Privacy and Cookies Policy and Declarations of Consent
Last updated: January 26, 2020
- Who We Are and What this Policy Is
Welcome to Profiler S.A., Ancien Dieweg 42, 1180 Brussels, Belgium and Profiler S.A., Rue des Primeurs 5, 2361 Strassen, Luxembourg. We are a BeLux-based HR Consultancy firm to many multinational and local organizations in Belgium and Luxembourg. We provide a variety of services to these clients and other parties, including, but not limited to:
- Search & Selection
- External Assessments
- HR Audits
- Interim Management
- Organizational Design
- And many more
For additional information on our Services please visit http://profiler-consulting.eu/home/ . Our consultants provide these Services from our offices in Luxembourg and Belgium.
Profiler 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 Profiler S.A. 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 following terms 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 or coached by Profiler in connection with the Services;
”Client” means any of the organizations or individuals who contract Profiler’s 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 http://www.profiler-consulting.com/ and all web pages hosted at this web address
- Processing of Your Personal Information
As part of our Services, we specialize in the global search, integration, assessment, coaching and development of Candidates for or in executive and similar management positions as well as in the boards of directors for or on behalf of our Clients, based on data held by or made available to Profiler. In the event you are interested in becoming a Candidate for one of our Client Services, you can provide us with information on your personal and professional background that we may take into consideration as part of the relevant Client Services. For example, you may provide this information directly to one of our consultants, or upload your CV through our Site.
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 Client 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 Client 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 Personal Information may be Processed as follows:
3.1 For Client Services
Your Candidate Information Processed by Profiler and / or selected Profiler partners might contain (a) your contact details (name, address, phone number, email address, etc.), (b) your biographical data, (c) information on your professional education, (d) your educational credentials, professional diplomas and certificates, and (h) any Sensitive Personal Information you might chose and explicitly consent to disclose to us. If you are a Candidate for Client Services relating to executive search, your Candidate Information may in addition contain (e) your employment and compensation history, (f) data on your suitability for Client opportunities we compile as part of our assessments of your professional profile, (g) 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 Client Services.
As part of Client Services, your Candidate Information may be Processed for the purposes of:
- providing Client 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 Client Services.
If you are a Candidate for Client Services relating to executive search, your Candidate Information may be Processed for the following additional purposes:
- 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, assessing your suitability for Client opportunities; introducing you to Clients as a Candidate; verifying your educational credentials, professional diplomas and certificates; and 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 Client Services for which your Candidate Information has been intended. Your Candidate Information will be Processed until you revoke your declaration of consent given when sharing Candidate Information with us. Upon the revocation of your declaration of consent, we will delete your Candidate Information from all databases.
Your Candidate Information will mainly be Processed by and on behalf of Profiler. However, depending on how and where the Client Services need to be performed in your individual case, your Candidate Information may be shared with third parties as follows:
- Your Candidate Information will be stored in databases located in Belgium. The servers hosting the databases are operated by our IT provider and accessible to members of Profiler or third-party service providers , such as our IT partner.
- Via our proprietary databases, your Candidate Information will be available to the consultants and administrative staff of Profiler in various countries worldwide for the purposes of providing the Client Services;
- Your Candidate Information might be disclosed to selected partners with whom we may work on specific projects when providing Client Services;
- If you are a Candidate for Client Services relating to executive search and 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 they 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 separate and specific consent from you.
In this context, please be aware that various companies of Profiler, most of the third-party service providers operating the database 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. These include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Information within the Egon Zehnder group of companies and our third party service providers and selected partners, which require all of them to protect Personal Information they Process from the EEA in accordance with the European Union General Data Protection Regulation.
3.2 In relation to the Use of our Site
The cookies we use can be categorized as follows:
- Session Cookies: These are cookies that allow our Site to collect information about what you do during a browsing session each time you visit the Site. When connecting to our server, your device will be allocated a session ID, which enables our server to identify your device during the session and facilitates Site usability. These cookies are temporary and are set to be deleted when you leave the Site;
- Persistent Cookies: These are cookies that are stored by your Internet browser for more than a session and are set to expire within a defined time period. Persistent cookies enable us to remember your settings and information, so you do not have to keep re-entering them whenever you visit our Site. They also measure how you use and interact with the Site and enable us to personalize the Site. For example, they may allow us to alter the rotation of images on the Site so that different images will be displayed on your next visit;
- First-Party Cookies: These are cookies that we store and access on your device in our capacity as controller of your Personal Information when you visit our Site. They might include cookies related to third-party service providers, provided that we control and determine the purposes and means of the Processing of your Personal Information logged by such cookies. As a result, first-party cookies might log user-related Personal Information accessible to and Processed by third parties on our behalf and subject to our instructions.
- Third-Party Cookies: These are cookies that are stored and accessed on your device by third parties determining the purposes and means of the Processing of your Personal Information logged by such cookies.
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.
(b) Third Party Services
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.
Additionally, we use the following Social Media Platform Cookies, all intended to facilitate linking and following by or from the respective platforms:
1, Hacker Way, Menlo Park, CA 94025, USA
2029 Stierlin Ct. Ste. 200, Mountain View, CA 94043, USA
1355 Market Street, San Francisco, CA 94103, USA
In addition to the above, you can manage the cookies of various third-party service providers by setting respective opt-out cookies on http://www.aboutads.info/choices/ or http://www.youronlinechoices.com/uk/your-ad-choices.
(c) Do-Not-Track Disclosure
Laws such as California Business and Professions Code § 22575 require us to disclose how our Site responds to Internet browser ”Do Not Track” signals and/or other mechanisms that seek to provide consumers with the ability to control the collection of their Personal Information through online tracking for certain purposes, such as targeted or behavioral advertising.
However, in ”Cookies” and ”Third-Party Services” above, we describe how you may use mechanisms similar to the ”Do Not Track” technology of certain Internet browsers in order to effectively prevent us or third parties from collecting your Personal Information through online tracking. To the extent that you make use of these mechanisms, your preference not to be tracked or to be tracked only to a limited extent will be honored by us and the third parties providing services to us.
3.3 Personal Information Pertaining to Children
Our Services are not intended to be used by minors and we do not want to collect information from minors. If a child’s parent or a guardian believes their child may have provided Personal Information to us, please write us using the contact details provided in ”How to Contact Us” below and we will delete that Personal Information, subject to the applicable law and this Policy.
- 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.
- Your Rights
Subject to the applicable law, you have the right to: (a) obtain information about your Personal Information we Process; (b) to request the correction or completion of incorrect Personal Information we Process; (c) to request the deletion of Personal Information we Process; (d) to object to our Processing of your Personal Information or to Restrict the way we Process such Information; and (e) 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.
- Retention of 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; and (iv) to show that we have fulfilled or continue to fulfill our obligations towards our Clients in relation to assignments you may have been involved in.
- 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.
- 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:
Avenue Louise 65
Rue des Primeurs 5