Online privacy statement
1. Before or at the time of collecting personal information, we will identify, directly or indirectly, the purpose for which the information is being collected;
2. We will collect and use personal information by lawful means with the sole objective of fulfilling those purposes specified by us or as required by law, and we will only retain personal information as long as necessary for the fulfillment of those purposes;
3. We will protect personal information by reasonable security safeguards against loss or theft as well as unauthorized access, disclosure, copying, use or modification;
4. We will not sell or rent any identifiable personal information to any third party;
6. We may collect information about your computer hardware and software, such as your browser type, IP address, domain names, use and access times, and referring website addresses, if applicable, for purposes of operating and maintaining the quality of our service; and
7. PTS is fully committed to conducting our business in accordance with the foregoing principles in order to ensure that the confidentiality of personal information is protected and maintained.
Under the European Union’s (“EU”) General Data Protection Regulation (“GDPR”), personal data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information
PHOENIX TECHNOLOGY SYSTEMS INC. (or “PTS,” “we,” “us,” or “our”), as a data processor, is a U.S. based company which hosts a web and mobile-based time and expense storage and reporting system (“Phoenix”) on its secure server in order to record time and expenses for its clients (the “data controllers”). Naturally, Phoenix stores data fields to enable the entry and approval of time and expenses. These data fields are provided by PTS clients, who contract workers to provide services. We process your personal data based on the documented instructions of clients. This personal data typically includes biographical information (such as first and last name), company name and personnel number, contact information (such as email and postal addresses), and IP address.
Why does PHOENIX TECHNOLOGY SYSTEMS INC. need to collect and store personal data?
In order to allow clients to utilize Phoenix, we need to collect personal data in order to record time and expenses for clients. We may also use the personal data we receive in order to respond to requests or questions or send appropriate communications as instructed by clients. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy.
Will PHOENIX TECHNOLOGY SYSTEMS INC. share my personal data with anyone else?
We will NOT pass your personal data on to third parties, including service providers contracted to PTS, in the course of dealing with you. However, PTS shares personal data with our cloud hosting service in order to enable service functionality. We require this provider to maintain at least the same level of confidentiality that we maintain for your personal data. PTS remains liable for the protection of your personal data that our provider may access, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing.
How will PHOENIX TECHNOLOGY SYSTEMS INC. use the personal data it collects about me?
PTS will process (collect, store and use) the information you provide in a manner compatible with the GDPR and similar applicable regulations, such as the United Kingdom GDPR. We will keep your information accurate and up to date, and not keep it for longer than is necessary. PTS is required to retain information in accordance with the law, such as information needed for audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held for longer than these periods depending on individual business needs.
Under what circumstances will PHOENIX TECHNOLOGY SYSTEMS INC. contact me?
PTS may contact you in order to resolve service issues, respond to your requests or questions, or send you updates or marketing communications. Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.
Can I find out the personal data that the organisation holds about me?
PTS, at your request, can confirm what information we hold about you and how it is processed. If PTS does hold personal data about you, you can request the following information:
Identity and the contact details of the person or organization that has determined how and why to process your data. In some cases, this will be a representative in the EU or the United Kingdom.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of PTS or a third party, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
If we intend to transfer the personal data to a third country or international organization, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, and in cases of data transfer from the United Kingdom, we will ensure there are specific measures in place to secure your information, such as the approved Standard Contractual Clauses.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority.
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
You may also have the right to correct, amend, or delete your information. Please contact us through the contact information below if you wish to do so.
What forms of ID will I need to provide in order to access this?
PTS may provide you information on your personal data where a request includes Client approval notification along with a government issued identification card.
PHOENIX TECHNOLOGY, Inc.’s GDPR Compliance Efforts and You
At PTS, we are well aware of the data protection requirements brought about by the GDPR, which took effect on May 25, 2018. We’re proud to announce that PTS’s services have been reviewed and modified to address its GDPR obligations. In addition, PTS has undertaken compliance efforts to address requirements of the United Kingdom GDPR.
Let’s talk a little bit about the GDPR and United Kingdom GDPR and what to expect from us.
What Is the GDPR?
The GDPR is an EU regulation intended to harmonize, update, and strengthen data protection laws in the EU. It’s a comprehensive privacy law that aims to protect the personal data—and rights related to that data—of persons residing within the EU. The GDPR defines personal data as “any information relating to an identified or identifiable natural person.” What constitutes personal data is interpreted broadly by regulators. Name, home address, email address, and identification card number are obvious examples of personal data, but the term can also include geolocation data, IP address, cookie ID and device identifiers, among many other types of data.
Although promulgated by the EU, the GDPR has global impact. Practically speaking, nearly every organization that collects or processes the personal data of EU residents or monitors their behavioral activity is now required to comply with the GDPR, whether or not such companies have any physical or legal presence in the EU. The United Kingdom has also adopted a version of the GDPR modified to apply to the processing of United Kingdom resident personal data (the “United Kingdom GDPR”).
How Is PTS Complying with the GDPR?
As the initial step in our GDPR and United Kingdom GDPR compliance initiative, we mapped our information systems to create a dashboard view of our IT systems, our data, and our data flows, with an emphasis on privacy impacts. We’re taking steps to ensure that our information systems and processes allow us to adequately and efficiently respond to individuals exercising their data privacy rights, and that these systems and processes allows us to demonstrate compliance with the new regulation.
We have finalized a Data Processing Addendum (“DPA”) for our clients in order to meet the data processing and transfer requirements of the GDPR and United Kingdom GDPR. The DPA adds GDPR-related privacy and security provisions into your service contract with us. The DPA also helps to ensure that personal data can be processed in PTS’s solutions in a way that fully respects the requirements of the GDPR and United Kingdom GDPR.
PTS uses approved data transfer mechanisms, such as the approved Standard Contractual Clauses, to transfer personal data from the EU or the United Kingdom to third countries.
VeraSafe has been appointed as PTS’s representative in the EU for data protection matters, pursuant to Article 27 of the GDPR. VeraSafe can be contacted in addition to PTS on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form:
Alternatively, VeraSafe can be contacted at:
VeraSafe Czech Republic s.r.o
Prague 1, 11002
What’s Changing at PTS?
Identity and the contact details of the person or organization that has determined how and why to process your data. In some cases, this will be a representative in the EU. Clients will have GDPR-related provisions built into their service agreements by default. They will not need to execute ad-hoc amendments related to data protection under the GDPR.
What’s Staying the Same?
Our solutions will continue to provide strong data security. Our solutions are still not intended to process any sensitive data. The PTS team will still have the ability to hard delete an individual’s data from the database if requested. The PTS team can still help you update, correct, and provide an individual with access to his/her personal data upon request.
Contact details of PTS’s Data Protection Officer / GDPR Owner:
Contact Name: PHOENIX TECHNOLOGY SYSTEMS Data Privacy and Compliance
Address line 1: 322 North Shore Drive, Suite 200
Address line 2: Pittsburgh, PA 15212
Telephone: + 1 317 455 5244