Collections and Uses of Personal Information
When you use or register with the Site, we may ask for certain Personal Information. The categories of Personal Information we may request include your name, your job title, your company's name and industry sector, your company's location and your contact information (email and phone number). Depending on the nature of your inquiry or activities on the Site, we may also obtain information about your professional interests through white papers or newsletters you request, as well as professional interests that you specifically describe to us. Providing Personal Information is necessary for performance of the services and functionalities offered by the Site. If you decline to provide the requisite Personal Information, we may not be able to process your inquiry or other requests.
The Site also utilizes cookies to track your online activities, including your registration, submissions, and information requests, in accordance with applicable law. Cookies are files placed on your computer by a website server. Cookies on this Site do not collect Personal Information, but we do track your online activities and may link that information with Personal Information you have provided us through online registration. Your web browser may be set to accept cookies automatically, but can be changed to decline them. The Help section of the toolbar on most browsers will tell you how to set your browser to prevent accepting new cookies, how to have the browser notify you when you receive a new cookie or how to disable cookies altogether. Please note that if you decline to accept cookies, then when and if you choose to download materials from the Site, you may be required to register each time you download materials from the Site.
We use Personal Information and other data collected through the Site to register you with the Site and to otherwise provide you with requested information or services. We may also from time to time use your Personal Information to send you automated email messages or marketing materials regarding our services. These email messages may contain web beacons and other features that help us make sure that you received and were able to open the message. You may opt out of receiving such marketing email messages at any time by sending a message with "unsubscribe" in the subject line to [email protected], or by following the instructions in any marketing communication.
Disclosures of Personal Information
Protiviti may disclose your Personal Information to third parties. The disclosure to third parties would occur in the following circumstances:
We may disclose Personal Information to our affiliates in your local jurisdiction or other locations as necessary or appropriate to provide the service you request, to contact you in connection with service offerings, or for other legitimate business purposes;
We may disclose information to companies and individuals we employ to perform business functions and services on our behalf. Such functions may include hosting our web servers, analyzing data, providing legal, accounting and marketing services, and providing other support services. All such parties will be under obligation to maintain the security and confidentiality of the Personal Information, and to process the data in accordance with our instructions; or
We may disclose Personal Information to the extent necessary or appropriate to government or regulatory agencies and advisors in order to comply with applicable laws, or if such action is necessary to protect the rights or property of Protiviti or its affiliated companies.
Collection and Use of Other Information
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. We may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Site functions properly.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of Site users and email recipients, market our services to you, measure the success of our marketing campaigns and compile statistics about Site usage and response rates.
- IP Address: Your IP Address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Site, along with the time of the visit and the pages visited. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Site. We may also derive your approximate location from your IP Address.
Please note that we may use and disclose Other Information for any purpose.
We may use third-party advertising companies to serve ads regarding our services when you access and use other websites, based on information relating to your use of the Site. To do so, these companies may place or recognize a unique cookie on your browser (including through use of pixel tags). By utilizing the Site, you consent to the use of cookie or other tracking technologies to serve you retargeted advertising.
Third Party Services
Personal Data Security and Confidentiality
We use reasonable organizational, technical and administrative measures designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
Personal Data Access and Correction
Revisions to the Policy
If we change this Policy we will post any updates here for your review. If we change material terms in this Policy, we will provide notice of the revised policy for 30 days on the home page at https://www.protiviti.com/HK-en/about-us with a link back to this page. We will also take other steps as necessary depending on the nature of the changes, including obtaining your consent where required by local data protection laws.
EU-U.S. and SWISS-U.S. Privacy Shield Framework Participation for European Client Engagement Data
Protiviti Inc. in the U.S. (the "Protiviti US") participates in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (the "Frameworks"). Protiviti US’s participation in the Frameworks applies to personal data received in the U.S. from the European Union (“EU”) and Switzerland (“Swiss”) about our corporate clients' personnel, customers and vendors (collectively, "European Client Engagement Data"). We are committed to subjecting such European Client Engagement Data to the Frameworks, including its Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability to the extent applicable to Protiviti US as a processor acting on behalf of our corporate clients. To learn more about the Frameworks, visit the U.S. Department of Commerce's Privacy Shield List here.
European Client Engagement Data Collection, Use, and Disclosure
We operate as a processor acting on behalf of our corporate clients regarding the collection, use, and disclosure of European Client Engagement Data and we process European Client Engagement Data that our corporate clients submit to our services in accordance with their instructions. If you are an employee at, or customer or vendor of, our corporate clients, please consult the privacy policies of that entity for information about its privacy practices.
Rights of EU and Swiss Data Subjects under the Frameworks
If you are an EU or Swiss data subject, you have the right to access your own European Client Engagement Data subject to certain limitations, such as where the legitimate rights of other persons would be infringed or where the burden or expense of providing access would be disproportionate. Please note that because Protiviti US personnel may have limited ability to access European Client Engagement Data our clients provide to us as part of our services, if you wish to request access, to limit use, or to limit disclosure, please contact us as described below and provide the name of the corporate client who submitted your data to us. We will refer your request to that corporate client, and will support them as needed in responding to your request.
Choices of EU and Swiss Data Subjects
We operate as a processor acting on behalf of our corporate clients and, as such, do not use or disclose European Client Engagement Data in a manner that is subject to choice requirements under the Frameworks.
Recourse, Enforcement, and Liability under the Frameworks
In compliance with the Frameworks, Protiviti commits to resolve complaints about our collection or use of European Client Engagement Data. Individuals with inquiries or complaints regarding our Frameworks policy should first contact us as specified below. In addition, please contact us as specified below if you have any questions, need access to your European Client Engagement Data, or otherwise need assistance. We remain responsible for our collection, use and disclosure of European Client Engagement Data in accordance with the Frameworks. We also are responsible for third party agents that are processing European Client Engagement Data on our behalf, unless we prove that we are not responsible for the event giving rise to the damage. In certain situations, we may be required to disclose European Client Engagement Data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
If you have an unresolved concern about European Client Engagement Data that we have not addressed satisfactorily, we have committed to cooperate with the panel established by the EU Data Protection Authorities and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to serve as our independent dispute resolution bodies for the Frameworks. We are also subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the Frameworks. In addition, under certain conditions, more fully described on the Privacy Shield website (available here), EU and Swiss residents may invoke binding arbitration for non-monetary issues when other dispute resolution procedures have been exhausted.
Please contact us here [email protected] if you have any questions, wish to exercise your rights of access, or seek other assistance related to our participation in the Frameworks as described above.
This Policy is effective as of October 22, 2018. If you have any questions about our website privacy policies, please contact us at:
Trish Finnemore, Privacy Officer
Protiviti Hong Kong Co. Limited
Level 24, No. 1 Martin Place
Sydney, NSW 2000