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 your personal information when you visit www.lhhpenna.com (the “Website”). This policy also describes the commitment of our United States affiliate, Lee Hecht Harrison LLC, to compliance with the EU-U.S. Privacy Shield Principles as further described below. To learn more about the Privacy Shield and to obtain a copy of the Privacy Shield Principles, please visit https://www.privacyshield.gov
Your personal information will be collected and handled by us for the following purposes:
Our use of your information as described above is permitted by applicable data protection law because it is:
We [do not] make any automated decisions solely on automatic processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
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.
To facilitate our efficient use of your information, and to provide you with the content and/or resources, we disclose your information to third parties. However, this disclosure will only occur in the following circumstances:
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.
As explained in the “Sharing with third parties” paragraph above, we share your personal information with the following:
We endeavour to take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.
Your personal information can be transferred and processed in one or more other countries, in or outside the European Union. 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. Those countries include the United States.
As stated above, our United States affiliate, Lee Hecht Harrison LLC, with registered address at: c/o Corporation Trust Company, 1209 Orange Street, Wilmington, Delaware 19801, USA, 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. Lee Hecht Harrison has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield programme, and to view our certification page, please visit https://www.privacyshield.gov/.
Lee Hecht Harrison is responsible for the processing of personal information it receives under the Privacy Shield and subsequently transfers to any third party acting on its behalf. Lee Hecht Harrison complies with the Privacy Shield for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield, Lee Hecht Harrison is subject to U.S. Federal Trade Commission regulations and enforcement. In cases of onward transfer to third parties of personal information of E.U. or Swiss individuals received pursuant to the Privacy Shield, we may remain liable for the acts of those third parties for their handling of personal information.
LHH has further committed to refer unresolved policy 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 acknowledgement 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. You may also contact your local data protection authority.
Please note that if your Privacy Shield complaint is not resolved through the above channels, a binding arbitration option may be available before a Privacy Shield Panel.
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 organisational security measures to prevent any unauthorised access, change, deletion or transmission of this personal information.
Under applicable data protection laws, you have the following rights:
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.
We will only send marketing communications to you via email where you have consented that we may do so.
We will usually offer you a tick box on the forms we use to collect your personal information where, if you agree to receive marketing communications, you have to click the box. Where we send marketing communications to you via email, you may opt out of receiving any further marketing communications by clicking the ‘unsubscribe’ or ‘opt-out’ function in the email. In addition, you can also exercise your opt-out right at any time by contacting us at email@example.com 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.
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.
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 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, EC3V 0EE, London; or via email to Privacy@LHH.com
You can request a copy of mechanisms relating to a specific transfer of your personal information by contacting Privacy@LHH.com
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