PRO respects the privacy of our users and is committed to the responsible use of our users’ information. Accordingly, we adhere to the following:
- We collect, retain and use user information for legitimate business purposes only. We limit the information we collect to that which we believe is appropriate and necessary to manage your needs, provide our services and comply with applicable laws.
- We strive to maintain the accuracy of user information.
- Our employees are responsible for protection of user information. We have internal policies and programs designed to protect your information.
- We limit the internal and external disclosure of user information. Other than set forth herein, PRO does not sell, trade, or rent user information.
- We may share our users’ non-personal, aggregated statistical information (e.g., website traffic patterns and website usage), but we do not share personally identifiable information (“PII”) with any entity that is not covered by this policy.
We provide security safeguards to protect user information. Multiple security layers including firewalls, sensor and host based intrusion detection protect all user data. All user data that is taken off site is encrypted using the Advanced Encryption Standard (AES). User information is scrambled using encryption technology before being sent over the internet. Although we cannot guarantee encryption or the privacy of your PII, the encryption technology makes it very difficult for PII to be stolen or intercepted while being transferred.
PRO Unlimited’s Commitments under the EU – US Privacy Shield
PRO follows the Privacy Shield Principles set forth at www.privacyshield.gov, which are summarized as follows:
- Notice: PRO will inform European Union data subjects of our data handling practices, which are set forth in this Policy. This includes, for example, the type of data collected, the purpose of processing it, and the conditions for onward transfers to third parties.
- Choice: PRO will give data subjects the opportunity to opt out of having their data disclosed to third parties (other than agents assisting the company with the processing 2 of the data), or having their data used in a manner that exceeds the original disclosures. With “sensitive data” (e.g., data concerning health, political opinions, sexual orientation, and the like), express affirmative consent must be given by the data subject.
- Accountability for Onward Transfer: Transfers of data by PRO to other data controllers or processors can only occur: (i) for limited and specified purposes consistent with the consent provided by the data subject; (ii) on the basis of a contract; and (iii) only if that contract provides the same level of protection as the Privacy Principles.
- Security: PRO will take reasonable and appropriate security measures to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration and destruction. If PRO uses a sub-processor, we will ensure that our contract with the subprocessor provides the same level of protection as provided by the Privacy Principles.
- Data Integrity and Purpose Limitation: PRO will take steps to ensure the personal data is reliable for its intended use, accurate, complete and current. The data used should be limited to that which is relevant to the purpose of the processing, and not processed in a manner that is incompatible with the purpose for which it was originally collected or subsequently authorized by the data subject.
- Access: Data subjects have the right to obtain confirmation of whether PRO is processing their data, and get a copy of the data. Data subjects are also be able to correct or delete personal data where it is inaccurate or has been processed in violation of the Privacy Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the data subject will be violated.
- Recourse, Enforcement and Liability: PRO is subject to the jurisdiction of the United States Federal Trade Commission, which has the right to enforce PRO’s compliance with the Privacy Shield Program. In addition, PRO has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
We may use many sources of information to help us meet the needs of our customers and users. We may collect personal information about you including:
- Information about your transactions with us, our affiliates or nonaffiliated third party users of the Wand™ vendor management system applications (“Wand applications”);
- Information we receive about you from applications and other forms, which we have collected by your use of PRO sites, or products or services obtained from us, one of our affiliates or nonaffiliated third party users of the Wand applications;
- Information about you as required or permitted by law;
- Your name and other contact details when you call us, write to us, contact us using our website, or establish and use a user account for a Wand application;
- Information about you when you apply for a job or contract with us (for example, your name and contact details, information about your working history and relevant records checks);
- Information we receive from our customers and other third party users of our application. For example, the Wand applications are used by companies to manage their workforces. We collect information relating to individual workers from our customers and staffing agencies that use the Wand applications. Companies may ask their staffing agencies to use the application so these entities can exchange information relating to candidates between one another. PRO collects this PII by virtue of hosting the application. The information PRO collects may include sensitive information, such as data your employer has deemed relevant to employment-related or record-keeping purposes, where you provide that information to us or to the entities using the Wand applications.
- Information about you if you are an individual who is, or who was employed by, one of our staffing agency suppliers, contractors, related companies, agents and/or customers. For example, PRO may collect the personal information of the employees or contractors of the entities using the Wand applications.
Disclosing Personally Identifiable Information
For the purposes described in this policy, we may disclose personally identifiable information (PII):
- To any of our related PRO companies;
- To our customers, suppliers, contractors and service providers, professional advisers, dealers and agents;
- To government agencies or individuals appointed by a government responsible for the investigation and resolution of disputes or complaints;
- To anyone to whom our assets or business (or any part of it) is transferred or offered to be transferred;
- Where you have otherwise consented; or
- As otherwise required or authorized by law.
Given that the Internet is a global environment, using the Internet to collect and process personal information necessarily involves the transmission of data on an international basis. Therefore, by communicating electronically with us, you acknowledge our processing of personal information in this manner. However, we will endeavor to protect all personal information collected through the PRO sites (including the Wand applications) in accordance with applicable data protection standards and laws.
Cookies and IP Address Tracking
A cookie is a small piece of data sent from a website and stored in a user’s web browser while
the user is browsing that website. Every time the user loads the website, the browser sends the
cookie back to the server to notify the website of the user’s previous activity.
take advantage of cookies, you may have your browser not accept them, although this may
disable or render unusable some of the features of the PRO sites.
PRO sites may also detect and use your IP address or domain name for internal traffic
monitoring and capacity purposes, or to otherwise administer the application. No personal
information is obtained; rather the patterns of usage of visitors to the website may be tracked for
the purposes of providing improved service and content based on aggregate or statistical review
of user site traffic patterns.
PRO sites may contain links to other websites. PRO is not responsible for the privacy practices
or the content of such other websites. The privacy policies applicable to such other websites
those websites. PRO will not be liable for any use of those websites.
Retargeted advertising (or behavioral retargeting) uses information collected from a user’s previous online actions, such as pages visited or searches made. This information is used to provide more relevant information to the user from the PRO and Wand-related sites. This information is also used to display relevant PRO employment opportunities if you have “opted in” to this service. The information collected is linked to an anonymous cookie ID (alphanumeric number); it does not include any information that could be linked back to an individual, such as name, address or credit card number.
PRO retains your information for only as long as is necessary to fulfill the stated purposes for which it is collected, or as required or permitted by applicable laws or regulations.
US – Swiss Safe Harbor
PRO is a participant in the Safe Harbor program developed by the United States Department of Commerce and the Federal Data Protection and Information Commission of Switzerland. For personal data associated with individuals or firms located in Switzerland, PRO has agreed to fulfill the requirements of the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from and Switzerland. For more information about the Safe Harbor program and to view PRO’s certification, please visit the Department of Commerce’s Safe Harbor website at http://www.export.gov/safeharbor.
Accessing and Updating Your Personal Information
You have a right to access the personal information we hold about you. To obtain a copy of the personal information we hold, please write or email us at the address shown below. (Please note that we may be entitled to charge a small fee for providing you with copies of personal information we may hold about you; you will be advised in advance of the existence and amount of any such charges at the time of your request.)
To opt to not have your personal information shared as set forth herein, please contact us at the address shown below; provided, however that to the extent you are a registered user of one of PRO’s sites, your personal information is a requirement and removal of your personal information will result in termination of your user account (i.e., termination of your ability to use the PRO site and/or Wand applications).
In the event you have any questions or complaints, access requests and other issues arising under our Privacy Shield Program, under the US-Swiss Safe Harbor framework, or under our privacy policies, please contact our Chief Privacy Officer:
PRO Unlimited, Inc.
1150 Iron Point Road, Ste. 100
Folsom, CA 95630