Privacy Policy

Last Updated: October 2023

1. INTRODUCTION
Providentia Law Corporation (“Providentia”; “Company”) welcomes visitors, clients, potential clients, employees, attorneys, candidates, and potential candidates (hereinafter referred to as “Website User(s)”) to its website properties and implements Website Terms of Use (“Terms”) to inform users of Providentia’s practices when using its website properties. In addition to these  Terms, Providentia implements this Privacy Policy to inform Website Users how their personal information is processed through their use of  Providentia’s website properties.

A. About
Providentia respects and is committed to protecting the privacy rights of its Website Users. This Privacy Policy provides an understanding of Providentia’s practices with respect to the collection, use, access, transfer, disclosure, and/or retention of personal data and/or sensitive personal information processed through any means including machine learning and/or artificial intelligence (“AI”), obtained in connection with our Services and business processes.

As used in this Privacy Policy  “Personal Data” and/or “Personal Information” means information about an identified or identifiable natural person. Providentia through its recruiting activities may also process Sensitive Personal Data/Information meaning information about an identified or identifiable natural person that if lost, misused, or accessed/modified without authority, would adversely affect the privacy to which the individual is entitled under 5 U.S.C. Section 552a (the Privacy Act).

Providentia, depending on the circumstances and applicable data protection law, will use different legal basis for processing personal information depending on the context in which that information is collected, used, accessed, transferred, disclosed, and/or retained. Providentia may process Personal Data when it is in its legitimate interest and/or based upon explicit consent from the end user to deliver its Services. Providentia provides Terms that each Website User agrees to when interacting with its website properties and/or using  the Services. These Terms provide the terms and conditions for the use of Providentia’s Website Services, including the end user’s informed consent to process their personal data in line with Providentia’s recruiting services.

B. Providentia Services
Providentia is a modern law firm that forms embedded relationships with our clients to provide them with an adequate balance of talent and advisory services (the “Services”) to meet our corporate clients’ business goals and talent strategies.

Our Services include:

• Outside Counsel Services – Providing technology companies with a seasoned attorney to help guide them through the ever changing area of technology law and legal operations including the areas of privacy, cybersecurity, technology law, fintech, and regulatory compliance.
• Secondee Services – Providing technology companies with the right balance of contingent workforce attorneys and/or legal professionals to fulfill project-based activities required for compliance and/or strategic reasons.

2. EFFECTIVE DATE OF PRIVACY POLICY
This Privacy Policy is effective as of the Last Updated Date and will remain in effect except with respect to any of its provisions that are changed in the future, in which case the changes will become effective on the date they are posted on the website or we otherwise notify you of the changes. We reserve the right to change this Privacy Policy at any time. Changes, modifications, additions, or deletions will be effective immediately on their posting to this site. You should check this policy periodically as its terms may change from time to time. Your continued use of the site after we post any such modifications will constitute your acknowledgment of the modified policy and your agreement to abide and be bound by the modified policy. We will also revise the “Last Updated” date found at the beginning of this Privacy Policy when we post changes to it.

3. SOURCES OF PERSONAL DATA

• Attorney Information Submitted to Us – Providentia may collect, access, use, transfer, retain/store your personal information that you submit to us, usually in the form of a resume and/or CV, for consideration of Outside Counsel and/or Secondee Services roles. Providentia will collect, access, and use this personal data based on your consent, which is given upon submission of your resume for a particular posted position. Furthermore, Providentia will securely retain/store this personal information in perpetuity unless we are notified in writing to remove your personal information from our Services. Providentia will never sell your personal data but we will share the personal data submitted to us via your resume and/or CV with the required client(s) in order to deliver the Services. We will discuss each potential position where you would be a successful candidate and obtain your consent for submission of your resume/CV to the positions that interest you.
• Client Information collected through website properties – Providentia may collect, access, use, transfer, retain/store personal information received from potential client inquiries about Providentia Services. Consent to collect, access, use, transfer, retain/store client personal information is received upon submission of a client inquiry. Furthermore, Providentia will transfer and retain/store personal information to and from active clients in order to deliver and manage and monitor the Services. Providentia will never sell its client personal data, however we do share personal information to deliver and manage and monitor the Services.
• Information we obtain from other parties  – Providentia may receive and/or acquire information about you from other parties such as: (1) Websites and services like job boards (e.g. Indeed.com; monster.com), professional networking sites (e.g. LinkedIn; Slack), and blogs and websites where you post information; (2) Attorneys and/or Clients that provide current or prospective candidates for us to consider; (3) business intelligence sources, including data aggregators and list providers; (4) Your referrals and references; (5) trade journals and news sources, and Providentia group Affiliates meaning Attorneys or companies that have ownership and/or equity stake in Providentia, Attorneys of Providentia, and companies owned or under common control of Providentia.

Any Personal Information you provide to a third party will be subject to that third party’s privacy notice and our use of the Personal Information we obtain such from third parties will be subject to this Privacy Notice.

4. CATEGORIES OF DATA WE COLLECT
We collect the following categories of personal information in order to provide our Service to you:

1. Identifying Information such as your full name, gender, date of birth, marital status, employee ID number, signatures.
2. Contact Information such as your email address, telephone number, physical address, referral/reference contact data, and/or emergency contact contact data.
3. National Identifiers such as your Social Security Number (“SSN”), Driver’s License Number, Tax Number, Passport information, Visa information, and/or immigration and naturalization status and documentation.
4. Dependent’s Information such as full name, address, date of birth, and/or SSN.
5. Education and Professional Background such as your work history, resume/CV, academic records, professional qualifications, professional background, certifications, licenses, language proficiency, awards/honors, security clearance information, and other work/education  related activities.
6. Employment Details such as your job title, position, hire dates, base pay, bonus, communication, expense reimbursement, incentive pay, and any other wage related information. Additionally we may also collect performance and disciplinary records, timekeeping records, training records, and personality assessments information that you may take as part of the interview process or while you are active personnel at a client.
7. Background Check Information such as your background check, credit check, education verification, employment verification, and/or drug testing results. This type of information is obtained through your individual consent as part of the job hiring process.
8. Benefits Administration Information such as your medical and/or financial benefits enrollment information, including any Dependents’ Information you provide
9. Career Planning Information such as your career interests, desired compensation and benefits, desired work location and willingness to relocate, family information you provide as it relates to your career goals or plans, hobbies and interests
10. Financial Information such as your bank account routing and account information, tax information, payroll information and withholdings, and credit card information (for example if you choose to provide it for booking a hotel for work travel)
11. Health and Safety Information such as your absence or leave records that contain health-related information (for example information about pregnancy, illness or other medical leaves of absence); information about your health as part of required occupational health screenings or related to a workplace injury; health information related to disability or other accommodation requests; health information related to COVID-19 symptoms, COVID-19 testing results, or COVID-19 vaccination status. Health information we hold about employees related to our self-funded medical plans is covered by our HIPAA Privacy Notice and not this Notice.  You can obtain a copy of our HIPAA Privacy Notice from our intranet, our benefits website or by sending an email to compliance@prolawpc.com.
12. Geolocation Information such as time and physical location related to your logging into our network or applications or using your badge to enter one of our office locations.
13. Biometric Information such as fingerprints (we will collect fingerprints only if we have provided you with a notice prior to collecting it that explains the reason for collection, which is usually for purposes of timekeeping or a security system). If a customer where you will be placed collects fingerprints, we will provide you with that information where we know it, but it is the customer’s responsibility to notify you since they are collecting the fingerprint.
14. Characteristics of Protected Classifications Data such as race and national or ethnic origin, gender, and veteran status (for example in order to complete legally required EEO-1 or OFCCP reporting or other DEI company initiatives); disability status, information about religion (including religious dress and grooming practices and sincerely held religious belief, practice or observance), for example as part of a request for an accommodation; pregnancy and childbirth information (for example when you request FMLA leave or short-term disability); status as a victim of domestic violence, assault or stalking (if you request time off or an accommodation as allowed under law); union membership (if as part of working for one of our clients you are part of a union)
15. Audio, Visual or Similar Information such as photographs (for example for your security badge, your photo for our intranet or photos of you at company events), video interviews, information technology help desk phone call recordings, WebEx/Teams/Zoom/Google Meet video and audio recordings and video captured by our security systems.
16. Device Information such as your IP address, browser type and version, browser plug-in types and versions, operating system and platforms of Providentia that you operate.
17. Other Information such as any other Personal Information you may elect to provide to us.

5. PURPOSE FOR COLLECTING THE DATA
We collect the categories of Personal Information listed above from the mentioned sources for the purposes of providing our clients with subject matter expert attorneys to fulfill roles as Outside Counsel to Providentia clients and/or Secondee Attorneys to Providentia corporate clients. This Personal Information must be collected to:

1. Comply with applicable local, state and federal laws and regulations;
2. Evaluate attorney applicants and candidates for Services;
3. Process payroll and/or travel and expenses;
4. Obtain and verify background, credit, and education and/or drug testing as well as employment references;
5. Verify your ability to work;
6. Track time and attendance at work;
7. Communicate with you regarding work related matters;
8. Communicated with contacts in case of emergency or other necessary circumstances;
9. Arrange business travel;
10. Establish and manage training, professional development and employee recognition programs;
11. Evaluate, make and communicate decisions regarding your employment, including decisions to hire, terminate, promote, demote, transfer, suspend or discipline;
12. Administer, manage and maintain benefits, including group health insurance, retirement accounts, short-term disability, and other Company benefits and perks;
13. Manage your job-related performance and/or employee conduct, including by engaging in lawful monitoring of your activities and communications;
14. Investigate and handle workplace investigations (such as investigations of workplace accidents or injuries, harassment or other misconduct), disciplinary actions or termination;
15. Administer and maintain our operations for safety purposes, including preventing the spread of illness and administer programs during a pandemic (e.g., COVID-19);
16. Implement, monitor and manage electronic security measures (including detection of security incidents);
17. Grant and monitor your access to secure company facilities;
18. Verify and respond to consumer requests under applicable consumer privacy laws;
19. Promote and foster diversity, equity and inclusion in the workplace;
20. Perform workforce analytics, data analytics and benchmarking;
21. Perform company audits;
22. Engage in corporate transactions requiring review of employee records and information, such as for evaluating potential mergers and acquisitions;
23. Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance, including managing workers’ compensation claims;
24. Evaluate, assess and manage the Company’s business relationship with vendors, service providers and contractors that provide services to the Company;
25. Improve user experience on Company computers, networks, devices, software applications or systems, and to debug, identify and repair errors that impair existing intended functionality of our systems; and
26. Exercise or defend our legal rights.

6. HOW WE DISCLOSE YOUR INFORMATION
Providentia discloses your Personal Information for various business purposes in order to deliver its Services and/or based on your consent when signing up for our Services. The following categories of Personal Data have been disclosed for business purposes to deliver, manage, and/or maintain the Services. Furthermore, for all Personal Information categories below, except for Biometric Information, we may disclose, as is appropriate under the circumstances, to government and/or law enforcement entities and lawyers.

1. Identifying Information and Contact Information: Attorneys, clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, back-office solutions, security vendors, data analytics providers, insurance vendors, company banks, benefits providers); Providentia affiliates; auditors, consultants and other professional advisors
2. National Identifiers: Attorneys, clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, back-office solutions, security vendors, data analytics providers, insurance vendors, company banks, benefits providers); Providentia affiliates; auditors, consultants and other professional advisors
3. Dependents’ Information and Benefits Administration Information: Attorneys, vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions and back-office solutions, security vendors, insurance vendors, company banks, benefits providers); Providentia affiliates; auditors, consultants and other professional advisors
4. Education and Professional Background: Attorneys, clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking and back-office solutions, security vendors); Providentia affiliates; auditors, consultants and other professional advisors
5. Employment Details and Career Planning Information: Attorneys, clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, human capital solutions and back-office solutions, security vendors); Providentia affiliates; auditors, consultants and other professional advisors.
6. Background Check Information: Attorneys, clients  and potential clients (where you have authorized release); vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, human capital solutions and back-office solutions, security vendors); Providentia affiliates; auditors, consultants and other professional advisors
7. Financial Information: Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions and back-office solutions, security vendors); Providentia affiliates; auditors, consultants and other professional advisors
8. Health and Safety Information: Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions, security vendors); Providentia affiliates; auditors, consultants and other professional advisors
9. Geolocation Information: Attorneys, clients and potential clients; vendors, contractor and other service providers (e.g., badge entry information systems, security vendors); auditors, consultants and other professional advisors
10. Biometric: Not disclosed
11. Characteristics of Protected Classification Data: Attorneys; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as human capital solutions, security vendors); Providentia affiliates; auditors, consultants and other professional advisors
12. Audio, Visual or Similar Information: Attorneys; vendors, contractors and other service providers (e.g., Company intranet system (for photos), video conferencing providers, security providers); auditors, consultants and other professional advisors
13. Device Information:Attorneys, vendors, contractors and other service providers (e.g, IT operating and system and platform vendors; networking monitoring systems; security providers); auditors, consultants and other professional advisors

We do not knowingly collect, sell, or share the Personal Information of minor individuals under 16 years of age.

We do not use Sensitive Personal Information for purposes other than those allowed under applicable data protection law.

7. RETENTION OF PERSONAL INFORMATION

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with Services you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. Please contact us as described in the “How to Contact Us” section below for more information on our employee data retention schedule.

8. YOUR RIGHTS AND HOW TO EXERCISE THEM

You have the following rights with respect to your Personal Information:

• The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling, or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
• The right to delete Personal Information that we collected from you, subject to certain exceptions;
• The right to correct inaccurate Personal Information that we maintain about you;
• If we sell or share Personal Information, the right to opt-out of the sale or sharing;
• If we use or disclose sensitive Personal Information for purposes other than those allowed by applicable data protection law, the right to limit our use or disclosure; and
• The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by applicable data protection law.

9. HOW TO EXERCISE YOUR RIGHTS
You may submit a request to exercise the rights listed by submitting an email to compliance@prolawpc.com or calling us at (650) 943-2410.

For all requests, after submitting the request, we will require additional information to reasonably verify your identity.

If you would like to update your personal information, such as to notify us of a change of name or address, or if you have questions about your employment, please contact the Providentia Talent Department.