Privacy Policy

Effective date: May 15, 2024

Graebel’s Commitment To Privacy

Your privacy is important to us. To better protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and website footer. This notice supplements other materials you may have received or will receive from Graebel Companies, Inc. or its affiliates. Graebel regularly reviews this Privacy Notice and ensures that we process your information in a manner that is in compliance with applicable regulations.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Scope of this Notice

This privacy notice (“Privacy Notice”) applies to Graebel Companies, Inc. and its affiliates and subsidiaries (collectively, “Graebel”, “we” “our” or “us”). We respect your privacy rights and value your trust. This Privacy Notice describes how we collect, receive, use, store, share, transfer, and process your personal data, as well as your rights in determining what we do with the information that we collect or hold about you.

Graebel is responsible for the processing of your personal data when you interact with our websites and services and products (“Sites and Services”) and any other sites or services under our control where this Privacy Notice is displayed. If your employer has entered into an agreement with Graebel, your employer has obtained your consent for the processing of your personal data as part of our Sites and Services.  By accessing our Sites and Services you are confirming your consent to this processing on behalf of your employer.  You may contact us at any time via the methods described below to exercise your rights or with any questions.

International Transfers

For data transfers to and from the European Economic Area and other locations we utilize data processing agreements with the current Standard Contractual Clauses approved by the European Commission or UK. In each case, we put in place appropriate technical and organizational measures to protect personal data, and additional safeguards in relation to the potential impact of US laws. Due to the ever-changing nature of legislation around data privacy, we reserve the right to make lawful changes as needed.

Data Privacy Framework Participation and Compliance

Graebel Companies, Inc., and its subsidiaries Graebel Relocation Services Worldwide, Inc., Move Management, Inc., and Graebel Movers International, Inc., participate in and have certified compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), 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. Graebel is committed to subjecting all personal data received from European Union (EU) member countries, the United Kingdom (and Gibraltar), and Switzerland, respectively, in reliance on the Data Privacy Framework, to the Framework’s applicable Principles. To learn more about the Data Privacy Framework, visit the U.S. Department of Commerce’s Data Privacy Framework List: https://www.dataprivacyframework.gov.

Graebel, as a participant in the Data Privacy Frameworks, upholds its obligation and continues to fulfill the requirements therein to continue to be on the Data Privacy Framework List. The U.S. Department of Commerce continues to administer the Data Privacy Framework program and maintains the List.

Graebel is responsible for the processing of personal data it receives, under EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, and subsequently transfers to a third party acting as an agent on its behalf. Graebel complies with the Data Privacy Framework Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Data Privacy Framework, Graebel is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Graebel may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Data Privacy Framework website https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Graebel has further committed to cooperate with the EU data protection authorities for EU and United Kingdom (and Gibraltar) employees, and the Swiss Federal Data Protection and Information Commissioner for Swiss employees, with regard to unresolved Data Privacy Framework complaints concerning human resources data transferred from the EU or Switzerland, respectively, in the context of the employment relationship.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Graebel commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

Graebel complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. Framework regarding the collection, use, and retention of personal data transferred from the European Union, the United Kingdom (and Gibraltar), and Switzerland to the United States. Graebel has certified to the Department of Commerce that it adheres to the Data Privacy Framework Principles. If there is any conflict between the terms in this privacy notice and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about Data Privacy program, and to view our certification, please visit https://www.dataprivacyframework.gov.

Graebel will offer EU, the UK, and Swiss individuals whose personal data has been transferred to us the opportunity to choose whether the personal data it has received is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal data by contacting us via the methods listed in the “How to Contact Us” Section of this Notice.

Data Subject Rights

Data Subjects such as under the General Data Protection Regulation and privacy laws of other countries including, but not limited to, Australia, Brazil, China and Singapore are given a variety of rights including: Right to Request Access, Right to Rectification, Right to Object, Right to Erasure, Right to Restriction of Processing, Right to Portability, and the Right to Make a Complaint to Regulators. To exercise any of the following rights, please complete the form after clicking on the Individual Rights button above.

Where the request pertains to your personal data on behalf of our customers (i.e. your employer, as the data “controller”) (“Customer Data”), Graebel will forward such requests to the customer (i.e. your employer the data “controller”) and will respond to requests from such customers within a reasonable time-frame.

Right to Request Access
You may request details of personal data which we hold about you. Upon request, we will provide a copy of such personal data within a reasonable timeframe.

Right to Rectification
If you believe that any personal data we are holding on you is incorrect or incomplete, please contact us as soon as possible. We will promptly correct any personal data found to be incorrect.

Right to Object
You may choose to object to the collection or use of your personal data:
a) Whenever data is processed for the legitimate interest of Graebel.
b) Whenever data is processed for a task carried out in the public interest or in the exercise of official authority vested in Graebel. Please note that your objection may be overridden by the legitimate interests of Company to process and collect your personal data.

Right to Restriction of Processing
You may have the right to restrict further processing of your personal data in the following situations:
a) You contest the accuracy of the personal data.
b) The processing of the data is unlawful.
c) The personal data Graebel has reached the defined retention period no longer needs the personal data for the purposes of the processing, but you require the personal data to establish, exercise, or defend legal claims.
d) You object to the processing may be restricted pending the verification of whether Graebel’s legitimate grounds override your rights as a data subject.

Right to Portability
You have the right to receive your personal data in a structured, commonly used and machine-readable format. Graebel will assist in the transmission of such data to another entity, upon request, to the extent technically feasible.

Where the request pertains to Customer Data, Graebel will forward such requests to the customer (i.e. your employer, as the data “controller”) and will respond to requests from such customers within a reasonable time-frame.

Right to Make a Complaint to Regulators
You have a right to file a complaint to the supervisory authority which oversees data protection compliance in the area where you live or work or where you believe we have infringed your privacy rights.

Use for Materially Different Purpose
An individual may opt out of use of their data for a purpose other than the purpose for which it was originally collected by contacting us via the methods listed in the “How to Contact Us” section of this Notice.

Consumer Rights

Consumers subject to United States privacy laws and privacy laws of other countries including, but not limited to, Australia, Brazil, China and Singapore are given a variety of rights relating to their personal data, subject to certain exceptions and limitations including: Right to Know, Right to Opt-Out, Right to Limit Use of Sensitive Information, Right to Delete, Right to Correct, and Right to Non-Discrimination.

To exercise any of the following rights, please complete the form after clicking on the Individual Rights button above, send us an e-mail at [email protected], or write us at 16346 Airport Circle, Aurora, Colorado, 80011, Attention: Chief Information Security & Privacy Officer. For security purposes, please do not include any confidential or sensitive personal data, such as a social security number or order-tracking number, in any email or other correspondence.

Right to Know
You may request details of personal data which we hold about you, as well as the right to know if your data is being sold or shared and with whom. Upon request, we will provide a copy of such personal data within a reasonable timeframe allowed by law.

Right to Opt-Out
You have the right to opt-out of any data selling or sharing with third-parties, although some services we provide may be limited.

We may provide your personal data to companies that provide services to help us with our business activities such as shipping your order or offering other services related to your relocation. These companies are authorized to use your personal data only as necessary to provide these services to us.

If you do not want us to share your personal data, contact us here. Information that we share is largely for the purpose of providing services that were requested by you. If you opt-out of having your information shared, it may limit the services we are able to provide to you.

Right to Limit Use of Sensitive Information
You have the right to limit the use of your sensitive information. We only collect sensitive information necessary to perform services requested by you.

Right to Delete
Upon a verified request, you have the right to request deletion of the information we hold about you. In order to verify a request, we may request information from you for the purpose of verifying your identity. If you cannot be verified, we will treat your request as an Opt-out Request.

Right to Correct
If you believe that any personal data, we hold about you is incorrect or incomplete, please contact us as soon as possible. We will promptly correct any personal data found to be incorrect, subject to verification.

Right to Non-Discrimination
You have the right to not be discriminated against for exercising any of the above rights. This includes the right to not be denied access to our services.

Authorized Agents
Your Consumer Privacy rights may be exercised by authorized agents; however, verification of your identity will be required.

The Information We Collect

When you visit our websites or interact with our organization, we will not collect certain personal data from you unless you decide to provide information to us.

Graebel does not share, sell, rent, or trade Personal Identifiable Information with third parties for their promotional purposes.  “Personal data” means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly — in particular, by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

This notice applies to all information collected or submitted on Graebel websites. On some pages, you can order services, make requests, and register to receive materials. If you no longer wish to receive communications from us, you can unsubscribe from our emails or opt out by contacting us at [email protected].

You are not required to provide this information, however the services we can offer you may be limited without it. We use this information solely as required to provide requested services and user.  We may collect your personal data (Customer Data) on behalf of our customers (i.e. your employer), as the data “controller”.

The types of personal information collected at these pages may include:

• Name
• Company name
• Company identifiers (Employee Numbers, Payroll ID, Company Entities, Supervisor Information)
• Title
• Address
• E-mail address
• Telephone number
• Services requested
• Moving locations and moving date(s)
• Identification numbers (Social Security Number, Passport Number, National Identification Numbers)
• Financial information (bank wire information)
• Visa and immigration information (including Sex)
• Travel information (itineraries, travel dates, travel locations)
• Accompanying family members’ personal information
• Device ID
• Other demographic information

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.

Collection of Third-Party Personal Data

Third-party personal data is collected within the Relocation Authorization tab. The types of third-party personal data we collect are name, date of birth and gender. We only use this information for purposes such as adding authorized users on your account or as needed to provide services you have requested. If you believe that one of your contacts has provided us with your personal data and you would like to request that it be removed from our database, please contact us here.

The Way We Use Information

We use the information you provide about yourself when placing an order to complete that order. We use return e-mail addresses to answer the e-mail we receive. We use information to better design our website, diagnose problems with our Web server, administer our website, to maintain the security of our website, and as required by applicable law. For example, we may gather information telling us that X number of individuals visited a certain area on our website. We use Customer Data for the purpose of providing the service for which the Customer has engaged Graebel.

We have a legal basis to use this information because:

• It is necessary to perform our contract with our Customers.
• We have a legitimate business interest in assisting you with managing relocation services provided to you.
• You have given your consent to the processing of your information to the data controller.

Customer Testimonials/Comments/Reviews

We post customer testimonials/comments/reviews on our website which may contain personal data. We do obtain the customer’s consent via email prior to posting the testimonial to post their name along with their testimonial. If you wish to update or delete your testimonial, you can contact us here.

Our Commitment to Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. We hold our employees accountable for maintaining the privacy and integrity of our customers’ and your information. We provide ongoing training programs that are designed to keep our employees informed of our Privacy Principles.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, we cannot guarantee its absolute security. If you have any questions about the security of your personal data, you can contact us here.

Protecting the Privacy of the Very Young is Especially Important

For that reason, no part of our website is structured to attract anyone under the age of 18. However, due to the nature of the services we provide, we may need to collect information from a child’s guardian about the child for the purposes of providing our service. We will not collect more information than necessary, and we will safeguard the information we collect from you about your child. We encourage parents to actively participate in their children’s activities on the Internet and to educate children on the safe use of the Web.

Our Commitment to Continually Improve Digital Accessibility

We have a commitment to Diversity, Equity and Inclusion and strive to ensure our digital platforms are accessible to people with disabilities. We follow global accessibility standards to provide an optimal digital experience for all users.

To do so, we may request information from a user to customize and optimize their online experience but will not collect personal data from a user unless you decide to provide the information to us.

If you experience any challenges with content availability or functionality on this website, or if you have suggestions on how to make our digital platforms more accessible to people with disabilities, please contact us.

Consent

At Graebel, we believe that you own your Personal data. We will always give you a choice regarding how Personal data provided to us may be used. Most of the Personal data we have has been given to us by employers (our customer) for the purpose of providing their employees our services. In these cases, the consent to collect personal data, and remove personal data, is held by the employer since we are acting as a service provider for them.  During the process of helping our customers’ employees move their homes and businesses and/or relocate to new areas, Graebel may share personal data with carefully selected third-party companies, organizations and government agencies in order to facilitate an easy moving process and give our customers’ employees access to local resources they might find helpful in their new location. Such companies may include (based upon services being offered):

• Affiliates within our family of companies
• Real Estate Brokerages
• Temporary Housing companies
• Mortgage companies
• Appraisal companies
• Title companies
• Inspection organizations
• Immigration firms
• Tax preparation companies
• Company-directed payroll partners
• Destination Service providers
• Language/Cultural Training companies
• Any other person or entity we reasonably think is customary, necessary or advisable for the business purposes disclosed in our Privacy Notice or to whom we are obliged by applicable law or regulation to make the disclosure
• Any other party where we have obtained your consent or authorization

Our transferees will always have the opportunity to opt in or out of any data collection or distribution, although some services we provide may be limited. If you do not want us to share your personal data with these companies, contact us here.

We may provide your personal data to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your personal data only as necessary to provide these services to us.

Disclosure

We will share your personal data with service providers, and other third parties only in the ways that are described in this Privacy Notice, or when we have your consent. The only exception to this Notice is when we are required to do so by law, such as to response to lawful requests by public authorities, including to meet national security or law enforcement requirements, comply with a subpoena, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If Graebel is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.

Accountability

Graebel takes our responsibility to manage your information and protect your privacy very seriously. We have made the commitment to have our Privacy Policies, Notices, and Practices audited by independent organizations.

Because we are committed to your privacy and value your trust, this site has agreed to notify you of the following:

1. The personal data of yours that is collected
2. Which organization it is that is collecting the information
3. How the information is used
4. With whom the information may be shared
5. The choices are available to you regarding the collection, use, and distribution of the information
6. The type of security procedures that are in place to protect the loss, misuse, or alteration of information under the company’s control
7. How you can correct any inaccuracies in the information

How to Correct or Update Your Information

Upon request Graebel will provide you with information about whether we hold any of your personal data. You can access, correct factual errors, and update your personal data regardless of geographic location in which one resides by contacting Graebel’s Chief Information Security & Privacy Officer by contacting [email protected].

Individuals may request access, correction, or deletion of personal data by completing the form after clicking on the Individual Rights button within the “Data Subject Rights” or “Consumer Rights” sections of this Notice or by referring to the “How to Contact Us” section of this Notice.

To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections. We will respond to your request to access within 30 days. If you wish to cancel your account or request that we no longer use your information to provide you services, please coordinate through the company which coordinated with Graebel and provided services to you. You may coordinate this effort by contacting Graebel’s Chief Information Security & Privacy Officer by contacting [email protected].

Retention of Personal Data

We follow all applicable laws governing the retention of your data. The factors that influence how long we retain your data include:  legal requirements, if your employers account with us is active, or if the information is still needed to fulfill the purposes for which it was collected. We retain the data we collect from you for different periods of time depending on the purposes the information is needed for and the terms of our agreements with our Customers.

Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when we process a payment on your behalf we will retain this data for longer periods of time as required for tax purposes.

Generally, we do not collect more information than necessary to complete our services.  Based on the applicable laws of your region, you may have the right to request deletion of personal data we collect from you.

Third-Party Sites

To better serve you, we often provide links to other websites that may be of interest to you. We have no control over and are not responsible for the content or the operators of such sites. Therefore, this Privacy Notice will not apply to information you may provide on such sites. You should contact the operators of any third-party website if you are concerned about the privacy of the information that may be collected when you use the site.

Social Media Widgets

Our website includes Social Media Features (“Features”), such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Cookies/Tracking Technologies

Technologies such as cookies, beacons, tags, scripts, or similar technologies may be used by Graebel and affiliates for analytics or service providers. These technologies are used in analyzing trends, website administration, tracking users’ movements around the site and to gather demographic information in order to provide a more user friendly and optimal user interface for customers.

We use cookies for analytics. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

We partner with a third party to either display advertising on our Website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

How to Contact Us

Please feel free to contact Graebel’s Chief Information Security & Privacy Officer. Should you have other questions or concerns about this Privacy Notice or this website, please call us at +1-800-723-6683, send us an e-mail at [email protected], or write us at 16346 Airport Circle, Aurora, Colorado, 80011, Attention: Chief Information Security & Privacy Officer. For any matters requiring the attention of our Data Protection Officer, please send an e-mail to [email protected]. For security purposes, please do not include any confidential or personal information, such as a social security number or order-tracking number, in any email or other correspondence.

Changes in this Privacy Policy

As we continue to update our privacy notice, we will post those changes to this Privacy Notice, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Privacy Notice at any time, so please review it frequently.  Policy changes will take effect when posted.