Last updated: June 1, 2021
1.WHO WE ARE AND WHAT THIS POLICY IS
Welcome to Skill Equity GmbH, Opernplatz 14, 60313 Frankfurt, Germany (collectively “Skill Equity“, “we“, “us“ and “our“ etc.). We are an owner managed boutique offering bespoke leadership advice and executive search services (collectively, and among others, our “Services“) under our brand Skill Equity Partners.
Skill Equity takes its responsibility for the processing of your personal data and information very seriously, whether provided to us on our website, via email, via social networking sites, in person or otherwise.
For the purpose of this Policy, the controller of personal data is Skill Equity GmbH and our contact details are set out in the “HOW TO CONTACT US“ section at the end of this Policy.
In addition to terms defined elsewhere in this Policy, the ones listed below shall have the following meaning throughout this Policy:
“Candidate“ means any candidate, interested person, or Client employee or board member, who is considered, evaluated, assessed, coached or developed by Skill Equity in connection with the Services;
“Client“ means any of the organizations or individuals who contract our Services;
“Personal Information“ means any information that either (a) personally identifies a natural person; or (b) pertains to an identifiable natural person, i.e. someone who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity, or (c) constitutes individually identifiable information about an individual consumer collected by us online through our website and that we maintain in an accessible form, or that (d) we are otherwise required to protect under applicable data privacy laws (including, but not limited to, national, international and supranational data protection and privacy laws, directives, regulations and comparable legal acts). Examples of Personal Information include your contact details such as your name, email address, birthday or phone number as well as information about your professional education and experience, skills, preferences, membership in professional organizations, etc.;
“Processing“ (and variations such as “Process“) means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, restriction, erasure or destruction;
“Sensitive Personal Information“ means Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation;
“Site“ means www.skillequitypartners.com and all web pages hosted at that domain.
3.HOW WE PROCESS YOUR PERSONAL INFORMATION
We perform our Services based on data held by or made available to Skill Equity.
In the event you are interested in becoming a Candidate for one of our Services, you can provide us with information on your personal and professional background (“Candidate Information“) that we may take into consideration as part of the relevant Services.
Providing any Candidate Information is purely voluntary on your part. Although it is generally true that, the more information you share with us, the better we are able to assess you and/or your potential suitability for or within an executive or similar management position, we urge you not to disclose to us any Candidate Information that is likely of little or no relevance for the respective Client Service.
If and to the extent you share Candidate Information with us, we might follow up with you using the contact details you may have provided in order to clarify any questions we might have or obtain complementary information from you. If you are a Candidate for Services relating to executive search, we might in addition (i) conduct assessments of your professional profile and perform searches for information on your personal and professional life publicly available via social media services (e.g. Facebook, Google, LinkedIn, Twitter, etc.), on the Internet, or within data you have previously disclosed to us, provided that such information might be of importance for the relevant Services; and (ii) source Personal Information about you from third party data providers (e.g. BoardEx), whereby we take appropriate measures to ensure that such third party data providers are legally permitted or required to disclose such information to us. Any resulting information will be considered Candidate Information and be Processed as described below together with the Candidate Information you initially provided us with.
Depending on your interaction with us, your Candidate Information Processed by Skill Equity and/or selected partners may therefore contain (i) your contact details (name, address, phone number, email address, etc.), (ii) your biographical data, (iii) information on your professional education, (iv) your educational credentials, professional diplomas and certificates, (v) information and responses you may provide to evaluative measures, surveys and interviews, and (vi) any Sensitive Personal Information you might choose and explicitly consent to disclose to us. If you are a Candidate for Services relating to executive search, your Candidate Information may in addition contain (vii) your employment and compensation history, (viii) data on your suitability for Client opportunities we compile as part of our assessments of your professional profile, (ix) information on your personal and professional life publicly available via social media services (e.g. Facebook, Google, LinkedIn, Twitter, etc.) or otherwise on the Internet, or from third party data providers, that might be of importance in connection with the relevant Services, (x) information related to your travels for interviews within a recruitment process, if such travel arrangements are facilitated by us via our selected partners, such as your name, email address, phone number, passport number and date of birth (if mandatory), travel destination(s), and means of transportation, and (xi) in appropriate circumstances and in accordance with applicable local law, information about you which may be classified as “diversity information“ (such as your racial or ethnic background, gender, disability, age, sexual orientation, religion or beliefs, and/or socioeconomic background). Some of this information is considered Sensitive Personal Information (or protected legal characteristics under certain laws) and as such, stricter data and other protection measures, as required by applicable law, will apply.
Our legal basis for collecting and using your Candidate Information for the Services will depend on the Processing activity involved and the context in which it was obtained and therefore can either be based on our legitimate business interest or on your consent.
As part of Services, your Candidate Information may be Processed for the business purposes of:
providing Services on behalf of our Clients, which may include Processing of your Candidate Information within your own integration, assessment, coaching or development as part of respective assignments for our Clients;
operating the databases your Candidate Information is stored in; and
analyzing your information using analytical tools and comparing the results against other Candidates or potential Candidates, including categorization of Candidates through profiles developed by the software, to assist us in conducting Services.
If you are a Candidate for Services relating to executive search, your Candidate Information may be Processed for the additional business purposes of:
executing searches for potential Candidates on behalf of Clients that have an opening for an executive or similar management position or for a board directorship, including, but not limited to, (i) assessing your suitability for Client opportunities, (ii) introducing you to Clients as a Candidate, (iii) verifying your educational credentials, professional diplomas and certificates, (iv) where appropriate and in accordance with applicable law, using your diversity information to provide Clients with diverse pools of qualified Candidates, and (v) ensuring that you will not be recruited on behalf of another Client unless you request consideration for other opportunities;
informing you of open executive or similar management positions potentially suitable for you;
sending you information or materials that we believe you may find interesting, such as reports, research, invitations to networking events, or information regarding our Services, publications and surveys; and
approaching you as a Client contact for the introduction of other Candidates or as a source of information about potential Candidates for third-party Clients.
At no point will your Candidate Information be used for purposes other than providing the Services for which your Candidate Information has been intended. Your Candidate Information will mainly be Processed by and on behalf of Skill Equity. However, depending on how and where the Services need to be performed in your individual case, your Candidate Information may be shared with:
Consultants and administrative staff: Via our database, your Candidate Information will be available to all employees of Skill Equity for the purposes of providing the Services;
Clients: If you are a Candidate for Services relating to executive search, subject to our discretion, we might disclose excerpts of your Candidate Information such as your professional education and employment history with particular Clients in order to confirm whether such Clients might be interested in you as a Candidate with respect to an opening for an executive or similar management position they have informed us of. The information disclosed will be limited to what is necessary for this purpose. We will not disclose the entirety of your Candidate Information or otherwise introduce you to any Client in detail without first obtaining a consent from you;
Selected partners: Your Candidate Information might be Processed by selected partners with whom we may work on specific projects when providing Services, including third party travel agencies;
Software service and application providers: Your Candidate Information may be Processed by the software service and application providers as our Processors (such as Microsoft Corporation or Zoom Video Communication, Inc), located anywhere in the world, subject to binding contractual obligations to only Process your Candidate Information in accordance with our prior written instructions and to apply measures to protect the confidentiality and security of your Candidate Information, together with any additional requirements under applicable law; and
IT infrastructure service providers: Your Candidate Information will be stored on servers located in the European Union and in the United States. The servers are operated by and accessible to designated employees of Skill Equity as well as third-party service providers acting on behalf and as per instruction of Skill Equity, for the purposes of website management, information technology and related infrastructure provision.
In this context, please be aware that most of the third-party service providers operating the servers and some of our Clients or selected partners we might disclose excerpts of your Candidate Information to are located in countries outside of the European Economic Area (EEA) that have not been found by the European Union to provide an adequate level of protection of personal data, i.e. a level of protection of fundamental rights and freedoms that is essentially equivalent to that guaranteed within the European Union. Similarly, the countries your Candidate Information, or parts thereof, might be transferred to in accordance with the above may not be found to provide an adequate level of protection by jurisdictions outside of the European Union. However, we have taken appropriate safeguards to require that your Candidate Information will remain protected in accordance with this Policy.
4.USE OF OUR SITE
However, please be aware that this might render certain functions of our Site inoperable or more difficult to use. Depending on the Internet browser you use, you might also be able to specifically reject third-party cookies. In this context, please note, however, that third parties might still have access to your Personal Information to the extent that such information is logged by first-party cookies.
For additional information on first-party and third-party cookies used on our Site in the context of third-party services and for information on how you might stop such cookies from being stored on your device, please see “Third-Party Services“ below.
4.2. THIRD PARTY SERVICES
We use the following services provided by third parties:
Our global client database and web portal is managed and hosted by the following service provider: Clockwork ESE, Inc 4357 Cedarhurst Circle, Los Angeles, CA 90027, USA, www.clockworkrecruiting.com
On our Site, we use the following services provided by third parties:
Google Analytics Our Site uses Google Analytics, a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google“). Google Analytics uses “cookies“, which are text files placed on your computer, to help analyze how users use the Site.
The information generated by the cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. The United States has not been found by the European Union to provide an adequate level of protection of personal data, i.e. a level of protection of fundamental rights and freedoms that is essentially equivalent to that guaranteed within the European Union. Similarly, the United States may not be found to provide an adequate level of protection by jurisdictions outside of the European Union.
On our behalf, Google will use the information collected for the purpose of evaluating your use of the Site, compiling reports on website activity for us and providing other services relating to website activity and Internet usage to us. Google will not associate your IP address with any other data held by Google. Neither will we match, link or otherwise connect any information received from Google with Personal Information collected through other components of the Site.
In the latter case, an opt-out cookie will be set on your device, which prevents the future collection of your data when visiting this Site. Be aware, however that the opt-out cookie will only be effective within the Internet browser you used to access the above link and only for as long as you do not delete the opt-out cookie.
Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/gb.htmlor at https://www.google.de/intl/en_uk/policies/.
We use the following Social Media Platform Cookies, all intended to facilitate linking and following by or from the respective platforms:
LinkedIn 2029 Stierlin Ct. Ste. 200, Mountain View, CA 94043, USA
5.OUR DATA SECURITY
Protecting your Personal Information is important to us. We use appropriate technical and organizational measures and safeguards designed to help prevent unauthorized access, unlawful Processing, and unauthorized or accidental loss of your Personal Information. This includes, for example, the encryption of your communication with us over the Site based on the Secure Sockets Layer (SSL) protocol.
Subject to the applicable law, you have the right: (i) to obtain information about your Personal Information we Process; (ii) to request the correction or completion of incorrect Personal Information we Process; (iii) to request the deletion of Personal Information we Process; (iv) to object to our Processing of your Personal Information or to restrict the way we Process such Information; and (v) to request to receive Personal Information in a structured, commonly used and machine-readable format and to ask us to transmit that Personal Information to you or directly to a third party. To make a respective request, please use the contact details provided in “HOW TO CONTACT US“ below.
7.HOW WE RETAIN YOUR PERSONAL INFORMATION
We will retain your Personal Information where we have an ongoing consent or legitimate interest to do so. Kindly note that once our relationship with you has ended, your Personal Information may still be relevant for our current or future legitimate business purposes. For example, we may be required to retain certain Personal Information: (i) for our business records; (ii) to be able to establish, exercise or defend our legal rights; (iii) to show that we are compliant with applicable laws; or (iv) to show that we have fulfilled or continue to fulfill our obligations towards our Clients in relation to Services you may have been involved in.
8.AMENDMENTS TO THIS POLICY
From time to time we may change our business activities and/or our policies and procedures with respect to the Processing of Personal Information. Where appropriate in these cases, we will, subject to applicable law, revise, supplement, or replace this Policy. When the Policy changes, we will post the substitute version and change the effective date listed at the beginning of the Policy.
When required by applicable law, however, we may provide you with advance notice of any changes to this Policy and with an opportunity to object to such changes. If you exercise your right to object, the changes will not become effective with respect to your Personal Information, but your ability to use our Services may be terminated or impaired. We will explicitly notify you of the consequences of the objection or non-objection to the extent and in the manner required by law.
9.HOW TO CONTACT US
We encourage your questions and comments about this Policy and our privacy practices. Please contact us using the information below, and we will respond to you as soon as reasonably possible:
Skill Equity GmbH
60313 Frankfurt / Germany