Online privacy statement
Under the EU’s 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., as a data processor, is a US based company who hosts a web and mobile-based data collection, transformation and reporting systems (“Phoenix”) on its secure server in order to execute data transformations for its clients (data controller). Naturally, for some applications the system stores data fields to enable the client specific functionality, for example, PTS stores time and expense data but not for Data Transformations, where data storage is not required. These data fields are provided it’s clients, who contract workers to provide services.
Why does PHOENIX TECHNOLOGY SYSTEMS INC. need to collect and store personal data?
In order to utilize the Phoenix software, we may need collect generic data in order to execute data transformations for its 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-party service providers contracted to PHOENIX TECHNOLOGY SYSTEMS INC. in the course of dealing with you.
How will PHOENIX TECHNOLOGY SYSTEMS INC. use the personal data it collects about me?
PHOENIX TECHNOLOGY SYSTEMS INC. will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will keep your information accurate and up to date, and not keep it for longer than is necessary. PHOENIX TECHNOLOGY SYSTEMS INC. 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 in addition to these periods depending on individual business needs.
Under what circumstances will PHOENIX TECHNOLOGY SYSTEMS INC. contact me?
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?
PHOENIX TECHNOLOGY SYSTEMS INC. at your request, can confirm what information we hold about you and how it is processed. If PHOENIX TECHNOLOGY SYSTEMS INC. does hold personal data about you, you can request the following information:
Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
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 PHOENIX TECHNOLOGY SYSTEMS INC. 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 organisation, 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, we will ensure there are specific measures in place to secure your information.
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.
What forms of ID will I need to provide in order to access this?
PHOENIX TECHNOLOGY SYSTEMS INC. accepts the following forms of ID when information on your personal data is requested with Client approval notification along with a government issued identification card.
PHOENIX TECHNOLOGY, Inc.’s GDPR Compliance Efforts and You
At PHOENIX TECHNOLOGY, Inc., we are well aware of the new data protection requirements brought about by the General Data Protection Regulation of the European Union, or “GDPR”, which took effect on May 25, 2018. We’re proud to announce that PTS’s services are fully compatible with its GDPR obligations.
Let’s talk a little bit about the GDPR and what to expect from us.
What Is the GDPR?
The GDPR is a European Union (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.
How Is PTS Complying with the GDPR?
As the initial step in our 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. 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. Additionally, we have appointed an outside data privacy consultant, VeraSafe, to act as our EU Representative on data protection matters, as required by Article 27 of the GDPR.
VeraSafe has been appointed as PHOENIX TECHNOLOGY's representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to the PHOENIX TECHNOLOGY, only 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 organisation 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:
Data Protection Officer / GDPR Owner contact details
PHOENIX TECHNOLOGY SYSTEMS
Data Privacy Compliance
Address line 1: 322 North Shore Drive, Suite 200
Address line 2: Pittsburgh, PA 15212
Telephone: + 1 317 455 5244