1. What Information We Collect and How We Collect It.
The type of information we collect depends on how you use the Site and how you interact with us. “Personal Information” means any data which can be associated with you as an individual, either directly or indirectly, and is collected on either a voluntary or involuntary basis.
The Personal Information we collect via the Site may include:
- Identity information, such as your name, organization name and position, postal address, e-mail address, telephone number, biographical data, social media links, and/or any other identifier by which you may be contacted online or offline.
- Technical data, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and/or platform, and other technology information relating to the devices you use to access the Site.
- Usage data, which includes information about your use of the Site, and any communications we may receive from you.
- Commercial Information, Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Marketing and communications data, including your preferences in terms of receiving marketing and other communications from us.
- Internet or other similar Platform activity, Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Inferences drawn from other personal information, Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The Site is not intended to store or transmit “special categories” or “protected classifications” of Personal Information, such as details about your race, color, ancestry, national origin, citizenship, religion, creed, medical condition, physical or mental disability, sex life, sexual orientation, gender identity, gender expression, political opinions, veteran or military status, genetic information, marital status, criminal convictions and offenses.
2. How We Collect Personal Information
We collect information from you in three different ways.
a) Personal Information you provide to us.
If you provide information on our Contact Us page through the Site, you will provide us with your identity, contact information, IP address and any other information contained within any attachments you submit (e.g. CV’s, resumes and cover letters, sale inquiries, etc.). This data is collected through direct solicitation and your voluntary submissions. You will also provide us with Personal Information when you correspond with us. We will track basic analytics (for example, open rates and click throughs) and may embed tracking codes in our regular daily email correspondence.
b) Personal Information we collect automatically as you navigate the Site.
In addition, as you use the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including your browser type, the Internet Protocol (IP) address used to connect your computer to the internet, and your usage habits, patterns and preferences. We collect this data using cookies, beacons and similar technologies. We use Google Analytics to help us analyze user habits while visiting our Site. The data gathered from cookies may be transmitted to Google servers in the United States. We employ IP address anonymization to ensure that there is no direct reporting of individual user IPs as part of this process. The information will be used by Google only for the purpose of evaluating website use, creating website activity reports, and other services relating to website activity and internet usage on behalf of PCS. The IP address that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google.
We may use any of the following, or other, cookies individually or in combination:
|Cookie name||What it is used for|
|Google Analytics||website analytics and visitor tracking|
|Wordfence||website security and access control|
|YouTube||user viewing preferences|
|Hubspot||website analytics and visitor tracking|
You can remove cookies from your computer through the browser settings. Please note however that doing so may affect, limit or degrade your ability to use of some features on the Site and other websites. Management of cookie settings varies from one browser to another, and the “Help” menu of your web browser should provide instructions how to manage cookies. For your convenience, the links below are to instructions provided by major web browsers relating to such management in those specific browsers:
- Chrome (http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647 or https://support.google.com/chrome/search?q=hot+to+delete+cookies&from_promoted_search=true)
- Internet Explorer (https://support.microsoft.com/en-gb/kb/278835)
- Firefox (http://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored)
- Opera (https://help.opera.com/en/latest/security-and-privacy/)
- Safari (http://support.apple.com/kb/PH5042)
- Safari for iPad and iPhone (http://support.apple.com/kb/HT1677)
c) Information You Provide to Third Parties.
If you use the Site’s interactive features to access a third-party site that is linked to the Site, the other user(s) or third-party site may provide us, directly or indirectly with your Personal Information. For example, another user may post your email address and name, or a third-party website may report a purchase you made from that site.
3. How and Why We Use Personal Information
a) You have given us permission to do so.
If you subscribe to our mailing list, we will send you updates and marketing information that you have consented to receive. Similarly, if you contact us with a question or comment, we may need your contact, identity, technical and/or usage information to respond.
b) To Respond to You.
When you contact us, we may collect information that identifies you (such as your name, address and a phone number) along with additional information we need to help us respond to the reason you contacted us and/or to answer your question or respond to your comment. We retain this information to assist you in the future and to improve our customer service, products, Services, and promotions.
c) To Contact You.
We may contact you with offers and information about our Products and Services and our affiliates, including to inform you about our promotions and special offers that may be tailored to your interests. You may opt out of receiving commercial messages (excluding transactional messages) from us by following the instructions contained in our electronic messages or by contacting us as set out below.
e) To Better Understand Our Customers and to Improve Our Services.
In the course of providing our Products and Services, we may collect information on our users’ demographics, interests and behavior and analyze that data. We do this to better understand and serve our users, and to improve our Products and Services.
f) We have a legitimate interest (reasonable business purpose) for doing so.
- We will use your identity, contact and usage information to keep our records up to date.
- We will use your technical information to:
- Make the Site available, to improve it, to conduct system maintenance, support, troubleshooting, reporting and to host data;
- Ensure that the Site is secure;
- Analyze how users interact with the Site; and
- Address technical issues you may experience with the Site.
We may also use any or all of the information above to administer and manage our business in general, which include engaging in “Know Your Customer” and anti-money laundering checks as required by law, regulation, or best business practices. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should, therefore, stop processing your data, please let us know at firstname.lastname@example.org.
g) We need to comply with legal or regulatory obligations.
In certain circumstances, we may need to retain or use your data to comply with laws or regulations.
4. How We Share Personal Information
- Service Providers. We may share your information with our trusted third-party service providers (including information technology providers such as website and mailing list hosts). We may provide your information to companies that help us with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us. When we share your information with our service providers, we will take commercially reasonable steps to help ensure that your data is kept secure and used only in accordance with this notice.
- Other Parties in Connection with a Corporate Transaction. We reserve the right to transfer any information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third-party, such as in the event of a merger, acquisition, or in connection with a bankruptcy reorganization.
- Affiliates. We may share information within our subsidiary companies and affiliates so that we may provide offers from those companies that may be relevant to you, better understand your preferences, and improve our Products and Services.
- Aggregated Data. We also may provide aggregated information, and data with personal identifiers removed, to third parties to describe how our customers are using PCS’ Products and Services.
- Sale of Personal Data. We do not “sell”, as defined in applicable state laws/regulations (e.g. the Nevada Privacy Act (SB 220)), personal information to any third parties for monetary or other financial considerations and have not done so within the previous twelve-month period from the effective date listed on this policy.
5. Privacy and Access Choices Available to You
- Choices with Respect to Cookies and Similar Technologies. You may block cookies and similar technologies in your browser or device settings, as and if permitted by such device.
- Choices with Respect to Interest – Based Advertising. You may opt out of receiving targeted advertising from participating ad networks, audience segment providers, ad serving vendors, and other service providers by visiting websites operated by the Network Advertising Initiative, Digital Advertising Alliance and Digital Advertising Alliance of Canada.
- Data Access. Subject to applicable law, you may also have a right to access, update, and correct inaccuracies in other personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in the personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
- Email Promotions. You may opt out of receiving commercial email, text message, and other electronic messages from us (excluding transactional messages) by following the instructions contained in those messages.
6. Other Important Information
- Children Under the Age of 13. Our Site is not intended for children under 13 years of age. No one under age 13 may use or direct any information to the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Site, use any of its features, subscribe to our mailing list, use any of the interactive links or post anything on the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verified parental consent, we will delete that information. If you believe we may have any information from or about a child under 13, in connection with the access or use of this Site, please contact us at email@example.com.
- Third-Party Links. This Site may contain links to other websites whose information practices may be different than ours. Please consult all third-party Sites’ privacy notices. We have no control and disclaim any and all responsibility and liability in connection with information that is submitted to, or collected by, third parties.
- Your California Privacy Rights. California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes.
- International transfers. This Site is hosted on servers located in the United States. We will endeavor to meet those data protection laws and regulations (including the General Data Protection Regulation, or “GDPR,” when and as applicable) to which we may be subject.
- General Data Protection Regulation. General Data Protection Regulation (“GDPR”) was passed by the European Parliament and establishes a standard for data privacy for all member states of the European Economic Area (“EEA”) (“EU”). Its purpose is to give EEA residents (described as “data subjects” by the GDPR) certain rights over their Personal Information, including, the:
- Right of access: Individuals can ask for a copy of the Personal Information retained about them and an explanation of how it is being used.
- Right to rectification: Individuals have the right to correct, revise or remove any of the Personal Information retained about them at any time.
- Right to be forgotten: Individuals can ask to delete their Personal Information. At your request, we will remove your contact information from the system, and we will not contact you again.
- Right to restrict processing: If an individual believes, for example, that their Personal Information is inaccurate or collected unlawfully, the individual may request limited use of their Personal Information.
- Right of portability: Individuals have the right to receive their Personal Information in a structured, commonly used and machine-readable format.
- Right to object: Where an individual decides that they no longer wish to allow their Personal Information to be included in analytics or to receive direct marketing emails or other personalized (targeted) marketing content at any time, the individual may opt out of use of their data for these purposes.
If you are a data subject falling under the scope of the GDPR, you can exercise the above rights. Please note that these rights are not absolute, and limitations/exceptions may apply in some cases.
In respect of transfers outside of the Company, we either implement the Model Clauses pursuant to Commission decision 2004/915/EC or 2010/87/EU (as appropriate) with the recipient of your Personal Information; and/or ensure that the recipient of your data is registered with the EU-US Privacy Shield.
You can obtain further information in this respect (including a copy of the Model Clauses) by contacting us.
- Data Security. The safety of your Personal Information is important to us, and we use various technical and organizational measures to secure it. However, the transmission of information via the Internet is not completely secure, and unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Although we take commercially reasonable measures to safeguard against unauthorized disclosures of information, we cannot guarantee the security of your data. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security, and any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. You acknowledge and agree that you are solely responsible for maintaining the security and confidentiality of your account username and password.
- How Long We Keep Personal Information. We will retain your Personal Information only for as long as it necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of that Personal Information, the purposes for which we processed the data and whether we those purposes may be achieved by another means, and the applicable legal requirements.
- Accessing or Correcting Your Information. You can review and change your personal information by sending an email to us at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
CALIFORNIA RESIDENTS: CALIFORNIA CONSUMER PRIVACY ACT NOTICE
Notice to California Residents/Your California Privacy Rights
California residents are entitled once a year to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year (e.g., responses to requests made in 2018 will contain information about 2017 sharing activities).
We do not share personally identifiable information about you to third party direct marketers.
California residents may request further information about our compliance with this law by sending a request to the address set forth in the Contact Us section. You must include “California Privacy Rights” in the subject line, and your full name, email address, and postal address in your request. Please note that under California law, businesses are only required to respond to a verifiable customer request once during any calendar year, and we are not required to respond to requests made by means other than through this physical mailing address.
California Consumer Privacy Act of 2018
This Privacy Notice for California Residents supplements the information contained in the Notice to California Residents/Your California Privacy Rights and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
The PCS Platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information“), but does not include in particular:
- Publicly available information from government records;
- Deidentified or aggregated consumer information;
- Information excluded from the CCPA’s scope, like: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and the California Financial Information Privacy Act (FIPA); and Driver’s Privacy Protection Act of 1994.
The Site has collected the following categories of personal information from its consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, and email address.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, physical characteristics or description, address, telephone number, and payment card information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar Platform activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Personal information does not include:
- Publicly available information from government records;
- Deidentified or aggregated consumer information;
- Digital images or photographs not used for identification;
- Information excluded from the CCPA’s scope, for example: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
PCS obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete, products you purchase, or information you choose to post or share.
- Indirectly from you. For example, from observing your actions on the PCS Platform.
Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our Products or Services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a Product or Service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns;
- To provide, support, personalize, and develop our Platform, Products, and Services;
- To create, maintain, customize, and secure your account with us;
- To process your requests;
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
- To personalize your PCS Platform experience and to deliver content and Product and Service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law);
- To help maintain the safety, security, and integrity of our Platform, Products and Services, databases and other technology assets, and business;
- For testing, research, analysis, and product development, including to develop and improve our Platform, Products, and Services;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PCS’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by PCS about PCS users is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third-party for a business purpose, but we do not sell your personal information to third parties. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
Service providers, including customer service, payment processing, marketing and analytical services; and
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category F: Internet or other similar Platform activity.
Category K: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
Service providers, including customer service, payment processing, marketing and analytical services; and
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold the following categories of personal information:
- California Customer Records personal information categories.
- Protected classification characteristics under California or federal law.
- Commercial information.
- Biometric information.
- Internet or other similar Platform activity.
- Geolocation data.
- Sensory data.
- Professional or employment-related information.
- Non-public education information.
- Inferences drawn from other personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that PCS disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights) we will disclose to you:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting or selling that personal information;
- The categories of third parties with whom we share that personal information;
- The specific pieces of personal information we collected about you (also called a data portability request); and
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that PCS delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights) we will delete and direct our service providers to delete your personal information from our records, unless an exception applies.
Even if verifiable, we may nonetheless deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
You may exercise the access, data portability, and deletion rights described above by submitting a verifiable consumer request to us using one of the following options:
Calling us at +1 (973) 805-7400
Sending an email to email@example.com
To exercise the right to access your personal information stored by PCS, you may submit for any of the following below by emailing firstname.lastname@example.org:
ACCESS TO MY PERSONAL INFORMATION
To exercise the right to obtain a copy of your personal information stored by PCS, you may submit a request to us by visiting:
EXERCISE PERSONAL INFORMATION PORTABILITY
To exercise the right to delete your personal information stored by PCS, you may submit a request to us by visiting:
DELETE MY PERSONAL INFORMATION
Personal Information Sales Opt-Out and Opt-In Rights
We do not sell your information to third parties. If you are 16 years of age or older, you have the right to direct us to not sell your personal information in the event our practices change in the future (the “right to opt-out”). For consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age, we will not sell your information in the event our practices change in the future.
In order to exercise the right to opt-out of personal information sales by PCS, you (or someone legally authorized) may submit a request to us by visiting:
DO NOT SELL MY PERSONAL INFORMATION
As noted above we do not sell your information to third parties. We will retain your opt-out request in the event our practices change in the future. Should your email address change, please submit a new request with your new email address. We reserve the right to take reasonable steps to verify your identity and the authenticity of the request.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Verification Requirement for Requests
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access, data portability, or deletion twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We will acknowledge receipt of your request within 10 days and will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will notify and inform you of the reason and extension period in writing.
If we receive a verifiable request to opt-out or Do Not Sell My Personal Information from you, we will act upon that request within 15 days from the date we receive that request.
If you have an account with us, we will deliver our written response to that account electronically. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance (e.g., an excel spreadsheet that has been converted into a changed-locked pdf).
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. PCS does not disclose personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write us at:
11 Vreeland Rd
Florham Park, NJ 07932
Attn: Privacy Officer
Changes to Our Privacy Notice
PCS reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the PCS Platform and update the notice’s effective date. Your continued use of our Platform following the posting of changes signifies and constitutes your acceptance of such changes.
Notice to Nevada Residents/Your Nevada Privacy Rights
Under Nevada SB 220, Nevada residents have the right to opt out of the sale of their Covered Information (as such term is defined under Nevada law). As noted above, we will not sell your information. However, if you are a Nevada resident, you may submit a request to opt out of future sales by us by writing to us at firstname.lastname@example.org. We will maintain your request in the event our practices change in the future. Should your email address change, please submit a new request to email@example.com with your new email address. We reserve the right to take reasonable steps to verify your identity and the authenticity of the request.
GENERAL DATA PROTECTION REGULATION (“GDPR”)
For those persons located in the United Kingdom and within the European Union and/or for data subject to the GDPR or UK data protection laws the following policy applies:
How do we use your data?
- Where you purchase products from or exchange products with us we will collect your name, company name and licence details if you are a business customer, IP address, email address, telephone number, payment details, proof of identity such as a copy of your driving licence or passport and any other information which we are required to obtain by applicable local law in order to perform our contractual obligations and provide you with our service.
- When you contact us either by phone, email or via social media we will usually collect your name, gender, contact details, social media handle and any other personal data that forms part of your message to us because it’s in our legitimate interest to make sure we can properly respond to your query.
- If our business is purchased. We process your personal information for this purpose because we have a legitimate interest to ensure the platform can be continued by the acquirer. If you object to our use of your personal information in this way, the acquirer may not be able to provide services to you.
Who do we share your data with?
- Entities within the PCS Group. PCS operates around the world and is made up of different group companies all working together to provide our services to customers and consumers. The PCS Group entities have determined that they are Joint Controllers in relation to the personal data collected (see How do we use your data?). This is because the PCS Group entities jointly determine the purposes and means of processing of the personal data. The PCS Group entities have therefore entered into an agreement which defines the principles and procedures they will adhere to and the responsibilities they owe to each other. The goal of this agreement is to ensure that personal data is protected and that you are able to effectively exercise your rights under data protection law (see What are my rights under data protection laws?).
- Partners, suppliers, and subcontractors for the performance of the contract we enter into with them or you.
- Purchasers of our business under our legitimate interest to ensure our business can be continued by the buyer.
Where is my data stored?
Where we store your data will vary depending on the location of the group company you are interacting with.
How long do we keep your data for?
We will only retain your personal information for as long as we need it unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.
In some circumstances we may carefully anonymise your personal data and how our site is used, so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to analyse our business and improve it moving forward.
What are my rights under data protection laws?
You have various other rights under applicable data protection laws, including the right to:
- Access your personal data (also known as a “subject access request”);
- Correct incomplete or inaccurate data we hold about you;
- Ask us to erase the personal data we hold about you;
- Ask us to restrict our handling of your personal data;
- Ask us to transfer your personal data to a third party;
- Object to how we are using your personal data; and
- Withdraw your consent to us handling your personal data.
You also have the right to lodge a complaint with us or the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales. If you are based outside of England and Wales, you can find your relevant supervisory authority here.
Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.
QUESTIONS, COMMENTS AND MORE DETAIL
Your feedback and suggestions on this notice are welcome – please reach out to us by email at firstname.lastname@example.org