- About us
PGC, its operating brands and affiliates are data controllers with respect to personal information about you that we receive from you and/or from our clients. We may also act as a data processor of your personal information in certain circumstances.
- Any person or company using our website or request information about our solutions
- Clients that purchase our solutions (or the key contacts that work for our clients) (“Clients”);
- Individuals that provide responses (“Participate”) in any of our solutions at the request of a client or ourselves
- Individuals and clients using any of our own or 3rd party solutions
- (“Solutions”) include all and any assessments, surveys, services, products, software delivered by us whether Piilo or 3rd parties
3. The personal information we process
You may give us information about you by filling in forms on any of our websites (“Website”), by corresponding with us by phone, email or otherwise, or through any solution, as you may be invited by us or our client to complete.
You may provide personal information to us when you register to use our solutions, subscribe to our information services, place an order, purchase solutions, post in discussion boards, enter a competition, promotion or survey, when you report a problem with our helpdesk or otherwise communicate at all with us.
3.1 Information we collect through our Website
The personal information we collect through our Website may include your name, occupation, company for which you work, business address, home address, email address and phone number, financial and credit card information, and biographical information. If you contact us, we may also keep a record of that correspondence.
- technical information, including your login information, browser type and version, time-zone setting, browser plug-in types and versions, operating system and platform;
- traffic data, location data, weblogs and other communication data, required for our own billing and administration purposes;
- usage data, such as the source address that the page request is coming from, including your Internet protocol (IP), domain name, date and time of the page request, the referring website (if any) and other parameters in the URL (e.g. search criteria); and
- information about your visit, including: the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); pages you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page; and any phone number used to call our customer service number.
The transmission of information via the internet either by or to us can never be completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to or from us via our Website or by email. If you use electronic means in order to transfer personal information to us, any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
3.2 Information we collect from participants and clients in our solutions
Clients may provide personal information about Participants that have been nominated to undertake an Assessment/Surveys or engage in using our solutions. This information may include the Participant’s name, email address and other contact details. Participants may also provide this information directly to us. Participants may take part in Assessments/Surveys and solutions through our Website, Piilo solutions, service providers or in a paper-and-pencil format.
When Participating, we will ask the Participant to provide responses that may constitute personal information. We categorize such personal information as follows:
- “Identification Data” which means information such as your name, email address and other contact details.
- You must provide Identification Data as this is required in order for us to administer the solution or give access to Piilo or 3rd party providers, to provide the results to the Client or ourselves
“Solution Data” which means your responses in solutions; this may include, or may allow us to deduce, information such as:
- behaviour in the workplace
- job fit
“Research Data” which means responses to questions about you and which will include information such as:
- your gender;
- your age;
- your cultural background;
- your qualifications;
- your work experience; and
- details regarding your employment, responsibilities and work.
Solutions may include your views on specific questions or environments which may impact Clients or ourselves which will be used to deliver our solutions.
3.3 Special categories of personal data
From time to time, Participants may volunteer additional personal information about themselves to us, which may include special categories of personal data. For example, Participants may inform us about a health issue or disability which may impact the way in which they interact with the solution. We will obtain explicit consent before further processing any special categories of personal data that a Participant provides. With your consent, this information will be communicated to the Client requesting the solution whose responsibility it is to take any decisions regarding the impact as a result of the information.
4. For what purposes do we process personal information about you?
We are committed to keeping your personal information confidential and secure. The way in which we use your personal information will depend upon whether you are a Client or a Participant.
4.1 Personal information about Clients when using our Website or solutions
We will use personal information about Clients in the course of providing solutions for the following purposes:
- to fulfil our obligations arising from any contracts entered into between you and us, and to provide you with the information and solutions that you request from us and billing you for the solutions provided;
- to provide you with information about further solutions we offer that are similar to those that you have already purchased or enquired about;
- to notify you about changes to our solutions;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
Personal information provided by you in relation to each of your visits to our Website and solutions will be used:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to better understand Website, solution usage, including what areas of our Website users prefer;
- to improve our site and solutions to ensure that content is presented in the most effective manner for you and for your computer; and
- as part of our efforts to keep our site safe and secure.
This information is stored in log files and is used for aggregated and statistical reporting as well as continuous improvement purposes.
4.2 Personal information about Participants when Participating in solutions
We process Identification and solution Data provided in relation to your Participation in solutions for the purpose of providing Services to our Clients. This may include processing this data in order to:
- identify your input and responses;
- assess your aptitudes and preferred working styles;
- produce reports for our Client who has made this available to you.
We may process Research Data for research purposes. We research responses to our solutions in the light of areas such as gender, age and cultural background over the longer term; this is considered best practice and allows us to monitor our solutions for fairness in use.
If you complete the solutions in a jurisdiction that prohibits completion of such Research Data, you should not complete those details to the extent such law prohibits doing so.
We may also process your personal information for the purposes of using and refining solutions, analysis, accounting, billing and audit, credit or other payment card verification, security, administration, enforcing and defending legal rights, systems testing, maintenance and product development, customer relations, performing our obligations to Participants and Clients whether under contract or otherwise, and to help us in future dealings with you.
Clients are entitled to use the personal information that we provide to them as part of our Services for their own purposes; however, such Clients are obliged to process such personal information in accordance with their own obligations under applicable data protection laws. You will have rights with respect to the manner in which our Clients process such personal information provided by us to them.
Our software are conducted, in part, on the basis of profiling, which means that we process your personal information using software that is able to process your responses to questions and provide estimates of different attributes including your personality, preferred behaviour, motivations, talents and abilities.
If you are a Participant, you should note that it is our Clients that make decisions on the basis of our assessments/surveys. If you have any questions about how results will be used in their decision-making process, you should ask the Client (i.e. your employer or potential employer) for further information. If you are a Client, it is your responsibility to ensure that your decision-making process – including how you interpret the Assessment results – complies with applicable laws.
6. Legal bases for processing your personal information
We must have a legal basis to process your personal information. In most cases, the legal basis will be one of the following:
- to fulfil our contractual obligations to Clients; for example, to use our solutions; and to ensure that invoices are paid correctly;
- to comply with our legal obligations;
- to meet our legitimate interests; for example, to provide the solutions, to conduct analysis that help us to improve our solutions, to ensure that any complaints or concerns can be promptly dealt with, and to ensure our records are kept up to date and accurate; and
Your consent, when we process any special categories of personal data about you. You have the right to withdraw your consent at any time by contacting us using the contact details below.
8. To whom may we disclose information about you?
Information about Participants will be disclosed to our Clients in the context of the provision of solutions to them. Individual responses may be disclosed to Clients, and reports will be provided to Clients, containing score, results and additional comments about a Participant.
Information about you may also be passed to other companies within the wider Piilo group and affiliates from time to time and their respective suppliers from time to time, which may include providers of:
- web services
- other professional services
We may also pass anonymized and/or statistically aggregated data to our approved agents as described above, and to current or future potential Clients or research institutions. Because this information cannot identify you as an individual, it does not constitute personal information.
We may disclose your personal information to third parties:
- In the event that we sell any part of our business or assets of our business, in which case we may disclose your personal data to the prospective buyer of the business or assets. We may also disclose your personal data to a vendor of another business or assets that we are acquiring or to a joint venture or merger partner.
- If our assets are acquired by a third party, personal information held about our Clients and Participants will be one of the transferred assets.
- Due to the international nature of internet-based services, we may from time to time appoint third parties to process data containing information about you on our behalf as a data processor, or store such information in, or transfer it to persons located in, countries outside of Canada, European Economic Area (“EEA”) and United States. These countries may not have data protection laws equivalent to those which are in force in the Canada, EEA or USA to protect your information. Where we transfer your information to such third-party data processors and/or third parties outside of the Canada, EEA or USA, we shall ensure that they provide sufficient guarantees in respect of the technical and organizational security measures, and take reasonable steps to ensure their compliance with those measures in order to ensure your information is adequately protected in accordance with applicable data protection laws. For more information on the appropriate safeguards in place, please contact us at the details below.
10. Third-party contact details
11. How do we protect information about you?
When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations and regulators’ expectations. We may also retain records to investigate or defend potential legal claims.
12. For how long do we keep information about you?
We retain Clients’ personal information for as long as we maintain a relationship with Clients, and then for a reasonable period of time that allows us to assist with any queries, requests or complaints regarding the solutions to commence or defend legal claims, and to comply with our regulatory obligations (including record retention obligations).
13. Your rights in relation to information about you
You are entitled to see the personal information that we hold about you. You may ask us to make any necessary changes to ensure that personal information about you is accurate and kept up to date. You will not have the right to make changes to solution data, however, as this would undermine the accuracy and value of the reports.
If you would like any further information about the personal information that we collect, the purposes for which we collect it and how we protect it then please write to us at email@example.com. This may include:
- a copy of the information we hold about you;
- to verify information we hold about you;
- to anonymize your personal information;
- to object to our use of your personal information;
- to restrict our use of your personal information; or
- to receive your personal information in a usable electronic format and transmit it to a third party (right to data portability),
We hope that we will be able to satisfactorily deal with any issues you contact us about. However, you have the right to lodge a complaint with your local Information Commissioner’s Office.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
15. Contact Information
If you wish to contact us, please send an email to firstname.lastname@example.org or contact us via the information provided on our website.
Updated: 1 September 2023.
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