Website Privacy Notice

Last Updated: November 9, 2026

Introduction

ADS Processing LLC doing business as “Empeon” (“Empeon,” “we,” “us,” or “our”) understands that when you engage with our website at https://empeon.com/ (the “Site”), you are entrusting us with personal information, and we are committed to transparency about how we collect, use, and share that information. This Privacy Notice describes how we collect, use, disclose, retain, and otherwise process personal information through the Site and in connection with our sales, marketing, and event activities, and explains the privacy rights you may have under applicable U.S. federal and state privacy laws.

This Privacy Notice does not cover the Empeon Platform or the separate Empeon App. Our processing of personal information through those products, including facial recognition data used for timekeeping, is described in the separate Empeon Platform and App Privacy Notice at https://empeon.com/platform-privacy.

About Empeon and the Empeon Platform

Empeon is a provider of an enterprise software-as-a-service (SaaS) application for human capital management (the “Empeon Platform”). Our customers are employers (“Employer(s)”) that use the Empeon Platform to manage their workforce. The Empeon Platform offers solutions for the following:

Human Resources Management
Employee Record Keeping
Talent Acquisition and Candidate Screening
Time and Labor Management (facial recognition timekeeping is available through the separate Empeon App)
Scheduling
Payroll Administration
Tax Management
Benefits Administration
HR Compliance
Reporting and Business Intelligence

For more details about our products, please visit our Solutions page.

Our Role: Controller and Processor

Under applicable data privacy laws, a “Controller” (also called a “business” under California law) determines the purposes and means of processing personal information. A “Processor” (also called a “service provider” or “contractor” under certain state laws) processes personal information on behalf of a Controller.

2.1 Employer Platform Data. Employers control the data they and their authorized employees and independent contractors (“Users”) input into and transmit through the Empeon Platform and the App, and Employers are the Controllers of their Users’ personal information (“Employer Platform Data”). Empeon acts as a Processor for Employers with respect to Employer Platform Data, and our processing is governed by our agreements with Employers. This Privacy Notice does not govern Employer Platform Data. That processing, including facial recognition data used for timekeeping, is described in the separate Empeon Platform and App Privacy Notice.

2.2 Regulated Data. This Privacy Notice does not govern information that is subject to sector-specific privacy laws, to the extent those laws apply. Any such information we process is governed by our agreements with our customers and applicable laws and regulations.

2.3 Employees and Job Applicants of Employers. If you are an employee or job applicant of an Employer using the Empeon Platform, please direct privacy inquiries and requests to that Employer. Employees access the Empeon Platform through the ESS Hub at https://hub.empeon.com/signin, and may clock in and out through the App if their Employer has enrolled them. Employers access the Empeon Platform through Workforce at https://app.empeon.com/signin. Access is available only to individuals whose Employer has invited or enrolled them.

Scope of This Privacy Notice

Empeon is the Controller of personal information collected through the Site and through our sales, marketing, and event activities. This Privacy Notice applies when:

You visit or interact with the Site;
You interact with Empeon as a representative of a business that has, or is considering, a relationship with us;
You register for or attend our marketing or training events;
You provide feedback about our products or services;
You receive sales or marketing communications from us; and
You visit an Empeon Platform sign-in page, before you log in (limited system usage information only).

This Privacy Notice applies to individuals regardless of whether they interact with us in a personal or business capacity, to the extent required by applicable law. Again, this Notice does not apply to the Empeon Platform or the App after login or enrollment, which are covered by applicable terms of use, customer agreements, and the Empeon Platform and App Privacy Notice.

Information We Collect

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable individual or household. It does not include de-identified or aggregated information or publicly available information as defined by applicable law.

4.1 Categories of Personal Information. We have collected the following categories of personal information:

Category	Examples	Sources	Disclosed for a Business Purpose To
Identifiers	Name, business email address, phone number, postal address, IP address, cookie identifiers, device identifiers	You; automatically from your device; data providers (such as business contact and company information databases); event organizers and co-sponsors; referral partners	Service providers; Employers (if you are their representative); professional advisors; government authorities where required
Personal information categories listed in Cal. Civ. Code § 1798.80(e)	Name, address, telephone number, employer	You; data providers (such as business contact and company information databases); event organizers and co-sponsors; referral partners	Service providers; professional advisors
Commercial information	Products or services you inquired about or requested, event registrations, feedback	You; event organizers and co-sponsors (event registrations)	Service providers
Internet or other electronic network activity information	Browser type, pages viewed, links clicked, referring URLs, time on page, interactions with our ads and emails	Automatically from your device; analytics and advertising partners	Service providers; analytics providers
Geolocation data (approximate only)	Country, state, or city-level location derived from IP address. We do not collect precise geolocation through the Site.	Automatically from your device	Service providers; analytics providers
Professional or employment-related information	Job title, company name, business role, business contact information	You; data providers (such as business contact and company information databases); event organizers and co-sponsors; referral partners	Service providers; Employers (if you are their representative)
Audio, electronic, or visual information, as applicable	Recordings of sales calls, webinars, or training events, with notice and, where required by law, consent	You	Service providers; the public, if we publish webinar or training recordings on third-party video platforms
Inferences	Product interests and preferences derived from your interactions with us	Derived by us from the categories above	Service providers
Sensitive personal information	We do not intentionally collect sensitive personal information through the Site.	N/A	N/A

4.2 Information You Provide. We collect personal information you provide when you submit a form, request a demo or resources, register for an event, contact us, or provide feedback. We use that information for the purposes described in this Privacy Notice.

4.3 Information Collected Automatically. When you visit the Site, we and our partners automatically collect information about your device and usage, including device identifiers, browser type and version, IP address, device type, approximate geographic location (country or city-level, based on your IP address), and performance and technical information. Much of this information is collected using cookies and similar technologies, as described below. This information may be personal information under applicable law, and we may combine it with personal information you provide.

4.4 Empeon Platform Sign-In Pages. Before you log in to the Empeon Platform, we may automatically log certain system usage information, such as IP address, operating system type and version, date and time stamps, and which Empeon Platform solutions you are using. We use this information for security, fraud prevention, and system administration. We do not use this information to identify you except (a) where your Employer instructs us to do so and provides information about your user account, or (b) as reasonably necessary to detect, prevent, or investigate security incidents, fraud, or illegal activity, or to comply with law. After login, your information is Employer Platform Data governed by customer agreements, the Empeon Platform and App Privacy Notice, and applicable laws. Login credentials you enter are processed on behalf of your Employer to authenticate you to the Empeon Platform and are not used for any other purpose.

4.5 Information from Third Parties. We may receive business contact and professional information about you from data providers (such as business contact and company information databases), event organizers, co-sponsors, and referral partners, as shown in the table in Section 4.1. We use this information for our sales and marketing purposes and treat it in accordance with this Privacy Notice.

Cookies and Tracking Technologies

We and our third-party partners use cookies, pixels, tags, and similar technologies on the Site. These technologies collect identifiers and internet activity information, which may constitute personal information under applicable law.

The technologies described in this Section apply only to the Site. We do not use advertising cookies, pixels, or similar technologies on Empeon Platform sign-in pages.

You can manage cookie preferences at any time through the link in the footer of the Site homepage, which uses a consent management tool provided by a third party service provider. You can also set your browser to refuse or remove cookies; if you do, some portions of the Site may not function as intended. Browser-level cookie controls may not opt you out of all tracking technologies.

Google Analytics. We use Google Analytics to evaluate your use of the Site, analyze performance metrics, and compile reports on activity. You can learn how Google uses data at https://policies.google.com/technologies/partner-sites and opt out of Google Analytics using the browser add-on available at https://tools.google.com/dlpage/gaoptout.

How We Use Your Information

We use the personal information we collect for the following business and commercial purposes:

To present the Site and its contents to you, and to analyze Site use for trends and statistics;
To route Employers and Users to the Empeon Platform sign-in pages;
To deliver requested resources, demos, events, or services;
To provide marketing materials and communications about our products and services;
To deliver targeted advertising, subject to your opt-out rights described in this Notice;
To detect, prevent, and respond to security incidents and fraudulent or illegal activity, and to debug and repair errors;
To provide you with notices about Empeon and notify you about changes to the Site or our services;
To comply with applicable laws and regulations, including court orders, and to establish, exercise, or defend legal claims;
To respond to lawful requests from law enforcement and other public authorities;
To protect the rights, property, or safety of Empeon, our business partners, you, or others, in accordance with applicable law; and
For any other purpose we describe to you when we collect your personal information.

We collect, use, retain, and disclose personal information only as reasonably necessary and proportionate to achieve these purposes. We will not collect additional categories of personal information or use personal information for purposes that are materially different, unrelated, or incompatible with those described above without providing you notice and, where required by law, obtaining your consent.

Disclosure of Your Information

We disclose personal information to the following categories of recipients:

Service Providers and Processors: vendors that perform services on our behalf, such as hosting, security, customer relationship management, email delivery, event management, video conferencing and call recording (such as Zoom), and analytics. We require these vendors, by written contract, to process personal information only as necessary to provide services to us, to protect its security and confidentiality, and to comply with applicable privacy laws.
Advertising and Analytics Partners: advertising networks, social media platforms, and analytics providers that collect information through cookies and similar technologies on the Site.
Employers and Customers: if you interact with us as a representative of an Employer, we may disclose information to that Employer for account administration, security, contractual, and legal purposes.
Event Co-Sponsors: if you register for an event we co-host, we may disclose your registration information to co-sponsors, as disclosed at the time of registration.
Professional Advisors: lawyers, auditors, accountants, and insurers, as needed for their services to us.
Government Authorities and Legal Process: law enforcement agencies, courts, regulators, and other public authorities where we believe disclosure is necessary to (i) comply with a legal obligation; (ii) protect the rights, safety, and property of Empeon, you, or others; or (iii) respond to lawful requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
Corporate Transactions: a buyer, successor, or other party in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business or assets, subject to applicable law.
With Your Consent: other parties when you direct or consent to the disclosure.

Sale, Sharing, Targeted Advertising, and Opt-Out Preference Signals

We do not sell personal information for monetary consideration. We do, however, allow certain advertising and analytics partners to collect identifiers, internet or other electronic network activity information, and approximate geolocation data through cookies and similar technologies on the Site to deliver targeted advertising. Under California law, this activity may constitute “sharing” personal information for cross-context behavioral advertising. Under the laws of other states, it may constitute “targeted advertising” and, in some states, a “sale.”

We may share the following categories of personal information to advertising networks, social media platforms, and analytics providers for the purpose of delivering and measuring targeted advertising: identifiers; internet or other electronic network activity information; and approximate geolocation data.

We do not sell or share sensitive personal information, including biometric information. We do not have actual knowledge that we sell or share the personal information of consumers under 18 years of age.

How to Opt Out. You may opt out of the sale or sharing of your personal information and of targeted advertising by using the “Your Privacy Choices” link in the footer of the Site, by enabling the Global Privacy Control signal as described below, or by contacting us using the information in the Contact Information section.

You do not need to create an account to opt out. You may use an authorized agent to submit an opt-out request on your behalf.

Opt-Out Preference Signals (Global Privacy Control). We recognize the Global Privacy Control (“GPC”) signal and other legally recognized opt-out preference signals. When we detect a GPC signal from your browser, we treat it as a valid request to opt out of the sale and sharing of personal information and of targeted advertising for that browser and device and, if we can associate the browser with you (for example, through a known email address or customer record), for your associated profile. We display on the Site whether we have processed your opt-out preference signal. To learn how to enable GPC, visit https://globalprivacycontrol.org.

Do Not Track. Some browsers transmit “Do Not Track” (“DNT”) signals. Because there is no common industry standard for interpreting DNT signals, we do not respond to DNT signals other than as legally recognized opt-out preference signals such as GPC.

Sensitive Personal Information

We do not intentionally collect sensitive personal information through the Site, and we do not use or disclose sensitive personal information for purposes that would give rise to a right to limit its use under California law. We do not sell or share sensitive personal information or process it for targeted advertising. Please do not submit sensitive personal information (such as Social Security numbers, financial account information, health information, or biometric information) through Site forms.

Your Privacy Rights

Depending on your state of residence, and subject to certain exceptions, you may have the following rights regarding personal information we process as a Controller under this Privacy Notice:

Right to Know and Access: to confirm whether we process your personal information and to access it, including the categories collected, sources, business or commercial purposes, categories of recipients, and the specific pieces of personal information we hold.
Right to Correct: to correct inaccurate personal information.
Right to Delete: to request deletion of personal information we have collected from or about you.
Right to Data Portability: to receive a copy of your personal information in a portable and, to the extent technically feasible, readily usable format.
Right to Opt Out of Sale, Sharing, and Targeted Advertising: see Sale, Sharing, Targeted Advertising, and Opt-Out Preference Signals.
Right to Opt Out of Profiling: to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not engage in such profiling using personal information collected through the Site.
Right to Limit Use of Sensitive Personal Information: we do not use sensitive personal information in a manner that triggers this right.
Right to Non-Discrimination: we will not discriminate or retaliate against you for exercising your privacy rights.
Right to Appeal: to appeal our decision on your request, as described below.

California residents have these rights whether they interact with us as consumers or business representatives.

Job applicants. If you apply for a job at Empeon, our Applicant Privacy Notice at empeonjobs.com/empeon/privacy describes how we collect and use your personal information and how to exercise your privacy rights.

How to Submit a Request. You may submit a request by: (a) emailing [email protected]; or (b) calling us toll-free at 800.930.9080.

Verification. To protect your information, we will verify your identity before fulfilling requests to know, access, correct, delete, or port, by matching information you provide (such as your name, email address, and details of your interactions with us) with information in our records. We may request additional information if needed. We will not require verification for opt-out requests, except as needed to prevent fraud.

Authorized Agents. You may designate an authorized agent to submit a request on your behalf. We may require the agent to provide proof of your signed permission and may require you to verify your identity directly with us, except where you have provided the agent with a power of attorney under applicable law.

Response Timing. We will confirm receipt of requests to know, access, correct, or delete within 10 business days and respond within 45 days. If we need more time, we may extend the response period by up to an additional 45 days, as permitted by law, and will notify you of the extension and the reason.

Appeals. If we deny your request in whole or in part, we will explain the reasons and how to appeal. To appeal, email [email protected] with the subject line “Privacy Request Appeal.” We will respond in writing within the time required by applicable law (generally 45 to 60 days) and explain our decision. If we deny your appeal, you may contact the Attorney General of your state of residence.

Employer Platform Data. If you are a User, you can access or update certain personal information in the Empeon Platform or contact your Employer to make a privacy request.

Additional Disclosures for California Residents

In the preceding 12 months, Empeon has collected the categories of personal information listed in the table in Section 4.1, which also identifies the sources of each category and the categories of recipients to whom we disclosed it for a business purpose. We describe the business and commercial purposes for collecting and using personal information in How We Use Your Information, and the categories of recipients in Disclosure of Your Information. We describe the categories of personal information we sold or shared, and the categories of third parties to whom we sold or shared them, in Sale, Sharing, Targeted Advertising, and Opt-Out Preference Signals. We describe how long we intend to retain each category of personal information, or the criteria we use to determine that period, in Section 12.2.

Notice of Financial Incentive. We do not offer financial incentives, price differences, or service differences in exchange for the collection, retention, sale, or sharing of personal information.

Data Security, Data Retention, and Transfer of Information

12.1 Data Security. We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information.

No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. If we become aware of a security incident affecting your personal information, we will notify you and applicable regulators as required by law. You are responsible for protecting the confidentiality of your Empeon Platform login credentials.

12.2 Data Retention. We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to comply with legal, accounting, or reporting obligations. The length of time we intend to retain each category of personal information, or the criteria we use to determine that period, is described below.

Category	Retention Period
Identifiers, personal information categories listed in Cal. Civ. Code § 1798.80(e), and professional or employment-related information:
Prospective customer or other business contact	For as long as you remain an active prospect or business contact, based on your last interaction with us (such as a form submission, email engagement, event attendance, or sales communication), or until you ask us to delete it
Representative of a current customer	For the duration of the customer relationship, plus as long as needed for legal, tax, audit, and dispute purposes
Cookie and device identifiers	For the duration set for each cookie, as listed in our consent management tool on the Site home page, or until you delete the cookie
Commercial information	For as long as you remain an active prospect or business contact, based on your last interaction with us, or, if you represent a customer, for the duration of the customer relationship, plus as long as needed for legal, tax, audit, and dispute purposes.
Internet or other electronic network activity information and approximate geolocation data	For the retention period set in our analytics and advertising tools, and no longer than needed to analyze Site use and measure advertising
Audio, electronic, or visual information	Recordings of sales calls are retained for as long as needed for the sales opportunity they relate to and for sales training and quality review. Recordings of webinars and training events are retained for as long as we make the content available, including on third-party video platforms where we publish it.
Inferences	For as long as we retain the underlying personal information from which they were derived.
Marketing opt-out and suppression records	For as long as needed to honor your request not to receive marketing communications.
Records of privacy requests and our responses	At least 24 months after the request.

We may retain information longer where required by law or to preserve evidence for legal claims (for example, under a legal hold). When we no longer have a legitimate business need to process personal information, we will delete or de-identify it. If deletion or de-identification is not technically feasible (for example, because the information is stored in backup archives), we will securely store the information and isolate it from further processing until deletion is possible. Retention of Employer Platform Data is described in the Empeon Platform and App Privacy Notice. Retention of facial templates used in the App is described in the Empeon Biometric Data Retention and Destruction Policy at www.empeon.com/biometric-retention-destruction-policy.

12.3 Transfer of Information. The Site is hosted in the United States, and personal information is stored and processed primarily in the United States. Our personnel and some of our service providers may access or process personal information from outside the United States. When we transfer personal information to service providers, we require them by written contract to protect it in accordance with applicable law and to process it only on our instructions.

Marketing Communications

You may unsubscribe from our promotional or commercial emails at any time by clicking the unsubscribe link at the bottom of any email. We will process your request within 10 business days. Even after you opt out of marketing emails, we may still send you transactional or relationship messages, such as communications about your account or our ongoing business relationship.

Links to Third-Party Websites, Children’s Privacy, Changes, Accessibility, and Contact Information

14. Links to Third-Party Websites. The Site may include links to websites, mobile applications, or services that are not owned or operated by Empeon (“Third-Party Sites”), whose privacy practices may differ from those described in this Privacy Notice. Links are not an endorsement of those Third-Party Sites or their products or services. Your visit to and information you submit to Third-Party Sites are governed by their privacy policies, which we encourage you to read. Empeon is not responsible for the privacy practices of Third-Party Sites.

15. Children’s Privacy. The Site is intended for business audiences and is not directed to children. We do not knowingly collect personal information through the Site from children under 13 years of age, and we do not knowingly sell or share, or process for targeted advertising, the personal information of individuals under 18 years of age. If we learn that we have collected personal information through the Site from a child under 13, we will promptly delete it. If you believe we have collected such information, please contact us at [email protected].

16. Changes to This Privacy Notice. We may update this Privacy Notice from time to time, consistent with applicable law, and will update the “Last Updated” date when we do.

17. Accessibility. This Privacy Notice is available in alternative formats upon request. Please contact us using the information below.

18. Contact Information. If you have questions or comments about this Privacy Notice or our privacy practices, or wish to exercise your privacy rights, please contact us:

Method	Details
Email	[email protected]
Toll-Free Telephone	800.930.9080
Mail	ADS Processing LLC d/b/a Empeon, Attn: Privacy, 400 Rella Blvd #214, Montebello, NY 10901