PRIVACY POLICY

Please take a few minutes to read our privacy policy ("policy") as it sets out important information relating to how we collect, use and disclosure your personal information. 

HOW TO CONTACT US

Questions, concerns, issues, and requests regarding our Policy should be addressed to our Legal Department by the following methods:

Legal Department

433 State Street, 4th Floor

Schenectady, NY 12305

Email Address: privacy@meetprospero.com

Tele (US): 866.327.6395

 

 

INTRODUCTION

We will collect personal information when you use the Site as part of the normal course of business. This Policy sets out how we collect and use personal information and your rights regarding our use of your personal information. Prospero Systems works with software vendors, buyers and prospective buyers, and third-party partners and this policy applies to all parties.

 

1.  INFORMATION THAT WE COLLECT ABOUT YOU

 

Categories of Information we collect about you include:

  • When you log in, we collect username and password, contact details, including first and last name, company name, company address, company billing address, company telephone number, job title, company email address, and company website URL/IP address;

  • Payment details;

  • Browser information such as website traffic and pages viewed;

  • Behavioral information, such as information on interests of buyers, vendors and 3rd party partners.

  • In addition, for software vendors, it may include information about the software that you offer, product name, type of software, marketing materials, demos, videos, diagrams, and product descriptions;

  • Interests and communication preferences;

  • Comments and feedback; and/or

  • Any other information that you provide to Prospero Systems through the service.

 

We use this Information for Certain Activities, for the following purposes:

  • To register you as a user of the Platform;

  • To review eligibility to use the website and Platform;

  • To assist you in soliciting, bidding for or completing a transaction;

  • To verify your identity with company;

  • To send you marketing emails;

  • To send you emails relating to your account;

  • To provide customer service

  • To investigate complaints, issues, concerns and resolve disputes;

  • To response to questions;

  • To notify you of special offers which may be of interest to you;

  • To update you on relevant new services and benefits (with your specific, prior opt–in consent, where required);

  • To provide answers to inquiries and questions from other users;

  • To facilitate contract discussions and negotiations with parties;

  • For internal analysis and research;

  • To facilitate your access to and use of our website and Platform;

  • To develop our services and administer our website;

  • To perform statistical and trend analysis to improve user experience and performance of our website;

  • To personalize the services and to select content to be communicated to you or to use features on the Platform;

  • To provide and improve our service, performance and user experience;

  • To monitor, investigate and resolve complaints, issues or concerns;

  • To troubleshoot;

  • To obtain payment for our services;

  • To monitor, investigate, and report any attempts to breach the security of our website.

  • To develop our service offerings.

  • To managing your profile and listings;

  • To conduct and promote our business on the website and Platform;

  • To prevent and detect security threats, fraud or other malicious activity;

  • To comply with our legal obligations, respond to government or judicial requests for information (including in the context of private litigation), resolve disputes, and enforce our agreements; and

  • To enforce our policies.

 

We may on occasion also match or combine the personal data that you provide with information that we obtain from other sources or that is already in our records, whether collected online or offline or by predecessor or affiliated group companies, for the purposes described above. We process your personal data on the following legal bases: for the performance of our agreement with you and/or for our legitimate interests. Our legitimate interests include operating and improving our Services and business; developing our current and new Services, features and products; improving or actualizing our Services; personalizing your experience of our Services; communicating with you; understanding user preferences; complying with legal obligations; and protecting business interests.

We may use and disclose automatically collected information for any purpose as set forth in this Privacy Policy, except where we are restricted by applicable law. If we combine any automatically collected information with personal data, the combined information will be treated by us as personal data. We may also use aggregated information for any purpose insofar as this information does not identify specific individuals and so is not personal data.

2.  ADDITIONAL INFORMATION

Where we collect and use information for our legitimate interests as mentioned above, a legitimate interest will only apply when we consider that your interests or rights requiring protection of your personal information do not override our legitimate interests. For more information regarding our legitimate interests as applied to your personal information, please contact us.

Our websites and online services are for individuals who are at least 18 years old. Our online services are not designed to be used by individuals under the age of 18.

Your personal information may also be processed if it is necessary: to respond to a lawful request from a law enforcement or regulatory authority, body or agency; in the defense of legal claims or in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of any of our Site terms.

3.  DATA SUBJECT RIGHTS

We ensure that the personal information we collect about you is accurate, complete and used for its intended purpose. You may access, review, correct and update your Information or close your account by contacting us by email on the contact details above. If you a citizen of the European Union you also have the rights listed below.

4.  EUROPEAN UNION RESIDENTS

In certain circumstances, you have certain rights regarding your personal information. A summary of each right and how you can exercise it is below. To exercise any of these rights, please contact us. Such requests should include information to allow us to verify your identity (e.g. your name, address, email address or other information reasonably required).

Where we receive your request to exercise one of these rights, we will respond without undue delay and in any event within one month of receipt of the request. This may be extended by a further two months in certain circumstances, e.g. where requests are complex or numerous.

We will provide the information free of charge, except where requests are manifestly unfounded or excessive, e.g. because of their repetitive character. In these circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request. We may ask for additional information to verify your identity before carrying out a request.

A.      Right to Access/Correct Your Person Information

You have the right to access your personal information that we hold about you and the right to be provide a copy of that information.  You have the right to correct any inaccurate information that we may hold about you.

B.      Right to Restricted Use of Your Personal Information

You have the right to ask us to restrict processing of your personal information where one of the following applies:

  1. The processing is unlawful, but you want us to restrict use of the data instead of deleting it;

  2. Where you contest the accuracy of your personal information, the restriction will apply until we have verified the accuracy or corrected your personal information;

  3. We no longer require the personal information for the purposes of processing, but are required to keep it in connection with a legal claim;

  4. You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.

 

C.      Right to Request Deletion of Your Personal Information

You have the right to ask us to delete your personal information in most circumstances. If you want to opt-out from receiving marketing communications, the best way to do so is to allow us to retain your information with a “do not contact” tag so we know not to contact you in the future.

There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required to comply with a legal obligation or for the establishment, exercise or defense of legal claims.

D.     Right to Object to Processing of Your Personal Information

You may object to our use of your personal information for marketing purposes. You may also object to processing of your personal information in cases where we have used legitimate interests as the basis for processing. In such cases, we will stop processing your personal information until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise, or defense of legal claims.

E.      Right to Data Portability

In most cases, you have the right to receive all personal information you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, where technically feasible.

F.      Right to Lodge a Complaint with a Supervisory Authority

If you object to our processing of your personal information, you have the right to complain to the data protection authority in the country where you reside, where you work, or where an alleged infringement of data protection laws has taken place.

5.  RETENTION PERIODS

We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations require us to retain it.

In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and the period required by tax and company laws and regulations; and as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.

6.  OTHER USES OF YOUR INFORMATION

We believe it is important to give you choices about the use of your Information. We will use your personal information as described in this Policy. If we want to use your information for a purpose not described in this Policy, we will first get your consent to do so.

A.      Marketing Communications

We will respect your wishes not to receive marketing communications and you have the option to change your marketing preferences by contacting us at privacy@meetprospero.com.  Please note that we will continue to send you service communications regardless of any opt-out request. We will not sell or share your information with third parties (other than our subsidiaries or affiliates) for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.

B.      Special Notices to California Residents

In response to California law, if you are a California resident, you are entitled to request information concerning whether your personal information has been disclosed to non-affiliated third parties for their direct marketing purposes. We do not share your personal information with non-affiliated third parties for such purposes.

C.      California Online Privacy Protection Act Notice Concerning Do Not Track Signals

"Do Not Track" is a preference you can set in your Web browser to let the websites you visit know that you do not want them collecting information about you. The Website does not currently respond to a "Do Not Track" or similar signal. We do not engage in the collection of personal information about your online activities over time and across third-party websites or online services to provide targeted advertising and we do not allow third parties to collect such personal information when you use the Website.  For more information about Do Not Track signals, please visit https://allaboutdnt.com/.

7.  SECURITY

We have implemented administrative, technical, and physical security measures to help prevent unauthorized access. Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot guarantee or warrant the security of any information you transmit via our websites or apps. Please note that you are responsible for maintaining the security of your credentials used to access any service or account, and you must report suspected unauthorized activity to us.

We make reasonable efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve, or deliver our programs, products, and services.

8.  COOKIES AND SIMILAR TECHNOLOGIES

A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as "cookies".

Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you. We may use such technologies to, among other things, track the activities of users of our Services, help us manage content, and compile statistics about usage of our Services.

We also include web beacons in e-mail messages or newsletters to track whether you open the messages. We use this information to customize our services and measure the overall effectiveness of our online content, advertising campaigns, and products and services we offer through the Site. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

9.  MISCELLANEOUS

A.     3rd Party Links

We provide links to other websites or resources that are not part of the products, programs, or services run by Prospero Systems. When you click on one of these links, you are moving to another website. We encourage you to read the privacy statements of these linked sites as their privacy policy may differ from ours.

B.     Changes to this Policy

From time to time, we may change and/or update this Policy. If this Policy changes in any way, we will post an updated version on the Site. We recommend you regularly review the Site to ensure that you are always aware of our information practices and any changes to such. Any changes to this Policy will go into effect on posting to this page.

C.    California Privacy Rights

 

PRIVACY STATEMENT- CALIFORNIA 

 

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Prospero Systems and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Personal information does not include:

  • Publicly available information from government records.

  • De-identified 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 obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.

  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.

  • Directly and indirectly from activity on our website. For example, from submissions and applying for job positions through our website portal or website usage details collected automatically.

  • From third-parties that we interact with in connection with the services we perform. For example, from job boards, search engines, and websites.

 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information when applying for a position or in your resume or documents submitted for employment.

  • To provide you with information or services that you request from us.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

 

We 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.

 

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter 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 performing the contract.

 

The following categories of personal information maybe disclosed for a business purpose:

  Category A:                Identifiers.
  Category B:                 California Customer Records personal information categories.

  Category C:                 Protected classification characteristics under California or federal law.

  Category D:                Records of products or services purchased, considered through our Platform.

  Category E:                 Behavioral activities.

  Category F:                 Browsing History, search history information on the Platform.

  Category I:                  Professional or employment-related information.

  Category J:                  Non-public education information

  Category K:                Profile reflecting personal preferences, characteristics and behavior on the Platform.

 

We may disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.

  • Service providers.

  • Clients

  • Third parties to whom you or your agents authorize us to disclose your personal information.

 

We will not and have not sold any personal information.

 

Your Rights and Choices

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 we 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, 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 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.

 

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. 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.

  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  3. Debug products to identify and repair errors that impair existing intended functionality.

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  6. 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.

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  8. Comply with a legal obligation.

  9. 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:

 

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.  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 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 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.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you services.

  • Provide you a different level or quality of services

Children’s Privacy

Our website is not intended for children under 16 years of age.  No one under age 16 may provide any personal information on the website.  We do not knowingly collect personal information from children under 16.  If you are under 16, do not use or provide any information on this website.  If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under 16, please contact us at the email address below.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

 

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 866.327.6395
Website: meetprospero.com
Email: privacy@meetprospero.com

 

Postal Address:

    Prospero Systems
    Attn: Legal Department
    433 State Street, 4th Floor
    Schenectady, NY 12305

866.327.6395

 

433 State Street, 4th Floor

Schenectady, NY 12305

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