Privacy Policy
Introduction
Pro CISO® B.V. is committed to safeguarding the personal information of our leads, customers, and website visitors. This policy explains what data we collect, why we collect it, how we use it, and your rights under the General Data Protection Regulation (GDPR).
This policy governs data collected via our website (prociso.com) and professional platforms such as LinkedIn, in connection with requests for quotes, product trials, and service delivery.
Information We Collect
We collect personal data directly from you when you interact with us. This includes:
- Contact details: name, postal address, email address, phone number
- Company name and job title
- Any additional information you voluntarily provide when submitting a request or enquiry
We do not collect sensitive personal data (special categories under GDPR Article 9) through our website.
Purpose of Processing
We use your personal data solely for the following purposes:
- To respond to your enquiries and provide information about our products and services
- To activate trials, demos, and service engagements you have requested
- To fulfil our contractual obligations where a service agreement is in place
- To comply with our legal and regulatory obligations
Legal Basis for Processing
The processing of your personal data is based on your consent, given when you submit a request through our website or LinkedIn. Where we have entered into a contract with you, processing may also be based on contractual necessity (GDPR Article 6(1)(b)). Where required by law, processing is based on a legal obligation (GDPR Article 6(1)(c)). Our record of which organisations visit our website is based on our legitimate interest (GDPR Article 6(1)(f)), as described below.
You may withdraw your consent at any time by contacting us at privacy@prociso.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Data Sharing and Disclosure
Pro CISO® B.V. does not sell your personal data. We may share data with carefully selected technology partners and sub-processors solely to deliver our services. All partners are required to comply with GDPR and maintain appropriate data protection standards.
We may disclose data where required by law, court order, or competent regulatory authority.
Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting obligations. For prospective customers who did not proceed to engagement, data is retained for a maximum of 24 months from last contact. Data relating to active engagements is retained for 7 years in accordance with Dutch financial record-keeping requirements.
Your Rights Under GDPR
As a data subject under the GDPR, you have the following rights:
- Right of Access - to obtain a copy of the personal data we hold about you
- Right to Rectification - to have inaccurate data corrected without undue delay
- Right to Erasure - to have your data deleted in certain circumstances ("right to be forgotten")
- Right to Restrict Processing - to limit how we use your data in certain circumstances
- Right to Data Portability - to receive your data in a structured, machine-readable format
- Right to Object - to object to processing based on legitimate interests or direct marketing
- Right to Withdraw Consent - at any time, without affecting prior lawful processing
To exercise any of these rights, contact our privacy team at privacy@prociso.com. We will respond within 30 days. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
Security of Your Personal Data
Pro CISO® B.V. is ISO/IEC 27001:2022 certified. We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures are reviewed and updated regularly as part of our Information Security Management System (ISMS).
If you believe you have discovered a security vulnerability in our systems or website, please see our Responsible Disclosure Policy.
Cookies and Analytics
Our website uses only technically necessary session cookies required for the site to function. We also use Google Analytics 4 in cookieless mode (client_storage: none) with IP anonymisation enabled. In this configuration, no _ga cookies are set and no personally identifiable information is sent to Google. Aggregate, anonymous usage data (page views, session counts) is collected solely to improve the website.
Because no cookies are placed and no personal data is transmitted, no consent banner is required under GDPR Recital 30.
Organisations That Visit Our Website
We keep a record of the organisations that read this website, not of the people who work for them. When you open a page we log which network your connection belongs to, which page you read, and the website you arrived from. We do this to understand which businesses are interested in our services: a legitimate interest under GDPR Article 6(1)(f). You can object to it at any time (see Your Rights).
- We set no cookies for this and store nothing on your device. We create no visitor profile, fingerprint or identifier that follows you between pages, visits or websites.
- We keep only the first three parts of your IP address (for example 145.220.14.0). That identifies a network, such as an office or an internet provider, and not a person or a device. The full address is never stored. If you connect over IPv6 we record nothing at all.
- We keep only the website you arrived from, never the full link, so a search you typed is never recorded. We record the name of the page you read, and whether you used a desktop, a phone or a tablet; your browser's identification string is not kept.
- If your browser sends "Do Not Track" or Global Privacy Control, we record nothing at all.
To put a name to a network we ask ipinfo.io, a provider that identifies which organisation owns a range of internet addresses. They receive the shortened network address and nothing else: never your full address, the page you read, or anything you typed. Because what we send is a network address rather than an address that identifies you, we treat this as information about an organisation rather than about a person.
Page records are deleted automatically after 90 days. What may be kept longer is the fact that an organisation visited us, which is information about a company rather than about you.
Your Enquiries
When you fill in our contact form we keep what you typed (your name, email address, company and message) so that we can answer you. The form sends your details straight to our own systems; there is no third-party form provider.
- We ask you to tick a box to confirm you are happy for us to contact you about your enquiry. We record that you ticked it, when, and the exact wording you agreed to. If you do not tick it, we do not keep your details.
- If you have unsubscribed from our marketing emails, sending an enquiry does not put you back on our lists: we answer your enquiry, and you stay unsubscribed unless you tick the box below and confirm.
Our Emails
We send two kinds of email, and they follow different rules.
- Replies and one-to-one emails. When you ask us something, for example a price through our website or through one of our partners, we answer you personally. These emails are part of handling your request, so they carry no unsubscribe link.
- Marketing emails: news, events and offers sent to many people at once. We send them only where the law allows it, every one has an unsubscribe link, and unsubscribing stops all of them, from every part of Pro CISO, at once. It does not stop us answering a request you make yourself.
You can also subscribe on our newsletter page, with the topics you care most about. We email you a link to confirm, and you are subscribed only when you click it; until then we keep the details you typed for at most eight days. The topics you choose only decide what we send you.
Our contact form has an optional box, “Send me Pro CISO emails”. If you tick it, we record that you did, when, and the exact wording, as your consent to our marketing emails. If you had unsubscribed before, ticking it is not enough on its own: we send a link to your address, and your emails start again only when you confirm.
Unsubscribed and changed your mind? Receive Pro CISO marketing emails again: enter your address and confirm with the link we send to it.
News Article Pages
Our news section links to articles published by other organisations. On the page we show for each article, the article's image is loaded directly from the publisher's website. When you open such a page, your browser requests that image from the publisher, who therefore receives your IP address and browser details, as with any website you visit. We send them no information about which of our pages you were on. Images are never shown in our news list or ticker, and we do not control the publisher's processing; their own privacy policy applies.
Changes to This Policy
Pro CISO® B.V. reserves the right to update this privacy policy at any time. Material changes will be notified via a notice on our website. The effective date at the top of this page reflects the date of the most recent revision.
Contact Us
For any questions regarding this policy or the handling of your personal data, please contact:
Pro CISO® B.V.Beneluxgebouw
Van Heuven Goedhartlaan 121
1181KK Amstelveen
The Netherlands
privacy@prociso.com