Effective Date January 4, 2024
Cornerstone Relocation Group, LLC respects your privacy. This Privacy Policy describes what information we collect and how it is used, collected, stored and protected. This Privacy Policy also describes the choices available to you regarding the use, access, and updates of your personal information. It applies to Cornerstone Relocation Group, LLC and its subsidiaries and/or affiliates including, but not limited to, Cornerstone Relocation Group GmbH, Frankfurt, Germany; Cornerstone Relocation Group Pte Ltd, Singapore, all entities hereinafter referred to as “Cornerstone Relocation”, “us” and “our.” By using our websites, you indicate your agreement and understanding of the practices outlined in this Privacy Policy.
Please note that a separate Privacy Policy applies to HR data relating to Cornerstone's own EU-based employees, details are available from
privacy@crgglobal.com.
Data Privacy Framework
Cornerstone Relocation 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. Cornerstone Relocation 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. Cornerstone Relocation 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. 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/.
Cornerstone Relocation is responsible for the processing of personal data it receives, under the EU-U.S. DPF and Swiss-U.S. DPF, and subsequently transfers to a third party acting as an agent on its behalf. Cornerstone Relocation complies with the EU-U.S. DPF and Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU/EEA, UK and Switzerland, including the onward transfer liability provisions.
The Federal Trade Commission has jurisdiction over Cornerstone Relocation’s compliance with the EU-U.S. DPF, UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF. In certain situations, Cornerstone Relocation may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-U.S. DPF, UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Cornerstone Relocation commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.
For complaints regarding EU-U.S. DPF, UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
What information do we collect?
When offering services to you, we request and collect personal information, such as your first and last name, postal and email addresses, location information, financial information and also relevant information about your family. All types of information are subject to the practices described within this Privacy Policy. You are not required to provide us with any personal information. However, please note that if you choose not to provide us with this information you may not be able to take advantage of all of the services offered.
You can log in to our website using sign-in services such as Google+. These services will authenticate your identity, and provide you the option to share certain personal information (such as your name and email address) with us, and to pre-populate our sign in form. Services like Google+ give you the option to post information about your activities on this website to your profile page to share with others within your network. We may also collect personal information from you in the course of telephone calls or e-mail exchanges with you.
We may provide you the opportunity to participate in surveys on our website. If you participate, we will request certain personal information from you. Participation in these surveys is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information, business information, and information about Cornerstone Relocation employees, our Clients, and our Clients' employees (such as name and performance criteria).
Why do we collect personal information?
We collect personal information, including information about our Clients’ employees and their household members, primarily for the purpose of offering our services, responding to your questions and concerns, enhancing website experience and analyzing website traffic to better understand how our website is used.
How do we use this information?
Cornerstone Relocation uses personal information to administer your account, list you in our member directory made available only to relevant Cornerstone Relocation employees and our Clients, reply to inquiries and contact users in connection with the services or options they have selected, such as specific relocation options, and subscribing to a newsletter. Periodically, we may also send out information on updates and new features to our website. If you do not wish to be contacted in connection with these services, you will be provided with an easy method specified within the communication, to opt-out of receiving these types of communications. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us and based on the privacy practices described within this Privacy Policy. The use of information collected through our service shall be limited to the purpose of providing the service for which the user has engaged Cornerstone Relocation. Cornerstone Relocation operates on behalf of its Clients; if you are an employee or customer of one of our Clients and would no longer like to be contacted by Cornerstone Relocation employees, or Clients that use our service, please contact the Client that you interact with directly.
We may combine and supplement the information we collect about you, with information from third parties and other sources, and add it to your account information. This may include publicly available demographic information, or employment or international information. This information may also include, user information to administer our services, additional contact information, and other information required to verify your identity or your business' identity. We will use this information for the purposes disclosed in this Privacy Policy.
Disclosure of personal information
Cornerstone Relocation will not share your personal information with any third parties who are not bound to act on Cornerstone Relocation's behalf. We may provide your personal information to companies, including sub-processors that provide services to help us with our business activities such as relocating employees or offering customer service. Personal information will be shared with our suppliers who provide essential parts of our overall relocation service to you, including, for example, temporary accommodation providers and local destination service specialists. Transfers to subsequent third parties are covered by the provisions in this Privacy Policy regarding notice and choice and the service agreements with our Clients. These companies are authorized to use your personal information only as necessary to provide these services to us. We will share your personal information with third parties only in the ways that are described in this Privacy Policy, or any other third party with your prior consent. It is against our policy to sell personal information collected online without consent.
Cornerstone Relocation may release your personal information if we are required to do so by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal processes, or if we believe in good faith that such an action is necessary to a) defend our rights and/or property b) protect against the unauthorized or misuse of Cornerstone Relocation’s websites or c) protect the personal safety or property of others. We may also disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Furthermore, if Cornerstone Relocation 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, uses of your personal information, and choices you may have regarding your personal information.
Notice and Choice
Your decision to provide Cornerstone Relocation with your personal information and to use our website is voluntary. Before providing you with services, we will issue you with a Notice and Consent Form and you may elect to prohibit us from using your personal information and thereby prohibit us from using or sharing any such personal information with our approved suppliers and subcontractors who assist us in providing services authorized by your employer. If you do choose to opt-out, we may be prevented from providing you (your family and/or domestic partner) with employer-approved relocation services and we shall inform your employer of your election.
Accessing your personal information
You have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Upon request Cornerstone Relocation will provide you with information about whether we hold any of your personal information. If you wish to request access, or deletion of your personal information please contact us at privacy@crgglobal.com, or you may contact your assigned Cornerstone Relocation consultant directly. You are entitled to have your personal information corrected, amended or deleted where it is inaccurate or processed in violation of Cornerstone Relocation's obligations under the Data Privacy Framework. We will respond to your request, or provide a reason for our denial within a reasonable timeframe.
Cornerstone Relocation will retain your information and the information we process on behalf of our Clients for as long as needed to provide services to our Client. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
California Consumer Privacy Act (CCPA) – No Information Selling
Cornerstone does not sell any personal information as set forth in the CCPA. We do not receive personal information as consideration for other services or other items that we provide to our Clients nor do we derive any rights or benefits regarding personal information.
As stated elsewhere in this privacy policy, our use of personal information is limited to providing contracted services as set forth with each of our Clients and we further warrant that Cornerstone will not take any action that will cause personal information transfers to qualify as a sale of personal information under the CCPA.
Information collected using Cookies and Other Tracking Technologies
Cornerstone Relocation, and our affiliates/analytics, such as LinkedIn, use technologies such as cookies, web beacons, tags, scripts or similar technologies. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the website, and gathering demographic information about our user base.
"Cookies" are a small amount of data sent to your browser by a web server. Cookies are most frequently used to 1) customize certain aspects of our site 2) allow us to monitor and measure website traffic AND 3) function as an user identifier when accessing restricted areas of this website.
(For example, you may be required to supply a user name and password when accessing an area of a website restricted to registered members only. After your user information is verified, a cookie is set that will enable you to navigate through the restricted area without having to login multiple times.)
Most browsers will allow you to control cookies settings including whether or not to accept them and how to block or remove them. Please note that if you choose not to accept cookies, you may not be able to access certain areas of this website.
You may also choose to opt-out of such tracking by clicking http://optout.aboutads.info. If you are located in the European Union and wish to opt-out from using cookies, you may do so by clicking
http://www.youronlinechoices.eu.
When you visit most websites, web servers automatically log non-identifying information such as browser type, operating system, IP (Internet Protocol) address and referral information. This information is used for internal reporting and analysis and allows us to track the usage of our website and its services. This provides us with valuable information on how to better serve our website visitors. We do not make any attempt to connect IP addresses or additional information stored within log files with an individual user.
Our website includes Social Media Features, such as the LinkedIn Follow button, or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it. Our website includes links to other websites whose privacy practices may differ from those of Cornerstone Relocation. If you submit personal information to any of those websites, their privacy statements govern your information. We encourage you to carefully read the privacy statement of any website you visit.
Security
Cornerstone Relocation takes every precaution to protect any personal information you choose to share with us, online and off-line. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy@crgglobal.com.
Changes to Privacy Policy
Any changes to this Privacy Policy will be displayed on our website for a reasonable period of time, prior to the change becoming effective. Additionally, we will notify you or our Client by email (sent to the email address specified in the account). We suggest that you check our website periodically for any changes.
Terms of Use
Please see our Terms of Use statement.
Comments/Questions
If you have any comments or questions regarding this Privacy Policy please contact us at privacy@crgglobal.com or Cornerstone Relocation Group, LLC, 106 Allen Road, Basking Ridge, NJ 07920.