Welcome to the proSapient Limited privacy notice (“Policy”).
proSapient Limited respects your privacy and is committed to protecting your personal data. This notice will inform you as to how we look after your personal data, including when you visit our website (regardless of where you visit it from), and tells you about your data protection rights and how the law protects you.
This notice aims to give you information on how proSapient Limited collects and processes your personal data, including any data we collect when you interact with us through our various channels online (such as our website at www.prosapient.com, our Industry Network of Experts (PINE), or via any other products and services we offer) and offline (such as over the telephone, in meetings or at events).
Our website(s), products and services are not intended for children and we do not knowingly collect data relating to children.
Prosapient Limited is the controller and responsible for all personal data we process from and about you through our various online and offline channels (collectively referred to as the “Company”, "we", "us" or "our" in this Notice).
We keep our notice under regular review. This version was last updated on the 18th of May 2023.
We may update our notice from time to time. We will notify you of any changes by posting the new notice on this page. You are advised to review this notice periodically for any changes. Changes to this notice are effective when they are posted on this page. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this notice, as required by applicable law.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or update this information directly where this is available to you. From time to time, we will ask you to confirm the accuracy of the personal data we process about you.
If you have any questions about this notice or our data protection practices, please contact us in the following ways:
Full name of legal entity: proSapient Limited
Email address: email@example.com
Postal address: 5th Floor, 33 Holborn, London EC1N 2HT.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Personal data means any information which relates to an identified or identifiable living individual.
There are three main types of individuals in respect of whom we collect personal data:
We collect, use, store and transfer different kinds of personal data about you:
This means you have freely agreed to our Terms & Conditions.
We process the following personal information (“Expert Information”), as it is necessary for our lawful purpose:
Who has access to your personal information?
What we do with your personal information?
This means you or your Company has signed a Client Agreement with us.
We process the following personal information (“Client Information”) as it is necessary for our lawful purpose and/or to perform a contract with you:-
Who has access to your personal information?
What we do with your personal information
We use your personal information to be able to manage and operate your engagements within the proSapient platform.
This means you have been contacted by a proSapient employee to offer consulting services.
We may process the following personal information (“Prospect Information”), as it is necessary for our lawful purpose:
Who has access to your personal information?
What we do with your personal information?
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
Experts - We collect expert data for the performance of the Expert Terms and Conditions you have consented to.
Prospects - We collect prospect data to contact you regarding the possibility of providing you with consulting opportunities.
Clients - We collect client data for the necessary performance of our contract with you.
You can withdraw your consent at any time by sending us an email at firstname.lastname@example.org.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Your personal data may be combined from these different sources for the purposes outlined below.
We will only use your personal data when the law allows us to. Most commonly, we rely on the following legal grounds to process your personal data for the following purposes:
Relying on our legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the instructions in the communication or contacting us at any time by emailing us at email@example.com.
Our Clients may elect to record and/or transcribe their consultations, calls and other interactions with Industry Experts. Where this is the case the recordings and transcriptions will be used by the Client for [legal and regulatory purposes, record keeping, quality control, or staff training purposes] or for other purposes. proSapient will also use these recordings and transcripts to develop and improve its Expert Network, for internal research and analytics and to improve business efficacies. Consent will be obtained to the extent this is required by applicable laws. As part of their compliance protocols, some Clients may have a professional (in addition to the Client user(s) chaperoning phone consultations and their presence may be announced or unannounced (i.e., the Industry Expert will not be notified) and may be active participants or silent on the phone consultations.
We may share your personal data with the parties set out below for the purposes that are described in this Privacy Notice or otherwise with your consent.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Further details are set out below.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see Section 9 to find out more about these rights. All these rights may be limited. Relevant exemptions are included in GDPR, UK GDPR and the Data Protection Act 2018. We will inform you of any relevant exemptions we rely upon when responding to any requests you make.
If you wish to exercise any of these rights, please contact us at firstname.lastname@example.org.
No fee is usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). For instance, the same principle applies to data deletion requests, for which we decide on a case-by-case basis what is needed to verify one’s identity depending on the type of information we have to delete – documents that are accepted as proof of ID can be i.e., ID, passport, driving license, etc. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In any case, we will confirm receipt of any email correspondence we receive from you as soon as possible.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you have any questions about this Notice or our data protection practices, including any requests to exercise your legal rights, please contact us at email@example.com.
For EEA Residents: Please contact our EU Representative by emailing firstname.lastname@example.org, telephoning +353 16319460 or writing to DPO Centre Europe Ltd, Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2.