General information
Last Updated: 28 March 2022
Lee Hecht Harrison Penna Limited and its applicable affiliates (“LHH”, “Company”, “we”, “us”, “our”) are committed to protecting and respecting your privacy.
This General Privacy Policy describes our privacy practices in relation to the information we collect from you when you visit our website, which is accessible at https://helloezra.com, or when you access or use any applications or features made available by us on or through or in connection with this Website or our services that link to this General Privacy Policy (collectively, the “Website”).
Note that when we collect Personal Information (defined below) from or about you in connection with a potential job opportunity, our Candidate Privacy Information Statement also applies and should be reviewed.
Personal Information we may collect from you in using this Website
When you visit and interact with this Website, we collect information about you, including Personal Information. “Personal Information” means information that identifies or relates to you, or as defined under applicable law. The following identifies the categories of Personal Information we collect directly from you (or about you) and how we collect such data:
Online forms and accounts: When you complete an online form or create an account on our Website, we may collect contact information such as your name (first and last), e-mail address, telephone number, physical address, and online user account details (collectively, “Identifiers”). We may also collect information pertaining to your professional qualifications, including your educational and professional background and salary (collectively, “Education and Qualifications”).
Communications with us online: We will collect any Personal Information you provide to us when you use our contact forms (for example “Contact”, “Contact us today”, “Send us a message”, or “Contact us about working together”). Providing us your Personal Information via our contact forms is not required; however, please note that fields marked with an asterisk (*) are mandatory fields, because we have determined we need this information to comply with or respond to your request, or to improve your future experiences with us and our Website. Other information or Personal Information you share with us when completing our contact forms is at your sole discretion. If you contact us, we will keep a record of that correspondence in accordance with our established retention protocol.
Marketing: We also may collect information for marketing purposes and analysis, including information on how you respond to email, SMS, phone and other marketing campaigns as well as feedback you provide about us and our services through our satisfaction surveys (collectively, “Correspondence and Feedback”). Messaging and data rates may apply for any SMS, MMS, and other electronic communications (typically, this is based on your carrier and service plan). For more information, please visit our Terms and Conditions.
Your company’s business needs: If you are interested in our suite of service offering such as career transition or recruitment services, we may collect Personal Information and other information about you in connection with your company’s employment or other needs, including without limitation, Identifiers such as your name (first and last), e-mail address, telephone number, as well as your company name, job title, job function, job level, industry, staffing or employment challenges, current recruitment model, your location, sector, experience working with our brands, company registration number, purpose of attendance (at an event), size of opportunity, and type of staffing or other need.
Social media, online forums, blogs, message boards: We also may collect Personal Information and other information about you when you choose to interact with us through social media platforms on which we are active. In addition, we also may collect the Personal Information you make available on your public social network profiles and on other public locations, including, without limitation, on Facebook, LinkedIn, Twitter, Instagram, or other company websites and/or job boards. The Personal Information we collect in this manner may include Identifiers (name (first and last), contact information, and location) and Education and Qualifications (education, training courses and internships, and work experience), skill sets (for example, foreign language skills), professional or employment-related information (education and work experience), and any other information you make available on social media platforms and other public locations (collectively, “Social Media Information”).
Career opportunities: If you apply for a career opportunity with or through us, we may collect Personal Information and other information from you, which may include Identifiers such as your contact information (name (first and last), physical address, telephone number, e-mail address), and Education and Qualifications, which includes education, training courses and internships, and work experience, skill sets (for example, foreign language skills) and any other information you listed on your resume or CV. For more information about our collection practices for job candidates, please visit our Candidate Privacy Information Statement.
Cookies and automated technology: To learn more about the information we collect about your equipment browsing actions, and patterns, please consult the “Cookies and automated technology” section below.
We collect any other Personal Information you choose to provide us.
Sensitive Personal Information. When you visit or interact with our Website, you are not required to submit information that may be considered sensitive, including your race or ethnic origin or data concerning your health or sexual orientation. If you decide to provide us with sensitive Personal Information, we will handle the information according to the practices identified in this General Privacy Policy as well as those identified in the Candidate Privacy Information Statement. We reserve the right to delete the information from our databases in accordance with applicable law.
How we use your Personal Information
We collect and use the information or Personal Information we collect from or about you, including your Identifiers, Education and Qualifications, Correspondence and Feedback, and Social Media Information, for the following business purposes:
to provide you, our clients and prospective clients, and our candidates and prospective candidates with our services.
to best tailor content and resources according to your preferences.
to respond to your requests or questions when you contact us.
to help us create, publish, and improve content most relevant to you.
to ensure that the content provided through the Website is presented in the most effective manner for you and for your device.
to allow you to participate in interactive features of our Website, when you choose to do so.
to further develop and improve the Website, and systems to better serve you. This mainly takes place in the context of new IT systems and processes so that information about you may be used in the testing of those new IT systems and processes.
where necessary, to comply with any legal obligation.
for our business contacts, to attempt to establish or strengthen a business relationship with you. This may include, for example, informing you how we can assist you with our services.
we also may use your information in:
investigating or responding to incidents and complaints, and/or
complying with investigations carried out by the police, government or regulators.
We also use the Personal Information we collect for commercial purposes. We may use your Identifiers, Education and Qualifications, Correspondence and Feedback, and Social Media Information in order:
to send you direct messaging or marketing via email, text message, and/or other communication means. You may opt-out of receiving future messaging or marketing communications at any time by emailing us using the information listed in the “Contact” section below. Messaging and data rates may apply for any SMS, MMS, and other electronic communications (typically, this is based on your carrier and service plan). For more information, please visit our Terms and Conditions.
to inform you about services, products, events that might be of interest to you (we may communicate by email, telephone, text message, mail and/or other communication methods).
to send to you other information – such as Company upcoming events or newsletters – that may be of interest to you.
to perform analytical research on our prospective client and candidate base, including the content, and the services/products in which they are interested.
to transfer data to third parties (see the “Sharing with third parties” section below).
Our use of your information as described above is permitted by applicable data protection law because it is:
necessary to fulfill a contract with you;
necessary for our legitimate interests in pursuing the purposes set out above, and such interests in each case not being overridden by your privacy interests;
in some cases, necessary to meet our legal or regulatory responsibilities, such as disclosures to authorities, regulators or government bodies; or
in some cases, necessary for the performance of a task carried out in the public interest and, when we use special categories of personal information, necessary for establishing. exercising or defending legal claims or where the processing relates to personal information manifestly in the public domain;
in limited circumstances, processed with your consent which we obtain from you from time to time, such as when you opt-in to receive marketing communications and news via email.
Do you have to give us your Personal Information?
You do not have to provide your Personal Information to us when generally navigating our Website. However, if you do not provide us with a required minimum, it may limit the services you can receive from us.
Do we process information about you without human intervention at all?
Yes, at times we may use automated systems/processes and automated decision-making (like profiling) to ensure we give you a bespoke experience with us. Our automated decisions are personas that we have created using user's past behavior, combined into a scoring model. This helps us prioritize requests and services.
How long do you keep my Personal Information?
We retain your Personal Information as long as necessary to fulfil the purposes set out in this General Privacy Policy in accordance with applicable legal and regulatory requirements. The retention periods of your personal information depend on the respective purpose for which the data is processed and the respective tool in which the personal information is processed in. It is not possible to outline the various retention periods in a reasonably intelligible format under this Policy. The criteria used to determine the applicable retention period are that we will retain the personal information set out in this policy for as long as (i) necessary for the respective purpose, (ii) necessary to carry out our business relationship with you, (iii) you have consented to, and/or (iv) required by applicable statutory retention laws.
Sharing with third parties
To facilitate our efficient use of your information and Personal Information, and to provide you with content and/or resources, to fulfil a request you make of us, or to otherwise provide our services, we disclose your information, including the Personal Information identified in the “Personal Information we may collect from you in using this Website” section above, to the following third parties:
To our suppliers. We engage suppliers to carry out administrative and operational work in support of our relationship with you. The supplier(s) are subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and they will only have access to and use the data they need to perform their functions. The relevant suppliers are often IT suppliers (who, for example, host or support our IT systems, including information about you such as Identifiers and the information described in the “Cookies and automated technologies” section below), premises management companies (who, for example, look after physical security at our buildings, and therefore need to know about you to allow access to our buildings) and/or back office finance and accounting management providers (who, for example, need to handle details, such as Identifiers, professional or employment-related information, and financial information like a bank account number of persons in order to process accounts payable and receivable). We also engage suppliers who provide technology services and solutions who, for example, provide video interview and skills assessment tools and may need access to your Identifiers, Education and Qualifications, Correspondence and Feedback, and Social Media Information.
To other members of The Adecco Group. We are part of “The Adecco Group”, an organization of related companies located across the world who are all subsidiaries of the same ultimate parent company, Adecco Group AG (a legal entity based in Switzerland). The Adecco Group companies perform a range of services including but not limited to temporary staffing and direct hire placement services, payroll services, recruitment, and selection services, testing solutions services, career transition services, talent development services, training and education services, outplacement and international mobility services. We may share your information with other members of The Adecco Group for different reasons:
information is shared with members of The Adecco Group that provide IT functions for The Adecco Group companies world-wide;
information may be shared with other affiliate companies of The Adecco Group locally and/or globally in furtherance of the services we or The Adecco Group provides. A list of the countries in which we operate is available in the ‘choose your country’ function of our website at www.adeccogroup.com.
Government & law enforcement. We will share your data with government, regulators, or law enforcement agencies if, at our sole discretion, we consider that we are legally obliged or authorized to do so or we believe it would be prudent to do so; and/or
Corporate reorganization. As part of due diligence relating to (or implementation of a merger, acquisition, or other business transaction, we may need to disclose your data to the prospective seller or buyer and their advisers.
We do not sell your Personal Information to third parties.
Cookies and automated technology
Automatic Data Collection. In addition to collecting Personal Information, we may use automatic data collection technologies to collect certain statistical (non-identifiable) information about your equipment, browsing actions, and patterns. This includes (i) details about your visits to our Website, which may include traffic data and location data, date and time of access, frequency and other communication data; and (ii) information about your computer and internet connection, which may include your IP address, operating system, browser type, and host domain; and (iii) details of referring website actions and patterns.
Cookies. We may collect information from you using a “cookie.” “Cookies” are small bits of data cached or stored on your computer based on your internet activity. They can be placed on your computer both by us as well as by third parties with whom we have a relationship, such as web analytic services and advertising networks. Cookies help us track and understand how individuals use and interact with our Website. For more information on the types of cookies that we use and your ability to disable cookies, please see the “Your choices regarding your Personal Information” section below and our Cookie Policy available at https://www.helloezra.com/legal/cookie-policy.
Web Beacons. We use a technology known as web beacons to collect your web log information. A web beacon is a small graphic used on a website or within an e-mail message designed to track pages viewed or messages opened. Web log information is gathered by the computer that hosts our Website (called a "webserver”) when you visit our Website. Web beacons in e-mails help us determine which of our e-mail messages were opened and whether a message was acted upon. They also help us analyze the effectiveness of our web pages by measuring the number of visitors to certain pages of our Website and how many visitors click on key elements of it.
Social Media Plug-ins. Our Website uses social media plugins (“Plugins”) from the social networks such as Facebook, LinkedIn, Twitter, and Instagram to enable you to easily share information with others. We may use information collected from the Plugins to learn about your interests and to help us better understand how to serve you. This information may include your preferences about how to contact you or further develop a business or professional relationship with you as well as demographic data. For more information, please visit our Cookie Policy at https://www.helloezra.com/legal/cookie-policy.
Do we transfer or store your data outside the EU/Switzerland/ United Kingdom?
Your Personal Information may be transferred to and/or stored in any country where we conduct business, which includes outside North America. By using our Website or by otherwise providing information to us, you understand that the information from or about you or your use of our Website may be transferred to and/or stored in countries outside of your country of residence, including the United States.
We shall only transfer your Personal Data to countries that provide an adequate level of data protection as defined by the applicable data protection authority, or where we have put in place appropriate safeguards to seek to preserve the privacy of your Personal Data. When we transfer your information to recipients in these countries, we will protect that information as described in this Privacy Policy and comply with applicable legal requirements.
For EU, UK, and Swiss Individuals: Privacy Shield Notice for Personal Data Transfers to the United States
LHH also participates in the EU-US and Swiss-US Privacy Shield Framework regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom and Switzerland, although, in light of the judgment of the Court of Justice of the EU in Case C-311/18, LHH does not rely on the Privacy Shield Framework as a legal basis for transfers of Personal Data.
We have certified with the Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield Principles, and to view our certification page, please visit https://www.privacyshield.gov/.
In compliance with the Principles, LHH commits to resolve complaints about our collection or use of your Personal Data. European Union (EU) and the United Kingdom and/or Swiss individuals with inquiries or complaints regarding LHH’s Privacy Shield Privacy Policy should first contact LHH directly at privacy@lhh.com.
For complaints that cannot be resolved, LHH commits to cooperate with the panel established by the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC), as applicable, and comply with the advice given by the panel or Commissioner about Personal Data transferred from the EU or Switzerland. In order to facilitate the handling of complaints, individuals in the EU can choose to contact their national DPA or use the form located at this link: http://ec.europa.eu/newsroom/document.cfm?doc_id=42962.
Individuals in the United Kingdom can contact the UK Information Commissioner by visiting https://www.gov.uk/data-protection/make-acomplaint . Individuals in Switzerland can contact the Swiss Information Commissioner by visiting https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html . This independent dispute resolution process is provided at no cost to the individual.
Under certain conditions an individual may choose to invoke binding arbitration to resolve any residual complaints not resolved by LHH, or the DPAs or FDPIC, as appropriate. If an individual formally invokes binding arbitration, LHH will follow the terms set forth in Annex 1 of the Privacy Shield Frameworks. For more information on binding arbitration visit https://www.privacyshield.gov/article?id=ANNEX-I-introduction .
As explained in the Privacy Notice, we sometimes provide personal information to third parties to perform services on our behalf. If we transfer personal information received under the Privacy Shield to a third party, the third party's access, use, and disclosure of the personal information must also be in compliance with our Privacy Shield obligations, and we will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.
LHH is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) for compliance and enforcement of the Privacy Shield and Swiss Privacy Shield. LHH is also committed to cooperating with EEA, UK, and Swiss data protection authorities. We may be required to disclose personal information that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Data Security
We maintain commercially reasonable security safeguards designed to protect the Personal Information we collect against unauthorized use, disclosure, alteration, or destruction. Although we aim to protect the security and integrity of the Personal Information we collect, we cannot guarantee or warrant that any information, during transmission through the Internet or while stored on our system or otherwise in any case, is 100% secure from intrusion by others. If you have reason to believe that your interaction with us is not secure or that data has been compromised, please immediately notify us of the problem by contacting us using the contact information below.
Your choices regarding your Personal Information
Disabling Cookies and Managing the Collection of Your Personal Information. At any time, you can disable cookies by adjusting your browser settings. Each browser is different, so please refer to the specific instructions related to your browser to learn more about cookie-related and other privacy and security settings that may be available to you. Please note, by disabling cookies, you may not be able to take full advantage of the services offered by our Website. For more information, please visit our Cookie Policy at https://www.helloezra.com/legal/cookie-policy.
Do Not Track. Currently we do not alter our information collection and use practices in response to Do Not Track signals.
Commercial E-mails, Newsletters, and Other Communications. Where we send marketing or other communications to you, you may opt out of receiving any further communications by contacting us or using the ‘unsubscribe’ or ‘opt-out’ function when available. You can also exercise your opt-out right at any time by contacting us using the information listed in the ”Contact” section below and providing the following information: your name, your email address, a contact telephone number, the marketing communications you would like to opt out of receiving.
Your rights
Under applicable data protection laws, you have the following rights:
Right to access and obtain a copy of your personal information: You are entitled to request confirmation whether we process any of your personal information. Where this is the case, you may have access to your personal information and to certain information about how it is processed. In some cases, you can ask us to provide you with an electronic copy of your information. In some limited circumstances, you also have the right to request portability of your personal information.
Right to correct your personal information: If you can demonstrate that the personal information we hold about you is not correct, you can ask that this information is updated or otherwise corrected.
Right to be forgotten/have data deleted: In certain circumstances you have the right to have your personal data deleted. You may make such a request at any time, and we will evaluate if your request should be granted, however this right is subject to any legal rights or obligations we may have to retain data. For situations where, in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so without undue delay.
Right to restrict or object to the processing of your data: In certain circumstances you have the right to restrict the processing of your personal information, or to object to certain processing.
To the extent our processing of your personal information is based on your consent, you also have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of such withdrawal.
You can also lodge a complaint about our processing of your personal information with your local data protection authority or regulator, as applicable.
To exercise your rights, please use the contact information listed in the “Contact” section below. Please note that to exercise the rights described above, it may be necessary for us to verify your identity or authority to make the request and confirm the Personal Information relates to you.
Candidates may access, review, correct or update their Personal Information in accordance with our Candidate Privacy Information Statement.
Children’s privacy
Our Website is designed and intended for adults. By accessing and/or using our Website, you represent that you are a legal adult. If you are not a legal adult, you must have your parent or legal guardian access and use the Website for you. If you want to purchase any goods or services that may be offered on our Website, such purchase(s) must be made by your parent or legal guardian on your behalf.
Changes to this General Privacy Policy
The terms of this General Privacy Policy may change from time to time. We shall publish any material changes to this General Privacy Policy through appropriate notices either on this Website or contacting you using other communication channels.
Contact
If you have any questions, comments and/or requests regarding this General Privacy Policy or to exercise your rights with respect to your Personal Information (as applicable), please contact us by email at privacy@lhh.com, or click here.