Lee Hecht Harrison Privacy Policy

GENERAL

This website ("Website") is the property of Lee Hecht Harrison LLC and/or its affiliates (herein after referred to as “LHH”, “us”, “we” and similarly intended designations). LHH is committed to respecting the privacy of visitors to our Website in accordance with applicable law and this privacy policy (“Privacy Policy”). This Privacy Policy describes what information we collect, how we collect and use it, and to whom it may be disclosed. By using this Website, you agree to the collection, processing, transferring, storing and all other aspects of handling of your personal and other information as is described herein this Privacy Policy. If you do not completely agree to the terms of this Privacy Policy, you may not use this Website.

CHANGES

We may make changes to this Privacy Policy from time to time. It is your responsibility to check each time you visit this Website for any updates. All changes are effective only from the date they are posted. The last date of revision (“Revision Date”) will always be posted below:

Revision Date: This Privacy Policy was last updated: April 11, 2017

TRANSFER OF DATA TO THE UNITED STATES

This Website is generally operated from the United States (U.S.). Except as otherwise expressed herein or where the law forbids, it is operated in accordance with United States law. You should be aware that United States privacy law may differ substantially from the relevant laws in your country of residence. In some jurisdictions, United States privacy law is considered inadequate. By using this Website you are agreeing that the personal and other information collected about you may be transferred to the United States and other jurisdictions where the data protection laws differ from your own country of residence. For residents of the European Union (E.U.) or Switzerland, please see the E.U.- U.S. and SWISS-U.S. PRIVACY SHIELD COMPLIANCE section below.

E.U.-U.S. and SWISS-U.S. PRIVACY SHIELD COMPLIANCE

LHH complies with the E.U.-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. LHH has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

In compliance with the E.U.-U.S. and Swiss-U.S. Privacy Shield Principles, LHH commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact LHH at: privacy@lhh.com .

LHH has further committed to refer unresolved privacy complaints under the E.U.-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Please note that if your Privacy Shield complaint is not resolved through the above channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Use of Your Personal Information:

See “HOW WE USE PERSONAL AND OTHER INFORMATION WE COLLECT” section below.

Access to Your Personal Information:

LHH acknowledges that E.U. and Swiss individuals have the right to access the personal information/data that we maintain about them. An E.U. or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct a query to LHH at privacy@lhh.com. If requested to remove data, we will respond within a reasonable timeframe. We have the right to request and receive verification of your identity to process your request.

Law Enforcement collection of your information:

We may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Accountability of Onward Transfers of Your Personal Information:

We may share the information we collect with third parties, as detailed in the “DO WE SHARE ANY OF YOUR INFORMATION WE COLLECT ABOUT YOU?” section below.

In any case that we transfer your information onward to third parties, we will have contracts with those third parties restricting their access and processing to comply with the Principles.

Where the Principles require it, we will provide you with the choice to opt-out and/or opt-in of having your personal information shared with third parties. You will be able to exercise such choice through different mechanisms depending on the circumstances. You can always notify us of your choice by contacting us at privacy@lhh.com. But in some circumstances, you may also be able to notify us of your choice through Website configuration options or through the registration process, if any.

In cases of onward transfer to third parties of data of E.U. or Swiss individuals received pursuant to the E.U.-U.S. or Swiss-U.S. Privacy Shield, respectively, we are potentially liable, unless we prove that we are not responsible for the event giving rise to the damage.

Federal Trade Commission:

Lee Hecht Harrison, LLC is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC).

WHAT INFORMATION WE COLLECT

We collect personal information (“Personal Information”) and other information (“Other Information”) about you when you visit this Website. Personal Information is information that can be used to identify you or information that relates to you. Other Information is information we collect but is not an identifier of you.

Personal Information

Types of Personal Information we might collect include any part of or your full name and your personal and/or work contact information which could include any or all of the following: physical address, email address, phone numbers, and fax numbers. We might also collect your job title, your position, role, and your company. We might collect your username and other login credentials for the Website. We might collect the results of your assessments, surveys and other content you provide, if any, to the online tools or other sections of the Website. We might collect a list of items or materials you download from the Website. And we might collect any other Personal Information you provide to us through the Website or offline of the Website through user-forms, contact requests or conversations with our personnel or consultants.

Other Information

We might collect your IP address, your browser version and the device type you are using to access the Website. We might collect general demographic information and your usage statistics on the Website including but not limited to the number of clicks, the number of times the Website is accessed, the pages you visited, the length of time you spent on each page and other information all in an aggregated form that does not identify you.

HOW DO WE COLLECT PERSONAL AND OTHER INFORMATION?

We collect your Personal and Other Information, both actively and passively, largely from your direct use of this Website but also in some cases from you in other ways, from your employer/ex-employer, and from third parties.

Active

We might collect information from your active use of the Website when you register to use or use the Website or any assessment or other tool on the Website. We might collect information when you submit a user form or any other request to us. We might collect information when you complete a survey, assessment or upload a resume or any other document. We might collect information from any other active event where you provide such information through the Website.

We might collect information from you that you provide to our personnel or consultants related to the services we provide either inside or outside of this Website, including any verbal communications.

In some circumstances your employer or ex-employer may provide information about you directly to us which we collect.

Passive

We might collect information about you passively from your use of the Website. For instance, we might collect your IP address and we may track the clicks, navigation, browser used and other information related to your use of the Website. In some cases we might collect information from third party social media profiles or plugins you provide or access on the Website. We might collect your geographical location such as when you are using a tool on our Website to find directions to one of our offices.

HOW WE USE PERSONAL AND OTHER INFORMATION WE COLLECT

  • Provision of Services: We use the information we collect to setup and administer login credentials for you and generally to provide services to you.
  • Business Records: We use the information to create and maintain invoicing and other business records about the provision of such services.
  • Certifications: We use the information we collect to maintain our coaching certifications or other certifications in the talent mobility industry by providing a certification board with your name, the name of your coach, your contact information, job title, company if applicable, type of services you received and number of hours of services that were delivered to you.
  • Administrative Information: We use the information we collect to send you news and information about the services, surveys, and questionnaires.
  • Marketing Communications: We use contact details that you provide us with to send you news and information about products, services and events offered by LHH. We may also send you information about products/services from third parties that we think might be of interest to you.
  • Legal: We use the information we collect to meet any required legal obligations or to protect LHH or other individuals from fraud or illegal activity.
  • Statistics: We use it to collect statistics and information on use of our Website.

DO WE SHARE ANY OF YOUR INFORMATION WE COLLECT ABOUT YOU?

  • Affiliates: We may share the information we collect with our affiliates and/or our parent company.
  • LHH Licensees: We may share information with Licensees if they are providing or have provided any portion of the related services to you. Licensees are third parties who are authorized by LHH under a Licensee Agreement to use the intellectual property and marks of LHH to provide services to LHH customers.
  • Third Party Consultants/Service Providers: From time to time we may engage or employ other companies and individuals to perform functions on our behalf. Such parties will have access to such personal information only to the extent required by them to perform their functions for us. They will use personal information only in accordance with our instructions and applicable law, and they may not use such information for any purposes that are not authorized by us.
  • Law Enforcement/Government Agencies: Where required by applicable law or if needed to protect ourselves or other individuals in a dispute or against fraud or illegal activity, we may share personal information with government, courts, regulators or law enforcement authorities.
  • Certification Board: We may disclose your name, job title, dates of coaching, and numbers of hours coached, as well as the name of your coach to third parties for certification purposes such as disclosing your name and contact details, and the length of time you were coached so our coaches can maintain their certifications with certain third party certification boards.
  • Communicating with You: We may use your information to notify you of communications regarding the use of this Website or any other services you are receiving from us. We may use your information to communicate with you when necessary and appropriate such as responding to you or helping you with logon credentials. We may use it to communicate with you for any other appropriate reason.
  • Employer/Ex-Employer: If the services are provided to you via your employer/ex-employer, we may provide a list of activities you engaged in and when on the Website. However, unless you give express consent, we will not share with your employer/ex-employer your answers to or results of any assessment you participate in. Note we also do not share your assessment answers or results with any third parties or affiliates unless required by law or unless you give express consent.
  • Recruiters/Other Third Parties: In some cases third party recruiters and other job placement professionals may be able to view any resume you upload to the Website.
  • Surveys: You consent to receiving a Survey from us about the services you have received which will be shared with LHH personnel providing the services including but not limited to coaches and consultants. You have the option to remove your name from the survey. By removing your name, your feedback to the survey will be shared anonymously. In any case, your feedback will be aggregated to report average quality results to employers who sponsor individuals in our programs. However, names are never associated with those average quality results provided to your employer.

DO WE SHARE ANY OF YOUR INFORMATION WITH THIRD PARTIES FOR THEIR DIRECT MARKETING PURPOSES?

No. We do not share your information with third parties for their direct marketing purposes.

Canadian Anti-Spam Law (CASL)

Where applicable, we abide by all requirements of CASL including but not limited to receiving consent from a recipient before sending a Commercially Electronic Message (“CEM” as such is defined by CASL) where such is required.

TRACKING ACROSS THIRD PARTY SITES

We may track you when you visit any of our affiliate sites. Also, we may use Google Analytics or another analytics tool which may track your usage and personal information across multiple unrelated sites. This tracking may identify you across sites.

See our Cookie Policy for more. DO NOT TRACK

This Website does not respond to the configuration of any do not track option you select in your browser.

COOKIES

See our Cookie Policy hereby incorporated by reference.

SUBMITTING THIRD PARTY PERSONAL INFORMATION AND SENSITIVE INFORMATION

If you submit any third party personal information to this Website, you must do so with the authority and permission of such third party. We rely on you and assume that you have permission for any submission of third party personal information to this Website. We ask that unless specifically requested to do so, you should not submit any sensitive information about you or another person including but not limited to a social security number or government id number, ethnicity, political affiliations or other sensitive information.

YOUR RIGHTS TO ACCESS PERSONAL INFORMATION

In most cases and in all cases where required by law, we provide individuals with rights to access and update personal information we have stored about them. Any individual who wishes to inquire about any personal information we may have stored can do so by contacting us (see CONTACTING US section). We reserve the right to ask for documentary evidence to verify your identity before we can deal with any request. For residents of the E.U. or Switzerland, please see the section on E.U.-U.S. and SWISS-U.S. PRIVACY SHIELD for your rights to access personal information.

HOW SECURE IS YOUR INFORMATION?

We have implemented appropriate measures to keep the servers on which your information is stored secure and free from unauthorized access and use, by enforcing physical security at the premises in which the servers are located, and by using industry standard technological measures which may include firewalls, intrusion detection systems, secured servers, database security, and other methods to prevent unauthorized remote access to the server.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Despite our best efforts to keep transmissions to and from our server secure, we are unable to absolutely guarantee security over the Internet and there will always be a risk of unauthorized access to information that you transmit to us.

OTHER LHH SITES

LHH offers other online tools and services through websites that have their own privacy policies and users should be aware and check those privacy policies before use. Another URL with the same second-level domain of “lhh” could have a different Privacy Policy. It is your responsibility to check.

CONTACTING US

If you have any questions about this Privacy Policy, you can contact us:

Via mail:
Lee Hecht Harrison, LLC
2301 Lucien Way, Suite 325
Maitland, Florida 32751 USA
Kindly indicate as subject: privacy query

Via e-mail:
privacy@lhh.com

EU DEFINITION

Any reference in this Privacy Policy to “EU”, “E.U.” or “European Union” means the European Union and Iceland, Norway, and Lichtenstein. © Lee Hecht Harrison 2017 All Rights Reserved

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