General Privacy Notice

General Privacy Notice


Last Updated 06/02/2024

Pontoon Solutions (including Pontoon Solutions, Inc. and/or its applicable affiliated companies such as, but not limited to: Pontoon Europe Limited; Pontoon Philippines, Inc.; Pontoon Singapore Pte. Ltd.; Pontoon Australia Pty Ltd; Pontoon Germany GmbH; and PONTOON (France)) (“Company”, “we”, “us”, “our”) is committed to protecting and respecting your privacy.

This General Privacy Notice describes our privacy practices in relation to the information we collect from you when you visit our website, which is accessible at https://www.pontoonsolutions.com, or when you access or use any applications or features made available by us on or through or in connection with this Website (collectively, the “Website”).

Note that when we collect Personal Data (defined below) from or about you in connection with a potential job opportunity, our Candidate Privacy Information Statement also applies and should be looked at. You can read our Candidate Privacy Information Statement by visiting here.

Note that when we collect Personal Data (as defined below) from or regarding you in relation to potential business engagements, our Client and Prospect Privacy Notice also applies and should be referenced. Please read our Client and Prospect Privacy Notice.

Index

Personal Data we may collect from you in using this Website

Sensitive Personal Data

How we use your Personal Data

Do we make any automated decision-making or profiling on you?

How long do you keep my Personal Data?

Sharing with third parties

Cookies and automated technology

Data Security

Do we transfer or store your Personal Data outside your home country?

Your rights

Children’s privacy

Changes to this General Privacy Notice

Contact

Personal Data we may collect from you in using this Website

When you visit and interact with this Website, we collect information about you, including Personal Data. “Personal Data” means information that identifies or relates to you, or as defined under applicable law.

Categories of Personal Data we collect about you:

  • Identity Data: including your first name, middle names, maiden name, last name, marital status, title, date of birth,gender; 
  • Contact Data: including your email address, telephone number, physical address, and online user account details.
  • Professional Information: including your job title, email address, phone number and addresses; 
  • Professional History: including your previous positions and professional experience;
  • Education and Qualifications: Information pertaining to professional qualifications, educational background, and salary.
  • Marketing and Communications Data: including information on when you receive and read marketing communications from us, which of our events you attend and marketing and communication preferences.
  • Profile Data: includes information about you, provided by you on our electronic portals and platforms including your usernames and passwords, purchases or orders made by you, your interests, biography, profile settings, marketing and communication preferences such as your preferred language of communication and content, alert and display preferences, content type and frequency of email alerts, content that interests you (including sectors, topics and jurisdictions), date of registration and current stage of registration, account status and level of access, and information from forms you fill in including responses to surveys and feedback provided;
  • Usage Data: includes information about your use of our Website, our electronic portals and platforms, as well as our local area networking facilities (including WiFi) and similar electronic services, such as interactions with our mobile applications, information collected progressively when you visit our Website, electronic portals and platforms, including your referral website, pages you visit, actions you take, information on last viewed/visited site and details of the content viewed including when and how many times the content was viewed, patterns of page visits, time details per visits (e.g. visit duration, number of visits, time spent on each page, frequency of visits), details about the path followed with special reference to the sequence of pages visited, interactions, functionalities and modules used, chat messages; 
  • Technical Data: includes technical information collected when you access our Website, our electronic portals and platforms which we offer or which we have agreed with you to use, including your internet protocol (IP) address or domain names of the devices utilised, your login data, browser type and version, uniform resource identifier (URI) address, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you are using;
  • Any other Personal Data voluntarily provided or obtained in accordance with applicable law.

The following identifies how we collect Personal Data about you:

    1. Online forms and accounts: We collect data when you complete online forms or create accounts on our Website.
    2. Communications with us online: We collect any Personal Data you provide to us when you use our contact forms or communicate with us online.
    3. Marketing: We collect information for marketing purposes and analysis, including your responses to marketing campaigns and feedback provided through satisfaction surveys.
    4. Your company’s needs: We collect data about you in connection with your company’s employment or other needs, including when you express interest in our services.
    5. Social media, online forums, blogs, message boards: We collect Personal Data and other information about you when you interact with us through social media platforms and other public locations.
    6. Career opportunities: We collect Personal Data and other information from you when you apply for a career opportunity with or through us.

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Sensitive Personal Data

When you visit or interact with our Website, you are not required to submit information that may be considered sensitive, including your race or ethnic origin or data concerning your health or sexual orientation. 

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How we use your Personal Data

We collect and use the information or Personal Data we collect from or about you for the following business purposes:

Purpose and/or activity  

Type of data

Legal basis for processing

To provide you, our clients and prospective clients, and our candidates and prospective candidates with our services.

 

  • Identity Data
  • Contact Data
  • Profile Data
  • Professional Information
  • Usage Data
  • Marketing and Communications Data

 

Legitimate interests: providing you with an access to requested services .

To best tailor content and resources according to your preferences and that the content provided through the Website is presented in the most effective manner for you and for your device.

  • Identity Data
  • Contact Data
  • Profile Data
  • Professional Information
  • Technical Data
  • Usage Data 
  • Marketing and Communications Data

 

Legitimate interest: analysing how our electronic portals and platforms are used, optimising our electronic portals and platforms, identifying areas of interest of our clients, gaining understanding of which content is most valuable to users

 

To respond to your requests or questions when you contact us.

 

  • Identity Data 
  • Contact Data 
  • Profile Data 
  • Usage Data 
  • Technical Data 
  • Marketing and Communications Data 
  • Professional Information

 

Legitimate interests: ensuring that you are provided with the best services

To allow you to participate in interactive features of our Website, when you choose to do so.

 

  • Technical Data
  • Usage Data

 

Legitimate interests: ensuring Website visitors have the best user experience.

 

To further develop and improve the Website, and systems to better serve you. This mainly takes place in the context of new IT systems and processes so that information about you may be used in the testing of those new IT systems and processes.

 

  • Technical Data
  • Usage Data

 

Legitimate interests:  ensuring the efficient and secure running of the Website, including through maintaining information technology services, network and data security 

 

Where necessary, to comply with any legal obligation.

 

  • Identity Data
  • Contact Data 
  • Professional Information 
  • Professional History 
  • Special Categories of Personal Data 

 

Legal or regulatory obligation 

 

For our business contacts, to attempt to establish or strengthen a business relationship with you. This may include, for example, informing you how we can assist you with our services.

 

  • Identity Data
  • Contact Data 
  • Profile Data 
  • Usage Data
  • Technical Data 
  • Marketing and Communications Data 
  • Professional Information
  • Education and Qualifications

 

Legitimate interests: ensuring the efficient and secure running of our business

We also may use your Personal Information in:

Investigating or responding to incidents and complaints, and/or

Complying with investigations carried out by the police, government or regulators.

 

  • Identity Data
  • Contact Data 
  • Profile Data 
  • Usage Data
  • Technical Data 
  • Marketing and Communications Data 
  • Professional Information
  • Education and Qualifications
  • Special Categories of Personal Data

 

 

Legitimate interests: reviewing how clients use, and what they think of, our services and improving them.

 

Legal or regulatory obligation

 

To send you direct messaging or marketing via email, text message, and/or other communication means. You may opt-out of receiving future messaging or marketing communications at any time by emailing us using the information listed in the “contact” section below. Messaging and data rates may apply for any sms, mms, and other electronic communications (typically, this is based on your carrier and service plan). For more information, please visit our terms of use.

  • Identity Data 
  • Contact Data 
  • Profile Data 
  • Usage Data 
  • Technical Data 
  • Marketing and Communications Data 
  • Professional Information 
  • Professional History

 

Legitimate interests: promoting our services, identifying ways to grow our business

 

To perform analytical research on our prospective client and candidate base, including the content, and the services/products in which they are interested.

 

  • Identity Data
  • Contact Data
  • Professional Information
  • Profile Data
  • Usage Data
  • Marketing and Communications Data 

 

Legitimate interest: identifying ways to grow our business by targeting our business development initiatives and marketing activities more effectively

 

To transfer data to third parties (see the “Sharing with third parties” section below).

 

  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data 
  • Professional Information
  • Education and Qualifications
  • Special Categories of Personal Data

 

 

Legitimate interests: ensuring the efficient and secure running of our business.

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Do we make any automated decision-making or profiling on you?

We may at times make automated decisions, use of automated decision-making is to ensure we give you a bespoke experience with us. Our automated decisions are profiles we have created, based on a user’s past behaviour, combined into a scoring model. For example, we use automated decisions to enhance your experience with the Websites.

We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Notice for further details.

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How long do you keep my Personal Data?

We retain your Personal Data for as long as necessary to fulfil the purposes set out in this General Privacy Notice in accordance with applicable legal and regulatory requirements.

The retention periods of your Personal Data depend on the respective purpose the information is processed for and the respective tool such Personal Data are processed in. It is not possible to provide the various retention periods in a reasonably intelligible format under this Notice. The criteria used to determine the applicable retention period are that we will retain the Personal Information set out in this Notice for as long as (i) necessary for the respective purpose, (ii) necessary to carry out our business relationship with you, (iii) you have consented to, and/or (iv) required by applicable statutory retention laws.

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Do we share your data with third parties?

We share your personal data with the following third parties below for the reasons also set out below:

Recipient

Reason for sharing

Suppliers

We engage engage a supplier to carry out administrative and operational work in support of our relationship with you. The supplier(s) will be subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and will only have access to the data they need to perform their functions; the relevant suppliers are typically IT suppliers (who host or support our IT systems, including information about you), premises management companies (who look after physical security at our buildings, and therefore need to know about you to allow access to our buildings) and back office finance and accounting management providers (who need to handle details of candidates in order to process accounts payable and receivable).

 

To other members of The Adecco Group

We are part of “The Adecco Group”.The Adecco Group companies perform a range of services including but not limited to temporary staffing and direct hire placement services, payroll services, recruitment and selection services, testing solutions services, career transition services, talent development services, training and education services, outplacement and international mobility services. We may share your Personal Data with other members of The Adecco Group for different reasons:

    • information is shared with members of The Adecco Group that provide IT functions for The Adecco Group companies world-wide;
    • information may be shared with other affiliate companies of The Adecco Group locally and/or globally in furtherance of the services we or The Adecco Group provides. A list of the countries in which we operate is available in the ‘choose your country’ function of our website at www.adeccogroup.com.

 

Government & law enforcement

We may share your Personal Data with government, regulators or law enforcement agencies if, at our sole discretion, we consider that we are legally obliged or authorized to do so or we believe it would be prudent to do so; and/or

 

Corporate reorganization

As part of due diligence relating to (or implementation of) a merger, acquisition or other business transaction, we may need to disclose your Personal Data to the prospective seller or buyer and their advisers.

 

We do not sell your Personal Data to third parties.

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Cookies and automated technology

Automatic Data Collection—In addition to collecting Personal Data, we may use automatic data collection technologies to collect certain statistical information about your equipment, browsing actions, and patterns. This includes (i) details about your visits to our Website, information about your computer/internet connection, and details of referring website actions and patterns.

Cookies—We may collect information from you using a “cookie.” “Cookies” are text files containing small amounts of information which are downloaded to your device (e.g. computer, smartphone, electronic device which accesses the internet) when you visit a website. Cookies help us track and understand how individuals use and interact with our Website. For more information on the types of cookies that we use and your ability to disable cookies see our Cookie Notice available at https://www.pontoonsolutions.com/en/cookies-policy.

Web Beacons—We use a technology known as web beacons to collect your web log information. Web beacons in e-mails help us determine which of our e-mail messages were opened and whether a message was acted upon. They also help us analyze the effectiveness of our web pages by measuring the number of visitors to certain pages of our Website and how many visitors click on key elements of it.

Social Media Plug-ins—Our Website uses social media plugins (“Plugins”) from the social networks such as Facebook, LinkedIn, Twitter, and Instagram to enable you to easily share information with others. We may use information collected from the Plugins to learn about your interests and to help us better understand how to serve you.

We offer ways to manage your online experience:

Disabling Cookies and Managing the Collection of Your Personal Data. At any time, you can disable cookies by adjusting your browser settings. Each browser is different, so please refer to the specific instructions related to your browser to learn more about cookie-related and other privacy and security settings that may be available to you.

Please note, by disabling cookies, you may not be able to take full advantage of the services offered by our Website. For more information, please visit our Cookie Policy at https://www.pontoonsolutions.com/en/cookies-policy/

Commercial E-mails, Newsletters, and Other Communications. Where we send marketing or other communications to you, you may opt out of receiving any further communications by contacting us or using the ‘unsubscribe’ or ‘opt-out’ function when available. You can also exercise your opt-out right at any time by contacting us using the information listed in the “Contact” section below and providing the following information: your name, your email address, a contact telephone number, the marketing communications you would like to opt out of receiving.

Please visit our Cookie Notice at https://www.pontoonsolutions.com/en/cookies-policy/.

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Do we transfer or store your Personal Data outside your home country?

When we share your personal data within Pontoon Solutions, this involves transferring your personal data outside the European Economic Area (“EEA”) and the United Kingdom.

Our business operates globally and therefore your personal data may be transmitted internationally. Where we do so, we will endeavour to ensure appropriate measures, as required by law, are in place to ensure the adequate protection of your Personal Data.

We shall only transfer data to parties who are outside the European Economic Area or UK:

  • to countries which the European Commission or the UK Information Commissioner believes offers an adequate level of protection pursuant to Art 45 of the UK and EU GDPR or;
  • where the Adecco Group has put in place appropriate safeguards to seek to preserve the privacy of your information.

For example, when personal data of EEA residents is transferred outside of the EEA we will use specific contracts approved by the European Commission (Standard Contractual Clauses) to ensure an adequate protection of the personal data.

Similarly, when personal data of UK residents is transferred outside of the UK we will use specific contracts approved by the UK Information Commissioner to ensure an adequate protection of the personal data.

Please contact us at privacy@pontoonsolutions.com if you would like further information or a copy of the specific mechanism used by us when transferring your personal data out of your country residence.

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Data Security

We have established appropriate security framework to help safeguard your personal data from accidental loss, unauthorised access, misuse, alteration, and unauthorised disclosure. Our appropriate information security policies, regulations, and technical measures have been implemented, considering the specific context and nature of processing, cost factors, and potential risks to individuals’ rights and freedoms. These technical and organisational measures include:

  • Pseudonymization and encryption of personal data.
  • Ensuring ongoing confidentiality, integrity, availability, and resilience of processing systems and services.
  • Establishing procedures for timely data restoration in case of technical or physical incidents.
  • Regular testing, assessment, and evaluation of the effectiveness of security measures.
  • Safeguarding all IT facilities to prevent damage, loss, or misuse.
  • Ensuring optimal security measures for our website.

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Your rights

You have certain legal rights with respect to the Personal Data that you provide and/or which we obtain about you depending on the country/state where you reside. For example, if you are a resident of the State of California, the California Consumer Privacy Act provides you with specific rights regarding your Personal Data. Additionally, by way of example, if you are a resident of the European Union, the General Data Protection Regulation (“GDPR”) provides you with specific rights regarding your Personal Data.

Under applicable data protection laws, you have the following rights: 

  • Right to access and obtain a copy of your personal information

You are entitled to request confirmation of whether we process any of your personal information. Where this is the case, you may have access to your personal information and to certain information about how it is processed. In some cases, you can ask us to provide you with an electronic copy of your information.

  • Right to the portability of your personal information

In some limited circumstances, you also have the right to request that we transfer (“port”) your personal information direct to another third party provider. 

  • Right to correct your personal information

If you can demonstrate that personal data that we hold about you is not correct, you can ask that this information is updated or otherwise corrected.

  • Right to be forgotten or to delete personal information (Right to be Forgotten)

In certain circumstances you have the right to have your personal data deleted. You may make such a request at any time and we will evaluate if your request should be granted, however this right is subject to any legal obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so within the required legal timeframes.

  • Right to restrict the processing of your personal information

In certain circumstances you have the right to obtain restriction of the processing of your personal information.

  • Right to object to the processing of your personal information

In certain circumstances you have the right to object to certain processing thereof on grounds relating to your particular situation. 

  • Right to withdraw consent

You have the right to withdraw consent at any time where we are relying on consent to process your personal information. 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.

  • Right to be informed about collection, sale or disclosure

You have the right to be informed of the categories of Personal Data that we collect about you as well as the categories of sources from which the Personal Data was collected. You also have the right to be informed of the business or commercial purposes for which we use, disclose, or sell, your Personal Data as well as the categories of third parties with whom we share that Personal Data, as set forth in this Privacy Notice.

  • Right to equal service for exercising your privacy rights

Unless permitted by applicable law, we will not discriminate against you when you exercise your privacy rights under the California Consumer Privacy Act or other applicable law, including by: denying you goods or services; charging you different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties; providing you with a different level of quality of good or services; or suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services.

To exercise your rights, please use the contact information listed in the “Contact” section below.

You can also lodge a complaint about our processing of your Personal Data with your local data protection authority or regulator, as applicable.

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Children’s privacy

Our Website is designed and intended for adults. By accessing and/or using our Website, you represent that you are a legal adult. If you are not a legal adult, you must have your parent or legal guardian access and use the Website for you. If you want to purchase any goods or services that may be offered on our Website, such purchase(s) must be made by your parent or legal guardian on your behalf.

Our Website is not intended for, and we do not knowingly collect information from or otherwise market our website or other materials to children under thirteen (13) years of age. If you are a parent or guardian of a child under the age of thirteen (13) and believe that he or she has disclosed Personal Data to us, please contact us using the information listed in the “Contact” section below. You may review and request the deletion of your child’s Personal Data or prohibit the further use of such information.

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Changes to this General Privacy Notice

The terms of this General Privacy Notice may change from time to time. We shall publish any material changes to this General Privacy Notice through appropriate notices either on this Website or contacting you using other communication channels. The date this General Privacy Notice was last revised is identified at the top of the page in the “Last Updated” legend.

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Contact

To exercise your rights with respect to your Personal Data (as applicable, such as a request to delete your data or to obtain a copy of the Personal Data we process in regards to you), please use the form at this link.

If you have any other questions, comments and/or requests regarding this Privacy Statement contact us by email at privacy@pontoonsolutions.com.

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German Residents

To exercise your rights with respect to your Personal Data (as applicable, such as a request to delete your data or to obtain a copy of the Personal Data we process in regards to you), If you have any other questions or comments and/or requests regarding this Privacy Statement contact us by email at datenschutz@adeccogroup.com.

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