The company that requested you to use the online tool is the data controller and PDA acts as the data processor. The controller decides which data are collected and for what they are used. If you have any concerns about the data requested or about the process, you should first contact them.
We act as processor through two main methods of data processing: (1) providing clients with access to their own logins on our server to administer the service themselves; or (2) administering the service of sending the final report on behalf of the data controller – this report is described as a self‑assessment in this document.The data controller decides what data is collected and what this data is used for. The company that requested you to use the online tool is the data controller and PDA acts as the data processor. The controller decides which data are collected and for what they are used. If you have any concerns about the data requested or about the process, you should first contact them.

We act as processor through two main methods of data processing: 1. providing clientswith access to their own logins on our server to administer the service themselves or (2) administering the service of sending the final report on behalf of the data controller – this report is described as a self‑assessment in this document.

6. 6. ARE YOUR PERSONAL DATA USED FOR PROFILING AND/OR AUTOMATED DECISION‑MAKING?
   General profiling is carried out without any automated decision‑making being used.
   The purpose of general profiling is to evaluate general personal aspects about data subjects in order to analyse and make predictions about their abilities to perform a job, their interests or their likely behaviours. The purpose of general profiling is to evaluate general personal aspects about data subjects in order to analyse and make predictions about their abilities to perform a job, their interests or their likely behaviours. To this end, different questionnaires may be used to collect such information.
   
   The categories of data used in general profiling are personal preferences, interests, reliability, behaviour, aptitudes, habits and values, which are necessary for the production of the PDA Assessment Report.
   By preparing these general profiles it is possible to identify the capabilities required to successfully perform a particular job so that this indicator becomes a reference for selection, evaluation, development, remuneration and even to support organisational change.
   PDA tools have been developed for the application of assessments of competencies and behaviours related to the work environment (e.g., initiative, patience, autonomy, etc.), allowing the identification of people’s behavioural profiles and uniqueness, managing their talent, developing skills and motivating them to reach their exponential talent.
   
   They are merely consultative support tools that address these goals without producing any automated decisions based on these assessments. These are merely consultative support tools directed at those purposes and no automated decisions of any kind are produced from such assessments. Therefore, they are not tools that automatically deny data subjects a job opportunity or place them at any disadvantage; that is, the results of the assessments do not cause significant exclusion or discrimination of data subjects.
   Data subjects do not correspond to an exhaustive defined group of persons and the profile describes only limited aspects relating to the categories of data indicated.
   In the process of general profiling, anonymisation techniques will be used to protect data subjects’ privacy, among other technical and organisational measures.

7. 7. ARE YOUR PERSONAL DATA USED FOR AUTOMATED DECISIONS?
   No, PDA does not make automated decisions through the processing of personal data with (or without) profiling in its tools.

8. 8. DOES PDA USE PERSONAL DATA FOR RESEARCH PURPOSES?
   PDA conducts research and data analysis. In this way, your data may be processed for research purposes.
   
   When we process personal data for research, we do so as controller, based on our legitimate interest in offering products and services that better meet our customers’ needs and wishes, always safeguarding the right to object to processing under the GDPR.
   
   Personal data processed for research purposes will be retained for the time appropriate to each case depending on the type of research in which it is involved.
   When we process personal data for research, we ensure that we take appropriate security measures, such as anonymization and pseudonymization procedures, so that your data is not or no longer identifiable, or can no longer be attributed to a data subject without the use of additional information listed separately.
   We ensure that our research team has access to the minimum amount of data necessary to carry out this work and that they are subject to ethical standards and the GDPR.
   Finally, once the research is completed, all data used is discarded or anonymized, making it impossible to identify an individual from the data.

9. 9. IF PDA IS THE CONTROLLER: WHAT IS THE LEGAL BASIS PDA RELIES ON TO USE YOUR DATA?
   It depends; however, we can assure you that PDA only processes data when we have a legal basis to do so.
   Depending on the variety of services we offer and how they are provided, we will rely on different legal bases when processing your data, which may include, without limitation, consent, performance of a contract or pre‑contract and/or compliance with a legal obligation.
   We may also process your data as controller to allow us to achieve our legitimate interests, always ensuring that these are carefully balanced and do not adversely affect your rights.
   In particular cases where we request your consent for the processing of your personal data, we will ensure that the consent obtained complies with applicable legislation, and is specific and informed where necessary and aligned with the purpose of the processing.
   Depending on the range of services we offer and how they are provided, we will rely on a different lawful basis when processing your data, which may be, non-exhaustively, consent, performance of a contract or pre-contract and/or compliance with legal obligation.
   We may also process your data as a data controller to enable us to achieve our legitimate interests, always ensuring that these are carefully balanced and do not have an adverse impact on your rights.
   In particular cases where we seek your consent to process your personal data. We will ensure that the consent obtained is in line with applicable applicable law and is specific and informed where necessary and in accordance with the purpose of the processing.

10. 10. HOW DOES PDA ENSURE SYSTEM SECURITY AND PROTECT YOUR DATA?
    At PDA we take seriously the security of the personal data entrusted to us.
    
    All our offices have access control systems and all PDA staff receive regular training on data protection and IT security.
    PDA periodically tests the security of our networks. Access to personal data is restricted and can only be accessed by those who have a legitimate reason to do so.
    All our offices are equipped with access control systems and all PDA employees receive regular training on data protection and IT security.
    If you would like to learn more about how we secure our systems, please read our Policies which are available on the website and provide more details on how we incorporate both security and privacy by design.
    However, absolute security cannot be guaranteed and no security system is impenetrable. Therefore, if any information processed and under our control is compromised as a result of a security breach, we will take appropriate steps to investigate the incident, notify the Supervisory Authority and, where appropriate, those users who may have been affected so that they can take suitable measures.

11. 11. USER RESPONSIBILITY
    By providing us with your data through electronic channels, the user guarantees that they are over 14 years of age and that the data provided to PDA are true, accurate, complete and up to date. For these purposes, the user confirms that they are responsible for the veracity of the data communicated and that they will keep such information duly updated so that it corresponds to their actual situation, being liable for any false or inaccurate data that they may provide, as well as for any damages, direct or indirect, that may arise. To this effect, the user confirms that he/she is responsible for the veracity of the data communicated and that he/she will keep such information conveniently updated so that it corresponds to his/her real situation, being responsible for any false or inaccurate data that he/she may provide, as well as for any damages, direct or indirect, that may arise.

12. 12. HOW LONG DO WE KEEP YOUR INFORMATION?
    At PDA we only keep your information for the period of time necessary to fulfil the purpose for which it was collected, to comply with the legal obligations imposed on us, and to address any potential liabilities that may arise from fulfilling the purpose for which the data were collected.
    
    In any case, and as a general rule, we will keep your personal information while there is a contractual relationship binding us or you have not exercised your right to erasure and/or restriction of processing, in which case the information will be blocked without any use beyond its conservation, while it may be needed for the establishment or defence of claims or some type of liability may arise that must be addressed.
    
    If you are completing an online assessment with one of our tools, PDA acts only as processor and the employer or prospective employer acts as controller, so they will decide how long the data should be kept and will manage the processing, retention and deletion process accordingly.
    
    For our clients who use our self‑assessment service (where we provide a managed service to send assessment links), the controller‑processor relationship remains, with PDA as processor; therefore, we will follow the client’s explicit instructions to delete data.
    
    If you wish to join our staff and apply for one of our job vacancies, the data provided will become part of our database and will be kept for the duration of the selection process and for a maximum of 01 year, or until you exercise your right to erasure.In the event that you wish to join our staff and apply for one of our jobs, the data provided will become part of our database and will be retained for the duration of the selection process and for a maximum of 01 year or until you exercise your right of deletion.

13. 13. TO WHOM DO WE DISCLOSE YOUR DATA?
    In general, at PDA we do not share your personal information, except for those disclosures that we must make on the basis of legal obligations imposed on us.
    You may inform us of your objection to the disclosure of your data; however, in such a case, it would not be possible to provide you with the requested service.
    Likewise, your personal information will be available to Public Administrations and to Courts and Tribunals for the purpose of addressing potential liabilities arising from the processing.

14. 14. INTERNATIONAL DATA TRANSFERS
    PDA is headquartered in Argentina and carries out international transfers of personal data. In turn, the servers are located in countries within the European Economic Area (EEA).
    Thus, international data transfers are made only to countries within the EEA, in accordance with both Argentine law (Law 25.326 – PDPA) and the GDPR.
    Furthermore, although Argentina has been declared a country with an adequate level of protection by the European Commission (Decision 2003/490/EC), PDA additionally applies the European Commission’s Standard Contractual Clauses (Art. 46 GDPR) to ensure data protection.
    Data transfers are carried out solely for the purposes indicated and under appropriate technical and organisational measures. In all cases, PDA guarantees the application of suitable safeguards to protect the privacy and security of your personal data.
    GO4CLIC Group S.L., as EU representative, monitors compliance with the clauses and acts as the point of contact with European data protection authorities.

15. 15. WHAT ARE YOUR RIGHTS IN RELATION TO THE PROCESSING OF YOUR DATA AND HOW CAN YOU EXERCISE THEM?
    Data protection regulations allow you to exercise your rights of access, rectification, erasure and portability of data, and to object to and restrict processing, as well as not to be subject to decisions based solely on the automated processing of your data, where applicable.
    
    These rights are characterised by the following:
    • Their exercise is free of charge, unless the requests are manifestly unfounded or excessive (e.g., repetitive), in which case PDA may charge a fee proportional to the administrative costs incurred or refuse to act.
    • You may exercise the rights directly or through your legal or voluntary representative.
    • We must respond to your request within one month; however, taking into account the complexity and number of requests, the period may be extended by a further two months.
    • If PDA does not act on the request, we will inform you, no later than one month, of the reasons for not taking action and of the possibility of lodging a complaint with a Supervisory Authority.
    Please note that, if you take a PDA assessment, the responsible party (this would normally be your employer, prospective employer or educational establishment) is ultimately responsible for assisting you in exercising your rights, so we recommend that you contact them in the first instance.
    To exercise your rights, PDA provides the following channel:
    • Send a document setting out the right to be exercised and the reasons, scanned and signed, to the email address gdpr@pdainternational.net, indicating in the subject line “Exercise of GDPR Rights”.
    You must prove your identity by attaching a photocopy or, where appropriate, a scanned copy of your ID card or equivalent document in order to verify that we only respond to the data subject or their legal representative, in which case proof of representation must be provided.
    
    
    Likewise, and especially if you consider that you have not obtained full satisfaction in the exercise of your rights, we inform you that you may file a complaint with the National Control Authority.

16. 16. HOW AND WHERE ARE YOUR DATA STORED?
    PDA guarantees the security of client and candidate data at all times.
    Our primary servers are hosted in top‑tier data centres within the European Economic Area (EEA), which strictly control access to the physical environment and provide exceptional system availability. At PDA we also manage our IT environment, ensuring that we maintain full control of the systems that underpin the assessments we provide and the information they contain.

17. 17. REPORT A DATA BREACH OR REQUEST RESOLUTION OF PRIVACY ISSUES
    If you believe there has been a loss of personal data that we use or manage, or an unlawful use or disclosure of such data, or any data privacy issue, please contact our Privacy Officer at gdpr@pdainternational.net.

18. 18. CHANGES TO THIS PRIVACY POLICY
    PDA reserves the right to review its Privacy Policy whenever it deems appropriate, in which case Users will be notified. For this reason, we ask Users to regularly check this privacy statement to read the most recent version of this Privacy Policy.
    Related documents: GDPR • Cookie Policy • Terms of Use • Legal Notice