Effective Date: June 18, 2020
Last Updated: November 22, 2024
This Consumer Privacy Statement explains how Automatic Data Processing Inc., all its consolidated subsidiaries, and ADP BrightJump (an ADP offering) (hereinafter “ADP”, "ADP name of service", "our", or "we"), uses and discloses Personal Data that is collected through ADP BrightJump, which includes all webpages associated with ADP BrightJump, all application programming interfaces (APIs), file transfers and csv uploads, and all applications and communication tools provided by ADP BrightJump when you interact with ADP as a consumer or website user.
ADP also has a Global Data Privacy Policy that applies to all ADP companies worldwide. An overview of our Privacy Program is located at www.adp.com/dataprivacy.
This Privacy Statement explains how ADP uses and discloses Personal Data that we collect from you when you engage with us as direct consumer of our products or services. Personal Data is any information that identifies you as an individual or relates to an identifiable individual.
This Privacy Statement explains our practices regarding Personal Data collected by ADP BrightJump for the purposes of this offering, product, or service.
Some examples of Personal Data collected or accessed with your permission, when you use ADP BrightJump include your name, address, email address, education, employment history, occupation, and any other information included on your resume when you choose to share your resume with us, social media profile (e.g. LinkedIn), or other information about how you engage with the offering.
With your permission, we will obtain Personal Data directly from you including: your name, email address, phone number, geographic location (city or area), education, employment history, skills and qualifications, any other information included on your resume when you choose to share your resume with us, and your IP address.
If you created a BrightJump account in connection with the submission of a job application on an ADP site, ADP BrightJump will also import Personal Data, including your name, email address, and resume from that system of record. We may also collect the name of the company and role that you submitted an application for.
We will also ask you for Personal Data when you interact with us, such as when you register on ADP BrightJump, set up an account, sign up to receive marketing communications, or request our services.
We need to collect Personal Data to provide the requested services to you. If you do not provide the information requested, we may not be able to provide the services. If you disclose any Personal Data relating to other people to us or to our service providers in connection with ADP BrightJump, you represent that you have the authority to do so and to permit us to use the Personal Data in accordance with this Privacy Statement.
If you interact with us through our website, we use cookies and other online tracking technologies to collect information about your device and your use of ADP BrightJump.
For more information about cookies and other online tracking technologies, please see the section “Cookies and Other Automatic Data Collection Technologies” below.
ADP BrightJump is an offering on ADP web properties that offers individuals tools to find job opportunities, prepare and submit job applications, access career coaches, and learn career skills. If you elect to make your profile visible to recruiters, you may also be contacted about relevant job opportunities. ADP BrightJump uses Personal Data to customize the products and services offered to you. ADP BrightJump also uses Personal Data to facilitate the creation of your account with the third party offering the product or service, and account management support, and customer service.
We also use your Personal Data for the following business purposes:
(a) Business Purposes for processing Personal Data pertaining to consumers. Personal Data pertaining to individuals with whom ADP has a business relationship is processed as needed, for example:
(1) To provide the information, product, or service requested by you, and as would be reasonably expected given the context in which the Personal Data was collected, and the information provided in the applicable privacy statement given to you (such as for personalization, remembering preferences, or respecting individual rights);
(2) For due diligence, including verifying the identity of you, as well as your eligibility to receive information, products, or services (such as verifying age, employment, or account status);
(3) To send transactional communications (such as requests for information, responses to requests for information, orders, confirmations, training materials, and service updates);
(4) To manage your account, such as for customer service, finance, and dispute resolution purposes;
(5) For risk management and mitigation, including for audit and insurance functions, and as needed to license and protect intellectual property and other assets;
(6) For security management, including monitoring individuals with access to the website; applications, systems, or facilities, investigation of threats, and as needed for any data security breach notification; and
(7) To anonymize or de-identify the Personal Data. Where we maintain or use de-identified information, we will continue to maintain and use such information only in a de-identified fashion and will not attempt to re-identify such information.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
(b) Business-necessary processing activities. We process Personal Data as needed (i) to protect the privacy and security of the Personal Data it maintains, such as in connection with advanced security initiatives and threat detection; (ii) for business structuring activities, including mergers, acquisitions, and divestitures; and (iii) for business activities, management reporting, and analysis.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
(c) Development and improvement of products and/or services. We process Personal Data to develop and improve its products and/or services, and for research, development, analytics, and business intelligence.
We engage in these activities based on our legitimate interest.
(d) Relationship management and marketing. We process Personal Data for relationship management, marketing, and to provide personalized services. This purpose includes sending marketing and promotional communications to you if you have not objected to receiving such messages, such as product and service marketing communications, investor communications, customer satisfaction surveys, and ADP news.
We will engage in these activities based on our legitimate interests, and with your consent to the extent required by applicable law.
(e) Operational purposes. Additionally, we use your Personal Data for purposes such as: (i) disaster recovery and business continuity; (ii) internal audits or investigations; (iii) implementation or verification of business controls; (iv) statistical, historical, or scientific research; (v) dispute resolution; (vi) legal or business counseling; (vii) compliance with laws and company policies; and/or (viii) insurance purposes.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
We disclose your Personal Data to:
The following table details the categories of Personal Data we collect and process, which categories of third parties may have access to your Personal Data for operational or business purposes, as well as which categories of Personal Data we “share” for purposes of cross-context behavioral or targeted advertising, including within the 12 months preceding the date this Privacy Statement was last updated.
Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes (see below for a more detailed description of these categories) | Processing Purposes (See section 3 How ADP uses your data for complete list) | Shared with Which Categories of Third Parties for Cross-Context Behavioral or Targeted Advertising |
---|---|---|---|
Identifiers such as name, contact information, unique personal identifiers, email address, IP address, online identifiers, government issued identifiers. | Service Providers / Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, Third Parties with Your Consent. | a (1, 2, 3, 4, 6, 7), b, d | Related Entities, Ad Networks. |
Personal information as defined in the California customer records law, such as name, contact information, financial, education, employment information. | Service Providers / Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, Third Parties with Your Consent. | a (1, 2, 3, 4, 6, 7), b, d | Related Entities, Ad Networks. |
Characteristics of protected classifications under California or federal law, such as race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, marital status, sex, gender expression, gender identify, age, sexual orientation, military or veteran status. | Not applicable. | Not applicable. | None. |
Commercial Information, such as transaction information and purchase history, including purchases considered, consuming histories or tendencies. | Service Providers / Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, Third Parties with Your Consent. | a (1, 2, 3, 4, 6, 7), b, c, d | None. |
Biometric Information, such as fingerprints, voiceprints and faceprints. | Not applicable. | Not applicable. | Not applicable. |
Internet or network activity information, such as IP address, mobile device ids, MAC address, browsing history, search history. | Not applicable. | Not applicable. | Not applicable. |
Geolocation Data, such as precise location/tracking data and coarse location/tracking data. | Not Applicable. | Not Applicable. | Not Applicable. |
Audio/Video Data, such as photographs. | Service Providers / Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, Third Parties with Your Consent. | a1, c | None. |
Education Information subject to the federal Family Educational Rights and Privacy Act such as education and training history, education degrees, qualifications/certifications. | Service Providers / Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, Third Parties with Your Consent. | a (1, 2, 3, 4, 6, 7), b, c, d | None. |
Employment Information. Professional or employment-related information, such as professional or employment related information such as work history and prior employer, background checks, performance rating or feedback, employer, occupation title/job role. | Service Providers / Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, Third Parties with Your Consent. | a (1, 2, 3, 4, 6, 7), b, c, d | None. |
Inferences such as any assumptions drawn from any of the Personal Data listed above to create a profile about, for example, an individual’s preferences or characteristics. | Service Providers / Subcontractors, Related Entities, Law enforcement/Legal authorities, Third Parties in the event of a Corporate Transaction, Third Party with Your Consent. | a (1, 2, 3, 4, 6, 7), b, c, d | None. |
Sensitive Personal Information, such as social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, union membership; mental or physical health diagnoses, condition, history or treatment, sexual orientation and sex life; Personal Data collected from a known child. | Not applicable. | Not applicable. | None. |
Opt-out of Sharing of Personal Data
To request to opt out of any future targeted advertising, including the sharing of your Personal Data for purposes of cross-context behavioral advertising, please go to www.brightjump.adp.com and click the Cookie Preferences – Do Not Share My Data link at the bottom of the page to toggle off advertising cookies.
Detailed Description of Categories of Third Parties
Third Parties to which we may disclose your Personal Data are as follows:
(a) Service Providers/Subcontractors
We may share your Personal Data with our service providers/subcontractors for certain business purposes. This information is provided in order for them to provide us with services such as payment processing, advertising services, marketing partners, web analytics, data processing, IT services, customer support and other services such as for the purpose of auditing and fraud investigations.
(b) Related Entities
We may share Personal Data between and among ADP, its subsidiaries, and affiliated companies for purposes of management and analysis, and other business purposes. For instance, we may share your Personal Data with our subsidiaries and affiliated companies to expand and promote our product and service offerings.
(c) Law Enforcement/Legal Authorities
We may be required to disclose your Personal Data to third parties including law enforcement agencies when required and to protect and defend our legal rights, protect the safety and security of users of our services, prevent fraud, respond to legal process (e.g. subpoena or court order), or a request for cooperation by a government entity, including as required by law.
(d) Corporate Transactions
In the event of sale, transfer, merger, reorganization, or similar event, we may transfer your Personal Data to one or more third parties as part of that transaction with the business entities or people involved in the deal negotiation or transfer.
(e) Third Party with Your Consent
We may share Personal Data about you with other third-party companies if you give us permission or direct us to share the data. We will share Personal Data with authorized agents that you authorize ADP to communicate to, including sharing your name and profile with ADP clients if you elect to make your profile visible to recruiters.
We do not sell and have not sold Personal Data, including your Sensitive Personal Data, in the preceding 12 months.
Sources of Personal Data
We collect this Personal Data actively (e.g. direct input from individuals) or passively (e.g., website cookies) from you. Additionally, we may also collect Personal Data from third-party sources, such as our affiliates, business partners, and service providers.
When you visit our website or use our mobile applications, we collect certain data by automated means, using online tracking technologies such as cookies, pixel tags, browser analysis tools, server logs, and web beacons.
Cookies. When you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a personalized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.
Pixel tags and web beacons. Pixel tags and web beacons are tiny graphic images placed on website pages, in our apps, or in our emails that allow us to determine whether you have performed a specific action. When you access these webpages or app functionalities, or when you open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our online offerings and promotions.
Automatically Collected Data. We collect many different types of data from cookies, pixel, tags, web beacons, and other online tracking technologies such as browser analysis tools. For example, we collect data from the device you use to access our website, such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located.
Our server logs also record the Internet Protocol (IP) address assigned to the device you use to connect to the Internet. An IP address is a unique number that devices use to identify and communicate with each other on the Internet. We may also collect data about the website you were visiting before you came to ADP and the website you visit after you leave our site.
In many cases, the data we automatically collect using cookies and other online tracking technologies is only used in a non-identifiable way, without reference to Personal Data. For example, we use data we collect about website users to optimize our websites and to understand website traffic patterns. In some cases, we do associate the data we automatically collect using cookies and other online tracking technologies with your Personal Data. This Privacy Statement applies to such automatically collected data when we associate it with your Personal Data.
Do Not Track. Although our website currently does not have a mechanism to recognize the various web browser Do Not Track signals, we do offer you choices to manage your preferences that are provided in sections 14 and 15, below. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/
Youtube Videos. Our website may include embedded YouTube videos. When you click on an embedded YouTube video that video is loaded from a domain operated by YouTube. Although we have enabled the Privacy-Enhanced mode for embedded YouTube videos, which prevents YouTube from placing tracking cookies on your device when viewing these videos on our site, YouTube may collect your IP address and other devices information for their own purposes. To learn more about YouTube’s Privacy-Enhanced mode visit the YouTube support page at https://support.google.com/youtube/answer/171780?hl=enGB&ref=axbom.com#.To learn more about YouTube’s processing of IP addresses visit YouTube’s privacy policy at https://policies.google.com/privacy?sjid=60584270626491410-NA.
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use ADP BrightJump and other websites or online services. You may receive advertisements based on information relating to your access to and use of ADP BrightJump and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.
If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Statement, please visit https://optout.aboutads.info/#/ and https://optout.networkadvertising.org/#/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.
We also process opt-out preference signals, such as the Global Privacy Control (GPC). The GPC is a mechanism that enables you to automatically communicate your privacy preferences to opt-out of sale and sharing of your personal information to this website. This ensures that your opt-out preference is honored through compatible browsers or extensions that support GPC, consistently across all websites accessed through the browser or device you are using. Go to your browser’s setting to enable GPC. If enabled you will receive notification or see a visual indication (e.g., banner or pop-up message) on our site confirming that your GPC signal has been detected and your opt-out request has been processed. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/.
ADP BrightJump uses third-party analytics providers, such as Google Analytics. This service uses cookies and similar technologies to collect and analyze information about the use of ADP BrightJump and report on activities and trends. These services may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
We use Google’s invisible reCAPTCHA application in order to protect against spam and other automated abuse. The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements, while on the page. The use of the reCAPTCHA service and the treatment of any information collected through the service are subject to Google’s applicable privacy policy, available at https://policies.google.com/privacy, and Google’s terms of service, available at https://policies.google.com/terms?hl=en.
ADP BrightJump is committed to maintaining the appropriate organizational, technical, and physical controls designed to protect Personal Data entrusted to us from anticipated threats and hazards and unauthorized access and use. ADP BrightJump will strive to provide security that is proportional to the sensitivity of the Personal Data being protected. Additional information about ADP's Global Security Organization may be found at https://www.adp.com/trust.
We retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:
(a) The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your Personal Data to address issues that may arise;
(b) Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
(c) Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
This Privacy Statement only addresses the use and disclosure of Personal Data by ADP BrightJump. This Privacy Statement does not address, and we are not responsible for, the privacy, data, or other practices of any third parties, including any third party operating a website, app, or service to which the ADP BrightJump links. This inclusion of a link does not imply our endorsement of the linked site or services. Our suppliers, business partners, and other third-party websites that may be accessible through ADP BrightJump have their own privacy statements and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by third parties prior to providing them with information.
ADP BrightJump may provide functionality allowing you to make payments using a third-party payment service with which you have created your own account. When you use such a service to make a payment to us, your Personal Data will be collected by such third party and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Statement. We have no control over, and are not responsible for, any such third party’s collection, use or disclosure of your Personal Data.
ADP BrightJump is not directed to individuals under the age of 18 and we do not knowingly collect Personal Data from individuals under 18. We do not sell or knowingly “share” (for cross-context behavioral advertising purposes) the Personal Data, including the Sensitive Personal Data, of minors under 18 years of age.
Subject to your consent where required by applicable law, we collect, use, and disclose Sensitive Personal Data for purposes of performing services for our business, providing goods or services as requested by you, ensuring safety, security and integrity, short term transient use such as displaying first party, non-personalized advertising, servicing accounts, providing customer service, verifying customer information, processing payments, providing analytic services, providing storage, activities relating to quality or product improvement, and other collection and use that is not for the purpose of inferring characteristics about an individual. We do not use Sensitive Personal Data beyond these purposes.
Unless we request it, we ask that you not send us, and you not disclose, any Sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or criminal background) on or through the ADP BrightJump or otherwise to us.
You may limit the information you provide to us. You may also limit the marketing communications that we send to you. To opt-out of marketing emails, simply click the link labeled "unsubscribe" at the bottom of any marketing email we send you. You may also change you communication preferences on the settings page.
Please note that if you are currently receiving services from us and you have decided to opt-out of marketing communications, we may still send you important administrative messages, from which you cannot opt-out.
If you have questions about your choices or if you need assistance with opting out, please contact us via email to privacy@adp.com. You may also write us at the address in the “How to Contact Us” section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.
You may contact us to request access to your data, to exercise any of the individual rights afforded to you by us or by applicable data protection laws and regulations. You may also write to us at the address in the “How to Contact Us” section below. If you send us a letter, please provide your name, address, email address, and detailed information about the changes you would like to make. We will respond to requests in accordance with applicable data protection laws.
To make an individual rights request for access, correction erasure or other rights, please contact us by completing our webform or by emailing us at brightjump@adp.com . We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Data subject to the request. We may need to request additional Personal Data from you, such as your name and email address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Data. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Data.
You may also write to us at the address in the “How to Contact Us” section below. If you send us a letter, please provide your name, address, email address, and detailed information about your request. We will respond to requests in accordance with applicable data protection laws.
Additional Individual Rights for US Consumers
US consumers may make the following specific rights requests, subject to applicable US consumer privacy law:
(a) Right to Access, Know and Portability -- You may request to know whether we process your Personal Data and request to access such Personal Data, including, where applicable, a request to obtain a copy of the Personal Data you provided to us in a portable format.
You may also request that we disclose the following information to you:
(1) The categories of Personal Data we collected and process about you and the categories of sources from which we collected such Personal Data;
(2) The specific pieces of Personal Data we collected about you;
(3) The business or commercial purpose for collecting or sharing Personal Data about you;
(4) The categories of Personal Data about you that we shared (as defined under the CCPA) and the categories of third parties with whom we shared such Personal Data; and
(5) The categories of Personal Data that we disclosed about you to third parties, and the categories of third parties to whom we disclosed such Personal Data (if applicable).
(6) A list of third parties to whom your Personal Data was disclosed.
(b) Right to Request Correction of your Personal Data -- You may request to correct inaccuracies in your Personal Data;
(c) Right to Request Deletion of your Personal Data -- You may request to have your Personal Data deleted; and
(d) Right to Opt-out of Targeted Advertising/“Sharing” for Cross-Context Behavioral Advertising --You may request to opt-out of targeted advertising, including the “sharing” of your Personal Data for purposes of cross-context behavioral.
To request to opt-out of any future targeted advertising, including the “sharing” of your Personal Data for purposes of cross-context behavioral or targeted advertising, please go to ADP.com and click the Cookie Preferences – Do Not Share My Data link at the bottom of the page to toggle off advertising cookies.
We also process opt-out preference signals, such as the Global Privacy Control (GPC). The GPC is a mechanism that enables you to automatically communicate your privacy preferences to opt-out of sale To request to opt-out of any future targeted advertising, including the “sharing” of your Personal Data for purposes of cross-context behavioral or targeted advertising, please go to ADP.com and click the Cookie Preferences – Do Not Share My Data link at the bottom of the page to toggle off advertising cookies. and sharing of their personal information to this website. This ensures that your opt-out preference is honored through compatible browsers or extensions that support GPC, consistently across all websites accessed through the browser or device you are using. Go to your browser’s setting to enable GPC. If enabled you will receive notification or see a visual indication (e.g., banner or pop-up message) on our site confirming that your GPC signal has been detected and your opt-out request has been processed. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/.
We will not unlawfully discriminate against you for exercising your rights under applicable US consumer privacy law.
Authorized Agents Submitting a Request on Behalf of a Consumer
You may choose to designate an authorized agent to make a request on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Agents may be asked to provide proof of their status as an authorized agent. Once a request has been submitted by an authorized agent, we may require additional information from you to verify your identity or confirm that you provided the agent permission to submit the request. Authorized agents may submit their request as detailed above.
Appeal Process
If you are a Colorado, Virginia, Montana, Oregon, Texas, or Connecticut consumer, and we refuse to take action on your request, you may appeal our refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us via email at brightjump@adp.com
Nevada Privacy Rights
ADP collects personal information from you in the course of providing requested services. Unless otherwise stated, ADP does not sell any Covered Information, as defined under Nevada law (S.B. 220). If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please contact privacy@adp.com
Please contact us if you have questions regarding this Privacy Statement. You may reach us via email at brightjump@adp.com or via mail at address below. If you send us a letter, please provide your name, address, email address, and detailed information about your question.
ADP Global Data Privacy and Governance Team
MS 325
One ADP Boulevard
Roseland, NJ 07068-1728 USA
If you believe that we have not handled your Personal Data properly or that it has breached its privacy obligations, under any applicable data protection laws, you may file your complaint in writing to the address above in the“How to Contact Us” section, or via email, to the Global Data Privacy and Governance Team at privacy@adp.com
The Global Data Privacy and Governance Team will investigate each complaint and notify you within a reasonable timeframe of the outcome of the investigation. If you are not satisfied by the resolution, you may file a complaint or claim with the relevant regulatory authorities or the courts.
From time to time, we may update this Privacy Statement, and we encourage you to review it regularly. If we make changes, we will notify you by revising the date at the top of the statement with a new “Last Updated” date. Any changes will become effective when we post the revised Privacy Statement on our sites or within our application. For a printable copy of this Privacy Statement, please go to https://brightjump.adp.com/public/terms-of-privacy.pdf