PRO Unlimited, Inc.'s Online Privacy Notice

(Updated May 27, 2021)

PRO Unlimited, Inc. and RightSourcing, Inc. (collectively, “PRO”) are committed to protecting the privacy of our users. We want to provide a safe and secure user experience. We endeavor to ensure that the information you submit to us remains private and use it only for the purposes as set forth herein. The following sets forth the Online Privacy Notice (“Privacy Notice” or “Notice”) for PRO’s websites (prounlimited.com, prounlimited.co.uk, and rightsourcingusa.com).

Privacy Policy

PRO adheres to the following:

• We collect, retain and use user personal data for legitimate business purposes only. We limit the personal data we collect to that which we believe is appropriate and necessary to manage user needs, provide our services and comply with applicable laws.
• We strive to maintain the accuracy of user personal data.
• Our employees are required to protect personal data. We have internal policies and programs designed to protect personal data.
• We limit the internal and external disclosure of personal data.

Categories of Information Collected and Processed

PRO may collect personal information about visitors to our websites, including usernames and other contact details shared with us when users call, write to, or contact us using our websites, requesting information about PRO or RightSourcing’s contingent workforce management services

The Reasons We Process Your Personal Data

User personal data is collected and transferred to provide users with information about the types of services that PRO performs for its customers. For example, upon request we may provide users information about PRO and its service offerings so that users can consider whether it might be interested in using our services.

How We Share Personal Data

For the purposes described in this Notice, PRO may disclose the personal data of users:
• To any of our related PRO companies (including PRO Unlimited, Inc. and its subsidiaries, and RightSourcing Inc.);
• To government agencies or individuals appointed by a government responsible for the investigation and resolution of disputes or complaints; or
• To third party contractors who perform services on our behalf, such as reviewing and developing our business systems, procedures and infrastructure (including testing or upgrading our computer systems);
• To comply with our legal obligations, regulations or contracts, or to respond to a court order, administrative or judicial process, such as subpoena, government audit or search warrant;
• In connection with the sale, assignment or other transition of all or part of our business such as to a potential purchaser and its legal/professional advisors); or
• Otherwise in accordance with your consent.

PRO does not:

• Use the data collected in any form of automated decision-making.
• Sell your personal data to any third parties.
• Collect or process personal data of persons who are less than 16 years old.

Security of Your Personal Data

PRO is committed to keeping your personal information secure. To help protect your personal data from unauthorized access, use, or disclosure, we employ a range of security technologies and procedures. For example, we store your personal information on computer servers with restricted access that are housed in secure facilities, and we encrypt some highly confidential or sensitive personal information when we send it.

Where We Store and Process Data

PRO and its clients work on a global scale, so personal data may be transmitted to countries other than those where it was obtained. Since we are based in the United States, we regularly move information gathered in other countries to the United States for processing. We will ensure that the transfer of your personal data to another country complies with all relevant laws and regulations.

Cookies
To make this site work properly, we sometimes place small data files called cookies on your device. Most big websites do this too.

What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

How do we use cookies?

PRO sites use the following cookies:

Google Analytics
Google Analytics uses cookies to measure user-interactions on our website. Google Analytics is a simple, easy-to-use tool that helps PRO Unlimited measure how users interact with website content. As a user navigates between web pages, Google Analytics provides us with JavaScript tags (libraries) to record information about the page a user has seen, for example the URL of the page. The Google Analytics JavaScript libraries use HTTP Cookies to "remember" what a user has done on previous pages / interactions with the website.

Marketo
Marketo uses a cookie value set (_mkto_trk) by its Munchkin JavaScript library in order to identify individual users on the domain of our site. The cookie, which sets to a user's browser, lasts up to two years, and is automatically renewed each time the user visits a page.

HubSpot
HubSpot uses cookie tracking to give us context of our site’s visitors. The cookie (__hstc) is for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).

6sense
6sense is an analytics-based solution that receives personal information about users online activity and commercial information. This can include sales data, web data/site activity data and lead information.

How to control cookies

You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. PRO does not track its users when they cross to third party websites, and does not use targeted advertising, and therefore does not respond to Do Not Track signals.

PRO sites 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 may differ substantially from this Privacy Notice, so we advise users to read them before using those websites. PRO will not be liable for any use of those websites. For Residents of the European Union, United Kingdom, European Economic Area and Switzerland With respect to the personal data of individuals in the European Union, United Kingdom, European Economic Area and Switzerland, please see Appendix A below.

For Residents of California

With respect to the personal data of California residents, please see Appendix B below.

Our Retention of Personal Data

Personal data will be stored according to the applicable laws or regulatory requirements and kept as long as is necessary to fulfill the purposes for which it was collected. Generally, this means that your personal data will be retained as documented in our corporate data retention schedule, contracts, and applicable supplemental documents.

Updates and Changes to this Privacy Notice

We will update this document if our privacy policies change so that you are aware of what information we gather, how it is used, and under what conditions it may be revealed. PRO reserves the right to alter, amend, or adjust this Notice at any time and without notice. This Notice is effective as of the date that appears at the top of this document. In the event of any questions about our privacy policies or related matters, please contact us at privacy@prounlimited.com.

Appendix A: For Residents of the European Union, United Kingdom, European Economic Area and Switzerland With respect to the personal data of individuals in the European Union, United Kingdom, European Economic Area and Switzerland, PRO has contracts with Model Contractual Clauses in place with clients, staffing suppliers and others that serve as the mechanism for the lawful transfer of personal data from those regions to other countries such as the United States. PRO also complies with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and/or Switzerland, respectively, to the United States. (However, PRO does not rely on the EU-U.S. Privacy Shield Framework as a legal basis for transfers of personal data in light of the judgment of the EU Court of Justice in Case C-311/18.) PRO has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

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 Programs.
a. EU- US Privacy Shield: PRO has further committed to cooperating with EU and UK data protection authorities (“DPAs”) with regard to unresolved EU- US Privacy Shield complaints concerning personal data transferred from the EU as described below. If a data subject does not receive timely acknowledgment from us of their complaint, or if we have not addressed the complaint to their satisfaction, they should contact the EU or UK DPAs (as applicable) for more information or to file a complaint. The services of the EU and UK DPAs are provided at no cost to data subjects.
b. Swiss- US Privacy Shield: PRO is also committed to cooperating with the Swiss Federal Data Protection and Information Commissioner. When covering non-HR data received from Switzerland, PRO is committed to cooperating with and complying with the advice of the Commissioner.
c. PRO is committed to cooperating with the EU and UK DPAs and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and complying with the advice given by such authorities with regard to human resources data transferred from the EU, UK and/or Switzerland in the context of the employment relationship.
d. In compliance with Privacy Shield Principles, PRO commits to resolve complaints about our collection or use of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact PRO at:

PRO Unlimited, Inc.
Email: privacy@prounlimited.com
1150 Iron Point Road, Ste. 100
Folsom, CA 95630
United States

Our EU representative for GDPR compliance purposes may be contacted at:
PRO Unlimited Global Netherlands BV
Kranenburgweg 135-A, 2583 ER
The Hague
Netherlands

If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, you can at any time lodge a complaint with the data protection authority of the EEA country where you live or with the data protection authority of the country or state where the PRO controller that collected your personal data has its registered seat. A list of the national data protection authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

Under certain conditions, you may invoke binding arbitration for complaints regarding Privacy Shield compliance that are not resolved by following the above complaint procedures. More information on binding arbitration can be found here: https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Your Data Subject Rights

EU and UK candidates, contingent workers, and employees (including individuals working in the EU and UK, or in some circumstances individuals who normally reside in the EU or UK who are working abroad) may have certain rights under applicable data protection laws, including the EU General Data Protection Regulation and local legal implementation of that Regulation. This includes the rights to:

● Make a request for access to and a copy of your personal information.;
● Request the rectification (or correction) of any incorrect personal data;
● Request the erasure (or deletion) of personal data that is no longer needed to serve the purposes for which it was obtained, or that PRO or its client does not need to keep for other legitimate purposes.
● Restrict or object to your personal data being processed.; and
● Request that your personal data be ported (transferred) to another organization.

These rights can be applied differently depending on the type of data involved and PRO's specific legal justification for processing personal data.

Please contact privacy@prounlimited.com if you want to exercise one of the above privileges. Any requests will be considered and responded to in compliance with relevant data privacy laws. Please be aware that we may ask you for detailed details in order to verify your identity and right of access, as well as to search for and provide you with the personal data we have about you. We may charge you a fair fee to access your personal data in limited circumstances; however, we will notify you of any fees in advance.

You have the right to revoke your consent at any time if we are depending on your consent to process your personal data. Please notice, however, that the lawfulness of the processing prior to the revocation of your consent will not be affected. EU and UK applicants, contingent workers, and employees (including those working in the EU and UK, as well as those who usually reside in the EU or UK but are working abroad) can also contact the Data Protection Officer at the following address with questions about how we handle personal data:

PRO Unlimited, Inc.
1150 Iron Point Road, Ste. 100
Folsom, CA 95630
United States
Email: privacy@prounlimited.com

Appendix B: For California Residents

The main body of this Privacy Notice provides information to California residents whose personal information is processed pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). (For purposes of this Privacy Notice, the term “personal data” has the same meaning as the term “personal information” is defined in the CCPA.) This Privacy Notice:
● Describes the categories of personal information PRO Unlimited collects from you (see “Categories of Information Collected and Processed”; and
● Describes the purposes for which that information is collected (see “Why We Process Personal Data” and “How and Why We Share Personal Data” above).
If you have questions about your personal information or our CCPA compliance program, please contact us:

PRO Unlimited, Inc.
Email: privacy@prounlimited.com
1150 Iron Point Road, Ste. 100
Folsom, CA 95630
United States