Privacy Policy

All collection, processing, and use (hereafter “usage”) of data by ProAction Consulting, LLC (hereafter “ProAction Consulting” or “ProAction”) is exclusively for the purposes of providing the ProAction Consulting services (hereafter “services”). The services have been designed with the goal of collecting as little personal data as possible to function. By “personal data," we mean all particulars related to an identified or identifiable natural person (the “data subject”).

The following statements describe which types of data we collect when you use our services, what happens with this data, and how you can object to this data processing, where applicable.

Data Controller and Owner

For the purposes of the EU General Data Protection Regulation (GDPR) (EU) 2016/679, the responsible entity is:

ProAction Consulting, LLC

+1-949-438-0287

proaction.info@norton.me

858 Production Pl

Newport Beach, CA 92663

United States

Definitions

“Our Website(s)” and “ProAction Consulting's Website(s)” refers to any website owned and/or operated by ProAction Consulting (as listed above), especially proaction.online.

"User" is the individual using our websites, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refer.

What Data we Collect

When you visit our website, our server temporarily saves details of your access in its logs. These logs contain the following data, and are kept until their automatic deletion:

• The IP address of the computer making the request

• The date and time of your request

• The requested URL

• The amount of data transferred to you in response

• Whether the request was successfully processed or not

• Identifying data about the browser and operating system you use

• The referring website from which you made the request

• The name of your Internet Service Provider

The purpose of recording this data is to make it possible to serve the website to you (by establishing a TCP/IP connection), to secure our servers, the technical activation of our infrastructure as well as the optimization of our services. Only in the case of unauthorized access or attacks on our infrastructure will your IP address be analyzed.

No further information is required from you in order to access our website.

Among the types of Personal Data that ProAction Consulting collects from User, by itself or through third parties, there are:

• First Name & Last Name

• Phone number

• Email

• Address, State/Province, ZIP/Postal code, City

• Password

• Cookie and Usage Data, IP address.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection. The Personal Data may be freely provided by the User, or collected automatically when using ProAction Consulting's Websites

Any use of Cookies – or of other tracking tools – by ProAction Consulting or by the owners of third party services used by ProAction Consulting, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.

Failure to provide certain Personal Data may make it impossible for ProAction Consulting to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through ProAction Consulting and confirm that they have the third party’s consent to provide the Data to the Owner.

The use of the Data processed by the Service

All Data processed via the analysis conducted by ProAction Consulting are used by ProAction Consulting only for the purpose of providing the service to the Users. Such Data will not be transferred or sold by ProAction Consulting to any third party, nor will it be used by the Owner for any purpose connected to ProAction Consulting’s own business. The Owner reserves the right to aggregate the Data imported on the application by the different ProAction Consulting Users, for the purpose of creating anonymized aggregated metrics.

Securing your Data

In order to secure your data, we have put in place technical and organizational measures which meet the requirements of the GDPR and require any third-party service providers we use to do the same.

When we use third parties to provide the services, for example infrastructure service providers, these third parties are only engaged after a comprehensive review.

Your data is only ever saved on secure servers, which may only be accessed by a few authorized personnel.

Third-Party Service Providers in non-EEA Countries

In order to provide our services, we may use third-party services located outside the European Economic Area. Where such transfer occurs, ProAction Consulting ensures that such transfer occurs under the necessary legal provisions as required by the applicable legislation in order to provide for an adequate level of protection of Your Personal Data (e.g. adequacy decision of the EU commission (e.g. EU-US Privacy Shield), binding corporate rules, or EU standard contractual clauses)

Use of Cookies

In addition to the previously listed data, cookies will be saved on your computer when you use our website. Cookies are small pieces of textual data which are saved on your hard disk by your web browser, through which ProAction Consulting, who sets the cookie’s contents, can collect certain information about you. Cookies cannot execute any code, nor transfer any viruses to your computer. We use them in order to analyze the use of the website anonymously or pseudonymously, and present relevant offers to you.

This website uses the following types of cookies, whose scope and functionality is detailed in the following paragraphs.

Transient cookiesare automatically deleted when you close your browser. They are used particularly as session cookies. These save a so-called “session ID” which is used to link subsequent requests made by your browser to each other. Through this, your computer can be recognized when you return to our website. These session cookies are deleted, when you log out, or close your browser.

Persistent cookiesare only deleted after a predetermined duration, which can be different for each cookie. You can delete these persistent cookies anytime, though the “Settings” configuration of your browser. We advise you, that if you do so, that not all functionality of this website will be available.

The placement of cookies on your computer can be prevented through the relevant settings of your internet browser. Previously set cookies can also be deleted through the settings of your browser. We advise you that preventing the placement of cookies on your computer can mean that not all functionality of our website are available without limitations.

Website Registration

The User can register on the website. For this to take place, it is required that the User enter their details in the various forms on our website. The data given by the User to register will solely be used for registration, and not passed to any third parties unless ProAction Consulting has a lawful ground to do so. In the course of registration on our website, your IP address, date, and time of access will be recorded, in order to prevent any potential misuse. During, or after the registration, the User is free to alter their personal data. It is also possible for the User to completely cancel their registration, so that all personal data is deleted.

Third-party services

InfluencerSoft

ProAction Consulting uses InfluencerSoft.com ("InfluencerSoft"). InfluencerSoft is our website host of all sales and marketing, and our platform for certain training packages and materials. They are our primary secure data repository.

The responsible entity is:

InfluencerSoft LLC (DBA - InfluencerSoft);

+1(844)331-0950

support@influencersoft.com

7486 La Jolla Blvd. #507

La Jolla, CA 92037

United States

If a user chooses to contact ProAction Consulting, either by emailing info [at] proaction.online, or any other email address associated ProAction Consulting, the content that the user chooses to submit may be transferred to Influencersoft's servers located in the United States, and saved there. InfluencerSoft may give this information to further parties where legally required to do so, or these parties are contracted to by InfluencerSoft.

You can find further information about InfluencerSoft’s data processing and data protection at:

https://influencersoft.com/privacy/

Calendly

ProAction Consulting uses Calendly to schedule appointments with customers and prospects & to notify users of meeting schedules, send reminders and cancellation notices.

The responsible entity is:

Calendly, LLC

+1(800) 979-9850

support@calendly.com

271 17TH St NW Ste 1000

Atlanta, GA, 30363-6201

United States

Personally identifiable information, including name, email address, phone number and location & country is submitted to Calendly's servers and saved there when a user chooses to request a time and date for meeting hosted or sponsored by ProAction Consulting.

The option to schedule a date and time is made possible through the use of JavaScript and cookies. Information obtained via the cookies and/or the JavaScript widget, including IP address, browser version, OS version, activity data, usage information, transaction information and plan details is transferred to Calendly's servers and saved there.

Other information, including IP address, browser & OS version, and timestamps, is submitted to Calendly when a user loads resources embedded in, or a link contained an email sent through Calendly.

The analyses of your actions on our website and with the notifications sent through Calendly may be transferred to us. Calendly may give any of your information to further parties where legally required to do so, or these parties are contracted to by Calendly.

You can find further information about Calendly’s data processing and data protection at:

https://calendly.com/privacy

Microsoft

ProAction Consulting uses Microsoft Outlook 365 for business suite applications including calendaring & scheduling, address book and email services.

Personally identifiable information, including name, email address, phone number and location & country is submitted to Microsofts's servers and saved there when a user submits that information to our website.

For more information refer to:

https://privacy.microsoft.com/

Facebook

ProAction Consulting has integrated Facebook into its website.

The responsible entity for Facebook is:

Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States.

When a User lives outside the United States or Canada, and Facebook undertakes data processing, the responsible entity is:

Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

If the user is logged into a Facebook account (even if it is not their own account) at the same time that they access the ProAction Consulting website, Facebook will additionally receive a notification that they have visited ProAction Consulting’s website. Facebook collects this information, so the theoretical possibility exists that it could associate it with the Facebook account. The same also applies to the “Like” button, or to the usage of Facebook comment forms; Facebook could associate this information with the logged-in Facebook account.

To prevent this, you can log out of any Facebook accounts prior to visiting the ProAction Consulting website. To do this, you must visit the Facebook website.

For further information relating to data protection and Facebook, please see:

https://facebook.com/about/privacy

Google AdSense

ProAction Consulting may use Google AdSense, a service provided by Google, Inc (hereafter “Google”) that enables us to advertise to previous visitors of our website and allows us to track the effectiveness of these ads.

The responsible entity is:

Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA, 94043, United States

The display of ads and measurement of their effectiveness is made possible through the use of cookies and clear gifs. Information obtained via these cookies and / or clear gifs is transferred to Google servers located in the United States, and saved there. The analyses of your actions on our website is transferred to us in the form of reports. Google may give this information to further parties where legally required to do so, or these parties are contracted to by Google.

You may opt-out of targeted advertising through Google AdSense by visiting:

https://www.google.com/ads/preferences/

You can find further information about Google’s data processing and data protection at:

https://policies.google.com/

Google Analytics

Our website uses Google Analytics. This is a service of Google which analyses website access and enables us to improve our site.

The responsible entity is:

Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA, 94043, United States

The analysis of your use of our website is made possible through the use of cookies. Information obtained via these cookies is transferred to Google servers located in the United States and saved there. The analyses of your actions on our website is transferred to us in the form of reports. Google may give this information to further parties where legally required to do so, or these parties are contracted to by Google. The Google tracking on our website uses the “anonymizeIp()” function, which truncates the transmitted IP addresses so as to prevent the direct identification of any individual users.

You can stop the placement of Google Analytics cookies on your computer through the settings of your web browser. If you do so, we cannot guarantee that all the functions of our website will be fully available to you. You may also stop the placement of cookies through the use of browser extensions, such as:

https://tools.google.com/dlpage/gaoptout

You can find further information about Google’s data processing and data protection at:

https://policies.google.com/

And

https://www.google.com/analytics/terms/

CloudFlare Inc.

CloudFlare is a monitoring service provided by CloudFlare Inc. that is used for monitoring service uptime and availability. Information that CloudFlare collect includes items such as IP addresses, DNS log data, and website performance data derived from browser activity. Place of processing: USA - Privacy Policy

Changes to this Privacy Policy

ProAction Consulting reserves the right to update this Privacy Policy from time to time without notice. Any changes are effective when we post the updated Policy on our website. We recommend that you regularly check back. We may provide you with notices about changes to this Privacy Policy if you are a registered user of ProAction Consulting Website.

Contact

Should you have further questions, or wish to contact us, you can write us an email to info [at] proaction.online. When you do so, the data required to answer your query will be automatically saved and processed. Your data will not be transferred to third parties unless ProAction Consulting has lawful grounds to do so.

Deletion of Personal Data

ProAction Consulting only keeps and processes personal data for so long as it is necessary. When the purpose of the data processing has been fulfilled, your personal data will be deleted in accordance with our data retention policy, unless we are legally required to retain it.

Right to Access, Change, or Delete Personal Data

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated, or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

Right to Access

Customers have the right to know what personal data about them is included in the databases and to ensure that such personal data is accurate and relevant for the purposes for which ProAction Consulting collected it. customers may review their own personal data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and ProAction Consulting policies. Upon reasonable request ProAction Consulting allows customers access to their personal data, in order to correct or amend such data where inaccurate. Customers may edit their personal data by logging into their account profile or by contacting ProAction Consulting by phone or email. In making modifications to their personal data, Users must provide only truthful, complete, and accurate information. To request erasure of personal data, customers should submit a written request to info [at] proaction.online.

Requests for Personal Data

ProAction Consulting will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the personal data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the User. If ProAction Consulting receives a request for access to his/her personal data from an customer, then, unless otherwise required under law or by contract with such customer, ProAction Consulting will refer such User to the customer.

Satisfying Requests for Access, Modifications, and Corrections

ProAction Consulting will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate personal data.

Questions, Complaints, Dispute Resolution

ProAction Consulting commits to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy policy should first contact ProAction Consulting at: info [at] proaction.online. Additionally, you always have the right to make a complaint to the relevant authorities (https://ico.org.uk/) regarding our processing of your personal data.

How you can exercise your rights

Should you wish to exercise any of these rights, you will need to provide proof of identification that you are the person to whom the data relates. The data you will receive includes data we have related to you, the source of that data, the recipients, or types of recipients to whom the data was transferred, and the purposes for which the data was stored. To exercise these rights, please contact our support at info [at] proaction.online

Our responsibilities as a Data Processor

As a technical services provider who stores the personal information of EU citizens on behalf of Data Controllers, we have certain responsibilities under GDPR which we comply with, including:

Managing Data Processing

ProAction Consulting has clear documentation on where our data comes from, how it is stored, and where it goes after we get it. ProAction Consulting will only process personal data on instructions from the controller, and inform the controller if it believes said instruction infringes on the GDPR (28.3)

Accountability and Governance

ProAction Consulting takes extraordinary steps to secure your data, ensure stability and uptime, manage data backup and disaster recovery, and regularly test security (32.1)

Authorized Use of Sub-Processors

ProAction Consulting uses sub-processors as a routine part of offering our service. It is our responsibility to ensure our subcontractors comply with GDPR, and we will comply with those rules. As a Data Controller, your agreement to our use of sub-processors is part of our legal Terms of Service and required to be an ProAction Consulting user.

Updated: July 2023