Privacy Notice and Declarations of Consent

Effective Date: September 1, 2017

 

1. Who We Are and What this Policy Is

Welcome to https://www.hightechpartners.net, the global website of Hightech Partners - ITP Holding SA group operating through 2 subsidiaries:

• IMC SA – Trading under the name of “Hightech Partners” – Avenue Louise, 500 – 1050 Brussels - VAT BE 0431 404 827 – in its capacity as Controller.
• Hightech Partners – ITP SA, Route du Mandement 197, 1242 Satigny, Switzerland – VAT CHE-115.910.621 in its capacity as Processor.

 

Hereafter commonly referred to as “Hightech Partners,” “we,” “us” and “our” etc..

We are a leading executive search firm and trusted advisor to many of the world’s most respected organizations.

We provide a variety of services to these clients and other parties, including, but not limited to:

• Executive Search (e.g., helping clients recruit executives for their organizations);
• Board Consulting (e.g., searching for directors, conducting board effectiveness reviews and appraisals of directors, and assisting in board successions);
• Leadership Strategy services;
• Executive Integration;
• Family Business Advisory services;
• Diversity and Inclusion services; and
• CEO succession

(collectively,  our “Services”). For additional information on our Services please visit Executive Search Services.  

We provide these Services through our consultants across Europe.

We respect the privacy of the visitors and users of our website (“you”, “your”) and are committed to protect their personal data and information according to the applicable law. This privacy policy (“Policy”) explains how, to what extent and for what purposes we are collecting and subsequently processing personal data and information collected through our website.

By using the website, you consent with the collection and use of information as set forth in this Policy.

The Controller is the responsible entity for the processing of your personal data and information on this website.

Our Data Protection Officer can be contacted at This email address is being protected from spambots. You need JavaScript enabled to view it.

 

2. Definitions

In addition to terms defined elsewhere in this Policy, the following terms shall have the following meaning throughout this Policy:

• “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 collected by us online through this 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 https://hightechpartners.net/ and all web pages hosted at that domain (such as the “Profile” page at https://hightechpartners.net /talent/leaders-circle/register-your-profile).

 

3. Processing of Your Personal Information

Depending on your interaction with the Site, your Personal Information is Processed, based upon your explicit consent, as follows:

(i) Your Profile – Declaration of Consent

As part of our Services, we specialize in the global search, placement and integration of candidates for executive and similar management positions (each a “Candidate”) on behalf of our clients (“Client Services”).

In the event you are interested in becoming a Candidate, you can provide us with information on your personal and professional background (“Candidate Information”) that we will, subject to our sole discretion, take into consideration or not as part of the Client Services. To do so, please visit https://hightechpartners.net /talent/leaders-circle/register-your-profile. By filling your profile, you will have to explicitly agree with the terms of this Privacy Policy at the bottom pf the page. You may provide information regarding your personal and professional background and upload your CV or resume in Microsoft Word or PDF format.

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 your potential suitability for an open executive or similar management position, we urge you not to disclose to us any Candidate Information that is likely of little or no relevance or may not even be legally considered as part of common hiring processes. This applies, in particular, to Sensitive Personal Information.

If and to the extent you share Candidate Information with us through the Site, 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.

In addition, we might 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 (so not directly obtained from you) or within data you have previously disclosed to us, provided that such information might be of importance to your qualification for a particular executive or similar management position. Any resulting information will be considered Candidate Information and be Processed as described below together with the Candidate Information you initially provided us with through the Site.

Your Candidate Information will mainly be Processed by and on behalf of Hightech Partners. However, depending on how and where the Client Services need to be performed in your individual case, your Candidate Information might, in addition, be Processed by the Partners l and Consultants listed on our website.

Your Candidate Information Processed by Hightech Partners might contain (a) your contact details (name, address, phone number, email address, etc.), (b) your biographical data, (c) information on your professional education, and (d) your educational credentials, professional diplomas and certificates. In addition, it may 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 that might be of importance to your qualification for a particular executive or similar management position, and (h) any Sensitive Personal Information you might choose to disclose to us.

Please provide us with any relevant modifications and changes in your personal data.

Your personal data will be processed and maintained in our records as long as your account is active and at the latest 24 months after the last contact, exchange of information or update of data.

As part of the Client Services, your Candidate Information may be Processed for the purposes of (a) executing searches for potential Candidates on behalf of clients that have an opening for an executive or similar management position, (b) assessing your suitability for client opportunities, (c) informing you of open executive or similar management positions potentially suitable for you, (d) introducing you to clients as a Candidate and potential future member of their management, and of (e) verifying your educational credentials, professional diplomas and certificates. In addition, your Candidate Information may be Processed for the purposes of (f) performing 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 to your qualification for a particular executive or similar management position, (g) providing integration services on behalf of a client you have been placed with by monitoring your integration with the client, speaking with all parties involved and lending support for you to reach full effectiveness in your new role as soon as possible, (h) approaching you, after you have been placed with a client, as a client contact for the placement of other Candidates or as a source of information about potential Candidates for third-party clients, (i) ensuring that, after your placement with a client, you will not be recruited on behalf of another client unless you request consideration for other opportunities, and of (j) operating the databases your Candidate Information is stored in.

At no point will your Candidate Information be matched, linked or otherwise connected with Personal Information collected through other components of the Site for purposes other than providing Client Services. Your Candidate Data will be Processed until you revoke your  consent given when sharing Candidate Data with us through the Site. Upon the revocation of your declaration of consent, we will delete your Candidate Data from all databases.

By sharing your Candidate Information with us through this Site, you explicitly consent to the Processing of your Candidate Information, including any Sensitive Personal Information you might choose to disclose to us, as described above. You acknowledge that you are under no obligation to provide your consent and that, if you choose to do so nonetheless, you may revoke your declaration of consent at any time with future effect by using the following contact details: This email address is being protected from spambots. You need JavaScript enabled to view it.

(ii) The Leaders’ Circle – Declaration of Consent

The Leaders’ Circle is our online executive community that you can join in order to receive newsletters (1) and participate in surveys we conduct on important topics (2).

To become a member of the Leaders’ Circle, you need to create a Leaders’ Circle membership account (“Account”) on Leaders' Circle.

As part of the registration process, we ask you to provide us with certain mandatory information marked with an asterisk. Such information includes your last name, salutation, email address and a password that you specify in order to be able to access your Account in the future. It is necessary for us to be able to address you personally when sending you newsletters or surveys as described below. In addition, it allows us to offer you an easy way to manage your Leaders’ Circle membership at any time.

Beyond the mandatory information, you may choose to provide us with additional information that helps us understand your professional background and adjust the Leaders’ Circle services to your personal preferences and interests (3). This information may include all or any of the following: your first name, the company you work for, your position and industry background, the city/country you reside or work in and/or your particular business interests. None of this information is necessary for you to join the Leaders’ Circle and providing it to us is purely voluntary on your part.

When receiving a registration for the Leaders’ Circle, we log and store the date/time of registration and the IP address the registration was received from. This solely serves for evidentiary purposes in the event an email address is used to register for the Leaders’ Circle by an unauthorized party. In addition, we verify the authorized use of an email address by sending to such address an email asking for confirmation of the registration via a contained link. If and when the link is clicked on, we will automatically be notified that the registration has been confirmed from the email account initially used for the registration. Only upon such confirmation will the registration for the Leaders’ Circle become effective and will we send newsletters or survey emails to the respective email address (double opt-in procedure).

Once you have registered for the Leaders’ Circle and, where applicable, indicated during the registration process that you wish to receive certain content, we will send you, at our sole discretion, emails in irregular intervals with summaries of third-party business articles that we believe will be of particular relevance to you, select comments, reviews and reports of our consultants on relevant business trends, issues and questions (“Leadership Insights”) and/or promotional content regarding our Services (“Newsletter Service”); emails in irregular intervals providing you the opportunity to participate in surveys we conduct among the members of the Leaders’ Circle to learn their opinions on important business topics. Participation in the surveys is purely voluntary on your part.

In the event you chose to participate in a particular survey by providing your opinion or sharing other information (each a “Contribution”) with us, we might, subject to our sole discretion, use such Contributions, or parts thereof, to cite or otherwise reference them in articles of the Focus Magazine published by Hightech Partners on a regular basis and accessible on the Site, from within the “Hightech Partners” mobile apps available in various app stores worldwide or in hard copy. However, unless we have obtained your explicit prior consent in the individual case, we will not use your Contributions in a way allowing your identification (the execution of surveys and the use of Contributions as described above “Conducting Surveys”).

The Personal Information you make available to us when registering for the Leaders’ Circle or managing your membership will be stored and otherwise Processed by us solely for the purposes of providing the Newsletter Services (1), Conducting Surveys (2) and send you personalized content (3). We will not share such Personal Information with any third parties. Nor will we match, link or otherwise connect it with Personal Information collected through other components of the Site.

The Personal Information you share with us when registering for the Leaders’ Circle or managing your membership will be deleted at the end of your membership in the Leaders’ Circle. However, we reserve the right to archive or otherwise store and make available to the public indefinitely any articles of the Focus Magazine written or otherwise composed during your membership with Contributions containing your Personal Information, provided that we have obtained, in the individual case, your explicit prior consent to include the Personal Information in the respective articles.

With registering for the Leaders’ Circle and providing your Personal Information in the process, you explicitly consent to the Processing of such Personal Information as described above. You acknowledge that you are under no obligation to provide your consent and that, if you choose to do so nonetheless, you may revoke your consent and end your membership in the Leaders’ Circle at any time with future effect by following the Unsubscribe Page accessible once logged-in through your Account and contained in any newsletter or survey email sent to your email address.

(iii) Profiling

We will not take purely automated decisions about you. Every decision will be made through the intervention of one of our Consultants.

 

4. Sharing Your Personal Information

Your Candidate Information will be shared with third parties as follows:

• Your Candidate Information will be stored in databases located in Switzerland, considered by the European Commission as one of the countries that offers an adequate level of protection of personal data . The servers hosting the databases are operated by and accessible to members of the Hightech Partners - ITP Network or third-party service providers solely acting on their behalf and as per their instruction in order to operate the servers. The third-party service providers that are to be considered as Sub-Processors are Swisscenter, LMWEB SA, Planet Communications (CHE-110.480.530)_ - Switzerland;
• Via the databases, your Candidate Information will be available to the consultants and administrative staff of the different companies of Hightech Partners group and the Partners listed on our website for the purposes of providing the Client Services;
• 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 separate and specific consent from you.
• We will not sell, share, or otherwise distribute your Personal Data to third parties except as provided in this Privacy Policy.

 

5. Your Rights

Your rights under this Policy and in accordance with the applicable laws, especially the GDPR  :

• You have the right of access to your personal data, we processed and a copy.
• You have the right to request a rectification or adaptation of any personal data and information.
• You have the right to request a restriction of the use of your personal data and information.
• You have the right to request an erasure of your personal data and information.
• You have the right to object to processing of your personal data and information
• You have the right to receive your personal data concerning in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
• You have the right to withdraw consent at any time.

To exercise these rights, please send us an e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it..

Or contact the Controller :  IMC SA, Avenue Louise 500, 1050 Brussels, Belgium. Tel: +32 (0)2 663 1600

A complaint with regard to the handling of personal data and the applicable GDPR regulations can be made with Commission for the Protection of Privacy, Rue de la Presse 35, 1000 Brussels,  +32 (0)2 274 48 00, This email address is being protected from spambots. You need JavaScript enabled to view it.

 

6. Cookies

Our Site makes use of cookies. Cookies are small text files downloaded by your Internet browser and stored on the device you use to access the Site (e.g., your desktop computer, tablet or smartphone). Depending on their purpose, cookies log specific user-related information such as your user preferences, authentication information, security parameters, data concerning the device you access the Site with and statistical information regarding your use of the Site. Where necessary during your visit of the Site or when revisiting the Site, your Internet browser transmits the cookies including the contained information back to the servers they were initially downloaded from. The analysis and Processing of such information allows us to ensure the functionality of the Site, improve your online experience and optimize the structure and content of the 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.

You may influence the scope and extent to which we use cookies when you visit our Site. In particular, you may prevent e.g. Third-Party cookies from being stored on your device by adjusting the respective settings on your Internet browser. For more information on how to do so in the settings of your particular Internet browser, please see the following information:

• Internet Explorer: https://privacy.microsoft.com/en-us/internet-explorer-ie11-preview-privacy-statement
• Chrome: https://www.google.com/intl/en/chrome/browser/privacy/
• Firefox: https://support.mozilla.org/en-US/products/firefox/protect-your-privacy
• Safari: http://www.apple.com/privacy/manage-your-privacy/

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.

 

7. Third-Party Services

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 analyse 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.

You may refuse the use of cookies by selecting the appropriate settings on your Internet browser. However, please note that if you do this, you may not be able to use the full functionality of our Site. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB  

Lastly, you can refuse the use of Google Analytics by clicking on the following link: Disable Google Analytics.

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.html or at https://www.google.de/intl/en_uk/policies/

 

8. Do-Not-Track Disclosure

Please note that we do not knowingly use Personal Information collected on our Site through cookies or other technologies for targeted or behavioral advertising, or knowingly allow third parties to use our Site to do so. If your Internet browser gives our Site a “Do Not Track” signal, the Site may not honor it to the extent that the Site uses cookies or other tracking technologies as described in “Cookies” or “Third-Party Services” above. We do not make any promises or guarantees about the effects of any “Do Not Track” signal we receive from your Internet browser because (a) the “Do Not Track” technology is not necessarily effective for any or all Internet browsers, mechanisms or technologies, (b) third parties we cooperate with may not honor your “Do Not Track” signal; and (c) technologies, Internet browsers and access devices may change from time to time and efforts to honor your “Do Not Track” signal might or might not be effective for each technology or across all platforms.

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

 

9. Personal Information Pertaining to Children

Our Site and 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.

 

10. 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 Socket Layer (SSL) protocol.

 

11. 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 new 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.

 

12. 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:

IMC SA - Hightech Partners

Avenue Louise 500

1050 Brussels

Belgium

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

¹ If you’ve previously visited our Site, you may have seen a different document called “Code of Conduct on the Processing of Personal Data.” As of the Effective Date, this Policy supersedes and replaces that other document. If you do not want this Policy to apply to Personal Information that we previously may have collected about you, please email this address This email address is being protected from spambots. You need JavaScript enabled to view it.  and we will make commercially reasonable efforts to delete or otherwise remove your Personal Information from our system(s). In your email, please provide us with your name and other identifying information and the type(s) of Personal Information that you would like us to remove.