PRIVACY POLICY

COMPANY PRIVACY STATEMENT

Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.

This page and its sub-pages tell you everything you need to know about how COMPANY (“COMPANY”; “we”) protect the personal data we process and control relating to you (“your personal data”; “your data”) and which rights you have in relation to the processing of your personal data.

Below, we first give a general description of how COMPANY protects your personal data. Further below, we also include specific information on the following:

How do we use personal data when you visit COMPANY’s website?
How do we use cookies (and other tracking technologies)?
How do we use personal data for marketing purposes?

1.How does COMPANY protect your personal data?

COMPANY attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with COMPANY, your personal data are in good hands.

COMPANY protects your personal data in accordance with applicable laws and our data privacy policies. In addition, COMPANY maintains the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.

The following sections provide further details as to how COMPANY processes your personal data:

Which categories of personal data do we collect and how do we process such personal data?
For which purposes and on which legal basis do we use your personal data?
Will we share your personal data with third parties?
What about sensitive data?
What about data security?
Where will your personal data be processed?
How long will your personal data be retained by us?
Which rights do you have with respect to the processing of your personal data?

WHICH CATEGORIES OF PERSONAL DATA DO WE COLLECT AND HOW DO WE PROCESS SUCH PERSONAL DATA?

We collect personal data of our employees, potential employees, clients, suppliers, business contacts, shareholders and website users. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.

Below is also a chart describing the categories of personal data we collect:

Additional personal details, contact details and identifiers.	In addition to the personal details listed above, COMPANY may collect additional personal details for recruitment/employment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history.
Education information and professional or employment-related information.	COMPANY may collect information about your education and professional or employment-related information, such as your employment history.
Sensitive data for recruitment purposes.	COMPANY may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. COMPANY collects this information for specific purposes, such as health/medical information in order to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.
Documentation required under immigration laws.	COMPANY may collect data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy).
Financial information for payroll/benefits purposes	Your banking and other relevant financial details we need for payroll/benefits purposes.
Talent management information.	Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.
Requested recruitment information	Information requested to provide during the recruitment process, to the extent allowed by applicable law.
Recruitment information you submit	Information that you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs).
Information generated by us during recruitment	Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.
Recruitment information received from third parties	Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable.
Audiovisual materials	Photograph, and images/audio/footage captured/recorded on CCTV or other video systems when visiting our office or captured in the course of recruitment events or video recruitment interviews or during any other virtual and live events (including recordings during virtual workshops or similar events).
Recommendations	Recommendations related information provided on your behalf by others.
Immigration	Documentation and related information required under immigration laws.
Employment history and background checks	Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.
Diversity related information	Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the COMPANY workforce, subject to legal limits.
Assessment information	Information generated by your participation in psychological, technical or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them.

Except for certain information that is required by law or by COMPANY policies (including management of an employment relationship with COMPANY), your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.

If you provide us with personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with COMPANY.

The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors.

FOR WHICH PURPOSES AND ON WHICH LEGAL BASIS DO WE USE YOUR PERSONAL DATA?

COMPANY uses your personal data only where required for specific purposes. Please view the table below for (i) a list of the purposes for which COMPANY uses your personal data and (ii) an overview of the legal basis for each such purpose.

Purpose	Legal basis
Managing our contractual and/or employment relationship with you.	Necessary for the performance of a contract to which you are a party.
Recruitment.	Justified on the basis of our legitimate interests for ensuring that we recruit the appropriate employees.
Facilitating communication with you (including in case of emergencies, and to provide you with requested information).	Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.
Operating and managing our business operations.	Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Complying with legal requirements.	Necessary for the compliance with a legal obligation to which we are subject.
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).	Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.
Social listening (Identifying and assessing what is being said about COMPANY and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements or other interactions on social media channels.)	Justified on the basis of our legitimate interest of protecting our assets and our brand on social media
Improving the security and functioning of our website, networks and information.	Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.
Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance within COMPANY and/or to provide a better user experience.	Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal data for marketing purposes?” below).	Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.
Specific Recruitment/Employment Purposes	Legal basis
Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.	Justified on the basis of COMPANY’s legitimate interests of ensuring that it recruits the appropriate employees.
Manage your application.	Justified on the basis of COMPANY’s legitimate interests of ensuring that it recruits the appropriate employees.
Facilitate communication with you.	Justified on the basis of COMPANY’s legitimate interests of ensuring proper communication within the organization and with you.
Perform administrative functions (e.g. reimburse you for interview-related expenses).	Justified on the basis of COMPANY’s legitimate interests of ensuring that it recruits the appropriate employees.
Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at COMPANY and how to attract and keep top talent.	Justified on the basis of COMPANY’s legitimate interests of ensuring that it continually improves its recruitment processes.
In some cases, record your online interview for review by additional recruiters and hiring managers.	Justified on the basis of COMPANY’s legitimate interests of ensuring that it recruits the appropriate employees.
If you register on our Careers website, we will enter you into a database to receive future mailings about COMPANY positions and events. You may also receive personalized job recommendations while browsing our Careers website.	Justified on the basis of COMPANY’s legitimate interests of ensuring that it recruits the appropriate employees.
Transfer your contact information, education data, employment data, application information and the CV, all as supplied by you in our recruitment system, to the COMPANY Talent Connection—a site that we maintain to notify you about new positions that may be of interest to you.	Justified on the basis of COMPANY’s legitimate interests of ensuring that it recruits the appropriate employees.
Administration of employee benefits	Justified on the basis of COMPANY’s legitimate interests of ensuring that our employees receive the applicable benefits.
Perform any legally required reporting and respond to legal process.	Compliance with a legal obligation.

Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy reviews and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact COMPANY’s Data Privacy Officer.

We will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.

To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal data, only in the countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal data will not be your consent but any other applicable legal basis.

We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

WILL WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and COMPANY’s internal policies. COMPANY may also transfer your personal data to any of its global affiliates/partners in furtherance of any visits to our COMPANY locations.

For example, we may disclose personal information to third parties for other business purposes as follows:

We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing;
To protect and defend the legal rights, safety, and security of COMPANY, our affiliates, users, or the public, including to protect against fraud and malicious activity; and
For other business purposes described in this privacy statement or for any other purpose disclosed to you at the time we collect the information or pursuant to your consent.

We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses (a copy of which can be obtained through the contact information included below). Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.

WHAT ABOUT SENSITIVE DATA?

We do not generally seek to collect sensitive data (also known as special categories) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term “sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

WHAT ABOUT DATA SECURITY?

We maintain organizational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.

We adopt market leading security measures to protect your personal data. This includes (without being limitative):

We hold an ISO27001 certification, which indicates that we adhere to the highest and strictest information security standards. This is a security standard awarded by the British Standards Institution (“BSI”) that serves as international certification that COMPANY adheres to the highest and strictest standards. This certification is the only auditable international standard that defines the requirements for an Information Security Management System (“ISMS”), and confirms that COMPANY’s processes and security controls provide an effective framework for protecting our clients’ and our own information.
We have a global Client Data Protection (“CDP”) program in place which governs the stewardship of client information and systems entrusted to us.
We have regular penetration testing performed by a third party provider, which continues to show the strength of our technical defenses.

WHERE WILL YOUR PERSONAL DATA BE PROCESSED?

As a global organization with operations throughout the world, personal data we collect may be transferred or be accessible internationally throughout COMPANY’s global business and between its entities and affiliates.

Any such transfers throughout COMPANY’s global business take place in accordance with the applicable data privacy laws and in accordance with our Binding Corporate Rules (“BCR”).

Our BCR reflect the standards contained in European data privacy laws (including the General Data Protection Regulation). Having our BCR means that all our group entities which have signed up to our BCR have to comply with the same internal rules. It also means that your rights (see “Which rights do you have with respect to the processing of your personal data?”) stay the same no matter where your data are processed by COMPANY.

WHAT ARE THE SOURCES WE GET YOUR PERSONAL INFORMATION FROM?

If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), COMPANY employees, contractors, (prospective) members of board of directors, shareholders, COMPANY’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third party data providers).

HOW LONG WILL YOUR PERSONAL DATA BE RETAINED BY US?

We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:

We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
We will only keep the data while your account is active or for as long as needed to provide services to you.
We retain your data for as long as needed in order to comply with our global legal and contractual obligations.

WHICH RIGHTS DO YOU HAVE WITH RESPECT TO THE PROCESSING OF YOUR PERSONAL DATA?

You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
Object to the processing of your personal data: this right entitles you to request that COMPANY no longer processes your personal data.
Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
Request the restriction of the processing of your personal data: this right entitles you to request that COMPANY only processes your personal data in limited circumstances, including with your consent.
Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to COMPANY, or request COMPANY to transmit such personal data to another data controller.

To the extent the processing of your personal data falls in scope of our BCR, you may also want to review your rights under our BCR.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting COMPANY’s Data Privacy Officer. Please note that this will not affect COMPANY’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to COMPANY first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against COMPANY with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).

2.HOW DO WE USE PERSONAL DATA WHEN YOU VISIT COMPANY’S WEBSITE?

In addition to the information set out above, the following sections describe how we use personal data when you visit COMPANY’s website:

Which personal data do we gather?
Do we include (links to) websites and programs of third parties?
How do we use personal data that we collect from our websites?

WHICH PERSONAL DATA DO WE GATHER?

COMPANY collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website’s technology).

We may collect and process the following personal data:

Personal data that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of personal data may provide further information as to why your personal data are needed and how it will be used. It is completely up to you whether you want to provide it.
If you contact us, we may keep a record of that correspondence.
We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Any postings, comments or other content that you upload or post to an COMPANY website.
Our website collects personal data about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookies section below for more information.

DO WE INCLUDE (LINKS TO) WEBSITES AND PROGRAMS OF THIRD PARTIES?

Our websites may include:

Links to and from the sites of our partner networks, advertisers and affiliates.
Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.

We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.

HOW DO WE USE PERSONAL DATA THAT WE COLLECT FROM OUR WEBSITES?

We use personal data for the purposes described in the section “For which purposes and on which legal basis do we use your personal data?” above, as well as to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected. For example:

Links to and from the sites of our partner networks, advertisers and affiliates.
Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the Cookies section below for more information.

3.HOW DO WE USE COOKIES (AND OTHER TRACKING TECHNOLOGIES)?

In addition to the information set out above, this section describes how we use cookies and other tracking technologies.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.

Please see our Cookies policy for more details including for information about your choices with respect to advertising and social media cookies and for access to our cookie consent manager.

4. HOW DO WE USE PERSONAL DATA FOR MARKETING PURPOSES?

In addition to the information set out above, the following sections describe how we use personal data for marketing purposes:

What are the sources of marketing data?
Do we send targeted e-mails?
Do we maintain Customer Relationship Management (CRM) databases?
Do we combine and analyze personal data?
Do we share personal data with third parties?
What are your rights regarding marketing communications?

WHAT ARE THE SOURCES OF MARKETING DATA?

The bulk of the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company.

DO WE SEND TARGETED E-MAILS?

We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from COMPANY, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

Targeted e-mails from COMPANY may include additional data privacy information, as required by applicable laws.

DO WE MAINTAIN CUSTOMER RELATIONSHIP MANAGEMENT (CRM) DATABASES?

Like most companies, COMPANY uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by COMPANY professionals based on their personal interactions with you. If you wish to be excluded from our CRM databases.

DO WE COMBINE AND ANALYZE PERSONAL DATA?

We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites such as our careers and corporate sites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn and Xing). We combine this data to better assess your experience with COMPANY and to perform the other activities described throughout our privacy policy.

DO WE SHARE PERSONAL DATA WITH THIRD PARTIES?

In addition to the third parties mentioned in the section “Will we share your personal data with third parties?” above, we may share your personal data with marketing agencies.

WHAT ARE YOUR RIGHTS REGARDING MARKETING COMMUNICATIONS?

You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship management (CRM) databases at any time. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.

5. HOW ELSE MIGHT WE USE YOUR PERSONAL DATA

In addition to the information set out above, the following sections describe other specific uses of personal data by some COMPANY affiliates.

Below, we provide you with further details about how we process your personal data in connection with any content creation / production purposes.

CONTENT CREATION / PRODUCTION ACTIVITIES

Some COMPANY entities are in the business of content production. We may process your personal data for these TV, film, marketing, advertising or other related content creation, production and distribution activities.

What personal data do we process in connection with production activities?

The personal data that we process for production purposes include images and footage of you and may include your location at the time of filming.
If you are a member of public, we will diligently attempt to make you aware of our location and filming activities in advance and will give you an opportunity not to enter the location where filming is taking place and participate in them.
If you are a focus of our filming activities (i.e. a contributor or talent such as an interviewee, extra or actor, as opposed to a member of public) we will also collect and process your name, contact information and any other information provided in any pre-filming questionnaires and/or release forms, such as next of kin details.
We may also collect and process special categories of data a such as health or disability information to the extent that this is necessary to enable us to make any necessary adjustments to our filming arrangements to assist or support you.

If you have any questions on data privacy or any aspects of our production activities, please contact us.

6. CONTACT US

Please contact us if:

You have a general question about how COMPANY protects your personal data.
You wish to exercise your rights in relation to your personal data rights (as set out in the sections “Which rights do you have with respect to the processing of your personal data?” and “Your rights regarding marketing communications“).
You would like a copy of the full version of our BCR.
You wish to make a complaint about COMPANY’s use of your data.

You can also contact COMPANY as data controller of your personal data via our Data Privacy Officer (preferably electronically) or via post.