Privacy Statement

Last Updated on June 26, 2024 and effective on March, 2017.

Introduction

This statement (the “Privacy Policy”) sets forth the privacy standards that Staffing Accountants, LLC; SA Professional Consulting; SAPRO Consulting Private Limited (India) and Bindz Consulting Private Limited (India) (d/b/a SAPRO) (together, “SAPRO”, the “Company(ies),” “us,” “we,” or “our”) utilize to collect, retain, and use personal data obtained from individuals using or accessing our website(s) located at www.sapro.com or mobile services or making use of any of the placement/ staffing services or management services or events offered by any of the Companies, physically and/or virtually (the “SAPRO Services” or “Services”).

This Privacy Policy also forms part of the SAPRO Terms of Use and/or Career opportunities and/or Contact Us and/or any services offered/ delivered by SAPRO and it applies to every person (“you”, “user(s)”,”he”, “she” “they”) who accesses or uses SAPRO’s online and/or mobile services and websites, including any software, service, feature, product, program and element provided by or on behalf of SAPRO in connection with such services or websites (collectively, the “Website”).

Introduction and purpose of the Privacy Policy

The SAPRO Services can be accessed at www.sapro.com. All intellectual property (including Our Website) is currently owned and operated by Staffing Accountants, LLC, New York, USA.

SAPRO is a full-service assurance, tax and advisory consulting / staffing augmentation / staffing management firm providing you with a world-class workforce perfectly optimized to meet your needs.

This Privacy Policy describes the way we collect, store, use, and protect personal information which you submit to us, either through the Website or other form of communication, whether digital or hard copy, in writing or verbally.

Please read this Privacy Policy and the Terms of Conditions before using the SAPRO Website or any of the services that we may offer.

Acceptance and consent

You accept all the terms in this Privacy Policy and Terms of Conditions when you use our Website or make use of any SAPRO Services and consent to us collecting and processing and storing the personal information as referred to in this Privacy Policy.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Services indicates your consent to the privacy policy posted at the time of use. It is your responsibility to consider the Privacy Policy each time you use our Website or the SAPRO Services.

International transfer

SAPRO is based in the U.S., South Africa and India, and the information SAPRO and its Service Providers collect is governed by the applicable law. If you are accessing the Services from outside of the U.S., please be aware that information collected through the Services may be transferred to, processed, stored, and used in the U.S. You expressly acknowledge and agree that your use of and access to any Services is governed by and subject to U.S. law and/or any applicable Law. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Services or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Information, in the U.S., South Africa, India and another other country as set forth in this Privacy Policy.

Privacy laws and protecting your Personal Information

We will take the necessary steps to protect your privacy, including as applicable, compliance with the Protection of Personal Information Act, 4 of 2013 ("POPIA") (for data subjects in South Africa), General Data Protection Regulations (“GDPR”) (for data subjects in the EU or EEA), Information Technology Act, 2000 (“IT Act 2000”) in conjunction with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”) (For data subject in India) and all reasonable steps to be in compliance with the applicable privacy laws governing data subjects outside of the EU/EEA, India and South Africa.

In this paragraph we provide information about the circumstances in which your personal data may be transferred to countries outside the EEA (Austria, Belgium, Bulgaria, Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom to the extent applicable) or Switzerland.

The Company has its principal place of business located at 3 Columbus Circle, 15th Floor, New York, 10019. The European Commission has made an "adequacy decision" with respect to the data protection laws of the United States. In the event the Company transfers any of your personal data to a third party in the United States or elsewhere outside of the EEA, such transfers will be protected by appropriate safeguards through the use of standard data protection clauses adopted or approved by the European Commission (the full list of these countries is available here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).

By providing your personal data to the Company and/or using our services, you are agreeing to the transfer and processing of your personal data to and in the United States in accordance with this Privacy Statement.

Your Rights - EU/EEA Data Subjects Only

In this paragraph, we have summarized the rights that EU/EEA data subjects have under applicable data protection law, including the GDPR. Some of the rights are complex, and accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection laws are:

  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent under certain circumstances.

If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Statement, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request, or your request to exercise any of your rights in relation to your personal data by written notice to us at the address provided herein. We have listed your rights that you have under data protection laws under GDPR and South Africa Privacy laws.

In addition to the above, you can learn more about the rights of data subjects subject to the GDPR by visiting: https://edps.europa.eu/data-protection/data-protection/legislation_en , relating to POPIA by visiting: https://inforegulator.org.za/ .

Personal Information we may collect

The term “personal information” refers to any information that may identify a person such as a name, surname, identity number, contact number, email address, religion, medical history, education, financial or any other information that is unique to an individual.

As used in this Privacy Policy, personal information we may collect from you on or through the Website or SAPRO Services may include, without limitation: your full name, surname, IP address, email address, age, race, gender, nationality, identity number, passport and visa details, photographs which identify you, personal contact details, work and schooling history when connected with other personal information, and your address or other location data.

Collecting your Personal Information

We collect information about you when you use our Website and communicate with us.

We may collect all types of personal information about you as described above. By using the Website and/or the SAPRO Services, you agree that we may collect and process all such personal information that you provide to us or that is provided to us on your behalf, to enable us to provide the SAPRO Services.

Please do not supply the following to us:

  • Any other person's personal information, unless the Company explicitly asks you to do so;
  • Any categories of your personal information that have not been explicitly requested by the Company;
  • Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by the Company to provide; and
  • Any confidential, proprietary, secret or legally protected information which are under any legal obligation to not provide to or share with the Company.

SAPRO may collect and store personal information from you in connection with:

  • providing the SAPRO Services or any other service/ product which SAPRO offers;
  • creation of your user profile as an Applicant and verification of your profile;
  • communicating with you about employment and/or secondment and/or staffing/ placing opportunities;
  • visits or browsing on the Website; and
  • Tracking of referrals that you make.

When you apply on the Website, you provide us with your e-mail address and your resume details, which contain your personal information. By providing us with this information, you consent to us collecting and processing your personal information in order for you to make use of and to allow us to provide and optimise the SAPRO Services for you.

We may also collect information about you from third parties. For example, you will be able to register and initiate the application process using Linked-In. To this end, the Website will be linked via your secure log-in portal to your Linked- In profile page. You consent to this integration and to SAPRO accessing and importing information from your Linked-In profile, such as profile picture and employment history, in order to create your SAPRO Applicant profile for presentation to appropriate/ prospective Clients’ of SAPRO or for SAPRO internally.

Privacy of Children Who Visit the Website.

We recognize the importance of children’s safety and privacy. Neither the Website nor the SAPRO Services are for use by, nor designed to attract, anyone under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are under age 18, you do not have permission to use the Website or the SAPRO Services. If we learn that we have collected personal information of a child under 18, we will take the appropriate steps to delete such information from our files as soon as reasonable practically possible.

Use of Cookies

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are widely used because they allow a website to recognise a user’s device and therefore allow enhanced functionality. You can find out more information about cookies at: www.allaboutcookies.org .

SAPRO, inter alia, uses cookies for the following purposes:

  • to compile statistical data on the use of our website and its functioning, so that we can monitor and improve it;
  • to facilitate users’ ability to navigate through our website, including allowing registered users to access secure parts of our website;
  • to allow us to optimize our advertising on 3rd party advertising platforms such as social media; and
  • to allow us to reduce malicious traffic to donation pages.

Please note that some cookies can be set by 3rd party content providers in content that is embedded in our site.

If you do not wish to receive cookies, you can set your web browser to restrict or block them. All modern browsers allow you to change your cookie settings, typically be found in the ‘options’ or ‘preferences’ menu of your browser. In order to understand these settings, the following link may be helpful: www.aboutcookies.org .

Definitions

First Party/ Third party cookies

Refers to the web domain placing the cookie. First-party cookies are those set by a website that is being visited by the user at the time – the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets the cookie through that website, this would be a third-party cookie.

Persistent cookies

These cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

Session cookies

These cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

Pixel tags

A pixel tag is not technically a cookie but is a similar type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies. Information collected is anonymous.

We use, inter alia, both Facebook and Twitter pixel tags. Pixel tags are used to track conversion from social media to our website. See more information on Facebook here and Twitter here.

If you disable cookies you will not be able to use all the interactive features of our website.

Our service providers and vendors may use cookies and those cookies may be stored on your computer when you visit our website. These service providers and vendors include: Salesforce (www.salesforce.com) Hubspot (www.hubspot.com) Outreach (www.outreach.com) Google Analytics (www.google.com/analytics) Google Tag Manager (www.google.com/analytics/tag-manager) Google AdWords (https://adwords.google.com) Facebook ( www.facebook.com ) LinkedIn (www.linkedin.com) Wordpress (https://wordpress.com) Lightcast (https://lightcast.io/ ) Apollo.io (www.apollo.io )

You should review the privacy and cookie policies of the above websites to learn more about the cookies that are used in connection with the above.

Purpose, uses and disclosure of information

Personal information which you provide to us will only be used for the purposes listed in this Privacy Policy and the Terms of Use of the SAPRO Service.

SAPRO may use your Personal Information to:

  • provide the SAPRO Services and/or any other products and services to you, which may necessitate sharing your personal information with third party service providers located in the USA or your country of residence or any country that SAPRO is delivering their services;
  • manage its relationship with you and third-party service providers;
  • communicate with you about the SAPRO Services and any other products, services or support offered by us and to send marketing communications in connection these services and products;
  • provide support to you in respect of the SAPRO Services;
  • improve the SAPRO Services;
  • provide personalised offers;
  • measure performance of marketing initiatives;
  • allow you to participate in competitions and surveys;
  • answer enquiries, provide information, support or advice about the SAPRO and any new products or services offered;
  • assess and improve the performance and operation of the Website;
  • prevent and detect security threats, fraud or other malicious activity;
  • process and respond to any complaint made by or about you;
  • updating our records;
  • in connection with any application for employment;
  • internal analysis of our business;
  • any statutory or regulatory purpose which requires the processing of your personal information;
  • legal and regulatory compliance;
  • fraud and crime prevention;
  • third party transactions, sales or due diligence;
  • if required by any law enforcement agency or in connection with any legal requirement where we are required by law to present this;
  • internal or external audits; and/or
  • any other purpose for which valid consent is obtained.

Our website may connect to various social media sites or apps, including Facebook, Twitter, LinkedIn, Instagram and Google+. You should visit the privacy policies of such sites or apps if you are connected to them as each individual site’s or app’s privacy policy will govern your use and access to same.

We may transmit or transfer personal information to countries outside of your home country, whether that is the United States, South Africa, India or otherwise. By using the Website or the SAPRO Services, you are agreeing to such transfer.

SAPRO is not responsible and cannot be held liable for the privacy practices of such third parties.

Demographical and statistical information about user behavior may be collected and used to analyse the popularity and effectiveness of the Website. Any disclosure of this information will be in aggregate form and will not identify individual users.

Quality and protection of your information

You are responsible for the accuracy of the information submitted to us and for ensuring that it is up-to-date, complete and accurate. It is your duty to maintain your profile and the details of your resume that is provided to us.

SAPRO implements security measures to prevent the destruction, unlawful access and loss of personal information, including establishing appropriate physical, electronic and managerial procedures to safeguard the personal information collected from you. This helps prevent unauthorised access, maintains data accuracy and ensures that personal information is used correctly. In order to carry out these security procedures, SAPRO may ask for proof of identity before personal information is disclosed to you.

While we will use reasonable means to ensure the security of your personal information, however, there measures do not guarantee that your personal information will not be accessed, disclosed, altered or destroyed by breach of such security measures. By using our Website and/or Services, you acknowledge that you understand and agree to assume these risks and the other provisions of this Privacy Policy.

SAPRO will not be liable for any breach of the security of your personal information resulting from causes or events that are beyond our reasonable control, including, without limitation, your own act or omission, corruption of storage media, defects in third-party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for unauthorized circumvention of any privacy settings or security measures contained on the Website. You also agree to hold SAPRO harmless of any damages (direct and/or indirect) for any potential and/or actual breach and/or any consequential damages that flows from the breach.

How SAPRO stores information collected from you

Information, including your personal information, when used in the SAPRO’s systems/ IT environment is stored in SAPRO’s systems and/or SAPRO’s IT environment which may be based in various locations around the world including the USA.

Information is held for as long as you maintain a profile with SAPRO (until you request us to delete it) or as long as may be legally required.

Information which you provide to us will be stored electronically and/or in hard copy, with reasonable security measures protecting this information. However, please note that we work with third party contractors, some of which host and operate certain features on the Website. Therefore, information that SAPRO collects from you may be collected in or transferred to a destination outside South Africa/ Indian, including in the USA or any other such region as deemed appropriate from time to time and/or may be processed by employees/independent contractors operating outside South Africa who work for or are contracted to SAPRO. By submitting personal information to us, you agree to the transfer, storage and processing of your personal information as set out in this Privacy Policy. SAPRO will take all appropriate steps to ensure that your data and personal information is treated securely and in accordance with this Privacy Policy.

Accessing and changing information

SAPRO may provide web pages or other mechanisms allowing you to delete, correct, or update some of the SAPRO-collected personal information, and potentially certain other information about you (e.g., profile and account information). SAPRO will make good faith efforts to make requested changes in SAPRO’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from SAPRO’s databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data as required by applicable law; and for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

Your rights regarding promotional communications

You have the right to prevent us at any time from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. Please allow up to ten (10) business days for changes to your email preferences to take effect. During that time, you may continue to receive email communications from us that were already in process. You can also indicate that you do not wish to receive marketing communication from us by sending correspondence to the below email address. Opting out of receiving our communications will not affect your receipt of service-related communications, such as if you request information from us, or if we have a data breach, or other such communications for which we have a legal obligation to inform you and/or to prevent fraud or harm to our Website, our business, and/or third parties.

Your California Privacy Rights

We collect various types of personal information about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us about how we have shared your information with third parties for their direct marketing purposes. Kindly see appendix A for the Privacy Notice for California residents.

Details of relevant contact details

POPIA (South Africa) related questions/ queries/ notices:

E-mail Address: data.privacy@sapro.com

Postal address: Block B, Knightsbridge Office Park, 33 Sloane Street, Bryanston, 2191

The data protection officer and/or grievance officer and/or complaints and/or contact us about anything to do with your personal data and data protection:

E-mail Address: data.privacy@sapro.com

Postal address: 3 Columbus Circle, 15th Floor, New York, NY 10019.

 

Appendix A

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

The following applies to you only if you are a California resident.

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. We do not share any Personal Information with third parties or corporate affiliates for direct marketing purposes.

Please note the following:

  • Users can visit the Sites anonymously without providing their Personal Information, but we may collect Personal Information, such as IP addressed, automatically through the use of cookies or other tracking technologies.
  • We will add a link to this Privacy Notice on our home page, or at a minimum, on the first significant page after entering the Sites.
  • Our Privacy Policy link includes the word “Privacy” and can easily be found on the page specified above.
  • Users will be notified of any privacy policy changes on our Privacy Policy page.
  • Users are able to change their Personal Information by emailing us or by calling us.
  • Some Internet browsers include the ability to transmit “Do Not Track” signals that give you control over the collection and use of web browsing information. Because uniform standards for “Do Not Track” signals have not yet been adopted, we do not process or respond to such signals in users’ web browsers at this time; and
  • We allow the collection of users’ behavioral tracking by third parties for analytical purposes only.

Your Rights and Choices

The California Consumer Privacy Act (“CCPA”) provides consumers who are California residents with specific rights regarding their Personal Information.

Right to Know About Personal Information Collected, Disclosed, or Sold

As a California consumer, you have a right to request what Personal Information we collect, use, disclose, and sell.

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request as described below, we will disclose to you:

  • The categories of Personal Information we collected about you
  • The categories of the sources for the Personal Information we collected about you
  • Our business or commercial purpose(s) for collecting or selling that Personal Information.
  • The categories of third parties with whom we shared that Personal Information.
  • The specific pieces of Personal information we collected about you

In addition, if we sold or disclosed your Personal Information for a business purpose, we will provide you with two separate lists disclosing:

  • Disclosures for a business purpose, identifying the Personal Information categories disclosed that each category of recipient obtained.
  • Sales and/or disclosures for a commercial purpose, identifying the Personal Information categories that each category of each category of recipient obtained; and

Right to Request Deletion of Personal Information

As a California consumer, you have the right to request that we delete any or all of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request to delete your Personal Information if retaining the Personal Information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of the Sale of Personal Information

As a California consumer, you have the right to opt-out of the sale of your Personal Information. We do not sell any Personal Information.

Right to Non-Discrimination if You Exercise any of Your Rights

As a California consumer, you have the right not to be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, if you exercise any of your California rights, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights to Know and to Delete

To exercise your rights to know and/or to delete described above, please submit a verifiable consumer request to us by either:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or your authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with your Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We will confirm receipt of your verifiable consumer request within ten (10) days and provide you with information about how we will process the request, describing our verification process and when you should expect a response. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period immediately preceding our receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is useable and should allow you to transmit the information from one entity to another entity.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Information We Collect from California Consumers

We collect Personal Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal Information does not include:

  • Publicly available information that is lawfully made from federal, state, or local government records.
  • Deidentified or aggregated consumer information
  • Medical information or protected health information governed by California and federal health information privacy laws.
  • Clinical trial information subject to the Federal Policy for the Protection of Human Subjects (the Common Rule)
  • Personal information regulated by the Fair Credit Reporting Act (FCRA)

Within the last twelve (12) months, we have collected the following categories of Personal Information from California consumers through our Sites. Some of the categories may overlap with each other:

Category of Personal Information

Examples

Collected

A. Identifiers

A real name, postal address, unique personal or online identifier, Internet Protocol (IP) address, email address, telephone number

YES

B. Personal Information described in the California Customer Records statute (Cal.Civ.Code §1798.80(e))

All of the Identifiers listed above, plus:

Signature, social security number, physical characteristics or description, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information

YES

C. Legally Protected Characteristics

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)

NO

D. Commercial information

Records of services obtained or considered

YES

E. Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or similar network activity

Browsing history, search history, information regarding a consumer's interaction with a website, mobile application, or online advertisement

YES

G. Geolocation data

Physical location or movements

NO

H. Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information

NO

I. Employment information

Professional or employment-related information

YES

J. Education information, defined as nonpublic personally identifiable information under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g and 34 C.F.R. Part 99)

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records

NO

K. Inferences drawn of other categories of Personal Information

A profile created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

YES

 

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from our Users. For example, from information that you provide to us through our online forms, email, or other means.
  • Indirectly from activity on our Sites. For example, from website usage details collected automatically.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to respond to an inquiry.
  • To provide you with information or services that you request from us.
  • To provide you with email alerts and other notices concerning our services, events or news that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our Sites and present the contents to you.
  • For testing, research, and analysis
  • As necessary or appropriate to protect the rights, property or safety of us, our Users, or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information or as otherwise set forth in the California Consumer Privacy Act (CCPA)
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

We do not disclose any Personal Information collected through our Sites for a commercial purpose.

We will not collect additional categories of Personal Information through our Sites or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your Personal Information to a third party for a business and/or commercial purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a business purpose:

Category A: Identifiers.
Category D: Commercial information
Category F: Internet activity

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a commercial purpose:

NONE

We disclose your Personal Information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Our service providers
  • Third parties to whom you authorize us to disclose your Personal Information in connection with services we provide to you.

In the preceding twelve (12) months, we have not sold any Personal Information.

Grievances and Complaints

Under California Civil Code Section 1789.3, residents of California who use this Website are entitled to know that they may file grievances and complaints with: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210, or by email at dca@dca.ca.gov.

Contact for More Information

If you have any questions or concerns about our Privacy Policy or this Notice regarding your privacy or Personal Information, please contact us at data.privacy@sapro.com .

Date last updated: May 17, 2023.

Your Access to and Control Over Information

You may opt-out of any future contacts from us at any time by clicking on the unsubscribe link on communication from us. If you wish to update your subscription information now, you may do so by clicking the 'manage my subscription' link at the bottom of any marketing or sales emaill from us.

Under the POPI Act (South Africa) and GDPR (and other European data protection laws), including the UK, and Switzerland you have the right to object to our processing of your personal data. You may exercise those rights by filling out the form on this page. We will honour your request by removing your profile from our services, and we will retain the email address you enter for purposes of storing and respecting your opt-out preference.