Privacy Policy

Effective Date: July 2026

1. Introduction

Welcome to Phoenix Human Capital Solutions LLC (“Company,” “we,” “our,” or “us”).

We are committed to protecting the privacy, confidentiality, and security of the personal information entrusted to us. This Privacy Policy explains how we collect, use, disclose, store, transfer, and protect personal information when providing human resources consulting, recruitment, payroll, compliance, executive coaching, employee relations, HR outsourcing, and related professional services.

This Privacy Policy applies to:

• Clients
• Prospective clients
• Job applicants
• Employees
• Contractors
• Consultants
• Website visitors
• Business partners
• Vendors
• Any other individual whose personal information we process.

2. Scope

This Privacy Policy applies to our operations worldwide, including services provided in:

• United States
• Canada
• European Union
• European Economic Area (EEA)
• United Kingdom
• Australia
• New Zealand
• Singapore
• Switzerland
• Latin America
• Middle East
• Africa
• Asia-Pacific

Where local privacy laws provide greater protection than this policy, the local law shall prevail.

3. Information We Collect

We may collect:

Personal Identification

• Full name
• Home address
• Mailing address
• Email address
• Telephone numbers
• Date of birth
• Government-issued identification
• Passport information
• Driver’s license
• Social Security Number (US)
• Social Insurance Number (Canada)
• National Insurance Number (UK)
• Other legally required identifiers

Employment Information

• Resume
• Curriculum Vitae
• Employment history
• Education
• Certifications
• References
• Professional licenses
• Performance records
• Compensation history
• Benefits information
• Attendance records
• Payroll records
• Timekeeping records

Recruitment Information

• Interview notes
• Assessment results
• Skills testing
• Background checks
• Reference checks
• Work authorization
• Immigration documentation

Financial Information

• Bank account information
• Payroll information
• Tax information
• Expense reimbursement records

Sensitive Personal Information

Where permitted by law and necessary for HR services:

• Disability information
• Medical accommodations
• Health insurance enrollment
• Race or ethnicity (where legally required)
• Veteran status
• Gender identity
• Religious accommodation requests
• Criminal background information (where legally permitted)

We process sensitive information only when legally authorized or with appropriate consent where required.

4. Information Collected Automatically

When visiting our website, we may collect:

• IP address
• Browser type
• Operating system
• Device identifiers
• Cookies
• Usage statistics
• Pages visited
• Referral URLs
• Session information

5. How We Use Personal Information

We use information to:

• Deliver HR consulting services
• Conduct recruitment
• Process payroll
• Administer employee benefits
• Conduct workforce planning
• Verify qualifications
• Conduct legally permissible background checks
• Manage employee relations
• Investigate complaints
• Conduct workplace investigations
• Comply with labor laws
• Respond to legal requests
• Improve our services
• Manage contracts
• Protect against fraud
• Maintain cybersecurity
• Communicate with clients

6. Legal Bases for Processing (GDPR)

Where the GDPR applies, we process personal information based on one or more of the following legal grounds:

• Consent
• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests
• Protection of vital interests
• Public interest where applicable

7. Cookies

Our website uses cookies to:

• Improve functionality
• Analyze traffic
• Remember user preferences
• Improve security

Users may control cookies through browser settings.

Where required by law, we obtain consent before placing non-essential cookies.

8. Sharing Information

We do not sell personal information.

We may share information with:

• Clients
• Payroll providers
• Benefits providers
• Recruitment platforms
• Background screening vendors
• Cloud hosting providers
• IT service providers
• Legal counsel
• Auditors
• Government agencies
• Regulatory authorities
• Courts
• Insurance companies

Recipients receive only the information necessary to perform their services.

9. International Data Transfers

Because we operate internationally, personal information may be transferred across borders.

Where required, transfers are protected through:

• Standard Contractual Clauses (SCCs)
• UK International Data Transfer Agreement
• Adequacy decisions
• Binding contractual safeguards
• Other lawful transfer mechanisms

10. Data Security

We maintain administrative, technical, and physical safeguards, including:

• Encryption
• Secure cloud storage
• Firewalls
• Multi-factor authentication
• Access controls
• Employee confidentiality agreements
• Vendor due diligence
• Security monitoring
• Incident response procedures

No transmission over the Internet is completely secure.

11. Data Retention

We retain information only as long as necessary to:

• Deliver services
• Meet legal obligations
• Resolve disputes
• Enforce agreements
• Maintain business records

Retention periods vary depending on applicable law.

12. Individual Privacy Rights

Depending on your jurisdiction, you may have the right to:

• Access personal information
• Correct inaccurate information
• Delete personal information
• Restrict processing
• Object to processing
• Withdraw consent
• Receive data portability
• Request human review of automated decisions
• Lodge a complaint with a supervisory authority

Requests may be submitted using the contact information below.

13. California Privacy Rights

Residents of California may have rights under applicable California privacy laws, including rights to:

• Know what personal information is collected
• Request deletion
• Request correction
• Obtain copies of personal information
• Limit use of certain sensitive personal information where applicable
• Exercise rights without unlawful discrimination

14. European Union Privacy Rights

Individuals located in the EEA may exercise rights under the GDPR, including:

• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to object
• Right to data portability
• Right to withdraw consent
• Right to complain to a supervisory authority

15. United Kingdom Privacy Rights

Individuals located in the United Kingdom have substantially similar rights under UK data protection law.

16. Canadian Privacy Rights

Individuals in Canada may request:

• Access to personal information
• Corrections
• Withdrawal of consent where applicable
• Information regarding our privacy practices

17. Children’s Privacy

Our services are intended for adults and employment-related purposes.

We do not knowingly collect personal information from children unless permitted by applicable law.

18. Automated Decision-Making

Where legally required, individuals may request information regarding automated decision-making or profiling and may request human review where applicable.

19. Third-Party Websites

Our website may contain links to third-party websites.

We are not responsible for the privacy practices of external websites.

20. Confidentiality

Because we provide professional HR services, all personnel are required to maintain strict confidentiality regarding client and employee information.

21. Data Breach Notification

If a data breach occurs, we will investigate promptly and notify affected individuals and relevant authorities where required by applicable law.

22. Changes to this Policy

We may update this Privacy Policy periodically.

Material changes will be posted on our website together with a revised effective date.

23. Contact Information

Phoenix Human Capital Solutions

Privacy Officer: Eva Dias

Address:
5600, Collins Avenue – Miami Beach, FL 33140 – USA

Telephone:
+1 305 842 9237

Email:
evadias@phoenixhcsolutions.com

Website:
www.phoenixhcsolutions.com

24. Questions or Complaints

Questions regarding this Privacy Policy may be directed to our Privacy Officer.

Individuals located in jurisdictions with data protection authorities may also submit complaints to the appropriate regulatory authority if they believe their privacy rights have been violated.