Pinnacle Group respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or you otherwise deal with us, and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here.

1. Important information and who we are
2. Who this policy is for
3. What personal data do we collect?
4. How is your personal data collected?
5. How we use your personal data
6. Sharing data
7. Transferring data
8. Data security and risks
9. Data retention
10. Your legal rights

1. Important information and who we are

   The owner of this website is Pinnacle Technical Resources, Inc., d/b/a Pinnacle Group, a Texas company with offices at 10670 North Central Expressway, Suite 600, Dallas, TX 75231. This privacy policy is issued on behalf of the Pinnacle Group and its UK and EEA subsidiary companies. When we mention "Pinnacle", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Pinnacle Group which is the controller responsible for processing your data. When we refer to the Pinnacle Group in the context of this privacy policy we refer to the following entities:

   • Pinnacle Workforce Solutions UK Limited
   • Pinnacle Workforce Solutions Ireland Limited
   • Pinnacle Workforce Solutions Slovakia s.r.o.

   If you are not sure which member of the Pinnacle Group is responsible for processing your data, please contact us using the details below.

   This privacy policy will inform you on how Pinnacle collects and processes your personal data in accordance with applicable privacy laws through your use of www.pinnacle1.com or www.ptrglobal.com (the "Site") or when you otherwise engage and communicate with us.

   This Site, and our services, are not intended for children aged under 13 and we do not knowingly collect data relating to children aged under 13.

   Please read this privacy policy carefully so you are aware of how we handle your personal data. By engaging with us or using our Site, you confirm that you have read and understood this privacy policy.

   If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

   Contact details

   Privacy Officer: Erin Stewart, General Counsel
   Email address: privacy@pinnacle1.com
   Postal address: 10670 N. Central Expy, Suite 600, Dallas, TX 75231
   Telephone number: 214-740-2424

   If you are based in the UK or the EEA, more information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from the relevant data protection supervisory authorities in your jurisdiction. You may make a complaint to the data protection regulator in the country where you usually live or work, or where an alleged infringement of applicable data protection laws has taken place. Please contact the relevant data protection supervisory authority in your jurisdiction for further information.

   The Information Commissioner's Office is the data protection supervisory authority in the UK. A comprehensive list of data protection authorities of European Union nations is here:

   Website: https://edpb.europa.eu/about-edpb/about-edpb/members_en

   We would, however, appreciate the chance to deal with your concerns before you approach the ICO or other supervisory authority, so please contact us in the first instance.

   Your right to object

   You have various rights in relation to our use of your personal data, including the right to object to our continued use or processing of your personal data. If you ask us to stop using your personal data for marketing purposes, we will stop using your personal data in this way.

   You may also ask us to consider any valid objections which you have to our use of your personal data where our lawful basis for doing so is our legitimate interest. For more information about your rights, please see the section below titled Your Legal Rights.

   Changes to the privacy policy and informing us of changes

   We keep our privacy policy under review and may update it from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, may be notified to you by email. We encourage you to check back frequently to see if there have been any changes to this privacy policy.

   It is important that the personal data we hold about you is accurate and current. If any of your personal data changes during your relationship with us, please update us so that we only hold correct personal data about you.

   Third-party links

   This Site may contain links to third-party websites or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

   We also have a social media presence, including LinkedIn and Facebook, which are linked on our Site.

   If you choose to enable those connections or communicate your personal data to us via any such third-party websites or social media, please remember that we do not control those third-party sites and are not responsible for their privacy statements. You should read the privacy policy of every website or forum that you visit or use to see how your personal data is used.

2. Who this privacy policy is for

   1. Website visitors and marketing contacts. (Those who directly engage with us in the context of visiting our Site or requesting marketing or other communications.)

   2. Customers, and employees of our customers. (Those to whom we provide our services.)

   3. Employment agencies (programme suppliers) and employees of our programme suppliers. (Those who provide services to our Customers.)

   4. Candidates for employment with Pinnacle Group or candidates for placement with our Customers. (Candidates may submit information directly to Pinnacle Group or it may be submitted by a programme supplier on a candidate’s behalf for submission to an open opportunity with a Pinnacle Group Customer, in which case we only process personal data on behalf of, and on the written instructions of, the programme supplier and/or Customer (except where law requires otherwise). Please contact your programme supplier and/or customer to find out about their privacy practices and to read their privacy policy.)

3. What personal data do we collect?

   Personal data, or personal information, means any information from which that person can be identified. It does not include anonymised data.

   We may collect the following types of personal data:

   1. Personal Identifiers, such as name, address, telephone numbers, email address, organisation details (e.g. your organisation name and job title), and identification documentation;

   2. Profile Information, such as a username and profile photo, which may be classified as identifiers under the GDPR;

   3. Technical Information, such as browser and device usage information, IP address, and operating system.

   4. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

   As a controller, we do not collect any Special Categories of Personal Data about you through this website or as part of the services we provide to Customers (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

   If you fail to provide personal data

   Where we need to collect personal data by law, or under the terms of a contract we have with you or a third party, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or a third party (for example, to provide you or a third party with services). In this case, we may have to amend the contract (or delay or cancel provision of the affected service), but we will notify you if this is the case at the time.

4. How is your personal data collected?

   We use different methods to collect data from and about you including through:

   • Direct interactions. You may give us your information by filling in online forms through this website or other designated online portals or by corresponding with us by email. This includes personal data you provide when you:

     • access our service or publications;

     • contact us and/or supply us with candidates for consideration in respect of a particular service contract for our customers

     • request marketing to be sent to you;

     • complete a survey; or

     • give us feedback or contact us.

   • Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

   • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

     • Our Customers

     • Our Programme Suppliers

     • Technical Data from the following parties:

       • Analytics providers such as Google (both in and outside the UK)

       • Performance data from providers such as Amazon Web Services to load balance / map sessions to targets

       • Technical information about your browser’s ability to display icons and emojis

       • User preference surrounding consent and preferences for subsequent visits to our websites

     • Identity and Contact Data from publicly available sources such as:

       • Job Boards

       • LinkedIn or other career sites

5. How we use your personal data

   We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

   • Where we need to perform the contract we are about to enter into or have entered into with you or a third party.

   • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

   • Where we need to comply with a legal obligation.

   Generally, we do not rely on your consent as a legal basis for processing your personal data. You have the right opt out to marketing communications at any time by contacting us.

   We have set out below the ways in which we will process your personal data, separated by the capacity in which you engage with us, and the legal bases that we will rely on for that purpose.

   We may process your personal data for more than one lawful ground. Please contact us if you would like to know the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

   • Website visitors and marketing contacts

     Purpose	Type of Data	Our reason
     To respond to your enquiries or feedback, or to provide customer support	Personal Identifiers Profile Information	In order to perform a contract with you. In our legitimate interests for the purpose of providing our services to you, a programme supplier, or our customers or for business development.
     To customise the service that we provide	Technical Information	In our legitimate interests to provide our services and for the development of our business.
     To conduct marketing	Personal Identifiers	In our legitimate interests to develop and promote our business. Your Consent

   • Clients, and employees of our clients

     Purpose	Type of Data	Our reason
     To register an account and identify you as a user of our services	Personal Identifiers Profile Information	In order to perform a contract with you. In our legitimate interests to provide our services.
     To deliver our services to you or a third party	Personal Identifiers Profile Information Technical Information	In order to perform a contract with you. In our legitimate interests to provide our services and run our business.
     To manage payments, or collect fees	Personal Identifiers Profile Information	In order to perform a contract with you. In our legitimate interests to provide our services and run our business.
     To comply with our legal or regulatory obligations	Personal Identifiers Profile Information Technical Information	Where processing your personal data is necessary for us to comply with a legal obligation that we are subject to.
     To conduct marketing	Personal Identifiers	In our legitimate interests to develop and promote our business. Your Consent

   Marketing

   You may receive communications from us or about our services if you or your employer have requested such information from us and you have not opted out of receiving that information. We may also use your personal data to provide you with information about our services that may be of interest to you. If at any time you do not wish to receive this information from us, contact us and we will remove your details from our marketing database or follow the opt-out link on any message sent to you.

   We do not share your personal data with third parties for marketing purposes, and do not send third party marketing on behalf of any other business.

   Cookies

   You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this Site may become inaccessible or may not function correctly. For more information on the cookies we use, please see our cookie policy.

   Change of purpose

   We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

   If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

   Please note that we may process your personal data without your knowledge or consent, but otherwise in compliance with this privacy policy, where this is required or permitted by law.

6. Sharing data

   We share your personal data with other organisations for the purposes for which we have set out above. This may include sharing data with:

   • internal third parties which are other companies in the Pinnacle Group acting as controllers or processors and who are based in and outside of the UK for delivery of projects and group wide services;

   • external third parties which are service providers acting as processors or subprocessors based in and outside the UK and EEA who provide services such as the software as a service providers used to run our business and/or serve our customers or business partners who provide business process outsourcing or similar services

   • our customers to whom you are providing or seeking to provide services

   • programme suppliers whom our customers engage to supply contingent labour or other services

   • authorities and regulators, such as HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in and outside the UK and EEA who require reporting of processing activities in certain circumstances; and

   • professional advisers including lawyers, bankers, auditors and insurers acting as processors or controllers based in and outside the UK who require reporting of processing activities in certain circumstances or who process your personal data for the purpose of delivering their services to us.

   We will ensure that we have appropriate arrangements in place to safeguard your personal data where we share your personal data with any third parties. We do not sell your personal data for commercial purposes.

   If you require any further information about third parties with whom we may share your personal data, please contact us.

7. Transferring data

   We share your personal data within the Pinnacle Group. This may involve transferring your data outside the UK or EEA as applicable.

   Many of our external third parties are also based outside the UK or EEA so their processing of your personal data will involve a transfer of data outside the UK or EEA.

   Whenever we transfer your personal data out of the UK or EEA, whether to an external third party or a company in the Pinnacle Group, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

   • We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

   • We may use specific contracts approved for use in the UK or EEA which give personal data the same protection it has in the UK or EEA.

   Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

8. Keeping your personal data secure

   We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

   We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

   If you would like further information about our security measures, please contact us.

9. Data retention

   We will only retain your personal data for as long as is necessary to fulfil the purpose for which we originally collected it, including where we must satisfy any contractual, legal, regulatory, tax or accounting requirements. If we reasonably believe there is a prospect of litigation, or in the event of a complaint, we may retain your personal data for a longer period.

   When determining the length of time for which we retain personal data, we will consider the amount, nature and sensitivity of the personal data and the potential risk of harm from any unauthorised access to the data.

   You can request details of the retention periods for different aspects of your personal data by contacting us.

10. Your legal rights

    Under the UK and EU GDPR, you have a number of legal rights.

    • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

      • If you want us to establish the data's accuracy.

      • Where our use of the data is unlawful but you do not want us to erase it.

      • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

      • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided your consent for us to use or where we used the information to perform a contract with you.

    • Withdraw your consent at any time where we are relying on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    If you would like to exercise any of your legal rights set out above, please contact us. You will not usually have to pay a fee unless your request is clearly unfounded, repetitive or excessive. We may also refuse to comply with your request in those circumstances.

    We may need to request certain information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure no unauthorised person obtains your personal data.

    We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    
    
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