Procurement Leaders as a data controller is committed to protecting your personal information. Our principal place of business is at Third Floor Prospero House, 241 Borough High Street, London, SE1 1GA, UK. More information about Procurement Leaders and its products and services can be found at www.procurementleaders.com.
If you have any questions or concerns relating to Procurement Leaders’ websites and/or data protection, please email firstname.lastname@example.org.
1. Information we collect
1.1 Online forms
We collect information from visitors to our websites when completing online forms. Personal information is data that identifies you and includes (but is not limited to) your name, business or personal email address, job title, organisation, organisation’s address, direct telephone number.
If you are a member of Procurement Leaders and access the restricted members only areas of our websites, Procurement Leaders may collect additional information relating to your participation in Procurement Leaders products and services. We also may obtain information about your access and use of Procurement Leaders research materials, decision-support tools, and other online and offline products and services.
You have choices about the information on your profile, such as your topics of interests, work experience, skills, and photo. Profile information helps you to get more from our services.
1.4 Award nomination entries
When individuals complete a nomination for the Future Leader, Lifetime Achievement and Procurement Leader awards, they submit their information and that of the nominee in an application form. Any personal information that is provided is used to review the nomination. The information about the winner may also be published on our website, in our magazine and social media channels.
1.5 Community areas and discussion forums
In certain community areas on the Procurement Leaders websites, members can locate other members who are able to help them deal with specific questions and challenges. By providing personal information for publishing to a profile in community areas, you acknowledge and agree that members can see and use that information, and that their use is not subject to the terms of this Policy.
1.6 Live Chat service
We use a third-party provider, Snap Engage, to supply and support our Live Chat service, which we use to handle customer enquiries in real time. If you use the Live Chat service we will collect your email address, if provided, and the contents of your Live Chat session.
1.7 Information collected by third parties
2 . How we use the information that we collect
Procurement Leaders processes personal information collected via our websites and registration forms for the following legitimate interests:
We use your data to authenticate you and authorize access to our services. We administer your membership and facilitate your access to Procurement Leaders resources, decision-support tools, and other materials available to you through your Program subscription. We may provide reservation or booking services for our events.
2.2 Communications & marketing
Your information may be used to send you details of those products or services that we offer that we have identified as likely to be of interest to you. This will be in accordance with any communication preferences that you may have indicated when you completed a data capture form.
We also enable communications between you and others through our services. We will use data about you to suggest connections for you and others (e.g. Match & Meet Event Hub platform) and enable you to invite others to connect with you. You may change your communication preferences at any time here.
2.3 At events
We may provide relevant information for hospitality and safety purposes to hotels and venues hosting our events. At some of our events we may use RFID-enabled badges (which we use to track your location around our event venue so we can better understand your areas of interest). You can opt to have your personal details anonymised at point of collection.
All transactions are processed through a gateway provider (WorldPay) and are not stored or processed on our servers.
2.5 Surveys and research
We may communicate with you about surveys, marketing, promotions, events, educational forums, and other exclusive opportunities offered by Procurement Leaders and its partners and affiliates. You are not obligated to respond to surveys.
2.6 Customer support
We use the data (which can include your communications) needed to investigate, respond to and resolve complaints and service issues.
2.7 Aggregate insights
We use your information to produce aggregate insights that do not identify you. For example, we may use your data to generate statistics about users, their profession or industry and the number of pages served or clicked on.
2.8 Data retention
We retain the personal data you provide while your membership is in existence or as needed to provide you services as listed in this policy. Data may persist in copies made for back up and business continuity purposes for additional time, including information required for regulatory and legal compliance.
3. How we share your information
Where information is shared with a third party for a legitimate business purpose, Procurement Leaders will seek reasonable assurances from that third party that the personal information will be processed for legitimate reasons and appropriately protected. Procurement Leaders may share your personal information with other companies or individuals in the following instances:
3.1 Our services
For legitimate business purposes connected with the provision of Procurement Leaders goods, services, and benefits for executive customers.
3.2 Disclosing your information to partners
Where you have downloaded a whitepaper and/or watched a webinar from that partner or you have subscribed to attend an event where partners are present.
3.3 Legal disclosures
3.4 Change in control of sale
In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
4. Choices about the uses of your information
4.1 The right to be informed.
1. Right to Access Your Data.
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. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
2. Right to Data Portability.
You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
3. Right to Delete Your Data.
You have the right to request that we delete any 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.
4. Right to Non-Discrimination for the Exercise of Your Privacy Rights.
You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
5. Right to Opt-Out of the Sale of Personal Information.
You have the right to opt-out of our “Sale” of their personal information that occurred during the twelve (12) months prior to your request. The California Consumer Privacy Act defines the term “Sale” broadly, and includes, our selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating (collectively a “Sale”) your personal information to another business or third party for monetary or other valuable consideration. You may exercise their right to opt-out the Sale of their personal information by completing our CCPA rights request form via the online portal or by contacting us at +1 833-650-0060 (toll free).
5. Other Important Information
5.1 Receiving Communications
We currently provide the following opt-out opportunities:
- At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.
5.2 Information security
Procurement Leaders has implemented reasonable technical and organizational security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal information. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we use commercially reasonable security measures such as encryption, firewalls, and transport layer security (TLS) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.
If Procurement Leaders collects account information for payment or credit, Procurement Leaders will use the information only to complete the task for which the account information was offered.
5.3 International transfers of personal information
Procurement Leaders operates the Websites in the United Kingdom and, depending on your country of residence, the submission of personal information to our Websites may involve some transfer of personal information to the United Kingdom. Your data may be accessed by Procurement Leaders’ employees and contracted processors outside of the United Kingdom. If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected.
5.4 Privacy Shield certified
Procurement Leaders, Inc., as an Affiliate of Procurement Leaders, Limited (for purposes of this Privacy Shield section, referred to as “Procurement Leaders”, “we”, “our” or “us”) complies with the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information and human resources data from European Union and the United Kingdom and Switzerland transferred to the United States in reliance on Privacy Shield. Human resources data means information related to our employees, such as information collected on a job application and employment history (“Human Resources Data”).
With respect to Personal Data and Human Resources Data received or transferred pursuant to the Privacy Shield Frameworks, Procurement Leaders is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU, UK and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information or Human Resources Data relating to you in the United States. Upon request, we will provide you with access to the personal information and Human Resources Data that we hold about you. You may also may correct, amend, or delete the personal information and Human Resources Data we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
In certain situations, we may be required to disclose Personal Data and Human Resources Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Procurement Leaders’ accountability for Personal Data and Human Resources Data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Procurement Leaders remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the Personal Data and Human Resources Data on its behalf do so in a manner inconsistent with the Principles, unless Procurement Leaders proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Procurement Leaders commits to resolve complaints about your privacy and our collection or use of your personal information and Human Resources Data transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom and Swiss individuals with Privacy Shield inquiries or complaints should first contact Procurement Leaders by email at email@example.com or via post at:
Procurement Leaders Limited
241 Borough High Street
With respect to personal information, Procurement Leaders has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
With respect to Human Resources Data, Procurement Leaders has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at www.privacyshield.gov/article?id=ANNEX-I-introduction.
5.5 Privacy Rights Specific to California Residents
Types of Information Collected Related to California Residents
During the last twelve (12) months, we have collected the following categories of Personal Information from consumers. Some of the categories of information collected specifically concerns our employees or contractors as opposed to consumers who purchase our products.
|Category||Type of Identifiers We Collect||Collected|
|Identifiers.||First and last name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address.||YES|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, address, telephone number.||YES|
|Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||YES|
|Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|Inferences drawn from other Personal Information||Profile reflecting a person’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 customers or from our employees. For example, information that customers provide to us when they sign-up for a program or conference.
- Indirectly from our customer. For example, through information we collect from our customers in the course of providing services to them through our corporate partners.
- Directly and indirectly from activity on our website (www.procurementleaders.com). For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
- From social media platforms and networks that you use in connection with our Sites, such as Facebook, LinkedIn, and Twitter.
- From third parties that interact with us in connection with the services we perform and the products which we produce.
Information We Share
Procurement Leaders may disclose your Personal Information to commercial providers for a business purpose. When we disclose Personal Information for these reasons, we enter into 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 for the purposes set forth in the contract.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:
- California Customer Records Personal Information categories;
- Internet or other network activity information;
- Commercial information;
- Internet or other similar network activity;
- Inferences drawn from other Personal Information.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates;
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the Services we provide to you.
- Service providers and other third parties we use to support our business, including without limitation those performing core services (such as credit card processing, customer support services, customer relationship management, property management, accounting, auditing, processing insurance claims, administering sweepstakes, surveys, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services.
- Commercial providers;
- Enterprise accounts, such as your employer.
We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of Client Command if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- Fulfill any purpose for which you provide it;
- Meet any applicable law, regulation, legal process or enforceable governmental request;
- Detect, prevent, or otherwise address fraud, security or technical issues;
- Protect against harm to the rights, property, assets or safety of Client Command, our customers or the public, content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law;
- For any other purpose disclosed when you provide the information; and,
- When we obtain your consent to do so.
We attempt to notify you about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Do Not Sell Personal Information
The idea of selling personal inforfmation in the traditional sense runs counter to Procurement Leaders’ core principles. We don’t sell data in this manner.
However, the CCPA significantly expands the definition of sale to include such things as disclosing, disseminating, making available, or otherwise communicating orally, in writing, or electronically, personal information to another business for any valuable consideration.
As a conference host and event coordinator, Procurement Leaders sometimes shares business contact information of those attending our events with the venues hosting these events, to create a business connection. California has defined this as a “sale” under the CCPA. Because of this, we must provide California consumer with an opportunity to opt-out. For more information on how to opt-out, please see the “Rights Specific to California Residents” Section.
Rights Specific to California Residents
Under the California Consumer Privacy Act, California residents have specific rights regarding their Personal Information. This section explains how California residents can exercise those rights and describes Californians’ rights.
Exercising Your Rights
If you are a California resident who chooses to exercise your rights, you can:
- Submit a request via emial or
- Call +1 833-650-0060 to submit your request.
Our Response to Your Request
Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete Personal Information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
Californians’ Rights With Respect to Personal Information
Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.
- Right to Access Your Data. 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. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
- Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
- Right to Delete Your Data. You have the right to request that we delete any 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.
- Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
- Right to Opt-Out of the Sale of Personal Information. You have the right to opt-out of our “Sale” of their personal information that occurred during the twelve (12) months prior to your request. The California Consumer Privacy Act defines the term “Sale” broadly, and includes, our selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating (collectively a “Sale”) your personal information to another business or third party for monetary or other valuable consideration. You may exercise their right to opt-out the Sale of their personal information by completing our CCPA rights request form via the online portal or by contacting us at +1 833-650-0060 (toll free).
We may deny your deletion request if retaining the 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; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
5.6 Links to other websites
To provide increased value to users of our websites, we may provide links to other websites or resources that are not part of the Procurement Leaders network of Programs. Procurement Leaders does not exercise control over these websites or their privacy practices, and any information you provide is subject to the Privacy Policies of those websites, and not this Policy.
5.7 Job applicants
Procurement Leaders Limited is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact Sian Duval firstname.lastname@example.org and refer to the information contained on the Procurement Leaders Careers website
Our websites contain business-related content and are specifically aimed at and designed for use by adults. The websites are not intended for use by children. We do not intentionally gather Personal Data about United States visitors who are under the age of 13 or about European Union, United Kingdom or Swiss visitors who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under the ages of 13 or 16 in the applicable jurisdictions, please contact us at email@example.com. If we learn that we have inadvertently collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
5.9 Changes to this policy
This Policy may change from time to time. It was last reviewed in April 2020. If we make material changes to this Policy, we will post any Policy changes on this page. If we feel it appropriate, we will provide a more prominent notice (including, for certain services, email notification). Your continued use of our websites following such posts or notices will signal your acceptance of such changes.
5.10 How to contact us
Procurement Leaders Limited
241 Borough High Street