Last Updated: 4/27/2020
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by contacting us (contact information provided below).
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you in connection with the purposes stated in Section 1 as follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
We use different methods to collect data from and about you including through:
Technical Data from the following parties:
(a) analytics providers, such as Google based outside the EU;
(b) search information providers, such as Dun & Bradstreet, based outside the EU;
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following ways for you to control your personal data that you have shared with us:
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt-out of receiving these marketing messages, this will not apply to personal data collected by us as a result of any of the other methods specified in Section 3.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (contact information provided below). If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products/services). In this case, we may have to cancel a product/ service you have with us but we will notify you if this is the case at the time.
We may share your personal data with the parties set out below for the purposes set out above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection as is afforded to it by ensuring at least one of the following safeguards is implemented:
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us (contact information provided below) if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
IF YOU ARE LOCATED IN THE EUROPEAN ECONOMIC AREA (EEA), UNITED KINGDOM OR SWITZERLAND.
THIS SECTION ONLY APPLIES TO USERS OF OUR PRODUCTS/SERVICES THAT ARE LOCATED IN THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM OR SWITZERLAND AT THE TIME OF DATA COLLECTION. WE MAY ASK YOU TO IDENTIFY WHICH COUNTRY YOU ARE LOCATED IN WHEN YOU USE SOME OF OUR PRODUCTS/SERVICES, OR WE MAY RELY ON YOUR IP ADDRESS TO IDENTIFY YOUR COUNTRY LOCATION.
Procurant processes Personal Data as a “processor,” “joint controller,” and as a “controller” under the European Union’s GDPR. A “controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions. With respect to your personal data that you enter or that is received through our Site, Procurant is the controller. Please do not hesitate to contact us if you have questions (contact information provided below);
If you are in the EEA, United Kingdom or Switzerland, you have the following rights (where applicable):
Access. You have the right to request a copy of the information we are processing about you;
Rectification. You have the right to have incomplete or inaccurate information that we process about you rectified;
Deletion. You have the right to request that we delete information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims;
Restriction. You have the right to restrict our processing of your information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it;
Portability. You have the right to obtain information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you;
Objection. Where the legal basis for processing your information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests, or if we need to continue to process the data for the establishment, exercise, or defense of a legal claim;
Withdrawing Consent. If you have consented to our processing of your information, you have the right to withdraw your consent at any time, free of charge. This includes where you wish to opt out from marketing messages.
You can make a request to exercise any of these rights in relation to your information by contacting us via the methods listed below within the Contact Information section. For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information. Please note that we may take up to 30 days to fulfill such request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. A list of local data protection authorities in European countries is available at https://edpb.europa.eu/about-edpb/board/members_en.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products/services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2019 will receive information regarding 2018 sharing activities).
To obtain this information please send an email message to firstname.lastname@example.org with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested applicable information to you at your e-mail address in response subject to any need to verify whether these rights apply to you.
Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
California Consumer Privacy Act Rights. Under the California Consumer Privacy Act (“CCPA”) California residents have certain rights regarding their personally identifiable information. If you would like to exercise these rights on or after January 1, 2020, please contact us using the email address, toll free phone number, or physical mailing address listed within the “Contact Information” section below. If sending an email, please send an email message to email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information. It may take us some time to respond to your request, but we will do so within the requirements of the CCPA.
This Policy discloses to you the personal information we collect from you and the purposes for doing so. Please see “How We Use Your Personal Data” above. The CCPA grants you specific rights, including the following:
Procurant can be reached by telephone at: 669-221-1026; by email at: firstname.lastname@example.org or by mail at Procurant USA LLC, 475 Alberto Way, Suite 220, Los Gatos, CA USA, Attention: Privacy Compliance.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month, unless a shorter time period is specified by the law, including the CCPA. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.