Persolvent | Privacy policy (2022-03)
Persolvent, and its employees, contractors, managers, officers, directors (“PERSOLVENT”) respect the privacy of all Personal Data it holds and is committed to protecting and limiting the use of such information in accordance with applicable data protection and privacy laws wherever it does business. “Personal Data” means any information relating to an identified or identifiable natural person. Consequently, PERSOLVENT has adopted this Privacy Policy (the “Policy”) to protect the individuals whose Personal Data PERSOLVENT controls or otherwise processes. The term “processing” is used in this Policy to cover all activities involving Personal Data, including, but not limited to: collecting, handling, updating, storing, deleting, sharing, accessing, using, transferring, and disposing of the Personal Data.
This Policy reflects global principles and standards on handling Personal Data. This Policy governs all PERSOLVENT business activity and the conduct of all PERSOLVENT employees, contractors and representatives with respect to Personal Data processed on behalf of PERSOLVENT.
It is PERSOLVENT’s policy and practice to comply with all applicable data protection and privacy laws wherever it does business. In the event an applicable data protection or privacy law requires any action or imposes any standard more stringent than this Policy, the requirements of the law shall control and take precedence over the requirements of this Policy. References to applicable law and regulations in this Policy are references to those laws and regulations directly applicable to PERSOLVENT.
Personal Data Covered by this Policy
All Personal Data processed by PERSOLVENT for any purpose MUST be processed in compliance with this Policy. PERSOLVENT may obtain such Personal Data directly from the individual (“data subject”), for example through website registrations, or indirectly through employees and third parties, for example, through contact information.
PERSOLVENT SHALL process some Personal Data on its own behalf for its own business purposes. When PERSOLVENT has the right to control when and how Personal Data will be collected and used, and for what purposes, the Personal Data is considered “Company Controlled Personal Data.” Personal Data that is Company Controlled Personal Data will often, but not always, be collected directly by PERSOLVENT.
Company Controlled Personal Data is Personal Data controlled and processed by PERSOLVENT related to the collection of accounts receivable, the processing of accounts payable, sales, marketing, and vendor and customer relationship management purposes. In some cases, PERSOLVENT SHALL use Controlled Personal Data for sanctions and anti-money laundering screening and to meet regulatory requirements.
PERSOLVENT SHALL process some Personal Data solely on behalf of its clients in the course of delivering PERSOLVENT services (“Services Personal Data”). PERSOLVENT SHALL process Services Personal Data to accomplish the business purposes of the client for whom the services are provided, and often, will not have a direct relationship with the subject of the Services Personal Data.
Typically, Services Personal Data will have been collected by the client and provided to PERSOLVENT for processing, but that is not always the case. In some cases, PERSOLVENT may not even know that the data it processes for a client includes Services Personal Data.
PERSOLVENT SHALL process Services Personal Data exclusively pursuant to contractual obligations, client’s instruction, its Record Retention Policy, and/or regulatory purposes, and SHALL be required to return the Services Personal Data to the client, or to destroy it, after it is no longer needed in accordance with those contractual obligations.
Standards Applicable to the Processing of Personal Data
The following standards MUST be applied by the employees, contractors, representatives, and third parties acting on behalf of each affiliated PERSOLVENT entity covered by this Policy with respect to Personal Data that is processed by PERSOLVENT:
PERSOLVENT SHALL process Personal Data fairly and within the law.
PERSOLVENT SHALL process Personal Data only in support of legitimate PERSOLVENT business purposes that are specified and explicit or apparent from the circumstances.
PERSOLVENT SHALL endeavor to verify the Company Controlled Personal Data it processes is accurate and where necessary, is kept current. PERSOLVENT SHALL endeavor to verify the Company Controlled Personal Data is adequate, relevant, and not excessive in relation to the purposes for which it is collected and/or processed.
Data Subject Rights. Where PERSOLVENT is required by law or regulation to provide data subjects with rights over their data, then PERSOLVENT SHALL enable these rights in accordance with said law or regulation. Where PERSOLVENT acts as a Processor, PERSOLVENT' client is responsible for compliance with applicable law or regulation. To submit a Data Rights Request, email PERSOLVENT directly: privacy@persolvent.com.
Personal Data used for Marketing Purposes. Where Company Controlled Personal Data is processed for the purpose of marketing and analytics, effective procedures exist allowing the subject of the Personal Data to opt out from such use. The opt-out option refers to the marketing of consumer or commercial goods or services to an individual data subject and SHALL not limit normal and customary communications by or on behalf of PERSOLVENT regarding the individual’s relationship with PERSOLVENT.
Data Security. Appropriate physical network and process security measures designed to protect Personal Data or Sensitive Personal Data processed by PERSOLVENT against accidental or unlawful destruction, accidental loss, alteration, or unauthorized disclosure or access are in place.
Data Access. PERSOLVENT SHALL take reasonable steps to determine who gains access to Personal Data. The
Data Transfers. Personal Data MUST not be transferred across any political or geographic boundary unless such cross-border data flow is authorized by agreement of the individual that is the subject of the Personal Data or the transfer is otherwise permitted by applicable laws.
Obsolete Personal Data. In accordance with the PERSOLVENT Records Management Policy, PERSOLVENT SHALL not retain Personal Data longer than necessary to accomplish the legitimate business purpose for which the Personal Data was collected and processed by PERSOLVENT or as required by the terms of a client contract or applicable law. Such obsolete Personal Data, and the media on which it is contained, MUST be destroyed in a secure manner or, where appropriate, returned to a client.
Disputes or Objections. PERSOLVENT SHALL address any complaints or disputes regarding Personal Data in order to settle in a timely fashion.
PERSOLVENT employees and contractors MUST seek advice in the case of any doubt about the lawfulness of a particular activity involving Personal Data or other requirements for compliance with this Policy. The PERSOLVENT Chief Privacy Officer is responsible for the general administration of this Policy.
PERSOLVENT employees and contractors SHALL receive Information Security and Privacy Awareness Training, which includes specific education on personal data protection, compliance, and risk management topics. Privacy training is provided annually and required of all employees and contractors. PERSOLVENT’ specialized training on handling health-related information is also annually assigned to employees and contractors who MAY handle this type of data.
All PERSOLVENT employees, contractors, and applicable third parties are required to adhere to established policies and standards. Violation of PERSOLVENT policies and/or standards may result in disciplinary action, up to and including termination. Any suspected violation of an PERSOLVENT policy or standard should be reported to either a management representative or the PERSOLVENT Compliance Officer.
Usage of Cookies
Persolvent and its service providers user cookies to receive and store certain types of information when you visit this site. This information helps the site recognize you, customize your website experience, remember your preferences, understand how you use the site, and prevent fraud or other harmful activities. Examples of information stored include, but are not limited to, pages you visit, ads and links you click on, browser type, viewing device, generalized IP-based geographic location, and search terms.
Persolvent also allows third-party companies (e.g. Google Analytics, Hubspot, and Squarespace) to place tags on its digital properties. The tags may collect information from cookies placed by other third-party companies. Please contact these third-party companies directly to learn more about your choices regarding these tags and information collected by the tags or visit www.allaboutcookies.org off site to learn how you can disable cookies through your web browser.