Introduction

ProCom Consulting, including its affiliates comprising part of the ProCom Consulting group of companies including Vindicia, Vubiquity, Stellar Elements, Openet, Astadia, Profinit, the Sourced Group (“ProCom Consulting”, “we” or “us”), is committed to protecting your privacy and processing your Personal Data (as defined below) responsibly.

This Privacy Policy describes how ProCom Consulting collects, uses, and shares to Personal Data related to its website users, job applicants, visitors of ProCom Consulting facilities, business contacts and business counterparties, as well as other individuals whose data we will collect (“user(s)” or “you”). It also tells you the choices you can make about how the information you provide to us is used.

For the avoidance of doubt, this Privacy Policy does not apply to the extent we process Personal Data in the role of a data processor on behalf of our customers or any third party. Such Personal Data will be subject to the customer’s or that other third party’s privacy policies, as applicable.
Learn more about what personal data is about:
What categories of Personal Data do we collect?

ProCom Consulting collects the minimum required Personal Data, considering its nature, sensitivity, and amount. The specific types of Personal Data will depend on the situation that triggered the need to collect your Personal Data:

Situations
Categories of Personal Data
when you register online or make an inquiry regarding our products and services, or provide us with comments or feedbacks.
information about your name, the company you work for, address, phone and fax numbers, e-mail address and line of business, etc.
If you interact with our website
Information about your device an your usage of our websites (such as Internet Protocol (IP) addressed or other identifiers), which may qualify as Personal Data using cookies, web beacons, or similar technologies
If you visit one of our facilities
Name, email address, phone number, photo, ID information, company name, time and date of arrival, images and videos, as explained in our monitoring clause below
If you attend an event
Attendee badge information which may include name, title, company name, address, country, phone number and email address, image and also video – if the event is recorded
If you apply for a job position at ProCom Consulting
Recruitment-related information, which may include name, email address, CV, telephone number, fitting assessment information, background checks when allowed by law and if required for the job position, profile photo, job history and other relevant information.
If you are representative of ProCom Consulting customers, partners or third parties we are in the business relationship with
information about your name, the company you work for, address, phone and fax numbers, e-mail address and line of business, etc.

We may anonymize or de-identify the Personal Data collected so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may use it or disclose it to others without limitation and for any purpose.
Learn more about personal data collected by other sources:
How we use the information we collect

We use and share Personal Data as described in this Privacy Policy and for the following purposes:

• To identify and authenticate your access;
• To conduct analytics in order to improve and customize our websites and the ways we communicate with you;
• To present you and your company business opportunities regarding our products and services;
• To send you marketing communications, updates and newsletters and present personalized content, provided that you can opt to stop receiving marketing materials at any time (opt-out);
• To manage your application for a job position at ProCom Consulting (as applicable);To enter into a contract or perform a contract with you (as applicable);
• To support and troubleshoot our services, to respond to your queries and communicate with you;
• To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request;
• To secure our IT systems, information and facilities, and to allow the provision of office services, business travel services, and health & safety in our premises;

Legal basis for using your Personal Data

We will only collect, use and share your Personal Data where we are satisfied that we have an appropriate legal basis to do this. The legal basis we rely on for the lawful handling of your Personal Data vary depending on the purposes and applicable law, including the following:

Necessary for performing a contract or take steps to enter into a contract with you.

Examples

When apply to a job position in ProCom Consulting
When we use your Personal Data to potentially engage in a service agreement with ProCom Consulting as a service provider or contractor.
Necessary for the purposes of ProCom Consulting’ legitimate interests to conduct and organize business

Examples

We have to keep our general business operations functional and safe. To this end we may, for example, processes personal data collected via monitoring of our networks, or CCTV footage at ProCom Consulting premises locations
We may collect your Personal Data in order to communicate with you and present you marketing materials and opportunities regarding our products and services
To comply with a relevant legal or regulatory obligation that we have; or
The handling of your Personal Data is based on your consent.

Examples

The optional storage of non-necessary cookies (as below)
Marketing materials for individuals ProCom Consulting does not have any prior relationship with.

Monitoring

In the extent you are visiting ProCom Consulting facilities or using ProCom Consulting network and systems, ProCom Consulting may access, monitor, intercept and review your use of ProCom Consulting’ systems, networks, domains and equipment for the purpose of protecting its employees, service providers, contractors, customers and business, as well as ensuring your compliance with ProCom Consulting’ policies and procedures, including security and data protection policies., as applicable to you. This may include, for example, monitoring of security controls such as CCTV and access-control systems, telephone log, internet and network usage, voicemail, e-mail and other communication facilities and means provided by ProCom Consulting which you may use during your relationship with ProCom Consulting. ProCom Consulting shall use such rights reasonably and in accordance with its policies and the applicable laws; therefore, all communications and activities on ProCom Consulting equipment and premises cannot be presumed private.
Sharing your Personal Data

ProCom Consulting implements controls to confirm that your Personal Data is shared in accordance with the applicable law.
ProCom Consulting may share your Personal Data with third-parties as well as other entities within ProCom Consulting group, as detailed below:

Security of your Personal Data

We take security very seriously. We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned. Measures we take include, for example:

placing confidentiality requirements on our staff members and service providers;
destroying or permanently anonymizing Personal Data if it is no longer needed for the purposes for which it was collected; and
applying security controls in the storage and disclosure of your Personal Data to prevent unauthorised access to it.

As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect User IDs and passwords, please take appropriate measures to protect this information. However, due to the open communication nature of the Internet, we cannot guarantee that communications between you and ProCom Consulting, and ProCom Consulting and you, will be free from unauthorized access by third parties.
Retaining your Personal Data

We will only retain your Personal Data as long as necessary to fulfill the purposes for which it was collected or to comply with legal or regulatory requirements, which might include:

• audit and accounting purposes;
• statutory retention terms;
• handling of disputes; and
• the establishment, exercise, or defense of legal claims.

The reasonable retention period will be established considering the purpose, nature, amount, and sensitivity of the Personal Data being processed.
Where your Personal Data is no longer needed, we will ensure that it is disposed of in a secure manner.
Transferring Personal Data globally

We operate on a global basis. Accordingly, your Personal Data may be transferred and stored in countries outside of your country or the territory in which it was originally collected, including in places that are not subject to an adequacy decision by the European Commission or your local legislation, or such territories which may be subject to different standards of data protection.
We will take appropriate steps to ensure that transfers of Personal Data are made in accordance with applicable law and carefully managed to ensure adequate level of security and protection of your privacy rights and interests.
Learn more on our appropriate steps to secure the transfer of Personal Data

Subject to the requirements and conditions set out in local privacy and data protection laws, you may have the following rights relating to your Personal Data:

request access to your Personal Data handled by ProCom Consulting, rectify it or update it.
request that your Personal Data will be excluded, in whole or in part, from the processing activities.
challenge ProCom Consulting decision to process your Personal Data to any processing of your Personal Data.
request to delete your Personal Data
withdraw your consent at any time (to the extent we base our processing on consent), provided that it will not affect the lawfulness of any processing based on such consent before its withdrawal;
require us to provide you with your Personal Data collected from you, in a structured, commonly used, machine readable format, or in limited cases, you can ask to have it transferred directly to another third party.

request to have an effective human intervention and cease automated decision-making, where you’re subject to a decision made by ProCom Consulting solely based on automated processing of your Personal Data, including profiling, which significantly procedures legal effects concerning you or similarly affects you.
Learn More on our automated decision-making activities
In some instances, the exercise of your right may be limited. For example when fulfilling your requests would impair: the rights of others, our ability to comply with our legal obligations and enforce our legal rights.
If you wish to exercise any of the above-mentioned rights, you may do so by submitting ProCom Consulting’ Data Subject Access Request form.
Learn more on exercising your rights

Children

The website is not directed nor targeted to children under the age of 16. ProCom Consulting will not knowingly collect Personal Data from children. If you are under 16, you may not submit information about yourself to us. In the event that we become aware that a User is under the age of 16 has shared any Personal Data, we will use reasonable efforts to dispose of such information. If you have any reason to believe that a child has shared Personal Data with us, please contact us.

Cookies and similar technologies

When you visit our websites, ProCom Consulting, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer browsing preferences, and improve and customize your browsing experience.

We use both session-based and persistent cookies on our websites. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off.
You can control the use of cookies in your devices by select which types of cookies are stored at any time using the ProCom Consulting cookies banner (except for strictly necessary cookies, which are always stored). Your preferences will take effect immediately after you save them in the ProCom Consulting cookies banner.

ProCom Consulting responsible entity and privacy representative information

ProCom Consulting Management Limited (Registered Address: 3rd floor, Chiswick Park Building 4, 566 Chiswick High Road, London, W4 5YE, United Kingdom) is the legal entity responsible for processing your Personal Data in the context of an interaction through our website or a communication with you online.

In all other cases, through different channels, platforms, or context, or where specifically indicated, the ProCom Consulting entity in your country or region is the legal entity responsible for processing of your Personal Data.
The primary point of contact for all issues arising from this privacy notice is our Data Protection Officer.

The Data Protection Officer can be contacted at: ProCom ConsultingDPOOffice@ProCom Consulting.com.

If you have any questions, concerns or complaints regarding our compliance with this privacy notice, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact our Data Protection Officer.

Updates to this Policy

We reserve the right, at our sole discretion, to change, modify, add, or remove portions from this privacy policy at any time to keep it up to date with legal requirements and the way we operate our business, and will place any updates on this webpage. Please regularly check these pages for the latest version of this notice. If we make fundamental changes to this privacy notice, we will seek to inform you by notice on our website or email.
If a material change is made to this Privacy Policy, the effective date will be revised, and a notice of such change will be posted on the updated Privacy Policy for 30 days. By continuing to use our websites and services, you agree that you have read and understood the Privacy Policy.
Privacy Policy effective as of:

December 19, 2024