/list.aspx

WEB SITES PRIVACY POLICY

This online privacy policy describes the information collected through the services available on our web sites,www.sodexomotivation.com, www.mypassinfo.com, tpc.mypassinfo.com, account.mypassinfo.com,orders.sodexomotivation.com (the "Sites") and the Esteem Pass Card Program, Ultimate Pass Card Program, and the Scrip Card Program and how we use that Information. Our policy also describes the choices you can make about how we collect and use your information.  If there is any conflict between the Sites’ Privacy Policy and the Privacy Principles, the Privacy Principles shall govern.

What type of information does Sodexo collect about me? 

Sodexo may collect personal information through its Sites, online forms, or by telephone.  

In addition to the personal information you actively provide us, we may also collect Site use information which includes Information about your Internet service provider, browser type, domain name, IP address, the web site that referred you to us, the web pages you request, the date and time of those requests, entry and exit points, and actions taken during your visit to the web pages.  Our collection of web site use information may involve the use of cookies and pixel tags.  When you visit our Sites, we do not collect (or grant permission to third parties to collect) personally identifiable information about your online activities over time and across different web sites or online services. 

Sodexo may also collect aggregated data, which is data from which the identity of an individual cannot be determined.  Since it is not personal information, Sodexo may use aggregated data in any way that it considers appropriate, which may include sharing the same with third parties.

How does Sodexo use personal information?  
Sodexo may use personal information in order to:

  • Process and manage your purchase of products and services, including the purchase and use of your Esteem Pass Card or Ultimate Pass Card;
  • Communicate with you about your order or purchases, or your Esteem Pass or Ultimate Pass Card account;
  • Manage your Esteem Pass or Ultimate Pass Card account and transactions;
  • Respond to your customer service inquiries;
  • Communicate with you about our brands, products, events or other promotional purposes, including co-branded offers, if you have opted to receive such communications;
  • Communicate, to the extent required, with and manage our relationship with Sodexo’s consultants, strategic partners, agents, distributors, suppliers, contractors and other third parties in order to provide services or products you have requested;
  • Improve the Sites; and
  • Meet any applicable legal and regulatory requirement.

Is my personal information shared with third parties?

We will give you the option to receive marketing and promotional information from retailers or other companies involved in the Esteem Pass or Ultimate Pass Card Programs. 

Our Sites may also share information with companies that provide support services to us (such as credit card processors, mailing houses or services,  item fulfillment providers, data aggregation, banks or insurance companies, or web hosts) or that help us market our products and services (such as email vendors). These companies may need information about you in order to perform their functions in accordance with the preferences you indicate. These companies may only use your information in accordance with the preferences you select and are not authorized to use the information we share with them for any other purpose.  These companies either subscribe to the Privacy Principles or we have entered into an agreement with them requiring that they provide the same level of privacy protection as required by the Privacy Principles. 

We may disclose specific information upon governmental request, in response to a court order, when required by law, to enforce our corporate policies, or to protect our or others' rights, property, or safety. We do not provide information to these agencies or companies for marketing or commercial purposes.

In the event of a sale of some or all of our business, Sodexo may disclose personal information to those involved in a transfer of all or part of the assets or business.

Unless permitted by law, no personal information is collected, without first obtaining your consent for the collection, use and sharing of that information.  Personal information acquired by the Sites will be relevant for its intended use.  By providing personal information to Sodexo, you agree and consent that we may collect, use and share your personal information in accordance with this privacy policy. 

In most cases, and subject to legal and contractual restrictions, an individual is free to refuse or withdraw his or her consent at any time upon reasonable, advance notice.  It should be noted that in some circumstances, certain Sodexo products and services can only be offered if a person provides personal information to Sodexo.  If you choose not to provide us with any required personal Information, we may not be able to offer the products or services requested.

How can I change what promotional communications I receive?

We may use your e-mail address and other contact information provided to us through the Sites or the Esteem Pass or Ultimate Pass Card Programs to send you promotional materials from us and, as an additional opt-in, from third parties.  If you do not want to receive such promotional information, you can remove yourself from any of these e-mail lists (opt-out) at any time through the “Contact Us” pages of the Sites for e-mail addresses and telephone numbers.

Please also note that even if you opt out of receiving promotional emails from us, we may still use your information to communicate with you for other purposes, such as orders/purchases, your Esteem Pass or Ultimate Pass Card account, customer service responses and other communications we consider necessary in order to service your account.

How do I remove or modify my personal information?
To remove or modify your personal information, please log in to either Site and modify your personal information in the profile area of your account, contact Customer Service through the Sites or telephone number provided on the Sites, or contact your Human Resources representative. 

Why does Sodexo collect web site use information? 
During your visit to these Sites, we will collect certain web site use information for a number of purposes, namely to:

  • Make your access to services and products more convenient and efficient;
  • Establish Site activity trends;
  • Enhance fraud prevention and detection measures
  • Monitor Site performance; and
  • Improve Site design and functionality.

Our collection of web site use information may involve the use of cookies.  A cookie is a small removable data file that is stored by your web browser on your computer.  Cookies allow you to place an order on our web site and allow us to enhance and personalize your online surfing and shopping experience.  We use cookies to remember the items in your cart, recognize you when you return to our Sites and analyze visitor behavior.

You can choose to have your computer warn you each time a cookie is being sent or you can choose to turn off all cookies. You do this through your browser (like Google Chrome, Firefox, Safari or Internet Explorer) settings.  Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookie settings.  If you turn cookies off, you won't have access to many features that make your site experience more efficient and some of our services will not function properly.

We also use clear GIFs, as well as pixel tags – tiny graphic images – to help us analyze your online behavior, but we do not tie that behavior to any personal information.

How is my personal information secured?  

Sodexo strives to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information.

We encrypt the pipe through which personal information, such as credit card numbers, is sent, using Secure Socket Layer (SSL) technology to ensure that your information is safe as it is sent over the Internet to our server.  Sodexo cannot guarantee the security of information on or transmitted via the Internet.

Do we transfer personal information internationally? 
If we transfer your personal information to another country, we will take appropriate measures to protect your privacy and the personal information that we transfer.

Do we collect information from children? 

The Sites are general audience sites that are not designed nor intended to collect personal information from children under the age of 13.  Sodexo does not knowingly collect personal information from anyone under the age of 13, and does not use such information if it discovers that it is has been provided.  To respect the privacy of children and to comply with the Children's Online Privacy Protection Act, children under the age of 13 should not provide any personal information on these Sites.  We ask that parents supervise their children while online.

What about links to other sites?  

Please be aware that we may provide links to third-party web sites as a service to our guests, and that we are not responsible for the content or information collection practices of those pages.  Please note that these web sites' privacy policies may differ from this privacy policy.  We encourage you to review and understand their privacy practices before providing them with information.

What enforcement measures do you undertake? 

Sodexo uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, and completely implemented and accessible in conformity with the Privacy Principles.  Do we collect information from children? The Sites are general audience sites that are not designed nor intended to collect personal information from children under the age of 13. Sodexo does not knowingly collect personal information from anyone under the age of 13, and does not use such information if it discovers that it is has been provided. To respect the privacy of children and to comply with the Children's Online Privacy Protection Act, children under the age of 13 should not provide any personal information on these Sites. We ask that parents supervise their children while online.

What about links to other sites?

Please be aware that we may provide links to third-party web sites as a service to our guests, and that we are not responsible for the content or information collection practices of those pages. Please note that these web sites' privacy policies may differ from this privacy policy. We encourage you to review and understand their privacy practices before providing them with information.

What enforcement measures do you undertake?
Sodexo uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, and completely implemented and accessible in conformity with the Privacy Principles.

Do we make changes to our privacy policy?
If we decide to change our privacy policy, we will post a new statement on our Sites and change the date at the top of the policy. Therefore, we encourage you to check the date of our privacy policy whenever you visit these Sites for any updates or changes.

What if you have questions, feedback, and concerns?

You may provide any questions, comments, or concerns about this privacy policy by contacting us at SodexoPass USA, Inc., 9801 Washingtonian Boulevard, Gaithersburg, Maryland 20878, support.sodexopass.usa@sodexo.com.

If your concern cannot be resolved through our internal process, we agree to dispute resolution using the following commission as a third-party resolution provider: 

European Commission

Directorate General Justice

Data Protection Panel, B-1049 

Brussels, Belgium

Telephone: (32-2) 299.11.11

Fax: (32-2) 298.80.94