PRO Unlimited, Inc.'s Online Privacy Notice
(Updated May 12, 2020)
PRO Unlimited, Inc. (“PRO”) is 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).
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.
We provide security safeguards to protect user personal data. Multiple security layers, including firewalls, sensor and host-based intrusion detection, protect all personal data. Personal data is scrambled using encryption technology before it is sent over the internet. Although we cannot guarantee encryption or the privacy of user personal data, the encryption technology makes it very difficult for personal data to be stolen or intercepted while being transferred.
For California Residents
This Privacy Notice provides information to California residents whose personal information is processed pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). It describes the categories of personal information PRO Unlimited collects and the purposes for which that information is collected. It also summarizes the rights California residents have and how they may exercise these rights. California residents may have the right to request access to the personal information we have collected about them, and deletion of the personal information we have collected from them. These rights are described in more detail below in the section entitled “User Rights Concerning Personal Data.” If you only have a business or employment relationship with us (e.g., you are an employee or contingent worker), these rights below may only be available to you after January 1, 2021, or as required by law. For purposes of this Notice, the term “personal data” has the same meaning as the term “personal information” is defined in the CCPA.
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 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, United Kingdom, and Switzerland, respectively, to the United States. PRO has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. The principles we follow can be summarized as follows:
1. Notice: PRO will inform European Union, United Kingdom, and Swiss users of our data handling practices, which are set forth in this Notice. This includes, for example, the type of data collected, the purpose of processing it, and the conditions for onward transfers to third parties.
2. Choice: PRO will give users the opportunity to opt out of having their data disclosed to third parties (other than agents assisting PRO with the processing of the data), or having their data used in a manner that exceeds the original disclosures.
3. Accountability for Onward Transfer: Transfers of data by PRO to other data controllers or processors can only occur: (i) for limited and specified purposes described below; (ii) on the basis of a contract; and (iii) only if that contract provides the same level of protection as the Privacy Shield Principles. In the context of an onward transfer PRO is responsible for the processing of personal data it receives under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on behalf of PRO. PRO complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. PRO shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless PRO proves that it is not responsible for the event giving rise to the damage.
4. 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 sub-processor provides the same level of protection as provided by the Privacy Shield Principles.
5. Data Integrity and Purpose Limitation: PRO will take reasonable steps to ensure the personal data is reliable for its intended use, and is 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.
6. Access: Data subjects have the right to obtain confirmation of whether PRO is processing their data, and get a copy of the data. Users are also able to correct or delete personal data where it is inaccurate or has been processed in violation of the Privacy Shield 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.
7. 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 data protection authorities (“DPAs”) with regard to unresolved EU- US Privacy Shield complaints. If a user 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 EU and UK DPAs are provided at no cost to users.
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 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.
1150 Iron Point Road, Ste. 100
Folsom, CA 95630
Our EU representative for GDPR compliance purposes may be contacted at:
PRO Unlimited Global Netherlands BV
Kranenburgweg 135-A, 2583 ER
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
Categories of Information Collected and Processed
PRO uses many sources of information to help us meet our needs and the needs of our customers and users. PRO may collect personal information about users including:
• User name 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; and
• Information about users when they apply for a job with us through the career opportunities feature on our websites (for example, user name and contact details, and information about their working history that is contained in their résumé).
PRO is headquartered in the United States, and any data collected from users is processed in the United States. User personal data is collected and transferred only:
• 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.
• To perform a contract with the user, or to implement pre-contractual measures taken at the user’s request. For example, users who provide their personal data through our career opportunities features will be considered for available jobs, and may be contacted with offers of an employment relationship.
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 RightSourcing Inc.);
• To government agencies or individuals appointed by a government responsible for the investigation and resolution of disputes or complaints; or
• As otherwise required or authorized by law.
PRO does not:
• Use the data collected in any form of automated decision-making.
• Collect or process “special categories of personal data” as that term is used in the EU General Data Protection Regulations (GDPR), Article 9, e.g., we do not collect or process data revealing the user’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning user sex life or sexual orientation.
• Collect or process personal data of persons who are less than 16 years old.
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.
PRO sites use the following cookies:
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).
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.
Data Storage and Retention
PRO stores user personal data, as described herein, on its servers, which are located in the United States. PRO retains user information only for as long as is necessary to fulfill the stated purposes for which it is collected, or as required by applicable laws or regulations.
• Personal data that is provided by users who are seeking information about PRO’s services will be retained for the duration of the complete potential sales cycle with your organization, not to exceed five years.
• Personal data that is provided by users through the career opportunities feature will be retained for up to two years.
User Rights Concerning Personal Data
Users have a right to access the personal data PRO holds about them. To obtain a copy of the personal data we hold, at no cost to them, users should write or email us at the address shown below. If access cannot be provided within a reasonable time, we will provide users with an estimate of the amount of time that will be needed to provide access. If for some reason access is denied, we will inform users of the reason for that denial.
Users may also request information about the purposes of PRO’s processing of their personal data, the categories of personal data concerned, whether any party outside PRO might have received the data from PRO, the source of the data if the user did not provide it themselves, and how long it will be stored. If users discover that any of their personal data is inaccurate, they have a right to have that data corrected.
Users may request that PRO erase their personal data or cease processing it, subject to certain exceptions. In many countries, users have a right to bring a complaint to the appropriate data protection authority if they have concerns about how PRO processes their data.
When technically feasible, at a user’s request PRO will provide their personal data to them or transmit it directly to another controller or processor. For any questions or requests related to user personal data, please contact us at the address shown below.
Updates and Changes to this Privacy Notice
By using the PRO websites, users agree to the terms and conditions of this Privacy Notice. If users do not agree to any of these terms and conditions, they should not use the PRO websites. If we change our privacy policies, we will update this document so that users are always aware of what information we collect, how it is used, and under what circumstances it may be disclosed. PRO reserves the right to modify, alter, or update this Notice at any time and without advance 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 firstname.lastname@example.org.
In the event you have any questions or complaints, access requests or other concerns or issues arising from your use of our websites or our privacy policies, please contact our Data Protection Officer:
PRO Unlimited, Inc.
1150 Iron Point Road, Ste. 100
Folsom, CA 95630