PCN Privacy Policy
1. purpose and objectives
PC Network Inc. ("PCN", "we", "us", "our") respects your privacy. This Privacy Policy explains what personal data we collect, why we collect it, who we share it with, how long we keep it, and the rights you have over it.
This Privacy Policy is issued by PCN on behalf of itself and its subsidiaries:
| Entity | Registered address | Role |
|---|---|---|
| PC Network Inc. | 851 Duportail Rd, 2nd Floor, Chesterbrook, PA 19087 | Parent company - US contracting entity, operations, and delivery |
| PC Network Canada, Inc. | 427 Princess Street, Suite 166, Kingston, ON K7L 5S9, Canada | Subsidiary - Canadian contracting entity, operations, and delivery |
| PC Network (UK) Limited | Merlin House, Brunel Road, Theale, Reading, RG7 4AB, United Kingdom | Subsidiary - UK/European contracting entity, operations, and delivery |
This Privacy Policy is a transparency notice, not a compliance policy. PCN maintains a separate internal GDPR Policy (GDP1401) that governs how we meet our obligations under the UK and EU General Data Protection Regulation. A separate written agreement with the customer, which may include a Data Processing Agreement (DPA), will govern the processing of personal data in connection with that customer.
Information about others
If you provide any personal data to us about anyone other than yourself, you must ensure that they understand how their personal data will be used and that you are authorized to disclose it to us (and to consent to its use on their behalf) before doing so.
Links to other websites
PCN websites and portals may contain links to other websites (such as those of our partners) that are not controlled by us or our service providers. These links are provided for your convenience.
We are only responsible for our own privacy practices and security of our systems, websites and portals. We recommend that you check the privacy and security policies and procedures of each and every other website that you visit.
Information about others
If you provide any personal data to us about anyone other than yourself, you must ensure that they understand how their personal data will be used and that you are authorized to disclose it to us (and to consent to its use on their behalf) before doing so.
2. Scope and Applicability
2.1. What this Privacy Policy covers
This Privacy Policy applies to personal data each company in the PCN group collects and uses as a controller (see Section 3) — that is, where PCN decides why and how the data is collected and used. Each of the companies in the PCN group may use one or more of the other companies in the group as a processor or subprocessor to process personal data for them.
In practice, PCN will process personal data as controller relating to:
visitors to www.pcn-inc.com and any other PCN website or microsite, landing page, or web form;
prospective customers and the individual contacts at customer and prospect organizations who directly engage with PCN;
named users under direct contracts for PCN services, including PCN-operated portals and other PCN-operated interfaces, in respect of their account, authentication and audit records;
individuals at our suppliers, subprocessors, resellers, and partners who directly engage with PCN concerning PCN services, sales, account management, etc.;
job applicants and candidates; and
anyone who contacts us by email, phone, web form, or at an event.
2.2. What this Privacy Policy does not cover
PCN acting as a processor. This Privacy Policy does not cover personal data when PCN is a processor. That is PCN acts on the customer's instructions documented in a contract with respect to the personal data controlled by customer.
Third-party sites and services. This Privacy Policy does not cover personal data collected directly by a third party through its own site, product, or platform, including OEM vendors whose products PCN supports, or any social, advertising, or content platform you reach from a link on our site. Those organizations publish their own privacy notices, and we encourage you to read them.
Employees and job applicants. Current PCN employees and contractors and job applicants are covered by PCN's internal HR privacy notice not by this Privacy Policy.
3. Roles and Responsibilities
Understanding which role PCN is playing determines who you should contact and which rights apply.
3.1. Where PCN is a controller
Examples of data for which PCN is the controller include personal data collected via:
our website, marketing and events;
sales, customer relationship management, account management, contracting, and billing;
account administration for named users of PCN-operated portals (identity, entitlement, authentication and audit records) of direct customers;
service desk, ticketing and support correspondence of direct customers;
supplier and partner management;
recruitment; and
security monitoring, fraud prevention, legal compliance, and the defense of legal claims in respect of our own business.
3.2. Where PCN is a processor
In its processor role, PCN ‘s processing of personal data will be regulated by a contract with the relevant customer. The customer will determine what personal data we process for them and any restrictions on that processing.
You should check the privacy policy of the PCN customer for details of what you should expect and how you can exercise your rights.
4. Personal data we collect
As controller, the personal data we collect depends upon the relationship you have with us but is principally as set out in this Section.
4.1. Website visitors
Device and connection data: IP address, browser type and version, operating system, device type, screen characteristics, language, and referring URL.
Usage data: pages viewed, time on page, links and documents clicked, form interactions, and the path taken through the site.
Cookie and similar identifiers: see Section 6. Used to collect information about you so we can provide the experiences you request, recognize your visit, track your interactions, and improve your, and other customers’ experiences.
4.2. Prospects and pre-sales
Identity and contact data: name, job title, employer, business email address, telephone number, work location, and business postal address.
Qualification and engagement data: information you provide through the pre-sales data collection, assessment scoping forms, event registrations, webinar attendance, and direct marketing preferences.
4.3. Customer, contract, and delivery
Account and credential data: username, unique user identifier, authentication factors, role and entitlement assignments, single sign-on identifiers, session and login records. We do not store passwords in a recoverable form.
Audit data: a record of actions taken in the PCN-operated portals, including the change types and workflows initiated, approved or rejected, together with the identity of the user and the timestamp.
Commercial data: contract, order, purchase order and invoicing contacts, and payment status. PCN does not collect or store full payment card numbers.
Network identifiers: IP addresses, MAC addresses, device hostnames, and DNS query logs that can identify an individual, directly or indirectly, when combined with other information. PCN treats this operational data as personal data and applies the appropriate safeguards to it.
Support and correspondence data: tickets, emails, call notes, screenshots, meeting recordings where you have been told a session is recorded, and the content of any files you attach.
4.4. Suppliers, subprocessors, and partners
Contact details, roles, due diligence, security assessment, certification, and contractual records we hold about the organization and its personnel.
5. How we use personal data, and our lawful basis
Where the UK GDPR or EU GDPR applies, we have a lawful basis for each use. The table below sets out how we use personal data, as well as our lawful basis for that use.
Note that, where PCN acts as a processor (see Section 3.2), the lawful basis for processing is determined by our customer, as controller, not by PCN.
| How we use your personal data | Data used | Lawful basis |
|---|---|---|
| We use website visitor data to operate and secure www.pcn-inc.com and keep it available | 4.1 | Legitimate interests (running and protecting our website); consent for non-essential cookies, tracking and analytics |
| We use prospect and pre-sales data to respond to enquiries, quote requests, questionnaires and assessment scoping | 4.2 | Steps taken at your request prior to entering a contract; legitimate interests (responding to business enquiries) |
| We use website visitor personal data; prospect and pre-sales personal data; and customer, contract, and delivery personal data for security monitoring, logging, threat intelligence, fraud and abuse prevention | 4.1, 4.2, 4.3 | Legitimate interests (protecting our systems, our customers and our people); legal obligation |
| We use supplier, subprocessor, and partner personal data for due diligence and management | 4.4 | Legitimate interests; legal obligation |
| We use website visitor personal data; prospect and pre-sales personal data; and customer, contract, and delivery personal data to maintain, troubleshoot, test and improve our offerings, including capacity planning | 4.1, 4.2, 4.3 | Legitimate interests (improving and securing our services) |
| We use all relevant personal data to comply with law, respond to lawful requests, and establish, exercise or defend legal claims | All | Legal obligation; legitimate interests (defending claims) |
6. Cookies, tracking, and analytics
PCN uses a small number of cookies and similar technologies on www.pcn-inc.com:
Strictly necessary cookies — required for the site to function, including session management, load balancing and security. These do not require consent.
Preference cookies — remember choices such as language or region.
Analytics cookies — help us understand which pages are used and how the site performs, so we can improve it.
We ask for your consent before setting any cookie that is not strictly necessary, and you can withdraw that consent at any time through the cookie preferences control feature on our site. Most browsers also let you block or delete cookies. Blocking strictly necessary cookies may stop parts of the site from working or may affect your user experience.
7. Who we share personal data with
We do not sell personal data. We disclose personal data to:
the other companies in the PCN group — for the delivery, support, and administration of our services;
Subprocessors and service providers — organizations that process personal data for us under written contract, restricted to what is necessary to perform their function.
Your organization — where you are a named user of a PCN-operated portal, your account and audit records are visible to your own organization's administrators on request;
OEM and third-party technology providers — where a support case must be escalated to vendor support, where a customer has directed us to integrate their environment with a third-party service, and in cases where third party services may require data collection for the purpose of improving the security of the services provided;
Professional advisers — lawyers, auditors, insurers and accountants, under duties of confidentiality;
Acquirers — a buyer in connection with a merger, acquisition, financing or sale of assets; and
Legal Authorities — law enforcement, regulators, courts or other public authorities, where we are legally required to do so.
8. Where we store and process personal data
PCN and its subprocessors process personal data in the following locations:
| Organization | Location | Function |
|---|---|---|
| PC Network Inc. | United States | Corporate, sales, service delivery |
| PC Network Canada, Inc. | Canada | Corporate, sales, service delivery |
| PC Network (UK) Limited | United Kingdom | Corporate, sales, service delivery |
| Zen Systems Inc. | United States | Delivery resourcing |
| TWO95 International Staffing Services Pvt. Ltd. (Zen Systems subsidiary) | India | Delivery resourcing |
| TWO95 International Staffing Services Pvt. Ltd. (Zen Systems subsidiary) | United Arab Emirates | Delivery resourcing |
| TMA Solutions | Vietnam | Delivery resourcing |
Much of PCN's service delivery is performed by remote access into infrastructure that the customer hosts and controls, rather than by copying customer data into PCN's own systems.
Restricted transfers of personal data from the UK and EEA.
transfers to Canada. Canada benefits from a European Commission adequacy decision for commercial organizations subject to PIPEDA and is recognized as adequate by the UK and the EEA.
transfers to the United States, India, the United Arab Emirates, Vietnam and any other country not covered by an adequacy decision. PCN relies on:
the European Commission Standard Contractual Clauses (SCCs) adopted on 4 June 2021, for transfers from the EEA; and
the UK International Data Transfer Agreement Addendum (UK IDTA Addendum) issued by the Information Commission for transfers from the United Kingdom.
9. How we protect personal data
We use appropriate physical, technical and organizational safeguards that are designed to protect your personal information. However, despite these controls, information relayed through public networks is always at risk.
PCN operates an Information Security Management System framed on ISO/IEC 27001:2022). Controls are selected through a documented risk assessment, and include:
role-based access control and least privilege;
encryption of data in transit and at rest;
network segmentation and boundary protection;
logging, audit and monitoring of system activity;
structured incident reporting and response;
information classification and handling;
personnel screening, confidentiality undertakings and annual security awareness training;
supplier security requirements and due diligence; and
change and configuration management, and secure development practices.
PCN is ISO 27001:2022 Certified.
Your responsibilities. No system is completely secure. You are responsible for keeping your credentials confidential, for enabling multi-factor authentication where offered, for configuring your own environment securely, and for telling us promptly at security@pcn-inc.com if you believe an account has been compromised.
Personal data breach notification. In the unlikely event PCN suffers a personal data breach in respect of personal data for which it is a controller and which is likely to result in a risk to individuals' rights and freedoms, we will notify the relevant supervisory authority and will notify affected individuals where the risk to them is high.
10. How long we keep personal data
We keep personal data only as long as we need it for the purposes set out in this Privacy Policy and then, unless we have a legal basis for retention, we will delete it, irreversibly anonymize it or put it beyond use.
11. Artificial intelligence and automated decision-making
PCN uses generative AI tools internally and our use of these technologies is governed by internal PCN policies. In summary:
We do not make decisions that produce legal or similarly significant effects about individuals based solely on automated processing and we do not use AI to make hiring decisions without human review.
AI-generated output used in our business operations is reviewed and verified by a qualified person; AI supports human judgement rather than replacing it.
PCN personnel are prohibited from submitting personal data to unapproved AI tools and from uploading personal data to approved AI tools without explicit approval.
We do not use personal data collected by PCN, to train publicly available foundation models.
Where an individual interacts with an AI assistant in a PCN interface, we tell the individual so.
If you believe an automated process has affected you unfairly, contact privacy@pcn-inc.com and we will arrange human review.
12. Your rights
Subject to the law that applies to you, you have a number of data protection rights which are the rights to:
be informed about how we use your personal data — which is set out in this Privacy Policy;
access the personal data we hold about you, and receive a copy;
rectify personal data that is inaccurate or incomplete;
erase personal data where we no longer have a lawful reason to keep it;
restrict processing while a dispute about accuracy or legitimate interests is resolved;
object to processing based on legitimate interests, and to object to direct marketing at any time, without needing to give a reason;
data portability — receive data you provided to us in a structured, commonly used, machine-readable format, and have it transmitted to another controller where technically feasible;
withdraw consent you have given at any time without affecting processing reliant on consent which we carried out before withdrawal;
not be subject to a decision based solely on automated processing that produces legal or similarly significant effects; and
complain — this should, in the first instance, be to us. You can also complain to a data protection supervisory authority.
Some of these rights are not absolute and are subject to exceptions and exemptions.
12.1. How to exercise your rights
Email privacy@pcn-inc.com, or write to the Privacy Lead, PC Network Inc., 851 Duportail Rd, 2nd Floor, Chesterbrook, PA 19087, USA.
Please tell us which right you are exercising and give us enough information to find your data. We may ask for proof of identity — we do this to make sure we do not disclose your data to someone else, and we will not use the identity information for any other purpose.
We will respond to requests within one month. If your request is complex or you have made several requests, we may extend this by a further two months and will tell you within the first month if we do. There is no charge, unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or decline it, and we will explain why.
If your request concerns data for which PCN is a processor, such as where it is held inside a PCN customer's environment, we will tell you and direct you to the relevant organization.
12.2. Complaints
We would like the chance to resolve any concern first — please contact privacy@pcn-inc.com. You also have the right to complain directly to a supervisory authority:
United Kingdom: Information Commissioner (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF — ico.org.uk
European Economic Area: the supervisory authority of the member state where you live, work, or where the issue arose. A list is published by the European Data Protection Board at edpb.europa.eu
Canada: Office of the Privacy Commissioner of Canada — priv.gc.ca; or the Commission d'accès à l'information du Québec for Québec residents
United States: the Attorney General of your state, where your state law provides for it.
13. Additional information for the United Kingdom and the EEA
This Section 13 supplements the rest of this Privacy Policy and applies if you are in the United Kingdom, the European Economic Area, or Switzerland. Where it conflicts with another section, this Section 13 prevails for those individuals.
13.1. Controller.
PC Network Inc. is the controller, except where PC Network (UK) Limited is the contracting entity or holds the data, in which case PC Network (UK) Limited is the controller.
13.2. UK establishment.
PC Network (UK) Limited, Merlin House, Brunel Road, Theale, RG7 4AB, is PCN's establishment in the United Kingdom. PCN is therefore not required to appoint a UK representative under Article 27 of the UK GDPR.
13.3. EU representative.
PCN has no establishment in the EEA. PCN does not offer services to, or monitor the behavior of individuals in the EEA, therefore, PCN is therefore not required to appoint an EEA representative under Article 27 of the EU GDPR.
13.4. Privacy contact.
PCN is not required to have a Data Protection Officer, but has nevertheless designated a Privacy Lead, accountable for data protection and reachable at privacy@pcn-inc.com.
13.5. Lawful bases.
See the table at Section 5.
14. Additional information for Canada
This Section 14 supplements the rest of this Privacy Policy and applies if you are in Canada.
PCN and PC Network Canada, Inc. handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, provincial legislation including Québec's Act respecting the protection of personal information in the private sector, as amended by Law 25.
Consent. We obtain consent for the collection, use and disclosure of personal information, except where the law permits otherwise. The form of consent reflects the sensitivity of the information. You may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice; we will tell you the consequences of withdrawal.
Accountability. PCN's Privacy Lead is accountable for personal information under PCN's control, including information transferred to a third party for processing.
Transfers outside Canada. Personal information may be stored or accessed outside Canada, including in the United States, the United Kingdom, India, the UAE and Vietnam, and is therefore subject to the laws of those jurisdictions, including lawful access by their courts and authorities. We use contractual and security measures to provide a comparable level of protection.
Access and correction. You may request access to, and correction of, your personal information by contacting privacy@pcn-inc.com. We will respond within 30 days or explain why we need more time.
Breach of security safeguards. We report breaches creating a real risk of significant harm to the Office of the Privacy Commissioner of Canada and to affected individuals and maintain records of all breaches of security safeguards.
Québec residents. You additionally have the right to data portability, the right to be informed of automated decision-making and to submit observations on it, and the right to request de-indexing or cessation of dissemination in the circumstances the Act provides. PCN's Privacy Lead acts as the person in charge of the protection of personal information.
15. Additional information for United States residents
This Section 15 supplements the rest of this Privacy Policy and applies if you are a resident of a US state with a comprehensive consumer privacy law, including California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana and others as they take effect.
15.1. Notice at collection.
The categories of personal information we collect are set out in Section 4. In the terms used by the California Consumer Privacy Act, as amended, these are: identifiers; personal information categories listed in the California Customer Records statute; commercial information; internet or other electronic network activity information; professional or employment-related information; and, for job applicants, education information. We collect these for the business purposes set out in Section 5 and retain them for the periods in Section 10.
15.2. Sensitive personal information.
PCN does not collect sensitive personal information for the purpose of inferring characteristics and does not use or disclose it beyond the purposes permitted without a right to limit.
15.3. No sale or sharing.
PCN does not sell personal information and does not share it for cross-context behavioral advertising. We have not done so in the preceding twelve months. We do not knowingly sell or share the personal information of anyone under 18.
15.4. Your rights.
Subject to your state's law, you have the right to know what we collect and why; to access a copy; to correct inaccuracies; to delete; to opt out of sale, sharing and targeted advertising; to limit the use of sensitive personal information; to appeal a refusal; and not to be discriminated against for exercising any of these rights. We will not deny you goods or services, charge you a different price, or provide a different level of quality because you exercised a privacy right.
15.5. How to exercise your rights.
Email privacy@pcn-inc.com or write to the address in Section 18. We verify requests by matching the information you provide against our records. An authorized agent may submit a request on your behalf with written permission and, where required, a power of attorney; we may still ask you to verify your identity directly.
15.6. Timing and appeals.
We confirm receipt within 10 business days and respond within 45 days, extendable once by a further 45 days where reasonably necessary. If we decline, we will explain why, and you may appeal by replying to our response with the word "Appeal". We will respond to an appeal within 45 days. If we deny your appeal, you may contact your state Attorney General.
15.7. Employees and B2B contacts.
California residents who are job applicants or business contacts have the rights described above in respect of the personal information we hold about them in those capacities.
16. Children's privacy
PCN's website and services are directed at businesses and are not intended for children. We do not knowingly collect personal data from anyone under the age of 18. If you believe a child has provided us with personal data, contact privacy@pcn-inc.com.
PCN does not direct services to, does not knowingly market its products and services to, nor does it knowingly solicit data from persons under the age of 18. Where such data reaches us unsolicited — for example in a support attachment or a log sample — we delete it promptly when it is identified as relating to a minor unless we are required or legally permitted to retain it.
17. Changes to this Privacy Policy
We review this Privacy Policy at least annually and update it when our processing changes or the law requires it. The effective date and version appear at the top. Where a change is material, we will take reasonable steps to notify you in advance — by email to customer and portal contacts, by a notice on our website, or both. Previous versions are available on request from privacy@pcn-inc.com.
18. Contact Us
| Purpose | Contact |
|---|---|
| Privacy questions, rights requests and complaints | privacy@pcn-inc.com |
| Marketing opt-out | opt-out@pcn-inc.com, or the unsubscribe link in any direct marketing message |
| Suspected security incident or vulnerability | security@pcn-inc.com |
| United States of America | Privacy Lead, PC Network Inc., 851 Duportail Rd, 2nd Floor, Chesterbrook, PA, 19087, USA |
| United Kingdom and Europe | Privacy Lead, PC Network (UK) Limited, Merlin House, Brunel Road, Theale, Reading, RG7 4AB, United Kingdom |
| Canada | Privacy Lead, PCN Network Canada, Inc., 457 Princess Street, Suite 166, Kingston, ON, K7L5S9, Canada |