Privacy Policy

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Last updated January 2, 2024

Propono believes your right to privacy is important. This privacy statement (“Privacy Statement”) is an explanation of the privacy practices of Propono (“we” or “us”). This Privacy Statement explains the types of information we collect via our website(s) and through other interactions with you and how we use, share, and protect this information and your rights regarding your personal information. By using our website or otherwise continuing to access information or communications from Propono, you agree to our use of such information in accordance with this Privacy Statement.

Propono As A Service Provider

When we act as a service provider for our customers, we collect personal information on behalf of our customers subject to our contractual obligations. To the extent we have agreed to act as a service provider in an applicable customer contract, we follow the instructions of our customer on how to process personal information on our customer’s behalf.

Information We Collect

In the course of offering and providing our products and services, we may receive information from and about you through information you provide, automatic tracking technologies and third parties. This information may include information that identifies, relates to, describes, references, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In connection with our business operations, we may have reason to collect information such as:

  1. Identifying information: such as a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number or other similar identifiers, usually related to a registration or directly provided by you.
  2. Financial information: such as a bank account number, credit card number, debit card number or any other financial information, usually as a result of your providing that information to purchase a product or a service or allow us to deliver a service.
  3. Commercial information: such as records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies.
  4. Internet or other similar network activity: such as browsing history, search history or information on a consumer’s interaction with a website, application or advertisement.
  5. Professional or employment-related information: such as your name, employer, current job title, company address, email address, telephone number and records of correspondence with us.
  6. Inferences we draw about you: such as information about your preferences, characteristics, predispositions, behavior or other trends that help us identify which services or products you may be interested in.
  7. Applicant information: such as your resume, work history, education, cover letter, drug screening information, background check information and other information required for our applications.

We do not usually seek to collect sensitive personal information except as necessary to render services requested by you or to evaluate applicants for employment. Personal Information does not include publicly available information or de-identified or aggregated consumer information.

How We Collect Personal Information

We may collect personal information about you because you provide it directly to us in connection with our website or the services that Propono provides or has previously provided or otherwise. We may receive personal information from Propono affiliates or from third parties, such as your employer, entities in which you have an ownership interest, a tax authority and/or other relevant authority/administrative bodies or our third-party marketing partners. In some cases, we may observe or infer personal information from the information you provide to us and/or the way you interact with us. In addition, we may receive personal information directly or indirectly from activity on our websites.

This personal information may be received by us through many different mediums, including in-person discussions, telephone conversations, and electronic or other written communications. Without access to all the personal information necessary to deliver a product or service, we may be unable to provide or deliver the product or services.

Where another party (such as a company or a partnership or any third parties acting on your or their behalf) provides your personal information to us, they must also comply with their obligations under relevant privacy laws and regulations. If you believe that the entity for whom you work or a third party has not provided you with details of the personal information that it holds about you and/or has not obtained your authority to provide us with that personal information for processing as described in this Privacy Statement, then please contact such entity directly.

Personal Information Relating to Third Parties

If any personal information which you provide to us relates to any third party, for example a spouse or civil partner, individuals (including children) who depend on you financially or a joint account holder or a beneficiary or trustee of a trust, then by providing us with their personal information you will need to ensure that you have obtained any necessary permissions from those persons to the use of their personal information in the way set out in this Privacy Statement, or you are otherwise permitted to give us this personal information. You should share a copy of this Privacy Statement with those other individuals before disclosing any personal information about them to us.

How We Use Personal Information

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

  1. To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
  2. To provide you with information, products or services that you request from us or our related affiliates.
  3. To provide you with email alerts, event registrations and other notices concerning our products or services or events or news that may be of interest to you.
  4. To carry out our obligations, including our legal obligations, and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  5. To improve our services, products and our website and present its contents to you.
  6. For testing, research, analysis and product development.
  7. As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  8. To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
  9. As described to you when collecting your personal information.
  10. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred.
  11. To evaluate you for employment at Propono or to begin the employment process.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Share Your Personal Information

We may disclose your personal information to a third party for the following purposes:

  1. Where relevant, we have a contract with you to provide services and processing your personal information is necessary for the performance of such contract.
  2. We have a legitimate interest in processing your personal information, which may be to:
    1. provide services to you and/or to the entity that has engaged us to provide the services;
    2. support the management of our client engagements;
    3. evaluate, develop or improve our services or products;
    4. to provide you with information about our services or products; or
    5. protect our business interests.
  3. We are subject to legal, regulatory or professional obligations.

Third parties and service providers to whom we disclose personal information

In connection with one or more of the purposes outlined in this Privacy Statement, we may disclose your personal information to:

  1. Propono affiliates.
    Categories of information shared: identifying information, financial information, commercial information, internet or other similar network activity, professional or employment-related information, applicant information and inferences we draw about you
    2. Those with whom you have requested us to share information, such as your spouse or civil partner. Categories of information shared: identifying information, financial information, commercial information, applicant information, and professional or employment-related information
    3. Competent authorities, including courts and authorities regulating us, in each case to comply with legal, regulatory or professional obligations or requests. Categories of information shared: identifying information, financial information, commercial information, internet or other similar network activity, professional or employment-related information, applicant information and inferences we draw about you
    4. Vendors and administrative, support, infrastructure and other service providers handling your information on our behalf. In each case, such vendors and service providers will be contractually bound by confidentiality and privacy obligations consistent with the obligations in this Privacy Statement. Categories of information shared: identifying information, financial information, commercial information, internet or other similar network activity, professional or employment-related information, applicant information and inferences we draw about you
    5. Third parties to whom we disclose information in the course of providing services to you or to the entity that has engaged us to provide the services. Categories of information shared: identifying information, financial information, commercial information, internet or other similar network activity, professional or employment-related information, and inferences we draw about you
    6. Social media platforms and analytics providers that we use to communicate with you and provide you with information you may be interested in.

Categories of information shared: identifying information (excluding sensitive personal information), internet or other similar network activity, and inferences we draw about you. Propono does not sell or lease your personal information to others. At this time, Propono does not “share” (as defined under the California Consumer Privacy Act) your personal information for cross-context behavioral advertising.


We have in place reasonable commercial standards of technology and operational security to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Only authorized personnel, with appropriate awareness of privacy obligations, are provided access to your personal information.

Retention Period

We retain personal information as long as is necessary to fulfill the purposes identified in this Privacy Statement or (i) as otherwise necessary to comply with applicable laws or professional standards or (ii) as long as the period in which litigation or investigations might arise in respect of our services. Where personal information is no longer needed, we either irreversibly anonymize the data (in which case we may further retain and use the anonymized data) or securely destroy the data.

Your Rights

You have various rights in relation to your personal information depending on the jurisdiction in which you are located. Depending on the applicable laws and under certain conditions, you may have a right to:

  1. Obtain confirmation that we are processing your personal information and request:
    1. a copy of the personal information we hold about you (sometimes referred to as “data portability”);
    2. the categories of personal information we collected about you;
    3. the categories of sources for the personal information we collected about you;
    4. our business or commercial purpose for collecting or selling that personal information; and
    5. The categories of third parties with whom we share that personal information.
  2. Ask that we update the personal information we hold about you or correct such information that you think is inaccurate or incomplete.
  3. Ask that we delete personal information that we hold about you or restrict the way in which we use your personal information.
  4. Withdraw consent to our processing of your personal information (to the extent our processing is based on your consent).
  5. Ask us to stop or start sending you marketing messages at any time.
  6. To the extent not inconsistent with applicable professional standards and the ownership of client workpapers, obtain and/or move your personal information to another service provider.
  7. Object to our processing of your personal information.

These rights are subject to certain exemptions, including without limitation to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). We may deny requests as permitted by law.

Where our processing of a sensitive or special category of personal information is reliant on your consent and you withdraw that consent, we will cease processing the relevant information for the purposes of providing our services and the effect may be that we are no longer able to provide the services.

However, we may still retain a copy of the relevant information for as long as necessary to comply with applicable laws or professional standards or as long as the period in which litigation or investigations might arise in respect of our services.

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

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
  2. Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  5. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  6. Otherwise comply with local or federal law.

To exercise any of your rights or raise any questions that you have about our use of your personal information, please contact us.

You, or a person authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You are limited as to how frequently you may make a verifiable consumer request for access or data portability. The verifiable consumer request must:

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  2. Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12- month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


We will not discriminate against you for exercising any of your rights.

Changes to this Privacy Statement

We may modify or amend this Privacy Statement from time to time at our discretion. When we make changes to this Privacy Statement, we will amend the revision date at the top of this page and the modified or amended Privacy Statement shall apply to you and your personal information as of that revision date. We encourage you to review the Privacy Statement on our website periodically to be informed about how we are protecting your personal information.

Contact us

If you have any questions or concerns regarding this Privacy Statement or your personal information, please contact our data protection officer by email at or by phone at 207-901-1000.