PPHC is committed to protecting and respecting your privacy.
This Privacy Notice (this “Notice”) explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure.*
It applies to those who may view and communicate with us through our website as well as people with whom we do business.
It applies to those who may view and communicate with us through our website as well as people with whom we do business.
PPHC reserves the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Notice, the ways in which we collect and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
*This Notice complies with the California Consumer Privacy Act of 2018 (the “CCPA”). Supplemental provisions applicable to visitors, users and others who reside in California are described below in the section below entitled CALIFORNIA RESIDENTS. For residents in the European Economic Area who may be entitled to rights under the General Data Protection Regulation issued by the European Union please see the section below entitled EUROPEAN UNION COLLECTION AND USE OF PERSONAL INFORMATION
Personal information is data that can be used to identify or contact a single person.
You are not required to provide any personal data to view our website. However, you may choose to provide personal data when requesting information, exploring business opportunities or as part of a business relationship with us.
Personal information which you may provide to us and which we may collect includes your name, email address, contact information, professional pursuits and qualifications (for example, CVs, grades, and transcripts).
We may store and use personal information to:
- track the usage of our website and to help us improve our services and understanding of the interests and needs of those who contact us;
- carry out our obligations arising from any contracts between you or the company you work for and us;
- provide you with the information and services that you request from us;
- guide us in answering your questions or to explore career, professional or business opportunities with you;
- develop analysis and business intelligence that enable us to operate, grow, protect, make informed decisions and report on the performance of our business
- pursue other legitimate interests of our own such as maintaining a database of contacts working with or in our industry for networking or business development purposes.
PROTECTING PERSONAL INFORMATION
We secure personal information against unauthorized or unlawful processing, and against accidental loss, destruction or damage by appropriate technical and organizational measures.
We evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal information.
We also take measures to ensure confidentiality, meaning that only people who have a need to know and use the personal information can access it.
SHARING YOUR INFORMATION
We will never sell or rent your personal information to third parties.
We sometimes share personal data among the group of companies owned by PPHC. We may also share personal data with vendors or agents working on our behalf for the purposes described in this Notice.
To the extent that we do share your personal information, we would only do so if we have entered into a written agreement with that party and that party has agreed to comply with our privacy standards as described in this Notice.
We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets, where we are required to do so by law, support auditing, compliance and corporate governance functions, in connection with legal proceedings or where disclosure is necessary to protect the vital interests of a person.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
CHANGES TO YOUR INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
For purposes of the CCPA, personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We may obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase;
- Indirectly from you. For example, from observing your actions on our Website;
- From third-party business partners such as social media sites (LinkedIn), ad networks, and analytics providers.
Please note that PPHC, in accordance with all applicable laws, will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Rights and Choices of California residents under the CCPA
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that PPHC disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that PPHC 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 (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:.
- Complete the transaction for which we collected the personal information, provide a 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 et. 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.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- contacting our General Counsel located at our headquarters in Washington DC; or visiting http://www.pphcompany.com/
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), 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.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you services.
- Charge you different prices or rates for the services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of services.
- Suggest that you may receive a different price or rate for services or a different level or quality of services.
EUROPEAN UNION RESIDENTS
Your rights in connection with personal information
If you are in the European Economic Area and are entitled to rights provided under the General Data Protection Regulation issued by the European Union you may:
- request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate,
- request erasure of your personal information where there is no good reason for us continuing to process it;
- object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground,
- object where we are processing your personal information for direct marketing purposes,
- request the restriction of processing of your personal information,
- request the transfer of your personal information to another party.
If you believe you may be entitled to rights provided under the GDPR and want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our General Counsel located at our headquarters in DC.