Company Data Protection Policy

PROJECT PARTNERS, LLC. Company Data Protection Policy refers to our professional commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care, security, and confidentiality.

With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights. This policy refers to all parties (employees, job candidates, customers, suppliers etc.) who provide any amount of information to us.

BRIEFLY WHO IS COVERED UNDER THE DATA PROTECTION POLICY?

Employees of our company and its subsidiaries must follow this policy. Contractors, consultants, partners, and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.

POLICY ELEMENTS - PERSONAL INFORMATION THAT WE COLLECT FROM YOU

As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as your business contact information, including your full name, job title, company name, address, phone number, email address, basic account numbers and other similar financial data where necessary, along with other usage information about the use of our website, including a history of the pages you view.

Our company collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply.

Our data will be:

Accurate and kept up to date
Collected fairly and for lawful purposes only
Processed by the company within its legal and moral boundaries
Protected against any unauthorized or illegal access by internal or external parties

Our data will not be:

Communicated informally, out of context to our industry
Transferred to organizations, states or countries that do not have adequate data protection policies
Distributed to any party other than the ones agreed upon by the data's owner (exempting legitimate requests from law enforcement authorities)

HOW WE MAY COLLECT/USE YOUR PERSONAL INFORMATION

We may collect this personal information directly from you through the following noted methods:

Tradeshows and conferences
Any forms completed by website visitors
Third party websites and search providers
Customer contact information
Customer agreements and their associated addendums
Vendor and subcontractor agreements and their associated addendums

We may also collect personal information about you directly from third parties per contractual guidelines:

In connection with providing Services pursuant to contracts with our corporate clients, we often obtain personal information of or client's customers, employees and/or agents. This personal information varies based on the Services provided, but may include names, contact information, account numbers and other similar financial data. With respect to personal information that we receive from or on behalf of our clients in-order to provide Services, our client remains the independent data controller and we act as a processor of such personal information. Persons entitled to use a system that is Processing Personal Data shall gain access only to the data to which they have a right of access, and Personal Data will not be read, copied, modified or removed without authorization in the course of Processing. A Data Protection Officer will be assigned to any client where personal data is accessed.

Marketing/promotional use of your personal information:

We do not share your information third parties with marketing partners for use in a mere random, non-relevant format of regarding joint marketing campaigns. We may periodically send newsletters and promotional email about our services, or other information that we think you may find interesting, of use, using the email address that you have provided. You can choose to be excluded/opt-out from any future e-mail and promotional communications at any time or change your preferences by visiting our website at http://www.projectp.com/reg/contact_us.cgi.

Personal information, and anonymous browsing may be used to gather broad demographic information used in marketing, promotion, analytics, or similar activities. This information may be aggregated to measure the number of visits, average time spent, page views and other statistics about users of a Site.

Furthermore, we may use your information in the following ways:

Marketing and sales purposes
Business and website analytics
To improve our products and services
To perform our contractual obligations to you where one exists

HOW WE SHARE YOUR PERSONAL INFORMATION

We only use, disclose, or otherwise process personal information when we have a lawful basis for doing so under applicable laws, including fulfilling our contractual obligations, complying with legal obligations, protecting the vital interests of a person, furthering our legitimate interests as a company, and for reasons to which you have consented.

We may also share personal information with the following categories of third parties: Sub-contractors we have engaged in connection with providing Services to our clients.

Our professional advisers, including our attorneys and accountants
Third parties to which we outsource certain services to assist with operating our business, such as IT managed service providers, document shredding services, software providers, information storage providers and other related service providers
Third parties to which our clients have directed us to share information in connection with our Services, such as our clients' attorneys and accountants
Third-party service providers that assist us with client data analytics
Third-party postal or courier providers that assist us with delivering marketing and other documents to you

We may provide personal information to other service providers with which we contract, to process personal information for us at our direction ("Sub-Processors"). We conduct reasonably appropriate due diligence on our Sub-Processors and include in our contracts with our Sub-Processors provisions requiring them to keep the personal information confidential, to process the personal information in accordance with our instructions and for no other purpose, to only retain the data as long as it is necessary to meet their obligations, and to maintain reasonably appropriate information security systems.

We will only share information that we collect or receive regarding our users with third parties under the following circumstances:

Consent: If we have a user's consent to share any information, we may do so. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please click on this link to submit a written request: information@projectp.com, dial +1.650.712.6200, or send your request via email to rportela@projectp.com.

Aggregate Anonymous Information: We may provide to others the aggregate statistics about our users' site activity for purposes of marketing, promotion, analytics, or similar activities. Note: none of these statistics will identify users personally.

Protection of Project Partners or Others in association: We may disclose information about our users to others if we have a good faith belief that it is required or permitted to do so by law or legal process to respond to claims, to protect the rights, property or safety of us or others, or take action regarding illegal activities or suspected fraud, or in response to national security or law enforcement requests.

Affiliates and Subsidiaries: We may share information among its affiliates and subsidiaries for the same purposes that we use the information.

HOW WE RESPOND TO DO NOT TRACK SIGNALS

Our website does not track users when they cross to third-party websites, does not provide targeted advertising to them, and therefore does not respond to Do Not Track (DNT) signals. We do not use automated decision-making functions, including profiling.

ACTIONS - TO EXERCISE DATA PROTECTION WE'RE COMMITTED TO:

Restrict and monitor access to sensitive data
Develop transparent data collection procedures
Train employees in online privacy and security measures
Build secure networks to protect online data fromcyberattacks
Establish clear procedures for reporting privacy breaches or data misuse
Establish data protection practices (database, secure locks, data encryption, frequent backups, access authorization etc.)

To exercise any change of collected data, click here: information@projectp.com, dial +1.650.712.6200, or send your request via email to rportela@projectp.com.

DISCIPLINARY CONSEQUENCES

All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.

Updates

Our Privacy Policy may change from time to time and all updates will be posted on this page. If you feel that we are not abiding by this privacy policy, you should contact us immediately via email at information@projectp.com or telephone at +1 650-712-6200.

Privacy Statement updated as of July 27, 2020