Política de privacidad

(Effective October 13, 2022)

CONTENTS


  1. GENERAL DATA PROCESSING PRACTICES
    1. Website Visitors
    2. Potential Candidates
    3. Candidates
    4. Participants in surveys and studies
    5. References of Candidates
    6. Service Providers, Business Partners and their Employees
    7. Business Contacts and Communication Partners
  2. INFORMATION FOR EUROPEAN UNION RESIDENTS
    1. Data Protection Officer
    2. Legal Basis according to GDPR
    3. Cross-Border Transfers of Data From the EU
    4. Change of processing purposes
    5. Automated decision making
    6. Your Rights according to GDPR
  3. INFORMATION FOR CALIFORNIA RESIDENTS
    1. Collection and Disclosure of Personal Information in Preceding 12 Months
    2. Disclosure or Sale of Personal Information in Preceding 12 Months
    3. Your Rights – California Residents
    4. Instructions for Exercising Your Rights
  4. INFORMATION FOR NEVADA RESIDENTS
    1. Your Rights – Nevada Residents
    2. Sale of Nevada Personal Information
  5. INFORMATION FOR CANADA RESIDENTS
    1. Consent
    2. Your Rights – Canada Residents
    3. Cross-border transfer
    4. Contact us
  6. INFORMATION FOR TURKEY RESIDENTS
    1. Legal basis according to TDPL
    2. Your Rights – Turkey Residents
    3. Cross-border transfer
    4. Contact us
  7. INFORMATION FOR PERSONS LOCATED IN JAPAN
    1. Your Rights – Japan Residents
    2. Instructions for Exercising Your Rights
    3. Joint Use
    4. Cross-border transfer
    5. Contact us

A. GENERAL DATA PROCESSING PRACTICES

Protecting your privacy is important to Boyden World Corporation, 3 Manhattanville Road, Suite ‎‎104, Purchase, NY 10577, United States of America, privacy@boyden.com, +1 914 747-0093 ‎‎("Boyden," "we," "us," or "our"). This Privacy Policy explains how Boyden collects, uses, and ‎discloses (“processes”) personal data on its own behalf and in conjunction with individual local ‎Boyden offices, and any additional rights you may have under applicable privacy law.‎ We and/or the local Boyden offices determine the purposes and means of the processing of personal data.

You can exercise your privacy and data protection rights by contacting privacy@boyden.com or your local Boyden office. Additional individual privacy and data protection rights are described in Parts B-F below, depending on the applicable law. Please note that we cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Thus, we may require that you submit additional personal data so that we can verify your identity. We will use such additional personal data submitted in connection with our verification process only to verify your identity and authority to make the request.

This Part A provides a general description of the processing of personal data by Boyden and local Boyden offices. The following Parts B-F of this Privacy Policy address specific local privacy regulations and amend this general description for the respective region.

Please find below the most important information about our typical data processing sorted by groups ‎of data subjects and types of data processing. For data processing activities that relate only to specific groups, and ‎processing activities controlled only by local Boyden offices, the obligations to provide ‎information are met separately.‎

The terms “data”, “personal data” and “personal information” are used interchangeably in this policy, and in each case include any information relating to an identified or identifiable natural person.

We process personal information from or about the following categories of individuals, as more fully described in the sections below:

1.

‎Website Visitors

‎1.1.

Web server log data
Each time a visitor to our website uses their browser to request access to a page on our website, our web server processes a range of data which the visitor’s browser ‎automatically transmits to our web server.

1.1.1.

In the past 12 months we have processed, and may continue to process, personal data from website visitors such as the IP address allocated to their ‎device, the date and time of the request, the time zone, the specific page or file accessed, ‎the HTTP status code and the data quantities transmitted; in addition, the website from ‎which their request originated, the browser used, the operating system of their device ‎and the language used.

1.1.2.

We obtain these categories of data directly and indirectly from activity on our website. For ‎example, from submissions through our website portal or website usage details collected ‎automatically.

1.1.3.

The purpose of the data processing of web server log data is the online presentation of Boyden and Boyden service.

1.1.4.

Web server log data is anonymized before storage. Web server log data will be deleted when it is no longer necessary for the purposes of processing.

1.1.5.

Web server log data are not passed on to third parties except under special ‎circumstances. In the event of the suspicion of a crime or in investigative proceedings, ‎data may be transmitted to the police and the public prosecutor’s office. We may also enter into service agreements with other businesses to perform services on our behalf, in particular to provide, ‎maintain, and support IT systems.‎

1.1.6.

Use of the website without disclosure of web server log data is not ‎possible.

‎1.2‎.

Cookies

 

We use cookies on our website. Cookies are small text files containing information that can be stored on the user's end device via the browser when visiting a website. The information stored in cookies can be read and processed when the website is visited again using the same device. In doing so, we use processing and storage functions of the browser of your device and collect information from the storage of the browser of your device.

In the structure of our Privacy Policy, we differentiate between Technically Required Cookies and Statistic Cookies. For the function of the website, Technically Required Cookies cannot be deactivated via the cookie management function of this website. However, you can deactivate cookies generally in your browser at any time. Different browsers offer different ways to configure the cookie settings in the browser. We would like to point out, however, that some functions of the website may not function or may no longer function properly if you deactivate cookies in your browser in general.

1.2.1.

Technically Required Cookies

1.2.1.1

Consent Cookies

 

We use so-called Consent Cookies to store your consent, possible revocation of consent and opt-out of the use of cookies on our website.

1.2.1.1.1

In the past 12 months we have processed, and may continue to process, personal data from website visitors such as HTTP data (HTTP data is protocol data that is technically generated when the website is visited via the Hypertext Transfer Protocol (Secure) (HTTP(S)): This includes IP address, type and version of your Internet browser, operating system used, the page visited, the page previously visited) refferer URL, date and time of the visit and User decision on cookies (User's decision on individual cookies or groups of cookies. Time of the decision and of the last visit)

1.2.1.1.2

We obtain these categories of data directly from the user (decision on cookies) and indirectly transmitted by the user's browser (protocol data, time stamp).

1.2.1.1.3

The purpose of data processing is the storage of the user decisions on cookies (consent, revocation, opt-out).

1.2.1.1.4

A negative user decision with regard to cookies is deleted at the end of the session. The other data will be deleted after one year.

1.2.1.1.5

We may also enter into service agreements with other businesses to perform services on our behalf, in particular to provide, ‎maintain, and support IT systems.‎

1.2.1.1.6

Without disclosure of personal data, the use of the website is not possible. Communication via the website without the disclosure of data is technically not possible.

1.2.1.2

Cf_bm Cookie

 

We use the Cf_bm Cookie identify and mitigate automated traffic to protect our website from bad bots.

1.2.1.2.1

In the past 12 months we have processed, and may continue to process, personal data related to the calculation of a bot score and a session identifier. The information in the cookie (other than time-related information) is encrypted. A separate cookie is generated for each site that an end user visits, as we do not track users from site to site or from session to session. The cookie is generated independently by our service provider Cloudflare, and does not correspond to any user ID or other identifiers in our web application.

1.2.1.2.2

We obtain these categories of data indirectly transmitted by the user's browser and how the user is using our website.

1.2.1.2.3

The purpose of data processing is to identify and mitigate automated traffic on our website to protect our website from bots.

1.2.1.2.4

The cookie expires after 30 minutes of continuous inactivity by the end user.

1.2.1.2.5

The recipient of the data is Cloudflare Inc., 101 Townsend Street San Francisco, CA 94107 USA.

1.2.1.2.6

Without disclosure of personal data, the use of the website is not possible. Communication via the website without the disclosure of data is technically not possible.

1.2.2

Statistic Cookies

1.2.2.1

Google Analytics

 

If you have given your consent, we use the web analysis tool Google Analytics on our website. With the help of Google Analytics, we can analyze the user behaviour of visitors to our website in pseudonymized and anonymised form.

You can deactivate the data processing by Google Analytics at any time in our "cookie board“. Alternatively, you can install a browser plug-in from Google which prevents data collection by Google Analytics:
https://tools.google.com/dlpage/gaoptout?hl=en

1.2.2.1.1

In the past 12 months, we have processed, and in the future may continue to process, personal data about website visitors such as Google Analytics HTTP data (This is protocol data that is generated for technical reasons when using the web analysis tool Google Analytics via the Hypertext Transfer Protocol (Secure) (HTTP(S)) used on the website: This includes IP address, type and version of your Internet browser, operating system used, the page visited, the page previously visited (referrer URL), date and time of the visit.), Google Analytics device data (Data generated by the web analysis tool Google Analytics and assigned to your device: This includes a unique ID for the (re-)recognition of returning visitors (so- called "client ID") as well as certain technical parameters for controlling data collection for web analysis.), Google Analytics measurement data (Device-related raw data (so-called "dimensions" and " measurement results"), which are collected and analysed by the web analysis tool Google Analytics when using our website: This includes, above all, information about the sources through which visitors reach our website, information about the location, the browser and the device used, information about the use of the website (in particular page views, frequency of visits and length of stay on accessed pages) as well as information about the fulfilment of certain purposes (in particular transactions in the online shop). The data is assigned to the client ID assigned to your device. As a result, device-related usage profiles are created in which all device-related raw data is combined into a client ID. The data that we collect using Google Analytics does not enable us to identify you personally (i.e. by your civil name). We also do not merge the device- related raw data and the resulting device-related usage profiles with data that directly identifies you personally without your consent.) and Google Analytics report data (Data contained in aggregated segment and device-related reports generated by the Google Analytics web analysis tool based on the analysis of device-related raw data.).

1.2.2.1.2

We obtain these categories of data indirectly transmitted by the user's browser and how the user is using our website

1.2.2.1.3

The purpose of data processing is to analyze user behaviour and to measure the reach of our website and advertisements to optimize our website.

1.2.2.1.4

The data will be deleted after one year.

1.2.2.1.5

The recipient of the data is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

1.2.2.1.6

The provision of data is not required by law or contract or necessary for the conclusion of a contract. There is no obligation on the data subject to provide the data. If the data is not provided, we cannot make web analysis using Google Analytics.

1.2.2.2

Hubspot Analytics Cookies

 

If you have given your consent, we use the analytics cookies of Hubspot on our website. The data collection is pseudonymised, unless you provide further personal data such as your name or email address when using the website. In this case, an allocation can take place.

You can deactivate the data processing by Hubspot at any time in our "cookie board“. Alternatively, you can disable Hubspot cookies for the browser you are currently using by deactivating the storage of cookies in your browser settings.

1.2.2.2.1

In the past 12 months, we have processed, and in the future may continue to process, personal data about website visitors such as Hubspot cookies-HTTP data (This is log data that is technically generated when Hubspot cookies are used on the website via the Hypertext Transfer Protocol (Secure) (HTTP(S)): This includes IP address, type and version of your internet browser, operating system used, the page accessed, the page previously visited (referrer URL), date and time of access.), Hubspot cookies -end device data (Data that is assigned to your end device by Hubspot Cookies: This includes a unique ID for (re)recognising returning visitors.)

1.2.2.2.2

We obtain these categories of data indirectly transmitted by the user's browser and how the user is using our website.

1.2.2.2.3

The purpose of data processing is to analyze user behaviour and to measure the reach of our website and advertisements to optimize our website.

1.2.2.2.4

The cookies that keep track of the relevant session of the user expires after 30 minutes. The cookie which tracks if the user has restarted their browser expires at the end of the session. All other data will be deleted after 6 months at the latest.

1.2.2.2.5

The recipient of the data is Hubspot Germany GmbH, Am Postbahnhof 17, 10243 Berlin.

1.2.2.2.6

The provision of data is not required by law or contract or necessary for the conclusion of a contract. There is no obligation on the data subject to provide the data. If the data is not provided, we cannot make web analysis using Hubspot.

2.

Potential Candidates

 

When we or a local Boyden office identify a potential candidate, we may collect business card data about such potential candidate from publicly accessible ‎sources, and we and the local Boyden office jointly determine the purposes and means of the processing of such ‎data and have entered into an agreement for that purpose. According to that agreement, ‎the local Boyden office is responsible to ensure the fulfilment of the potential candidate’s rights and will ‎inform them in a privacy notice about the contact details of the local office and the ‎publicly accessible sources of the data. However potential candidates may contact either us or the local Boyden office regarding any claims or complaints.‎

‎2.1‎.

In the past 12 months, we have processed, and in the future may continue to process personal data about potential candidates such as name, postal address, email address, telephone number, employment, employment history and title.‎

‎2.2‎.

We collect data about potential candidates from the following publicly accessible sources: Public business websites, ‎services such as LinkedIn, Xing or other business press or publications.‎

2.3.

Data about potential candidates are processed for the purposes of providing executive search services to ‎potential employers worldwide and identifying salary, market and hiring trends by analyzing aggregated data.‎

‎2.4‎.

Data about potential candidates will be deleted upon the potential candidate’s request or in accordance with Boyden's global data retention policy.‎

‎2.5.

Data about potential candidates is shared with Boyden offices worldwide upon request. A full list of Boyden ‎offices is provided here.‎

‎3.

Candidates

 

‎Whenever an individual authorizes Boyden to list them as a candidate for job offerings, we and the local ‎Boyden office jointly determine the purposes and means of the processing of such candidate’s data and have entered into ‎an agreement for that purpose. According to the agreement, the local Boyden ‎offices are responsible to ensure the fulfilment of the candidate’s rights. However all candidates ‎may contact either us or the local Boyden office regarding any claims or complaints.‎

‎3.1.

In the past 12 months, we have processed, and in the future may continue to process personal data about candidates, such as name, signature, postal address, email address, telephone number, education, employment, employment history, bank account number, race, color, age (40 years and older), ancestry, national origin, citizenship, religion or creed, medical condition, physical or mental disability, sex (including gender), sexual orientation, current and/or past employment history including performance evaluations, education records, files, documents, and other materials directly related to a student maintained by an educational agency or institution or by a person acting for such an agency or institution, such as grades, transcripts, personal interests, hobbies and background check information (like identity verification, criminal, civil and regulatory judgements, financial and credit ‎checks), health insurance information, information used to create a profile about a candidate reflecting the candidate’s intelligence and abilities or any other details a candidate may choose to share with us.‎

‎3.2.

Data about candidates may be collected from the candidate, from publicly accessible sources like websites (e.g. ‎Company or private websites, LinkedIn) and third parties that the candidate or their testimonials ‎have named as potential references.

‎3.3.

Data about candidates are processed for the purpose of providing the candidates with employment ‎opportunities and job or career related information as well as providing executive search ‎services to potential employers worldwide and identifying salary, market and hiring trends by analyzing aggregated data.

‎3.4.

The data retention period is seven calendar years from the last completion of the client ‎engagement or documented contact with the candidate, whichever is later.‎

3.5.

Data about candidates are shared with Boyden offices worldwide and with potential ‎employers to fulfill clients' or candidates' requests. A full list of Boyden offices is provided here.

‎3.6.

Candidates are not obliged to provide personal data. Without such personal data, however, we will not be ‎able to provide candidates with employment opportunities.‎

4.

Participants in surveys and studies

 

In the case where individuals have given their consent to participate in surveys or studies (“Participants”), Boyden and the local Boyden offices are processing their personal data for surveys and studies. We and the local ‎Boyden office jointly determine the purposes and means of the processing of Participant data and have entered into ‎an agreement for that purpose. According to the agreement, the local Boyden ‎offices are responsible to ensure the fulfilment of Participant rights. However all Participants ‎may contact either us or the local Boyden office regarding any claims or complaints.‎

4.1.

In the past 12 months, we have processed, and in the future may continue to process personal data about Participants, such as profile data requested by survey-service providers like Prophet (ID, name, language, due date of the questionnaire, reminder date of the questionnaire, email address, dates invitation sent, dates notifications of reminders sent, date profile sent, profile details) and survey reports (answers to the questionnaires). Some statistical studies are completely anonymous.

4.2.

The personal data about Participants is provided by the Participant or assigned by the survey-service provider.

4.3.

Participant personal data are processed for the purpose of conducting and evaluating surveys using questionnaires for business development reasons.

4.4.

The data retention period is seven calendar years from the last participation of the surveys or studies.

4.5.

We use service providers like Prophet Profiling Ltd. as data processors which are creating individual profiles for the participants and are conducting and evaluating the questionnaires on our behalf.

4.6.

Participation in surveys and studies is voluntary. Anyone who does not wish to participate in a survey or study can contact Boyden to discuss alternatives.

‎5.

References of Candidates

 

‎When we or a local Boyden office receive personal data from a candidate or other source about the candidate’s reference, we ‎and the local Boyden office jointly determine the purposes and means of the processing of the data about the candidate’s reference and have ‎entered into an agreement for that purpose. According to the agreement, the local ‎Boyden office is responsible to ensure the fulfilment of the rights of the candidate’s reference and will inform the personal reference ‎in a privacy notice about our contact details and source of their data. However all references of candidates may contact either us or the local Boyden office regarding any claims or complaints.‎

‎5.1.

In the past 12 months, we have processed, and in the future may continue to process personal data about references of candidates, such as name, postal address, email address, telephone number, employment, employment history, position, or any other details that the candidate or the candidate’s reference chooses ‎to share with us.

5.2.

Sources of data about a candidate’s reference are the candidate, another reference, or publicly ‎accessible sources like public business websites, services such as LinkedIn, Xing or other ‎business press or publications.

‎5.3.

Data about a candidate’s reference are processed for the purpose of providing executive search services to ‎employers and candidates.

5.4.

The data retention period is seven calendar years from the last completion of the client ‎engagement or documented contact with the candidate who named the data subject as a reference, ‎whichever is later.‎

‎5.5.

We may also enter into service agreements with other businesses to perform services on our behalf, in particular to ‎provide, maintain and support IT systems.‎

‎‎‎6.

Service Providers, Business Partners and their Employees

 

Boyden and the local Boyden office may process personal data regarding service providers, business partners and their employees.

6.1.

In the past 12 months, we have processed, and in the future may continue to process personal data about service providers, business partners and their employees, such as name, title, postal address, email address, telephone number, employment, employment history and any other details that they later choose ‎to share.‎

6.2.

Data about service providers, business partners and their employees may be collected from the applicable service provider, business partner, or their employees, or from publicly accessible sources like websites (e.g. ‎Company or private websites, LinkedIn).

6.3.

We process data about service providers, business partners and their employees for the purpose of preparation and performance of the contractual ‎relationship and for the fulfilment of legal requirements.

6.4.

All contractual data, content of communications and data relevant for accounting are stored in ‎accordance with the Boyden Global Retention Policy.

‎6.5.

Recipients of data about service providers, business partners and their employees may include banks for the processing of payments. Public authorities ‎and offices may receive data within the scope of their duties, insofar as we are obligated ‎or entitled to transmit data. Moreover in specific cases data may be transmitted to ‎a collection of service providers, legal advisors and courts. We may also enter into service agreements with other businesses to perform services on our behalf, in particular to provide, maintain and support ‎IT systems.‎

‎6.6.

Processing of the contact data from service providers and business partners and their Employees is necessary ‎in order to perform the contract or order. If the data are not provided, the contract ‎cannot be established or carried out. The provision of data is required for prospective ‎service providers, business partners and their employees. The communication is not ‎possible without the data.‎

‎7.

Business Contacts and Communication Partners

 

Boyden and the local Boyden office may process personal data regarding Business Contacts and Communication Partners.

7.1‎.

In the past 12 months, we have processed, and in the future may continue to process personal data about our business contacts and communication partners, such as name, postal address, email address, telephone number, employment, title or any other details that they later choose ‎to share with us.‎

7.2.

We obtain these categories of personal information from our business contacts and communication partners, from our clients or their agents, and from ‎third-parties that interact with us in connection with the services we perform.

7.3.

We process the data from prospective business contacts and communication partners for ‎the purpose of communication with them.‎

7.4‎.

Inquiries and communication data are automatically deleted after 10 years.‎

‎7.5.

We may also enter into service agreements with other businesses to perform services on our behalf, in particular ‎to provide, maintain and support IT systems.‎

‎‎7.6.

The provision of data is required for prospective business partners and communication ‎partners. The communication is not possible without the data.‎

B. INFORMATION FOR EUROPEAN UNION RESIDENTS

Provided the EU General Data Protection Regulation (GDPR) applies to our processing of your data according to Article 3 GDPR, in particular if your data is processed by a Boyden office in the European Union or if you are in the ‎European Union, the following conditions apply to you:

1.

Data Protection Officer

 

The Data Protection Officer and data protection representative of Boyden and Boyden’s local offices according to Article ‎‎27 GDPR (EU General Data Protection Regulation) is Rechtsanwalt Nikolaus Bertermann ‎‎(attorney at law), daspro GmbH, Kurfürstendamm 21, 10719 Berlin, Germany, phone +49 30 88 ‎‎77 41 50, Email: boyden@daspro.de.‎

2.

Legal basis according to GDPR

2.1.

The legal basis for the processing of your data under GDPR is as follows:

  • Web Server log data -- ‎The legal basis for the processing of Web server log data obtained while using the website is our legitimate interest, ‎specifically operation of a website and user interaction.
  • Technically Required Cookies -- The legal basis for the processing of data using Technically Required Cookies is our legitimate interest according to GDPR, specifically the interest in the easy and reliable control of cookies settings in accordance with the respective user decisions, the interest in protecting the website from bot attacks. The Technically Required Cookies are also considered necessary according to local privacy regulations like Article 5 (3) E-Privacy-Directive 2002/58/EC.
  • Statistic Cookies -- ‎The legal ‎basis for the analysis of user ‎behavior using Statistic Cookies is your consent.
  • Potential Candidate data -- The legal basis for the processing of potential candidate data is our legitimate interest to provide our ‎‎services.‎
  • Candidate data -- The legal basis for our processing of candidate data is your consent ‎and – as far as only your ‎business card details or data collected from publicly available ‎sources are processed – for our ‎legitimate interest to provide such services.‎
  • Data regarding participants in surveys and studies -- The legal basis for our processing of data regarding participants in surveys and studies is your consent.
  • Data regarding references of Candidates -- The legal basis for processing data regarding references of candidates is legitimate interest of the ‎candidate to name a reference ‎and legitimate interest of Boyden to evaluate the ‎candidate.‎
  • Data regarding Service Providers, Business Partners and their Employees -- ‎The legal bases for processing are in case of contracts with natural persons the contracts, ‎in case of contracts with legal entities the legitimate interest, specifically communication with ‎contact persons relevant to the ‎contract, as well as always the legal obligations, in particular ‎‎commercial and tax provisions. When checking, asserting or rejecting claims, the legal ‎basis is ‎legitimate interest, specifically asserting or defending ‎claims.‎
  • Data regarding Business Contacts and Communication Partners -- ‎The legal basis for processing data from actual and prospective business contacts and ‎‎communication partners is legitimate interest, specifically ‎communication with prospective ‎business contacts and communication partners.‎

2.2.

The foregoing legal bases for the processing of your data are defined in GDPR as follows: “consent” is specified in Article 6(1)(a) GDPR, “contract” is specified in Article 6(1)(b) ‎GDPR, “legal obligations” is specified in Article 6(1)(c) GDPR and “legitimate interest” is specified in Article 6(1)(f) GDPR.

3.

Cross-Border Transfers of Data from the EU

3.1

Cross-Border Transfers between Boyden offices

 

Data may be shared with some Boyden offices located outside of the EU. All Boyden offices have entered into ‎‎EU Standard Contractual Clauses (SCC) and set up internal privacy and data collection ‎policies. Boyden and local Boyden offices have updated their contracts and have implemented additional safeguards after the Schrems II decision of the ECJ (SCC plus) to protect the data. You may request a copy of the SCC from us or a Boyden office at any time.‎ Potential employers may be located outside of the EU and may ‎not have adopted appropriate or suitable safeguards.

3.2

Cross-Border Transfers for the data of our Website Visitors

 

Data of or Website Visitors may be shared with our service providers which we use as processor within the framework of a data processing agreement. We use Cloudflare Inc. as one of our service providers. We have entered into the EU Standard Contractual Clauses (2021/914; Module 2) with Cloudflare to protect your data. We also use Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Google Ireland Limited uses Google LLC in the USA (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) as its service provider. Google has also entered into the EU Standard Contractual Clauses (2021/914; Module 2) to protect your data. You can request a copy of the essential contractual contents of the standard contractual clauses at any time. In addition, we have obtained your consent for the cross border transfer to Google and Hubspot (Article 49 (1) (a) GDPR) via the cookie consent banner as a precautionary measure. You can revoke your consent at any time with effect for the future via the button in the cookie banner.

4.

Change of processing purposes

 

No change in the processing purposes described in Section A is ‎planned.

5.

Automated decision making

 

No automated decision-making (Article 22 GDPR) takes place.

6.

Your rights according to GDPR

 

You have the following rights under GDPR:

  • You may withdraw your consent at any time, if your data is processed based on your ‎consent. The withdrawal of consent does not affect the lawfulness of processing before ‎the withdrawal of consent.‎
  • ‎You may at any time object to the further processing of your data if your data is ‎processed based on our legitimate interest.‎
  • ‎You may at any time request access to your personal data processed by Boyden or any Boyden office.‎‎
  • ‎If our processing is based on your consent you have the right to data portability.‎
  • ‎You may request rectification of your personal data at any time.‎
  • ‎You may request erasure of your personal data at any time, provided that no right or legal ‎obligation of Boyden or any Boyden office requires further processing of your personal data.‎
  • ‎You may request restriction of processing for your data at any time.‎
  • ‎You may at any time lodge a complaint with a supervisory authority.‎

C. INFORMATION FOR CALIFORNIA RESIDENTS

Provided that you are a resident of California and the California Consumer Privacy Act (CCPA) applies to our processing of your personal information, the following conditions apply to you:

1.

Collection of Personal Information in Preceding 12 Months

1.1.

During the past twelve months, we have collected personal information that falls under the below listed California-designated categories of personal ‎information. For each category listed below, you can find the sources of the data, the purposes for which it is collected, and the third parties with whom it is shared in Part A of this Privacy Policy.

  • Category A: Identifiers such as real name, alias, postal address internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
    Data of Category A is processed of Website visitors, Potential Candidates, Candidates, Participants in surveys and studies, References of candidates, Service Providers, Business Partners and their Employees, Business Contacts and Communication Partners.
  • Category B: ‎ Personal ‎information ‎categories listed in ‎the California ‎Customer Records ‎statute, such as name, signature, social security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, or health insurance information.
    Data of Category B is processed of Potential Candidates, Candidates, Participants in surveys and studies, References of candidates, Service Providers, Business Partners and their Employees, Business Contacts and Communication Partners.
  • Category C: Characteristics of ‎protected ‎classifications ‎under California or ‎federal law, including age (40 years and older), ancestry, national origin, citizenship, religion or creed, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.
    Data of Category C is processed of Candidates and Participants in surveys and studies.
  • Category F: ‎ Internet or other ‎electronic network ‎activity ‎information, such as information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
    Data of Category F is processed of Website visitors.
  • Category I: Professional or ‎employment-‎related ‎information, including current and/or past employment ‎history including performance ‎evaluations.‎
    Data of Category I is processed of Candidates, Potential Candidates, Participants in surveys and studies and References of candidates.
  • Category J: Non-public ‎education ‎information, including Education records, files, documents, and other materials directly related to a student maintained by an educational agency or institution or by a person acting for such an agency or institution, such as grades, and transcripts.
    Data of Category J is processed of Candidates and Participants in surveys and studies.
  • Category K: Inferences drawn from other personal ‎information, such as information used to create a ‎profile about a consumer ‎reflecting the consumer’s ‎preferences, characteristics, ‎psychological trends, ‎predispositions, behavior, ‎attitudes, intelligence, abilities, ‎and aptitudes.
    Data of Category K is processed of Candidates and Participants in surveys and studies.

2.

Disclosure or Sale of Personal Information in Past 12 Months

2.1.

In the preceding 12 months, we have disclosed or sold to third parties the categories of personal information specified in Part A above.

2.2.

We do not sell the personal information of minors under 16 years of age without affirmative authorization.

3.

Your Rights – California Residents

3.1.

Rights to Know. You have the right to request that we disclose to you what personal information we collect, use, disclose, and sell about you. Specifically you have the right to request that we disclose:

  • the categories of personal information we have collected about you;‎
  • the categories of sources from which we collect personal information about you;‎
  • the business or commercial purposes for collecting or selling your personal information; ‎
  • the categories of third parties with whom we share your personal information; and
  • the specific pieces of personal information we have collected about you.‎

3.2.

Right to Request Deletion. You have the right the right to request the deletion of your personal information that we have collected or maintained, subject to certain exceptions;

3.3.

Right to Opt-Out of Sale of your Personal Information. You have the right the right to opt-out of the sale of your personal information by us, subject to certain exceptions;

3.4.

Right to Non-Discrimination. You have the right the right not to receive discriminatory treatment by us for the exercise of any of the foregoing privacy rights.

4.

Instructions for Exercising Your Rights

4.1.

Authority to Make a Request: Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

4.2.

How to Submit a Request to Know or Delete: To submit a request under any of your Rights to Know or the Right to Request Deletion, you can visit our website request page, or call us at +1 (855) 426-9336. ‎You will also need to satisfy the verification process requirements described below. You may make up to two requests in any 12-month period.

Please note that we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority ‎to make the request and confirm the personal information relates to you, in accordance with the verification process described below. ‎

4.3.

How to Submit a Request to Opt-Out of Sale: To submit a request to Opt-Out of the Sale of your Personal Information, you can visit our website opt-out request page or call us at +1 (855) 426-9336.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by going to our website.

4.4.

Process for Verifying Requests to Know or Delete: As part of our verification process, we may require that you submit additional personal ‎information so that we can verify your identity. If we do so, we will use any additional personal ‎information submitted in connection with our verification process only to verify your identity ‎and authority to make the request.‎

Making a consumer request does not require you to create an account with us.

We will only use personal information provided in a consumer request to verify the requestor's identity or authority to make the request.

D. INFORMATION FOR NEVADA RESIDENTS

Provided that you are a resident of Nevada and the Nevada Consumer Privacy Law applies to our processing of your data, the following conditions apply to you:

1.

Your Rights – Nevada Residents

 

Nevada residents have the right to request that we not make any sale (as that term is defined the in the Nevada Consumer Privacy Law) of certain categories of personal data that we have collected or will collect about you.

2.

Sale of Nevada Personal Information

 

We do not sell the personal information of any Nevada residents, as that term is defined in the Nevada Consumer Privacy Law.

E. INFORMATION FOR CANADA RESIDENTS

Provided you are a resident of Canada, the following conditions apply to you:

1.

Consent

 

By using our services, submitting information to us in connection with our services, by interacting with us, and by visiting, interacting with or using our website, you are providing your consent to the processing of personal data as set out in this Privacy Policy. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent, we may not be able to provide you with the requested services, and it may impact the functionality of our website.

2.

Your Rights – Canada Residents

 

You have the right to access and rectify the personal data we hold about you. You can request access or rectification by contacting us at as described under “Contact us” below.

3.

Cross-border transfer

 

Data about potential candidates is shared with Boyden offices worldwide upon request and personal data we handle may be stored or processed on our behalf by other Boyden offices. A full list of Boyden ‎offices is provided here. Some of our service providers may also access, process or store your personal data outside of the country where we are located and where you reside. Such data may therefore may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions.

4.

Contact us

 

If you have questions about this Privacy Policy and our data-handling practices, you may contact our Data Protection Team at privacy@boyden.com.

F. INFORMATION FOR TURKEY RESIDENTS

Provided you are a resident of Turkey and the Turkey data protection legislation (TDPL) applies to our processing of your personal information, the following conditions apply to you:

1.

Legal basis according to TDPL

 

The legal basis for the processing of your data under TDPL is as follows:

  • Potential Candidate data -- The legal basis for the processing of potential candidate data is that the data was made publicly available data by data subjects from the online channels
  • Candidate data -- The legal basis for our processing of candidate data is your consent ‎and – as far as only your ‎business card details or data collected from publicly available ‎sources are processed – that the data was made publicly available data by data subjects from the online channels; Processing of personal data of the Candidates is necessary, if it is directly related to the establishment or performance of the contract with Business Partners and it is needed to perform legal obligations as an employment agency.
  • Data regarding participants in surveys and studies -- The legal basis for our processing of data regarding participants in surveys and studies is your consent.
  • Data regarding references of Candidates -- The legal basis for processing data regarding references of candidates is their consent
  • Data regarding Service Providers, Business Partners and their Employees -- ‎The legal bases for processing are directly related to the establishment or performance of the contract with Business Partners.
  • Data regarding Business Contacts and Communication Partners -- ‎The legal basis for processing data from actual and prospective business contacts and ‎‎communication partners is directly related to the establishment or performance of the contract with Business Partners.

The foregoing legal bases for the processing of your data are defined in TDPL as follows: “consent” is specified in Article 5(1) TDPL; processing of personal data belonging to the parties of a contract, is necessary provided that it is directly related to the conclusion or fulfilment of that contract according to Article 5 (2) lit. c) TDPL; processing is mandatory for the controller to be able to perform his legal obligations according to Article 5 (2) lit. ç) TDPL (Legal obligations of employment agencies: Art. 17 and 19 of Law No. 4904) ;  data concerned is made available to the public by the data subject according to Article 5 (2) lit. d) TDPL;

2.

Your Rights – Turkey Residents

 

You have the following rights according to Article 11 TDPL:
You have the right to get information about whether your personal data has been processed; if personal data has been processed, the information about such data processing; information about the purpose for the data processing and whether the data was used for this purpose; information about the identities of natural or legal persons to whom the data is transferred to; correction, erasure, or removal of data; to object to the processing, exclusively by automatic means, of the personal data, which leads to an unfavourable consequence for you and to request compensation for the damage arising from the unlawful processing of personal data.
You can exercise your rights by contacting us at as described under “Contact us” below.

3.

Cross-border transfer

 

Data about Candidates and Potential Candidates are shared with our Business Partners and Prospective Employers for purpose of making an employment agreement according to Articles 9 and 5 TDPL and the legal obligations according to Art. 17 and 19 of Law No. 4904 . Boyden also shares the personal data of the data subjects to global database of Boyden, Filefinder, with the consent of the data subjects, for the storage purposes according to Article 9 TDPL.

4.

Contact us

 

If you have questions about this Privacy Policy and our data-handling practices, you may contact our Data Protection Team at privacy@boyden.com.

G. INFORMATION FOR PERSONS LOCATED IN JAPAN

Provided you are a person located in Japan, the following conditions apply to you:

1.

Your Rights – Japan Residents

 

In accordance with the Act on the Protection of Personal Information of Japan, you have the right to request us to notify you of the purposes of use of the personal data, or to disclose, make any correction to, discontinue the use or provision of, and/or delete any and all of, your retained personal data which is stored by us.

2.

Instructions for Exercising Your Rights

 

To exercise your rights, you can send an email to privacy@boyden.com. A response will be sent within one (1) month from our receipt of your request. If necessary, this period may be extended by us by up to two months, depending on the complexity and number of requests.

In the case of a request for deletion of your data and/or removal of your data, we may nevertheless retain such data in a temporary archived form for the period necessary to satisfy our legal, accounting and tax obligations.

3.

Joint Use

 

We would jointly use your personal data in the cases we have described in the General Part of this Privacy Policy (Part A). Here you will also find details on the items of personal data to be jointly used, parties to jointly use personal data, purposes of joint use and party responsible for management of jointly used personal data. Since we have thus fulfilled the joint-use requirements prescribed by Japanese law, we do not need to obtain separate consent.

3.1.

Items of Personal Data to be Jointly Used

3.1.a.

Potential Candidates: name, postal address, email address, telephone number, employment, employment history and title.

3.1.b.

Candidates: name, signature, postal address, email address, telephone number, education, employment, employment history, bank account number, race, color, age (40 years and older), ancestry, national origin, citizenship, religion or creed, medical condition, physical or mental disability, sex (including gender), sexual orientation, current and/or past employment history including performance evaluations, education records, files, documents, and other materials directly related to a student maintained by an educational agency or institution or by a person acting for such an agency or institution, such as grades, transcripts, personal interests, hobbies and background check information (like identity verification, criminal, civil and regulatory judgements, financial and credit ‎checks), health insurance information, information used to create a profile about a candidate reflecting the candidate’s intelligence and abilities or any other details a candidate may choose to share with us‎

3.1.c.

Participants in surveys and studies: profile data requested by survey-service providers like Prophet (ID, name, language, due date of the questionnaire, reminder date of the questionnaire, email address, dates invitation sent, dates notifications of reminders sent, date profile sent, profile details) and survey reports (answers to the questionnaires)

3.1.d.

References of Candidates: name, postal address, email address, telephone number, employment, employment history, position, or any other details that the candidate or the candidate’s reference chooses ‎to share with us

3.2.

Party to Jointly Use Personal Data

 

BWC and local Boyden Office(s)

3.3.

Purposes of Joint Use

3.3.a.

Potential Candidates: purposes of providing executive search services to ‎potential employers worldwide and identifying salary, market and hiring trends by analyzing aggregated data

3.3.b.

Candidates: purpose of providing the candidates with employment ‎opportunities and job or career related information as well as providing executive search ‎services to potential employers worldwide and identifying salary, market and hiring trends by analyzing aggregated data.

3.3.c.

Participants in surveys and studies: purpose of conducting and evaluating surveys using questionnaires for business development reasons

3.3.d.

References of Candidates: purpose of providing executive search services to ‎employers and candidates

3.4.

Party Responsible for Management of Personal Data

 

local Boyden Office

4.

Cross-border transfer

 

Personal data on potential candidates is shared with Boyden offices worldwide upon request and personal data we handle may be stored or processed on our behalf by other Boyden offices. A full list of Boyden ‎offices is provided here. In addition, personal data on candidates and potential candidates are shared with our business partners and prospective employers for the purpose of making employment agreements. The local Boyden office in Japan has entered into a data transfer agreement with the other Boyden offices located outside Japan (except for Boyden offices established in EU member states or the UK) which ensures that in case the personal data of potential candidates located in Japan is transferred and handled by Boyden offices located outside Japan (except for those located in EU member states or in the UK), such personal data is subject to levels of protection comparable to/meeting the standards applicable under the APPI.

5.

Contact us

 

If you have any questions or complaints about this Privacy Policy or our data handling practices, you may contact us at privacy@boyden.com.

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