Confidential Info Policy

Introduction

Pride Technologies, LLC, d/b/a Pride Global ¹ (“Pride” or “Company” or “Us” or “Our”) values the privacy of those who provide personal data and confidential information (“Personal Data and Confidential Information”) to it and recognizes the importance of protecting that information and data through compliance with this Personal Data and Confidential Information Policy (“Policy”).

This Policy describes how and why we collect, store, process, and use Personal Data and Confidential Information, and provides information about your rights. Pride’s processing of Personal Data and Confidential Information of people who are in the European economic area is governed by the European Union’s General Data Protection Regulation (the “GDPR”).

This Policy applies to both Personal Data supplied to us, either by an individual or by others and to Confidential Information supplied by clients or prospective clients. We may use Personal Data and Confidential Information supplied to us for any of the purposes as set out in this Policy, or as otherwise disclosed to you at the point of collection. However, Pride will only process Personal Data where it has a lawful reason for doing so.

This Policy applies to all Pride operations worldwide. This Policy contains important information about your rights; please read it and retain a copy for your records.

Information we Collect and Process

Pride may collect and process your Personal Data and Confidential Information so that it can provide staffing and recruitment services to clients and jobseekers – in doing so, Pride acts as a “data controller”. ² The Company will only process Personal Data and Confidential Information if it has a lawful reason for doing so and then, in compliance with the data protection and privacy laws of the applicable country and/or union.

The term “Personal Data and Confidential Information” concerns the following categories of data:

• Personal Data - Included in this category are classes of data which identify you (i.e., the “Data Subject”) and their personal characteristics. Examples are names, addresses, job title, employer, contact details, age, sex, date of birth, physical descriptions, identifiers issued by public bodies, e.g. SSN and NI numbers name, email address, job title, telephone number, marital status, educational background, employment application, employment history, criminal records history, financial history area of business, job role, jurisdiction, language, seniority, business contact information. Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal records global watchlist information, areas of expertise, details of salary and benefits, bank details, performance appraisals and salary reviews, records relating to holiday and other leave, working time records and other management records.

• Education and professional training information – Included in this category are matters which relate to the education and professional training of the Data Subject. Examples are academic records, qualifications, skills, training records, and professional expertise.

• Employment information – Included in this category are matters relating to the employment of the Data Subject. Examples are business role, line manager, employment and career history, recruitment and termination details, attendance record, health and safety records, performance appraisals, training records, agency employer, security records or other information necessary to determine a Data Subject’s fitness for employment.

• Financial details – Included in this category are matters relating to the financial affairs of the Data Subject. Examples are income, salary, billing rate, payments, benefits, or other information necessary to process payroll for a Data Subject.

• Goods or services provided – Included in this category are classes of data relating to goods and services which have been provided. Examples are details of the goods or services supplied, licenses issued, agreements and contracts.

• IT information – Included in this category is any information relating to a Data Subject’s use of technology or software including IP addresses, any information about the computing or mobile device a Data Subject is using, location data gathered from such devices, connection data, usernames and passwords, and social media handles.

¹ This includes, but is not limited to, the following Pride affiliated entities: Pride Capital Partners, LLC; Pride Technologies, LLC (Pride One); Russell Tobin & Associates, LLC; Pride Healthcare, LLC; Pride Accounting Services, LLC; Pride Technologies of Ohio, LLC; Pride BPO, LLC; Pride Accounting Solutions, LLC; Pride Advisory, LLC; PrideNow, LLC; Pride Compliance, LLC, Russell Tobin & Associates, Ltd., and Russell Tobin Associates Staffing Solutions India Private Ltd.

² Contact information for the appropriate data controller for each geographic region (India/APAC, Americas, and EMEA) is identified in the “Data Controller Contact Information” section of this Policy.

Sources of Information

Pride may collect and process your information, which includes your Confidential Information and Personal Data, received and/or provided from any one of the following sources. Accordingly, you understand that by your access or use of, and/or in any way your submittal of Confidential Information and/or Personal Data through the following sources, you consent to Pride’s collection, processing, and use of Personal Data in the manner(s) set forth in this Policy.

• Any Pride affiliated website: Pride One, Russel Tobin, Pride BPO, Pride Healthcare and PrideNow(collectively, the “Website”). Information may be gathered by email, text, and/or any other electronic messages (or form of communication) between you and the Website;

• Online forms;

• Through third-party mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interactions between you and the Website;

• When you interact with our advertising and applications on the Website or on third-party websites and services;

• LinkedIn or any other social media application;

• A direct submission of information from you by email, website inquiry, social media, phone or social media post;

• A former employer in response to inquiries or requests from Pride;

• An individual whose details you previously provided to us;

• Government Agencies, Credit Agencies, Background checking partners, in response to inquiries or requests from Pride;

• Third party web-based search tools or databases;

Use of Your information

Pride has a legal interest in processing your Personal Data and/or Confidential Information before, during, and after the end of your relationship with Pride. Where you supply us with Personal Data, we will assume, unless you instruct us otherwise in writing, that we can disclose your Personal Data in such manner as we believe is reasonably necessary, or as required by applicable law (and at all times in accordance with this Policy).

Care of Information

Pride has in place appropriate technical and organizational security measures to protect your Personal Data against unauthorized or unlawful use, and against accidental loss, damage or destruction. We put in place strict confidentiality agreements (including data protection obligations) with our third-party service providers.

Retention of Information

Pride retains your Personal Data and Confidential Information in our database for as long as it is necessary for the purposes set out in this Policy or as otherwise disclosed to you at the point of collection (being the length of the employment/business relationship).  If requested to be forgotten, your contact details will be deleted from the database in accordance with this Policy and GDPR.

Your Rights

Please be aware that you have the following data protection rights with respect to your Personal Data and/or Confidential Information:

• The right to ask us to provide you, or a third party, with copies of the Personal Data we hold about you at any time and to be informed of the contents and origin thereof, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of applicable law;

• The right to request erasure, anonymization or blocking of your Personal Data that is processed in breach of the law;

• The right to object on legitimate grounds to the processing of your Personal Data. In certain circumstances we may not be able to stop using your Personal Data. If that is the case, we’ll let you know and explain why;

• The right not to have your Personal Data be subjected to automated decision making and/or profiling; and

• Withdrawal of consent – when Personal Data are processed on the basis of consent an individual may withdraw consent at any time (this may apply to processing of special categories of Personal Data where you have instructed us to act on your behalf and includes the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership).

You consent to the Company processing your Personal Data (including your confidential information, personal data, and sensitive personal data) by virtue of your accessing, use, and/or in any way submitting of your Personal Data and/or Confidential Information through the sources identified in the “Sources of Information” section of this Policy. You have the right to withdraw your consent at any time by contacting our Data Protection Lead by email – privacy@prideglobal.com with the words “FAO Data Protection Officer” in the subject line of the email. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal, contractual, or other reasons required by law. Where this is the case, Pride will tell you and will restrict the Personal Data processed to only what is necessary for those specific reasons.

If you believe that any of your Personal Information that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check the accuracy of your Personal Information and to correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data, we process for you, access your Personal Data and/or Confidential Information or exercise any of the other rights listed above. Restriction of the type of information we process for you may prevent the Company from being able to provide work-seeking services for you.

To exercise any rights that you may have under applicable law with respect to your Personal Information and/or data, including but not limited to the right of access, rectification, deletion, or opposition to the processing of your data, as well as the right to limit the processing and management of your personal data, please email privacy@prideglobal.com with the words “FAO Data Protection Officer” in the subject line of the email. Pride reserves the right to update its Privacy Policy and/or to provide you with further information regarding the Privacy Policy and/or the processing of your Personal Data at any time and will provide you with reasonable notice of any such update/information.

Country/Region Specific Privacy Laws

Data Controller Contact information

Pride’s data controllers vary by geographic region. Please find the applicable data controller’s contact information (name, title, and email address) listed below:

Complaints or queries

Any questions, comments, or complaints regarding this Privacy Policy and/or Pride’s processing of your information are welcomed and should be addressed to Pride’s Data Protection Officer by email at Pride Global with the words “FAO Data Protection Officer” in the subject line of the email.

If you are not satisfied with Pride’s response or believe Pride is not collecting, processing, or using your personal information not in accordance with the law, you may file a complaint by contacting the appropriate governmental agency in your country at the following: United States, European Union, United Kingdom, Canada, Philippines, India, Brazil.

Acknowledgement and Consent for the Collection and Processing of Personal Data and Confidential Information

Pride¹ takes data protection seriously. Please read Pride’s Personal Data and Confidential Information Policy for information on how we handle your data and what your rights are with respect to said data. By clicking “accept” on the Control Your Privacy landing page, I acknowledge that:

1. I have read Pride’s Personal Data and Confidential Information Policy, that I understand the Policy, and that I agree to abide by the Policy.

2. I consent to Pride collecting and processing my personal data through any of the methods set forth in the Personal Data and Confidential Information Policy for Pride to provide requested staffing and recruitment services to clients and jobseekers. 

3. I consent to Pride’s use of sub-processors to process my Personal Data and/or Confidential Information. I further acknowledge and consent that those sub-processors may be based outside the state, province, country or other jurisdiction in which my Personal Data is stored, subject to parties taking steps to provide that the transfer is made in compliance with applicable data privacy laws if transfers are made to those sub-processors.

4. Pursuant to the European Union General Data Protection Regulation (“GDPR”), Pride, in its capacity as a data controller under the GDPR, must obtain my explicit, affirmative consent before it can collect or process any special categories of sensitive personal data for a lawful basis, including, but not limited to, employment, submission(s) online, education, etc.

5. Special categories of sensitive personal data include racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic, biometric data; health data; or data concerning a person’s sex life or sexual

6. Any special categories of sensitive personal data that is collected from me will be for the sole purpose of providing requested staffing and recruitment services to clients and jobseekers and is necessary for that purpose. This may include processing the special categories of sensitive personal data as required to execute contractual obligations in connection with the previously described purpose and compliance with applicable laws, and/or to execute the obligations to you concerning your employment with Pride (or any company). Special categories of sensitive personal data regarding a legal process which may have been provided to Pride by public authorities will be processed only for the purposes relating to a health or safety emergency and complying with any applicable law.

7. Special categories of sensitive personal data will be handled and processed only by the persons who are responsible for the necessary activities for the purpose above, and will be transmitted from the EU to Pride (or vice versa).

8. Refusal of consent may make it impossible for Pride to carry out its necessary activities for the purpose above, and may preclude Pride’s ability to provide requested staffing and recruitment services to you or others. 

9. Pride may process my “sensitive personal data” through any of the methods set forth in the Personal Data and Confidential Information Policy and for the transfer of said Personal Data and Confidential Information overseas (which may include areas outside of the EU), for the purposes outlined in this Acknowledgement.

10. For additional information, to request access to or a copy of your personal data, to request certain data be removed or corrected, or to withdraw this consent you may contact to Pride’s Data Protection Officer by email at privacy@prideglobal.com with the words “FAO Data Protection Officer” in the subject line of the email.  If you choose to withdraw your consent at a later date this will not change the fact that your personal data was legally processed up to that point. If you would like to withdraw consent, please contact Pride’s Data Protection Officer by email at privacy@prideglobal.com with the words “FAO Data Protection Officer” in the subject line of the email.

11. Pride is committed to ensuring the security of your information. We have put in place reasonable physical, technical, and administrative safeguards designed to prevent unauthorized access to your information.

¹ This includes, but is not limited to, the following Pride affiliated entities: Pride Capital Partners, LLC; Pride Technologies, LLC (Pride One); Russell Tobin & Associates, LLC; Pride Healthcare, LLC; Pride Accounting Services, LLC; Pride Technologies of Ohio, LLC; Pride BPO, LLC; Pride Accounting Solutions, LLC; Pride Advisory, LLC; PrideNow, LLC; and Pride Compliance, LLC.