1.    CHANGES. PBSepc may change this Policy from time to time in PBSepc’s sole discretion. Accordingly, PBSepc encourages you (“You” or “Your”) to review this Policy periodically. PBSepc shall post an announcement on the Website of any changes to this Policy. The most current version of this Policy shall be linked on the home page of the Website. 

This policy was last reviewed and updated 01/15.2020

2. INFORMATION COLLECTION, USAGE, AND DISCLOSURE.

PBSepc collects and processes certain information that may personally identify You (“Identifiable Information“).

            2.1 COLLECTION OF IDENTIFIABLE INFORMATION

PBSepc collects and processes the following Identifiable Information:

(a) Identifiable Information You give PBSepc. This is information about You that You give PBSepc by filling in forms on the Website or by corresponding with PBSepc by phone, e-mail or otherwise and includes [information You provide when You register to use the Website], [complete the Prospective Supplier Pre-Qualification Questionnaire] or [sign up to use the client portals]. The information You give PBSepc may include Your name, address, e-mail address, user name and password, phone number, Company Name, Job Title/Function, location and details of any comments or feedback You provide to PBSepc.

(b) Identifiable Information PBSepc collects about You. Concerning each of Your visits to the Website, PBSepc may automatically collect the following information:

[(i) technical information, including the Internet protocol (IP) address used to connect your computer or mobile device to the Internet, MAC addresses, traffic data, location data, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and cookies, which will be collected per PBSepc‘s Cookies Policy https://www.pbsepc.com/privacy-policy

(ii) details of Your visits to the Website and Your preferences and habits when using the Website; PBSepc will use this information to create a profile of You to enhance Your customer experience with PBSepc;

(iii) information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time), Your conduct via the Website and (where relevant) details of the fulfillment of any of Your orders, and any other site activity, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call PBSepc.]

            2.2 USAGE OF IDENTIFIABLE INFORMATION

(a) Identifiable Information You give PBSepc. PBSepc will use this information:

·to deal with your enquires and requests;

·to establish and maintain Your registration information;

·to notify You about changes to any of PBSepc‘s services;

• [to provide You with information about services PBSepc offers that are similar to those that You have already purchased or enquired about, as further detailed in the ‘Marketing’ section below];

·to provide You with customer support; and

·to ensure that content from the Website is presented most excellently for You and Your computer.

 (b) Identifiable Information PBSepc collects about You. PBSepc will use this information:

·[to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to improve the Website to ensure that content is presented most excellently for You and for Your computer

·to allow You to participate in interactive features of the Website when You choose to do so;

·to measure or understand the effectiveness of marketing to You and others, and to deliver relevant marketing communications about PBSepc services and offerings to You where permitted; and/or

·to make suggestions and recommendations to You and other users of the Website or PBSepc‘s services about goods or services that may interest You or them.]

2.3 USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS.

PBSepc relies on the following conditions to process Your Identifiable Information:

• To allow PBSepc to exercise its legitimate interests as a data controller: PBSepc relies on its legitimate interests as a data controller to process the Identifiable Information that You provide to PBSepcas part of Your registration and on contact/feedback forms and to process the Identifiable Information that PBSepc collects from You when You use the Website. It is in PBSepc‘s legitimate interests as a business to process the above information to provide you with information and updates concerning PBSepc‘s services and ongoing projects, to administer the Website, to ensure that content from the Website is presented to You effectively and securely, and to run promotional features.
• To allow PBSepc to perform its contract with You: If You successfully register with PBSepc as a trusted supplier or sub-contractor, PBSepc may enter into a contract with you for the provision of goods and/or services. For PBSepc to fulfill PBSepc‘s obligations under such a contract, PBSepc will need to collect and process Your Identifiable Information.

2.4 RETENTION OF YOUR INFORMATION.

[PBSepc will retain Your Identifiable Information for the period necessary to fulfill the purposes for which the information was collected. After that, PBSepc will delete it.

The retention period may vary depending on the purposes for which the information was collected. Where a specific legal or regulatory requirement applies to Your Identifiable Information, PBSepc will retain it for the period of time specified in such legal or regulatory requirements. In the absence of a specific legal or regulatory requirement, PBSepc will retain Your information for 10 years following the event to which it relates (e.g. the specific project, inquiry, etc). PBSepc may be required to extend the retention period if the information is required due to a complaint or because it is required for litigation. Please also note that PBSepc is sometimes legally obliged to retain the information, for example, for tax and accounting purposes.]

2.5 DISCLOSURE OF YOUR INFORMATION. PBSepc will not share Your Identifiable Information with third parties, save as follows:                       

• with PBSepc‘s business partners, product and services suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
• with PBSepc’s parents, subsidiaries, and sister companies for the purposes of marketing and only where You have provided Your consent, as described below; 
• with analytics and search engine providers that assist PBSepc in the improvement and optimization of the Website and other selected third parties;

PBSepc may also share Identifiable Information with law enforcement / regulatory authorities, other government officials and/or PBSepc‘s legal and professional advisors in order to (1) protect or defend the legal rights, property, safety, or security of PBSepc or anyone else, (2) protect against fraud or for risk management purposes, (3) comply with a legal process, legal requirement, judicial proceeding, or court order, (4) investigate a possible crime, such as fraud or identity theft, or (5) as required by law. 

PBSepc may also share Identifiable Information in connection with the (actual or potential) sale, purchase, merger, reorganization, liquidation, or dissolution of PBSepc.

PBSepc does not sell any customer or prospect data but may use such data for measurement or enhancement of customer experience in marketing or sales endeavors. PBSepc does utilize partners in the analysis of web traffic and social media data, but those partners are held to the same standards as PBSepc. Data ownership of web and social interactions occurring on PBSepc sites/platforms are the sole property of PBSepc.

            2.6 SECURITY. PBSepc takes reasonable precautions to protect Identifiable Information and has put in place certain processes and procedures to prevent unauthorized access of Identifiable Information. Unfortunately, there is always a potential risk in sending information through any channels, and PBSepc cannot guarantee that communications between You and PBSepc, including Identifiable Information, shall be free from unauthorized access by third parties. PBSepc shall not be held responsible (i) for any unauthorized access or illegal or unauthorized use of information, including Identifiable Information, or (ii) if Your information, including Identifiable Information, is accessed through unauthorized or improper use of Your account or login information or due to Your failure to secure Your username, password, or customer ID.

2.7 STORAGE OF YOUR INFORMATION. The data that PBSepc collects from You may be transferred to and stored at, a destination outside the European Economic Area (“EEA“). It may also be processed by staff operating outside the EEA (for example, in the United States), who works for PBSepc or one of PBSepc‘s suppliers. 

When we send Your data to a destination outside the EEA we will make sure suitable safeguards are in place, in accordance with European data protection requirements, to protect the data. In all cases these safeguards will be one of the following:

• Sending the data to a country that’s been approved by the European authorities as having a suitably high standard of data protection law.
• Putting in place a contract with the recipient containing terms approved by the European authorities as providing a suitable level of protection.
• Sending the data to an organization that is a member of a scheme that’s been approved by the European authorities as providing a suitable level of protection. One example is the “Privacy Shield” scheme agreed between the European and US authorities.

More information on these safeguards can be found here: https://ec.europa.eu/info/law/law-topic/data-protection_en.

2.8 MARKETING

PBSepc may use Identifiable Information (including Your email addresses, phone numbers, and unique Device numbers) to send You promotional materials relating to PBSepc’s services that are similar to those that you have already purchased or enquired about. If You have not previously purchased or enquired about such services, PBSepc will not send You promotional materials without first obtaining your consent to do so.

If You want to stop receiving such promotional materials from PBSepc, then You should follow the applicable unsubscribe or opt-out instructions. 

PBSepc’s affiliates or business partners may also use Your personal information to contact You about other goods and services, provided that You have given Your consent.

You may withdraw Your consent to the use of any of Your personal information for marketing purposes, at any time by contacting PBSepc at info@pbsepc.com You will also be given the opportunity in each marketing communication to opt-out of future marketing communications.

3. LINKS TO OTHER SITES. The Website may contain links to other websites. Those other websites may not have the same privacy policy as PBSepc, and PBSepc is not responsible for the privacy practices of those other websites. When You visit those other websites, You should read their privacy policies. This Policy applies solely to the Website and the information collected by PBSepc through the Website.         

4. Your rights

You have certain rights in relation to Your Identifiable Information that is processed by PBSepc. These rights are listed below. These rights are not absolute and apply subject to certain conditions, as set out in applicable data protection laws. Your rights may include:

• the right to access personal data held by PBSepc about You;
• the right to require PBSepc to rectify any inaccurate personal data held by PBSepc about You;
• in certain circumstances, the right to require PBSepc to erase personal data held by PBSepc about You;
• in certain circumstances, the right to restrict PBSepc‘s processing of personal data held by PBSepc about You;
• in certain circumstances, a right to receive personal data that You have provided to PBSepc in a structured, commonly used and machine-readable format. You may also have the right to require PBSepc to transfer this personal data to another organization, at Your request;
• the right to object to PBSepc‘s processing of personal data held by PBSepc about You (including for the purposes of sending marketing materials to You); and
• the right to withdraw Your consent, where PBSepc is relying on Your consent to use Your personal data (for example, to provide You with marketing information about PBSepc’s services and products).

To request account maintenance or changes or to update billing information, send Your email request to info@pbsepc.com. Otherwise, You can exercise the above rights by contacting PBSepc at info@bv.com

If You have any concerns regarding PBSepc‘s processing of Your Identifiable Information or are not satisfied with PBSepc‘s handling of any request by You in relation to Your rights, You also have the right to make a complaint to your relevant data protection authority. If you are located in Fort Lauderdale FL, then this is the Information Commissioner’s Office. Their address is:

First Contact Team

Information Commissioner’s Office