At ProChek1, based in Grand Rapids, Michigan, we take privacy seriously and consider it our primary responsibility. We are committed to ensuring the responsible use and management of data among our clients, affiliates, and suppliers worldwide. This notice specifically applies to our services and practices. Please note that our online properties may contain links to other websites and online services that are not under our control. If you provide personal information to these websites or online services, their privacy policies will govern using your personal information.
Individual Rights
Your Personal Information
Keeping and Securing Your Personal Information
Disclosing Your Personal Information
Ensure A.I. Transparency and Individual Rights
International Data Transfers
Additional Rights for U.S. Residents
Contact Us
Individual Rights
Depending on your location, you may have fundamental rights under privacy and data protection laws related to the data we process about you. You may exercise those rights through the form accessible from the Individual Rights Manager button above, by email, or by contacting us via telephone. These rights are usually free, and we will respond to your request within 30 days, or the specific timeframe required by the applicable laws. We will honor the requests you make related to your rights as the law allows, which means, in some cases, there may be legal or other official reasons that we may not be able to address the specific request you make related to your rights. The rights relate to:
Access to the personal information we process about you. This means you can request access to and receive details about the personal data we maintain about you and how we have processed it, as well as correct inaccuracies.
Correction of inaccurate or incomplete personal information about you.
Deletion of personal information about you.
Restrictions, temporarily or permanently, on processing some or all personal information about you.
Transfer of personal information to you or a third party where we process the data based on your consent or a contract with you and where our processing is automated; and Opt-out or object to our use of personal information about you where our use is based on your consent or our legitimate interests. Additionally, you may opt out of our use of the personal information we have either made available or disclosed to third parties for advertising purposes.
When you submit an individual rights request, you consent to us using your information to respond to your request. We will communicate with you via email in most cases. If you wish to withdraw your consent for us to respond to your request, you may do so via that email. Your consent includes that your request will come to the United States, where we are located. If you do not consent, we cannot respond to your request.
Additional Rights for U.S. Residents
You may have certain additional privacy rights if you are a California, Connecticut, Colorado, or Virginia resident. Please visit our U.S. resident’s page for further information on these rights.
Your Personal Information
What is personal information?
Personal information is data that identifies, relates to, describes, or can be associated with you, including data that could be used to identify, locate, track, or contact you.
How we collect your personal information depends upon how you interact with us
The categories and specific types of personal information we obtain about you depend on how you interact with us and our products and services. Depending upon this interaction, you may fall into one of the following data subject categories:
· Website Visitors – Those who visit our website or online properties.
· Customers/Partners – Customers, business partners, or express interest in our solutions or content.
· Employees/Applicants – Employees, direct contractors, job applicants, or former employees.
· General Consumers – Those who engage with us in activities or relationships not already listed, for example, respondents to customers’ assessments and vendors.
We list the activities (sources) below in which we collect personal information on or from you. Depending upon the activity (source), we may collect different categories and specific types of personal information from you. These activities may overlap; a customer may visit our website. Suppose you provide any personal information to us online, such as by filling out a form, attending a webinar, or through cookies (tracking technologies). In that case, we only use this information with your consent. Depending on how you interact with us, you may withdraw consent by exercising Your Rights as described above, including submitting a request through our Individual Rights Manager, our Cookie Preferences Manager, by phone, or by email.
Where is your personal information stored or accessed?
Because we have engineering, product, and support operations in the U.S., Canada, and the Philippines, most personal data will be accessed from these
locations. Most information is hosted at Amazon Web Services in the U.S., but Cookie Consent Manager (and Consent Manager in general) is hosted at AWS in Ireland. We also offer an option to host platform data in Germany. In addition, through our remote work environment, we may have employees or contractors who access the data from other countries, such as Brazil, Australia, or the United Kingdom.
ONLINE ACTIVITIES – Data subject categories: all
Information is provided to us anytime you visit our website or engage in other online activities, such as using our solutions. In most cases, this information is collected based on our legitimate interests in ensuring our website or other online activities function correctly or that we provide the user experience we wish to provide. If it is based on our legitimate interest, we have determined that our business interest in gathering this information does not significantly impact your rights. In other activities, we may rely on your consent. If so, you can refuse consent or change your mind. These options are discussed in more detail below. We have tried to be comprehensive, but if you have any questions, please do not hesitate to contact us. We keep this information for as long as we have a business or potential relationship with you.
Online Forms
We process the information you provide, such as your name, email address, company where you work, phone number, job function, job title, country, and any comments you provide. Given that we are a business-to-business (B2B) company, we do this to respond to your request for information or resources or, in our legitimate interest, to collect information to reach out to you for potential business interest. We may contact you with marketing communications using the information you submit in these online forms. You can easily opt out of future communications using the opt-out link provided in the emails sent to you. If you opt out but then complete another form, you cancel your opt-out.
Cookies and other online tracking technologies
We use cookies and other data-collection technologies to help you do the following:
We use browser sessions and persistent cookies. Session cookies are temporary cookies erased from your device’s memory when you close your Internet browser or turn your computer off. In contrast, persistent cookies are stored on your device until they expire unless you delete them before that time. We group browser cookies on our site into three categories, which you can manage through our “Cookie Consent Manager,” – and you can return to this Cookie Consent Manager anytime to change your preferences.
· Required cookies: These cookies are necessary to enable the basic features of this site to function, such as allowing images to load or allowing you to select your cookie preferences.
· Functional cookies: These cookies allow us to analyze your site use to evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, remember your login details or provide information about how our site is used.
· Advertising cookies: These cookies may be used to disclose data with advertisers so that the ads you see are more relevant to you, allow you to disclose certain pages with social networks, or enable you to post comments on our site.
· Some cookies may be placed by third-party service providers who perform some of these functions for us.
· In addition, there are browser settings that you can set in your internet browsers, such as Internet Explorer, Google Chrome, or Mozilla Firefox, which can also address cookies and trackers. Sometimes, these settings contradict what you may choose on a website. For example, suppose you set your browser settings to refuse all non-essential cookies. When you visit our page and make a cookie selection, that preference is stored as a cookie and may override your selection per your browser settings. This means the site won’t remember your choice on your next visit, and you may have to make a selection every visit. This may be frustrating and is not something we do deliberately. There are many efforts underway by companies, technology, lawmakers, and others to make this a better user experience for everyone – and we at ProChek1 are actively trying to make this a more straightforward process.
· The Global Privacy Control (GPC) is another technological tool that may be used to control your cookies and tracking preferences. To learn more about the GPC, please download and use a browser supporting the GPC browser signal by clicking here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you must turn it on for each supported browser or browser extension you use.
· To the extent these online tracking technologies are deemed to be a “sale” / “share” (which includes targeted advertising, as defined under the applicable laws) under applicable U.S. state laws, you can opt out of these online tracking technologies by submitting a request via a form at this link: Do Not Sell or Share My Personal Information. For further information on the privacy rights of U.S. residents, please see our Notice for U.S. Residents page.
Server log files
We automatically gather server log file information when you visit our websites. This includes the IP address, browser type, referring and exiting web pages, and operating system. We do this based on our legitimate interest in ensuring our website operates as intended or identifying what may need to be changed.
Other online activities
To administer our website and our technical solutions and to understand how our website visitors navigate through our websites and technical solutions, we monitor our website and solutions based on our legitimate interest to continuously improve the experience for our users. We may further analyze the information we gather online to improve the online experience, resources, and tools we provide to our users. This is also based on our legitimate interest in providing appropriate materials or user experiences.
COMMUNICATION AND ENGAGEMENT – Data subject categories depend on activity; see below.
ProChek1 is a business-to-business (B2B) company, meaning we sell our solutions to other businesses and do not typically engage with general consumers for profit. However, general consumers may engage with us either on behalf of our customers or through other activities, such as webinars. These activities are provided in more detail in this section. We keep this information as long as we have a potential or actual business relationship with you or if there is a legal obligation to keep the information. You may also revoke your consent where you consented to provide us with the information. Where we do not collect identifying information, we may not be able to remove the information because we will not know which information you provided.
Suggestions, Complaints, Inquiries – Data subject categories: all
We process personal information about you based on our legitimate business interests for the following purposes, to which you may exercise your rights to object as described above:
· To investigate complaints or concerns to ensure that such complaints or concerns are addressed appropriately.
· To send optional customer satisfaction surveys once your complaint has been resolved to improve our processes.
· To evaluate the characteristics and needs of our customers to improve our solutions and
· To communicate with you about ProChek1 events, industry, or privacy-related news to engage with you as a member of the privacy community in which we participate.
Opinion / Feedback Surveys – Data subject categories: all
We process your survey responses if we engage in a general consumer survey. You may answer or not when it is presented to you. Withdrawing your consent will not be possible as we do not ask or collect identifying information and only use answers in large groupings, such as all “Yes” or “No” answers to a particular question. We would not be able to pull your answers out.
Suppose you participate in our market or product/services research and surveys. In that case, whether delivered by us or a service provider on our behalf – we may process your email address, job title, phone number, survey responses, company name, job function, state, country, relationship with ProChek1, and any comments you provide. We may provide remuneration in exchange, such as a gift card. We conduct online consumer surveys to learn about your views on critical privacy-related issues based on our legitimate interest in better understanding the privacy market and improving our solutions; we do not directly collect any personal information about you when we conduct these surveys. However, cookies and data collection technologies may be used to manage the delivery of the surveys. You may choose to respond and opt out of future communications. This is through our legitimate interest in obtaining your feedback and, in part, through your consent to such activities.
Customer Engagement – Data subject categories: customers/partners
This may include voluntary participation in our customer community offerings, such as online communications, group meetings, and other engagements. You must consent to participate in such activities, and if so, you can revoke your consent easily by withdrawing from such activities. You must agree to follow the engagement rules, which will vary by the method of engagement.
Webinars/Presentations/Speaking Engagements – Data subject categories: all.
Suppose you register for or attend our webinars (or other presentations). In that case, your I.P. address and additional technical information may be disclosed to the hosting provider or application, such as Zoom. Where applicable, registration information and any comments or feedback you provide to us will be captured.
If you are invited to be a guest in a ProChek1-hosted or sponsored webinar (or other presentation), your contact information will be processed as part of the production. This generally includes your name, email address, phone number, company name, image, and job title. These programs are recorded and broadcast publicly, as is the nature of such programs, including your voice and image and the information you disclose. Follow-up information for the webinars will be sent to the registered email address, and you can opt out anytime. If you do register for another webinar, you will be opted back into communications.
Interest in our Solutions – Data subject categories: all
Suppose you request or indicate an interest in information about our solutions or partnership opportunities. In that case, we process your name, email address, phone number, job title, information about the company where you work, including its website address, and any comments you provide. We add business information related to the company where you work from third-party sources, such as business intelligence providers, information from publicly available sources such as LinkedIn, as well as information about the number and frequency of your interactions with us online and offline, such as at events, webinars, email communications, and our website. We maintain and update this information as we continue to engage with you. Once you express interest in our solutions, engaging with you may be based on your consent or our legitimate interests. If we rely on consent, it will be clear that you are providing consent because you will complete a form or register for an event. As such, you can cancel your consent using the opt-out link in our emails or by contacting us via an individual rights form, email, or phone.
Marketing Communications – Data subject categories: all
We may send you marketing communications (including sales, information, events, and business development communications) about our solutions, events, or resources that may interest you. For these communications, we process your name, phone number, email address, postal address, job title, job function, company name, and information about which of our solutions you use, or which may interest you, including any responses you make to such communications. We also process automatic information such as what we collect via cookies, I.P. address, device type, browser, and if the email was opened. We may also associate other information to the communication for insight, such as company size, company financial information, and whether the company is a current or prospective customer. These communications are initiated in our legitimate interest to engage you in business. However, if the information was collected through our online forms, you consented to be contacted. We track these communications to determine whether, when, and the IP address and associated city of marketing communication we sent were viewed based on our legitimate interest in effectively managing and improving such communication.
Communications may also ask for your review of our solutions from your perspective as a customer or user. We do this from our interest in having you evaluate our performance. You may opt out of marketing emails using the unsubscribe link.
Telephone / Video Calls – Data subject categories: all.
Suppose you have consented to a recorded telephone call or video conference with ProChek1. In that case, we may process your name, email address, job title, image, and voice for analytical purposes to improve our training and customer relationship management and to provide recorded information to our customers upon request. For example, a customer may want a recording of a demo of a particular solution. For any such telephone calls or video conferences, a Notice of the intent to record will be provided before recording. You may decline the recording before or during the meeting and request deletion of the recording at any time. All such recorded sessions will be automatically deleted within 180 days.
Contracts / Relationship Management – Data subject categories: customers/partners, plus vendors
We process your name, email address, postal address, company name, billing information (e.g., purchase order number, bank wire information, credit card number), company size, company financial information, and signature, along with communication content and any comments or feedback you may provide. Some information about you may come from other individuals. For example, a colleague may tell us you moved to another company or a different role. Similarly, such information may be available publicly, such as on LinkedIn.
We use this information to facilitate the contract execution and to deliver on the contract. We will email you about your use of our solutions, obtain your input on new features, functionality, and content, and provide information about updates to our solutions. We will also discuss ProChek1 events or industry/privacy-related news with you. We have a legitimate business interest in renewing your subscription-based solutions to retain you as a customer or partner and providing additional solutions you request based on our legitimate business interest and contractual obligation to respond to your reasonable requests.
In addition, to better understand the needs of the privacy and business communities we aim to serve, we analyze our interactions with you online and offline. This helps us improve how we provide information and engage specifically with you, including helping us determine when you might be ready to make a purchase based on repeated interactions with ProChek1. We want to understand the business that you work for, and your prior experience based on our legitimate interest in tailoring our communications with you to improve our engagement with you from a business perspective. We also want to understand your business and privacy-related needs based on our legitimate interest in developing and enhancing our solutions to address your needs and make them more relevant. Lastly, we do not make any automated decisions about you that would result in legal or other similarly significant or detrimental effects on you.
USING OUR SOLUTIONS – Data subject categories: customers/partners – and their data subjects
ProChek1 is a business-to-business (B2B) company, meaning we sell our software solutions to other companies. You may use our solutions because your company purchased our software for their privacy compliance needs or because you work with a company that does business with our customers. In most cases, this information should be your business information, not your personal information, but we do not control what information our customers enter about you. Below, we provide information in three categories: 1) our customers’ authorized users, 2) the ProChek1 platform, and 3) consumer-facing solutions. We develop and discontinue solutions based on our business strategy and developments, so not all solutions are detailed below, but apply in a general sense based on how you engage with us.
When using our solutions, we may ask you to provide business information related to the company where you work. Business information may include your company’s practices, policies, processes, and supporting documentation. This business information is stored on ProChek1 systems, and we use it to provide the solutions you have contracted us to provide and by the terms and conditions outlined in agreements between ProChek1 and your company.
Customer’s Authorized Users
Authorized users or other individuals named in our solutions, such as respondents to customer assessments, fall under the control of the customers’ determinations, meaning ProChek1 cannot grant access or delete information without the customers’ permission. We retain this information for the length of the customer contract, deleting it as required by the customer or for a set period (generally three years from termination) in agreement with the customer. Suppose you are a licensed or other authorized user of our privacy technology platform. In that case, we process your name, email address, username, password, I.P. address, job title, phone number, information about the company where you work, actions you have taken in the applications on the platform or in response to communications, such as record creation, changes, input, responses, analysis, and approvals, and tickets filed on your behalf related to our platform.
For individuals at our customer companies or potential customer companies, we process this information to provision and de-provision your account on our platform; authenticate you to enable you to access your account on our platform, including adding users of the solution; provide customer service and support, and investigate issues that you raise; deliver our assurance programs and solutions to you, including provision of our seals, where applicable; resolve disputes related to your organization’s privacy practices; provide alerts in the platform based on your implementation; and help you build, implement, manage, and demonstrate your privacy program and practices using our solutions. We may further analyze the use of our solutions and characteristics of the companies that use our solutions (e.g., by size and industry sector) to help us understand and make decisions about customer and market needs, to improve our solutions, to design new solutions, and to inform partnership and business development decisions.
ProChek1 Platform, e.g., powered by E-Verified (including external respondents)
To engage with our solutions, you will either be an authorized user as described above or a non-system user whose customer sends you information to complete. For example, a customer may send you a vendor assessment, or you may be a business process owner for the customer and need to complete a data inventory or Data Protection Impact Assessment. In both cases, we are a vendor (a processor/sub-processor) to our customers, and the customer is responsible for determining their processing purpose and choosing to communicate with you. You may contact us or the customer to learn more if you have any questions.
ProChek1 established E-Verified in 2023 and provides these services through our ProChek1 platform. In most cases, the uses and purposes are the same as those listed on the platform. However, in some instances, the customers may disclose such information to other individuals. The authorized users may enter your information into our platform to send you materials or download the materials and send them directly. We are a vendor (processor) to our customers, and their use of your information is based on their determinations. You may contact the customer or us for more details if you have any questions.
Consumer-facing Solutions, e.g., Individual Rights, Cookie Consent, Privacy Central (includes consumers who engage with customers)
Some of our solutions that customers use is consumer-facing, such as Individual Rights Manager or Cookie Consent Manager. If you are a consumer interacting with any of our solutions, we are a vendor (processor) to our customers. As such, the customers are the ones who determine the processing purpose and use your information through our platform. In most cases, we anticipate that their basis for processing your data is consent, but you must confirm that with the customers. We use our solutions, so in that case, we are the “customer” if you engage with the Cookie Consent Manager on our website or submit a request through the Individual Rights Manager.
· Individual Rights Manager
When you submit an individual rights request using a form, we process your name, email address, residence, type of request, the particular type you select on the form, any comments you provide, and any additional information customers need to verify your identity. When you submit a request to another company that has implemented our Individual Rights Manager, we process the information you provide in the form implemented by that company. We support the management of your request by the company and the retrieval of information responsive to your request. Communications related to an individual rights request, including providing more information or the data requested, will be managed through the platform using ProChek1’s email server hosted in either Frankfurt, Germany, or Virginia. Although we allow our customers to customize the categories of personal information they wish to collect, we neither recommend nor know of the collection of the category of sensitive personal information.
· Cookie Consent Manager
If you have consented through our Cookie Consent Manager (CCM), we process your full I.P. address at initiation to infer your location and serve you the correct cookie banner. After this, we pseudonymized the I.P. address to record your consent choice (opt-in or opt-out). We stored it in our CCM application at our data center in Dublin, Ireland, for 13 months. When you first visit our website, we drop a browser-specific cookie. Additionally, session cookies will be set by the ad networks listed in our preference manager to honor your preferences if you choose not to receive interest-based advertising. Our cookie only knows your last set of preferences and does not reflect your browser’s current cookies state. Suppose you clear your browser history, which includes removing the opt-out cookies set by companies. In that case, we cannot identify or honor your previous preferences when you return to this site from that browser. You will need to re-access the opt-out tool to reset your preferences.
The connection between your browser or device and any other personal information may not have been “known” to us until you provide more information. Some of our customers may “know” who you are across browsers or devices based on their collected personal data. In those instances, our customer may direct us to collect and store in its CCM instance an identifier (e.g., I.P. address) it uses to identify you across browsers or devices. You can visit our customers’ websites or contact them to learn more about their data privacy practices.
· Consent Preference Manager
If a customer of ProChek1 has implemented our Consent & Preferences Manager, we process any data related to you collected by this customer to help them manage your consent and preferences. This data may include various categories of personal information selected by the customer. Although we allow our customers to customize the categories of personal information they wish to collect, we neither recommend nor know of the collection of the category of sensitive personal information.
· Ads Compliance Manager
We process information about your interests if you click through an icon associated with our Ads Interests Manager in an online advertisement. We process cookies to deliver our interest-based advertising notice and choice programs opt-out tools to assist with you opt-out choices and to help us measure usage. Our opt-out tool signals companies not to use your browsing behavior to provide interest-based advertising by setting their opt-out cookie in your browser. When you access our preference manager, session cookies will be placed by the ad networks listed in our preference manager to honor your preferences if you choose not to receive interest-based advertising. Clearing your browser cookies will remove all cookies, including the opt-out cookies set by the companies. You will need to re-access the opt-out tool to reset your preferences. Our cookie only knows your last set of preferences and does not reflect your browser’s current cookies state.
· Dispute Resolution
We encourage you to use Dispute Resolution Program to report and resolve privacy complaints you may have concerned Dispute Resolution Program Participants. We process your name, email, and country location if you file a privacy-related complaint. We will also request that you provide the details that gave rise to your complaint. Any additional personal information you choose to provide in the complaint form is optional.
For both of these, we will not disclose your name and contact information with the company you are complaining about unless you consent. If not, we can still tell the complaint to the company (with your consent), but we may only be able to resolve your complaint by knowing more details. We will respond to your complaint via email, and if you want to withdraw your consent, you can do so by replying to that email.
Also, suppose you reside in a country with rules about sending information to other countries, called cross-border transfers. In that case, you must consent to sending your information to the United States, where we have offices and process personal data for dispute resolution. We may also have employees in other countries who access the information through our platform or email. This consent applies to your submission to us and our communication with the company about the complaint, which may also be in another country. We cannot process your information or register your complaint without consent.
EMPLOYMENT-RELATED ACTIVITIES – Data subject categories: employees, applicants
This section applies to current, past, and future employees or individuals in an employment-like relationship, such as contractors, consultants, volunteers, interns, externs, or others acting in a work-related capacity. We keep this information for the time required by law or based on your consent, for example, for employment applications.
Employment Activities
Applying to work at ProChek1: If you used to work at ProChek1, we process personal information about you and your professional experience, education, and training, such as your application, your name (and any former names), postal address, email address, phone number, universities attended, academic degrees obtained, grades, professional certifications and licenses, employment history, and curriculum vitae or resume.
Offer of employment or contractor position: If we extend an offer of employment or a contractor position at ProChek1 to you, we will process personal information about the position to which you have been appointed, your job title at ProChek1, the compensation or project-based contractor rate we offer to you, whether you accept the offer, your signature, and your starting compensation or project-based contractor rate, and your start date at ProChek1.
Employment-Related Background Checks: We engage service providers to conduct background checks that involve processing personal information as permitted by the laws where you reside and work. More details are provided to you regarding our request to complete these checks. We also have designated employees, usually H.R. or your supervisor, who will do reference checks. We contact individuals you have provided and engage in conversation (written or oral) about you, your work habits, challenges, experience, and more. We do not control the information provided to us by these references.
As an employee or contractor of ProChek1: we may process personal information about your benefits, nationality, residency status, email address, office or other workplace location including remote work arrangements, work phone number, mobile phone number, photographs, passport, visas, marital status, beneficiaries and /or dependents and their associated data related to benefits such as date of birth or relationship status, emergency contact details, financial account information, social security number or other government-issued identification number, holiday and paid time off days which may include the reasons for the time off, salary, incentive compensation, ProChek1 stock options granted, ProChek1 stock ownership, assigned projects, feedback and opinions, performance against your set goals, training completed, any performance improvement plans, any disciplinary actions taken, system accounts, technology and physical assets provided to you, your role and actions taken in connection with ProChek1 projects and processes. This will include information voluntarily provided by you, such as would be disclosed in a typical work environment, such as photos of pets, anecdotes about family, and other such information you choose to disclose with colleagues.
If your employment with ProChek1 ends, we process the personal information necessary to offboard you from ProChek1, including the deactivation of your access to our systems and fulfilling our financial, benefits, and related obligations concerning the end of your employment with ProChek1.
In certain countries, supplemental privacy notices will be provided to ProChek1 employees and contractors, and where applicable, consent will be obtained to ensure compliance with local requirements.
We process personal information about you based on our legitimate interests to establish and manage our relationship with and responsibilities to you and for the effective operation of our business, including activities necessary to comply with laws or contracts, such as:
· Recruit new talent to join ProChek1.
· Onboard employees and contractors to ProChek1.
· Grant and ensure appropriate access to ProChek1 systems and facilities.
· Ensure the security and safety of the workplace and the tangible and intangible assets for which we are responsible.
· Assign roles and responsibilities.
· Manage team and cross-functional communications and collaboration.
· Promote a positive workplace culture.
· Administer payroll.
· Benefits administration.
· Award and pay incentive compensation.
· Invoice payments.
· Managing ProChek1 projects and processes.
· Maintaining corporate, financial, and other essential business records and reporting.
· Evaluating financial and operational performance; and
· Managing compliance, including, but not limited to, our privacy, security, accounting, labor and employment, and other legal and regulatory obligations.
Statistical and research purposes: We may further analyze information to evaluate and understand employee engagement and develop plans to improve our workplace culture continuously.
Using Devices for Work Activities
You may participate in communication processes, which may be recorded, such as video conferences, phone calls, or written correspondence, or video/audio presentations for public release (webinars, podcasts, etc.), and such may be performed from your device. ProChek1 may inadvertently collect information from your surroundings or device. You should consider this if using a personal device for work purposes. We may also request or require security software to be installed. More information can be found in the employee handbook and various policies and communications from executives or other personnel in crucial roles.
ProChek1’s Personnel Scope of Work
You may engage with customers, other employees, technology, vendors, and individuals as part of your employment activities. Your actions or communications will typically be recorded via online tools or communication technologies. These recordings may be temporary or permanent, depending on their intent. For example, if you write code that may become a permanent entry in ProChek1’s platform. If you engage with regulators on an investigation, that will likely become a long-term record both for ProChek1 and the regulator.
Keeping and Securing Your Personal Information
We will keep personal information about you for as long as we provide solutions to you or your company, as long as you work for or with us, and as long as we are addressing a concern, question, complaint, or request you have made to us; as applicable to our interactions with you; as long as the law requires us to do so; or for the period we need to maintain the information, e.g., to respond to investigations or lawsuits. If we have a contract or other agreement with you or your company, we will follow the retention obligations of that agreement.
We may keep data longer if we have a legal obligation to keep it, maintain necessary records for legal, financial, compliance, or other reporting obligations, and enforce our rights and agreements. We also may save data about you for statistical analysis or research purposes.
We take appropriate security measures to protect personal information against loss, misuse, unauthorized access, alteration, disclosure, or destruction. We have also implemented measures to maintain the ongoing confidentiality, integrity, and availability of the systems and services that process personal information and will promptly restore the availability and access to data in case of a physical or technical incident.
Disclosing Your Personal Information
At ProChek1, we only disclose personal information in ways that we tell you about. Depending upon your location, we do not sell or rent personal information to third parties, and we do not disclose personal information with third parties that are not owned by us, under our control or direction, or in a direct business relationship with us except as described in this Notice. We share personal information (as share is defined under specific data protection laws) with third-party advertisers and website analytics providers. You may have certain additional privacy rights if you are a California, Connecticut, Colorado, or Virginia resident. Please visit our U.S. residents’ page for further information on these rights.
Service providers / Vendors. We disclose personal information with service providers/vendors that help us with our business activities. Service providers support us in processing the types of personal information described above in the section “What personal information” and for the purposes described in the section “Why do we process personal information.” They are only authorized to process that information as necessary and as directed by us. Some of these providers qualify as “sub processors” under the General Data Protection Regulation because they are used to provide services that our customers purchase.
Business partners. ProChek1 forms various partnership relationships to whom we may disclose your information legitimately under one of the reasons described in the Notice or receive information from them. We only permit partners to process your information as necessary and directed by us. Sometimes, the partners may be contracted through ProChek1, such as customers who purchase education modules through one of our partners. In other cases, partners may disclose your information with us, and their privacy notices will also apply.
Third-party cookies and similar technologies. While ProChek1 does not sell personal information to third parties, ProChek1 does disclose data related to cookies and similar technologies with third parties both to evaluate and optimize the performance of and analyze your use of our online services and for advertising purposes. This may qualify under U.S. state laws as “selling” or “sharing.” You may consent to our use of these technologies, reject non-essential technologies, or further manage your preference with our Cookie Preferences or by submitting a request via our Do Not Sell My Personal Information form.
We are required by law. If we are required to disclose personal information as part of a legal process, we will take commercially reasonable steps to inform you as part of that process. We may also be required to disclose personal information in response to lawful requests by government authorities, including requests from national security agencies or law enforcement. Some of these requests may be made by regulatory oversight agencies investigating a complaint; others may be made by law enforcement looking for information.
Safety, fraud prevention, government requests, and protection of our rights are all reasons we may disclose personal information where we believe it is necessary in good faith.
Mergers, acquisitions, divestitures, or asset sales, but only if the acquiring organization agrees to this Notice’s protections, where this is within our control. If we are under the control of a court, such as in bankruptcy proceedings, we may have little authority to ensure this protection.
Ensure A.I. Transparency and Individual Rights.
Promote explainable A.I.: Advocate for using interpretable A.I. models and layperson explanation techniques. This not only aids in regulatory compliance but also enhances trust among users.
Document A.I. processes: Maintain comprehensive documentation detailing A.I. system design, training data, use cases, and ethical considerations. This aids in transparency and regulatory compliance.
Promote meaningful human oversight: Ensure that human intervention is not just a token gesture. Reviewers should genuinely influence A.I.’s decisions and be equipped to understand A.I.’s reasoning.
Mitigate biases: Collaborate with A.I. teams to identify and rectify potential biases in training data and model outputs. Regularly audit A.I. systems for fairness and non-discrimination. Introduce privacy policy layers to mitigate bias at each stage of a build.
Provide continuous monitoring and feedback: Establish review processes and regularly audit with updated AI-enabled Privacy Impact Assessments (PIAs), especially on high-risk applications. Ensure reviewers are trained and have the authority to override A.I. decisions.
Know the data: Understand the types of data A.I. systems use, including training data, deployment data, and potential data embedded within A.I. models. Recognize how data flows, is processed, and is stored.
Enhanced Data Protection: It is essential to prioritize protecting sensitive data during A.I. processing. To achieve this, it is recommended to use privacy preserving A.I. techniques, such as differential privacy and federated learning. Ideally, these data engineering solutions should be integrated into the system’s original “plumbing” rather than being added on afterward.
Facilitate individual rights: Ensure that individuals can exercise their rights, such as data access, correction, and deletion, even in complex A.I. systems. Implement user-friendly processes for rights requests.
International Data Transfers
ProChek1 is headquartered in the United States, and almost all data we process will be accessed from the United States. Please see our Safeguards for more information on how we protect customer data in international transfers.
This means that we may transfer, access, or store personal information about you outside the European Economic Area (“EEA”), Switzerland, the United Kingdom, China, or another country requiring legal protections for international data transfer. When we do, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:
· We may transfer personal information to countries with privacy laws recognized by the country from which the data are transferred as providing similar protections for the data (“adequacy”).
· We may enter into written agreements, such as standard contractual clauses and other data transfer agreements, with recipients that require them to provide the same level of protection for the data.
· We may seek your consent to transfer your personal information for specific purposes.
· We may rely on other transfer mechanisms approved by authorities in the country from which the data are transferred.
Data Privacy Framework
ProChek1 participates in the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the U.K. Extension to the EU-U.S. Data Privacy Framework (U.K. Extension), and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), having self-certified to the U.S. Department of Commerce our adherence to the Data Privacy Framework Principles. ProChek1 is committed to applying the EU-U.S. Data Privacy Framework Principles and, as applicable to the United Kingdom (and Gibraltar), the Swiss-U.S. Data Privacy Framework Principles (as appropriate) to all personal information received from countries within the European Economic Area and as applicable the United Kingdom (and Gibraltar), Switzerland.
To learn more about the Data Privacy Framework, visit the website. Under the Data Privacy Framework, we are responsible for processing personal information we receive and subsequently transfer to a third party on our behalf. We are liable for ensuring that the third parties we engage support our DPF commitments. The U.S. Federal Trade Commission has regulatory enforcement authority and jurisdiction over ProChek1’s compliance with and processing of personal information received or transferred under the EU-U.S. Data Privacy Framework and the U.K. Extension to the EU-U.S. DPF (when practical), and the Swiss-U.S. Data Privacy Framework (when applicable). ProChek1 commits to cooperate and comply with the advice of the regulatory authorities to whom you may raise a concern about our processing of personal information under the Data Privacy Framework, including the panel established by the E.U. and U.K. authorities and the Swiss FDPIC. This is provided at no cost to you. Please see the section at the beginning about your rights.
Data Privacy Framework Inquiries & Complaints (data from the EEA, Switzerland, or the United Kingdom (and Gibraltar)
In compliance with the EU-U.S. DPF, the U.K. Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, ProChek1 commits to cooperate and comply, respectively, with the advice of the panel established by the E.U. data protection authorities DPAs, the U.K. Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) about unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, and, when practical, the U.K. Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
When practical, ProChek1 commits to cooperate and comply, respectively, with the advice of the panel established by the U.K. Information Commissioner’s Office (ICO), the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) about
unresolved complaints concerning our handling of personal data received in reliance on the U.K. Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. Under certain conditions, described more fully on the Data Privacy Framework website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Contact Us
If you have any questions about this Notice or our privacy practices, you can contact us by mail, telephone, or email:
ProChek1
3970 S. Green Brooke
PO 888162
Grand Rapids, Michigan 49588
Phone: 1-888-490-0963
Complete contact information of our privacy policy, including of our representatives where this is legally required, is available on our website. If you have concerns about how we handle your personal information, you have the right to complain about us to the privacy regulator in your country, state, or province. Please refer to this page for complaints under the GDPR, the UK GDPR, or the Philippines Data Privacy Act.
Changes to this Notice
We may revise this privacy policy from time to time and will post the date it was last updated at the top of this privacy policy. We will provide additional Notice to you if we make any material changes affecting your privacy rights.
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