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Introduction

Protecting the privacy of users of our products and services is important to TriNet. TriNet makes use of any personal information you provide to us only for the purposes outlined in this policy. To the extent TriNet's International Privacy Policy ("International Policy") is applicable and there is any conflict between the terms of this policy and the International Policy, the terms of the International Policy shall govern.

This policy also does not apply to any information that you may provide directly to third parties including via third-party sites linked to TriNet's website or its service portal—HR Passport®. While we actively seek to ensure that our Suppliers and Service Providers maintain high standards regarding the protection of personal information collected on their websites, TriNet is not responsible for the privacy practices employed by such sites.

Information We Collect

If you are a non-customer, the only information TriNet.com collects from you is your email. TriNet will never sell, borrow, or trade the email addresses in our possession to any other company for the purpose of contacting you regarding commercial services. If you are a TriNet customer or employee we collect the information necessary to provide our services.

Usage Tracking

We track user traffic patterns throughout all of our sites, but this tracking is never associated with non-registered individual users. We compile aggregate data mainly by tallying page views throughout our sites. This information may include the URL that you just came from (whether this URL is on our site or not), which URL you next go to (whether this URL is on our site or not), and what browser and computing platform you are using.

In addition, we use cookies on certain pages of our site. We may also offer certain features that are only available through the use of a cookie. Cookies enable you to enter your password less frequently during a session. Cookies can also help us provide you information that is targeted to your interests. Cookies are stored on your hard drive, not on our site. Most cookies are "session cookies," meaning that they are automatically deleted at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our site, and you may be required to reenter your password more frequently during a session.

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the site, we may collect such information into a file specific to you. If you submit questions via our site, we may post your question on the site, and reprint it in various articles and customer communications. We will never include the name or contact information of people who submit questions, regardless of which channel we use to distribute content.

Use of Information

We use personally identifiable information about you to improve our marketing and promotional efforts, to statistically analyze site usage, to improve our content product offerings, to customize our site's content, layout, and services and provide our services (if applicable).

We may also use information about you to deliver information to you that, in some cases, is targeted to your interests, such as new services and promotions. By voluntarily providing information, you consent to the collection and use of your personally identifiable information as described in this policy.

We may use your email address, mailing address, and phone number to respond to your requests for proposals, and to contact you regarding administrative notices, new product offerings, and communications relevant to your use of the site.

We use information in the file we maintain about you, and other information we obtain from your current and past activities on the site, to resolve disputes and troubleshoot problems. At times, we may look across multiple users to identify problems or resolve disputes, and we may evaluate information about you to look for users using multiple User IDs or aliases.

Customers and Worksite Employees of TriNet

If you are a customer (also referred to as a worksite employer) or worksite employee serviced by TriNet, we may collect and maintain personally identifiable information including, but not limited to, name, address, phone number, social security number, taxpayer identification number, age, marital status, occupation, salary, benefits, dependent information, etc. through HR Passport or other means. This information will be used to provide our professional employer and other HR-related services including sharing such information with the worksite employer to extent permitted by applicable law. By using our services you agree to the terms of use contained in this policy.

Disclosure of Information

Unfortunately, due to the existing regulatory environment, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this policy. By way of example (without limiting the foregoing), we may be forced to disclose information to the government or third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. By your use of the TriNet website or TriNet's services (as applicable), you hereby accept these terms and you authorize us to disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us to legal liability. Therefore, although we employ industry-standard practices to protect your privacy including the use of firewalls and Secure Socket Layer (SSL) technology no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we do not promise, and you should not expect, that your personally identifiable information or private communications will remain private always.

As a general proposition, we do not sell or rent any personally identifiable information about you to any third party. The following describes some of the ways that personally identifiable information about you may be disclosed to third parties.

Legal Requests

We cooperate with law enforcement and other third parties to enforce laws, intellectual property and other rights. Therefore, local, state, federal and international law enforcement can request and may receive your personally identifiable information.

Suppliers and Other Service Providers

We may use third-party Suppliers and Service Providers to facilitate provision of our professional employer and HR-related services. For example, we may outsource the operations of one or more aspects of our site to a Supplier or Service Provider who performs services according to our requirements. In all cases, we restrict how these Suppliers and Other Service Providers may access, use and disclose information received from our site. We do not permit these Suppliers and Other Service Providers to access information about you, other than that information necessary for them to complete the services for which they are contracted. Under no circumstances do we allow them to disclose, sell, lend or in any other way transmit data about you to third parties.

Control of Your HR Passport Login Password—for Customers and Worksite Employees Only

Except as specifically permitted by this section, you may not disclose your password to access HR Passport to any third party nor share it with any third party. If you lose control of your password, you may lose substantial control over personally identifiable information about you and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password. You may, however, disclose your password to certain third parties with whom we have entered into specific contractual and technical arrangements designed to safeguard your password ("Authorized Password Users"), in order to enjoy the benefits of those third parties' services in relation to our services.

Reviewing and Changing Your Personally Identifiable Information—for Customers and Worksite Employees Only

Once you receive a username and password for "Customer Login," you can review and change the information you submitted during registration. You must promptly update your registration information if it changes. We will retain in our files information you have requested be removed in some circumstances, such as to resolve disputes, troubleshoot problems and enforce any applicable agreements. Further, such prior information is never completely removed from our databases due to technical constraints and the fact that we back up our systems. Therefore, you should not expect that all of your personally identifiable information will be completely removed from our databases in response to your requests.

Security

We use industry standard methods, such as firewalls and Secure Socket Layers (SSL), to safeguard the confidentiality of personally identifiable information about you. Using SSL means that data such as names and passwords cannot be easily deciphered by outside users. However, "perfect security" does not exist on the Internet.

Changes in this Privacy Policy

TriNet reserves the right to change this policy at any time without prior notice given to users of this site. This Privacy Policy was last updated on October 6, 2010. Please check here regularly to be sure you learn and understand any changes to the policy.

Legal Disclaimer

TriNet.com and HR Passport contain a great deal of content regarding legal and human resource matters. This content has been prepared for educational and information purposes only. The content does not provide legal advice or legal opinions on any specific matters. Transmission of this information is not intended to create, and receipt does not constitute, a lawyer-client relationship between TriNet, the author(s), or the publishers and you. You should not act or refrain from acting on any legal matter based on TriNet.com or HR Passport content without seeking professional counsel.

TriNet Client Communication Disclaimer

This proprietary communication has been prepared for educational and information purposes only. The content does not provide legal advice or legal opinions on any specific matters. Transmission of this information is not intended to create, and receipt does not constitute, an attorney-client relationship between TriNet and you. TriNet is not an insurance company, but rather is the single-employer sponsor of all of its health benefit plans. Nothing contained herein constitutes an offer to sell, buy, or procure insurance.

TriNet is the single employer sponsor of all its benefit plans. TriNet makes these plans available to qualifying worksite employees ("WSEs"), with whom TriNet has established an employment relationship, and who perform services for customers of TriNet in a Professional Employer Organization ("PEO") or service model. Under this model, TriNet incurs all expenses associated with its plan sponsorship and maintenance, and TriNet bills the customer for its services. The customer has no other financial obligation to TriNet, its other customers, or any of its insurance carriers for benefit plans sponsorship or provision. TriNet's carriers have no recourse against TriNet customers. Other than compliance with TriNet's contract terms, customers have no legal responsibilities to TriNet or the WSEs or any other TriNet customer for plan sponsorship or compliance.

Any references to "your benefit programs or plans" are not legal terms or terms of art, and should not be confused with legal plan sponsorship, participation, or fiduciary compliance. These terms and others, such as "your employees" or "your selections, plan, or investments," are used solely as lay terms of convenience so that you understand we are referring only to the decisions made and TriNet plans available in a specific worksite or to a specific group of WSEs.

Insurance coverage exclusions and limitations apply. In the event there is a conflict between any of the information contained in any benefits guidance materials provided by TriNet (including but not limited to information contained in any TriNet website, the Benefits Confirmation Statement, any written or electronic pamphlets, letters, emails, text messages, and statements made by TriNet employees) and TriNet's Plan document, the Plan document will control. Also, if there is a conflict between an official certificate provided by TriNet's insurance carrier(s) (the "Carrier Certificate") and either TriNet's Plan document, any TriNet Summary Plan Description, statements made by a TriNet employee, or any other benefits guidance materials provided by TriNet (including but not limited to those described above), the Carrier Certificate will control.

Copyright Notification

TriNet.com, is the property of TriNet. • ©2010, All rights reserved.

Trademark Information

The TriNet logo and design, Ambitions Realized, and HR Passport are registered trademarks of TriNet. All other trademarks, trade names, service marks and logos appearing on this website belong to their respective companies.

Website Administrator

Send comments to Website Administrator

This privacy policy applies only to Personal Information transferred to TriNet HR Corporation (together with its affiliates, subsidiaries and parent corporations, "TriNet") from the European Union ("EU") and other countries outside of the United States. All other Personal Information transferred to TriNet is subject to TriNet's "Terms of Use/Privacy Policy" posted on www.trinet.com

Introduction

TriNet delivers HR outsourcing services that allow small companies to do what they do best. Thousands of organizations have turned to TriNet for human resources, benefits, payroll, workers' compensation, and strategic human capital services. As their trusted HR advisor, TriNet helps these companies contain HR costs, minimize employer-related risk, and relieve the administrative burden of HR. As part of TriNet's suite of HR outsourcing services, TriNet coordinates provision of payroll, benefits and related services to its clients' locations abroad. In order for TriNet to provide this vast array of services, TriNet must collect certain personal information regarding the employees of its clients.

Protecting customer and employee privacy is important to TriNet. TriNet adheres to the Safe Harbor Agreements concerning the transfer of personal data from the European Union (EU) and Switzerland to the United States. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the Principles) with respect to all data received from outside of the United States. If there is any conflict between this privacy policy and the Principles, the Principles shall govern. This privacy policy outlines our general policy of practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all Personal Information received by TriNet from outside of the United States whether in electronic, paper or verbal format.

Definitions

"Personal information" or "Information" means information that 1) is transferred from outside of the United States to TriNet; 2) is recorded in any form; 3) is about, or pertains to a specific individual; and 4) can be linked to that individual.

Safe Harbor Principles

Notice: TriNet shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which TriNet discloses or may disclose that Personal Information. TriNet shall provide the individual with the choice and means to limit the use and disclosure of their Personal Information by TriNet for a purpose other than which it was originally collected.

Personal Information includes, but is not limited to: name, employer, title, position held, length of employment, documents that verify employment, work address, work phone number, home address, home telephone number, country of domicile, copy of government identity card, copy of passport, date of birth, gender, marital status, family status, compensation, salary information, tax information, names and birthdates of dependants, copy of passport and bank information. This Personal Information is transmitted to payroll and benefit providers and other vendors that participate in providing clients payroll, benefits and related services.

Choice: Trinet will offer individuals the opportunity to choose (opt out) whether their Personal Information is 1) to be disclosed to a third party (other than a vendor with whom TriNet has contracted with in connection with providing payroll, benefits and other related services) or 2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Onward Transfers: Prior to disclosing Personal Information to a third party, TriNet shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. TriNet shall ensure that any third party to which Personal Information may be disclosed subscribes to the Principles or is subject to law providing the same level of privacy protection as is required by the Principles or agrees in writing to provide an adequate level of privacy protection.

Data Security: TriNet shall take reasonable steps to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration or destruction. TriNet has put in place appropriate physical, electronic and managerial procedures to safeguard and secure Personal Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. TriNet cannot guarantee the security of Information on, or transmitted via, the Internet.

Data Integrity: TriNet shall only process and use Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual – using Personal Information to provide payroll, benefits and related services. To the extent necessary for those purposes, TriNet shall take reasonable precautions to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access: TriNet shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights or persons other than the individual would be violated.

Enforcement: TriNet 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, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal processes, we agree to dispute resolution using the Better Business Bureau EU Safe Harbor Program — an independent resource mechanism — as a third-party resolution provider.

Amendments

This privacy policy may be amended from time to time by the posting of a revised policy on this website.

Privacy Complaints by European Union Citizens

In compliance with the Safe Harbor Principles, TriNet commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact TriNet at:

1100 San Leandro Boulevard
Suite 400
San Leandro, CA 94577
Attention: General Counsel
legal@trinet.com

TriNet has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by TriNet, you may contact:

Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor  
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Phone:  703-276-0100
Web:  www.bbb.org/us
Email:  eusafeharbor@council.bbb.org