Lee Hecht Harrison Penna Limited (“LHH”, “we” or “us”) is committed to protecting and respecting your privacy.
This Policy (together with other documents referred to herein) describes what personal information we collect from you and how we process and protect your personal information when you visit (the “Website”). This policy also describes certain choices that you have regarding use, access to and correction of your information.
Personal information we may collect from you
· We will collect personal information on your visits to the Website including, but not limited to, traffic data, location data, weblogs, content from surveys and contact forms and other communication data and the resources that you access. Our collection of this personal information will make your visit to the Website easier in the future, as we will be able to suggest Content that is relevant to you based on the location from which you access the Website.
· We will collect any information that you provide to us when you use our contact forms (for example “Contact us” or “Subscribe to our newsletter”. The provision of your personal information via our contact forms is not a statutory or contractual requirement; however, please note that fields marked with an asterisk (*) are mandatory fields, because we need this information to comply with or respond to your request. Other information or personal information that 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.
· We use your personal information to send you direct marketing via e-mail when you opt-in for this purpose in the relevant contact form. You may opt-out of receiving future marketing communications at any time.
How we use your personal information
Your personal information will be collected and handled by us for the following purposes:
· to best tailor Content and resources according to your preferences.
· to respond to your request or questions when you contact us.
· to send you other information – such as LHH upcoming events or newsletters – that may be of interest to you.
· to help us to 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 the interactive features of our Website, when you choose to do so.
· to further develop and improve the Website and systems to serve you better.
Our use of your information as described above is permitted by applicable data protection law because it is:
· 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. See further information about B2B Communications in the “Marketing communications” section below.
We do not make any automated decisions solely through automated means without implementing suitable measures to safeguard your rights, freedoms and legitimate interests.
The retention periods of your personal information depend on the respective purpose for which the data are processed and the respective tool in which the personal information is processed. 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 to provide you with the content and/or resources, we may disclose your information to third parties. However, this disclosure will only occur in the following circumstances:
· To suppliers, contractors and agents: from time to time we may engage or employ other companies and individuals to perform functions on our behalf. Examples include the hosting and/or maintaining of Website content, the provision of certain features contained on the Website, or the provision of marketing services. In some countries, we engage third parties to operate on our behalf pursuant to a licence agreement, and if your request for information applies to services or functions they perform, we will provide such personal information as may be necessary for them to fulfil your request. All such recipients will only have access to your personal information as required by them to perform their functions and they are not permitted to use such personal information for any other purposes. These recipients will be subject to contractual confidentiality obligations.
· To other entities belonging to the Adecco Group, including our LHH affiliates (i.e. any companies directly or indirectly controlled by Adecco), including their suppliers, contractors and agents, which may be involved in the provision of the Website or the content, so that we can better serve you or, simply, to respond to your requests (e.g. when you use contact us forms). A list of LHH companies is included here https://www.lhh.com/office-locator and a list of Adecco Group companies is included here https://www.adeccogroup.com/worldwide-locations/
· To government, police, regulators or law enforcement authorities if we consider that we are legally obliged or authorised to do so, or it would be prudent to do so.
IP addresses and cookies
We collect information about your computer, including (where available) your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns and does not identify you or any individual.
If your computer is shared with other people, we advise that you do not select the ‘remember my details’ option when that option is offered by the Website.
Where your personal information is stored and processed.
As explained in the “Sharing with third parties” paragraph above, we share your personal information with the following:
· Third-party suppliers, contractors or agents: where we use a third-party supplier, contractor or agent, your personal information remains under our control and we have controls in place to ensure that your personal information is adequately protected.
· Other companies in the Adecco Group, including our LHH affiliates: we have entered into groupwide arrangements to ensure that your personal information continues to be subject to an adequate level of protection.
We endeavour to take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.
If you are a resident of, or are located in the European Economic Area (“EEA”), Switzerland or the United Kingdom, we shall only transfer your data outside the EU to countries which the European Commission believes offer an adequate level of protection to you, or where we and our affiliated companies have put in place appropriate safeguards to seek to preserve the privacy of your information.
LHH continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.
With respect to transfers of personal information to the U.S., Lee Hecht Harrison complies with the principles of the EU-U.S. and Swiss-U.S. Privacy Shield frameworks developed by the U.S. Department of Commerce and the European Commission and Swiss Federal Data Protection and Information Commissioner, respectively, regarding the transfer of personal information from the EEA, Switzerland or the United Kingdom to the U.S.. LHH is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission with respect to personal data received or transferred pursuant to the Privacy Shield Frameworks. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. To learn more about the Privacy Shield programme, and to view our certification page, please visit https://www.privacyshield.gov/. Lee Hecht Harrison remains responsible for the processing of personal information that it receives under the Privacy Shield and subsequently transfers to any third party acting on its behalf.
Please note that, despite the invalidation by the Court of Justice of the European Union of the EU-US Privacy Shield Framework as a mechanism for transfers of personal data between the EU and the U.S. in Case C-311/18, LHH intends to maintain its self-certification under the EU-US Privacy Shield Framework and remains committed to complying with the Privacy Shield Principles. For more information on the U.S. Department of Commerce’s continued administration of the Privacy Shield programme, please visit https://www.privacyshield.gov/article?id=EU-U-S-Privacy-Shield-Program-Update.
Although we will do our best to protect your personal information, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to the Website or any third party; for this reason, any transmission is at your own risk. We will use strict operational procedures and adequate technical and organizational security measures to prevent any unauthorised access, change, deletion or transmission of this personal information.
Your rights. How you can access, correct and delete your personal information
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.
· Right to correct your personal information: If you can demonstrate that 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 that we may have to retain data. In 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.
· Object to Processing. In certain circumstances, you have the right to object to the manner in which we process your Personal Data, including where we are relying on a legitimate business interest for such Processing or engaging in direct marketing.
Right to restrict processing: You may be entitled to request that we restrict the Processing of your Personal Data, for example, in circumstances in which the accuracy of the Personal Data is contested.
· California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. Please note that we do not rent, sell, or share in any manner, your personal information in personally identifiable form to anyone for marketing purposes. To exercise your rights, click here.
To the extent that 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 the data protection authority of the Member State of your habitual residence, of your place of work, or of an alleged infringement of your rights.
*All requests are subject to applicable law. In accordance with applicable law, we will take steps to verify your identity and the request before processing any request, including, for example, requiring you to provide identifying information about yourself, your account, your prior interactions with us and/or such other additional information as may be required by law.
We will only send marketing communications to you, as an individual, if you have explicitly consented to us doing so. If you do give explicit consent, you have the right to withdraw such consent. You can withdraw consent by visiting the service portal, if such is provided for your service, or by sending us a message. Learn how to send us a message by visiting the ‘Contact Us’ section.
B2B Communications. If you represent our prospect, partner or customer, either prior to entering into an agreement with Adecco or during a business relationship between Adecco and the legal entity which you represent, we may process your basic contact details (e.g. your name, surname, job position, company name, e-mail, and telephone number) to the extent that is necessary to carry out our joint business relationship. When we can legally do so, we may augment this information in order to ensure that it is accurate. This processing of your personal data is based on our legitimate interest in maintaining and developing our business relationship and customer base, promoting our products, services and customer loyalty programmes. Generally, you cannot opt out of these sorts of communications, which are not marketing-related but merely required for the relevant business relationship.
You may easily opt out of receiving any further marketing communications at any time. Simply click the ‘unsubscribe’ or ‘opt-out’ function at the bottom of the email. In addition, you can also exercise your opt-out right at any time by contacting us at click here [●] 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.
Other LHH sites
We offer online tools and services through other websites which may be accessed through this Website and which have their own privacy policies that govern our handling of your personal information when you visit those websites.
Changes to this Policy
The terms of this Policy may change from time to time. We shall publish any material changes to this Policy through appropriate notices either on this website or by contacting you using other communication channels.
Questions, comments and requests regarding this Policy are welcomed and should be addressed to us by mail at: Lee Hecht Harrison Penna Limited, 55 Gracechurch Street, London, EC3V 0EE, United Kingdom; or click here.
You can reach our Data Protection Officer or request a copy of mechanisms relating to a specific transfer of your personal information by clicking here.
Date: 1 September 2020