(Updated February 8, 2021)
PRO Unlimited, Inc. ("PRO") is committed to protecting the privacy of the users of the Wand Vendor Management System ("Wand VMS" or "Wand") and that of the individuals whose personal data is collected, processed or stored on or through the Wand VMS, (collectively "users" or "data subjects.). We want to provide a safe and secure user experience. We endeavor to ensure that the personal data submitted to us remains private, and used only for the purposes as set forth herein. The following sets forth the Privacy Notice ("Privacy Notice" or "Notice") for PRO's Wand VMS.
PRO adheres to the following:
We collect, retain and use personal data for legitimate business purposes only. We limit the information 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 personal data.
Our employees are required to protect personal data on our system. We have internal policies and programs designed to protect personal data.
We limit the internal and external disclosure of personal data.
We do not share personal data with any third parties, except as set forth below.
We provide security safeguards to protect personal data. Multiple security layers, including firewalls, sensor and host-based intrusion detection, protect all data in the Wand system. Data is scrambled using encryption technology before being sent over the internet. Although we cannot guarantee encryption or the privacy of personal data, the encryption technology makes it very difficult for personal data to be stolen or intercepted while being transferred.
RatePoint Business Intelligence is our on-demand rate and hiring intelligence platform. Users of RatePoint are not required to provide any personal data to PRO in order to use the platform. For a description of the cookies used for RatePoint, please see the information listed in the “Cookies” section below
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, 2022, 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.
With respect to the personal data of individuals in the European Union, 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, the United Kingdom, and/or 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:
Notice: PRO will inform European Union, United Kingdom and Swiss data subjects 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.
Choice: PRO will give data subjects 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.
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.
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.
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.
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 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.
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.
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.
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 for use in the context of the employment relationship, PRO is committed to cooperating with and complying with the advice of the Commissioner.
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.
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: [email protected]
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 found here: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
PRO uses many sources of information to help us meet our needs and the needs of our customers and users.
Personal Data: PRO collects personal data including:
For workers directly employed by PRO: PRO maintains certain personal data about our employees as part of our general employee records. This includes contingent workers who are directly employed by PRO and assigned to work at our clients ("PRO Employees"). PRO's records include a PRO Employee's name, address and contact details, marital status, educational background, employment application, history with the company, areas of expertise, details of compensation and benefits, bank details, performance appraisals and salary reviews, records relating to holiday and other leave, working time records and other management records (collectively, "Employee Data"). Most of this Employee Data is collected, stored, and processed in the Wand VMS.
For workers employed or supplied by third parties: PRO maintains personal data about contingent workers employed or supplied by third parties such as temporary employment agencies and other labor providers. This may include the contingent worker's name, contact information such as a telephone number and email, details of the worker's assignment such as location, department, and title, and the worker's pay rate. Most of this personal data is collected, stored, and processed in the Wand VMS.
For customers and PRO staff employees: Limited personal data is kept on the Wand VMS for users such as client managers and PRO staff employees. This may include the user's name, contact information (such as telephone number and email), title and location.
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 perform a contract with them or their employer, or if it is necessary for the legitimate interests pursued by PRO except where such interests are overridden by the interests or fundamental rights and freedoms of the user that require protection of the of the 's 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 RightSourcing, Inc.). PRO uses Employee Data for a variety of personnel administration and employee, work and general management purposes. For example, PRO needs this information to administer payroll and employee benefits, to maintain general human resource management records (including sickness and other absence records), conduct performance and compensation reviews, determine suitability and fitness to render services to our customers, operate the company's IT and communications systems, comply with our recordkeeping obligations, and give references;
To third parties who provide PRO with legal and accounting advice, or who provide or administer our insurance, retirement funds, and employee benefits;
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 the customer(s) for whom the contingent worker provides services;
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.
Anonymized Data and Aggregated Statistical Information.PRO may use anonymized data and aggregated statistical information to enhance its services and in connection with other services PRO may offer to its customers. PRO also may use the aggregated and statistical data derived from the operation of Wand, including, without limitation, the number of records in the system, the number and types of transactions, configurations, and reports processed in the system and the performance results for the system for purposes of providing or improving service, benchmarking service performance, preparing statistics and system metrics, and marketing, or to provide other services that PRO may offer to its customers; provided however, that PRO’s use of anonymized data and/or aggregated statistical information will not reveal personal data to any third party.
General: 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 Wand work properly, we sometimes place small data files called cookies on your device. Most big websites do this too.
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.
Wand uses the following cookies:
Google Analytics
Google Analytics uses cookies to measure user-interactions on Wand. Google Analytics is a simple,
easy-to-use tool that helps PRO Unlimited measure how users interact with content.
As a user navigates between 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 Wand.
Other Cookies
We also use cookies for session tracking. When a user logs into Wand, a session for the user starts.
Cookies are used for the purpose of letting Wand know that the user is already authenticated. A session expires when the user logs out or is inactive for 30 minutes.
The cookies used for this purpose are:
Jessionid
Birt.sessionid
Access_token
Refresh_token
Expires_in
Device_id
Xsrf_token
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 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 of workers who are directly employed by PRO, or directly employed or supplied by third parties such as temporary employment agencies, will be retained for so long as required by the laws of the jurisdiction in which the worker provides services. Generally these laws require the personal data be retained by PRO for a period of time following the termination of the worker's services, often up to seven years. In addition, some personal data may be required to be retained by PRO under the terms of PRO's contract with the client for whom the worker provided services. The specific retention period for particular worker's personal data may be obtained by contacting us at the address set forth below.
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.
By using the Wand VMS, 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 Wand VMS. 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 [email protected].
In the event you have any questions or complaints, access requests or other concerns or issues arising from your use of Wand or our privacy policies, please contact our Data Protection Officer:
PRO Unlimited, Inc.
Email: [email protected]
1150 Iron Point Road, Ste. 100
Folsom, CA 95630
United States