Effective Date: July 6, 2018
We are committed to protecting your personal data and to respecting your privacy. Our privacy practices reflect applicable legal requirements, including the General Data Protection Regulation, or GDPR, (“Applicable Data Protection Laws”). Depending on the service provided, we may provide additional or different privacy statements or notices for specific interactions you have with us or to highlight how we use your personal information for specific services.
1. Who We Are
1.1 RHR International Consultants Ltd. is a data “Controller” as defined under Article(4)(7) of the EU General Data Protection Regulation.
2. Personal Data We Collect About You
2.1 “Personal data” is information that relates to an identified or identifiable natural person (a human being). This website is not intended for children, and we do not knowingly collect personal data relating to children. Anonymous data, i.e., data from which you cannot determine a natural person to whom it relates, is not personal data.
2.2 We may collect from you and/or track the following information in connection with your use of the Site:
- Technical Data — Your internet protocol address, home server domain name, type of client computer, type of web browser, and Site pages that you visit, each for purposes of system administration and auditing the Site’s activity;
- Contact Data — The email address(es) that you use to communicate with us via email or otherwise provide to us;
- Identity Data — First name, last name, date of birth, and gender; and
- Other Data — any other information you provide to us through the Site.
2.3 We may collect anonymised details about your use of the Site for the purposes of aggregate statistics or reporting. Aggregated data (your data combined with other people’s data) may come from your personal data, but if it does not directly or indirectly reveal your identity, it is not considered personal data. For example, we may combine and analyse your use of the Site to measure the number of users accessing a specific Site feature.
3. If You Do Not Provide Personal Data
3.1 If we are obligated to collect your personal data by applicable law or under the terms of a binding contract, and you do not provide that data when requested, we may not be able to perform our obligations under the contract and may decline to provide you with goods or services. In such case, we will notify you at the time.
4. How Do We Collect Your Personal Data?
4.1 We use different methods to collect personal data from and about you, including when you fill out a form or give us information online or by email. Other instances where we may collect information are when you:
- Visit our Site or social media (e.g., through cookies);
- Enter a competition or promotion;
- Sign up for our mailing list/newsletter;
- Enquire about or order products through this Site or via phone, fax, email, post, or in person;
- Create an account on our website;
- Provide feedback;
- Provide job application information;
- Fill in a form on our Website; and/or
- Otherwise contact us.
4.2 Personal data may also be collected by third-party service providers who assist us in operating the Site, including:
(a) Google Analytics:
- We use Google Analytics to help analyse how you use our Site. Google Analytics generates statistical and other information about website use by means of cookies. Google will store this information.
- If you do not want your website visit information reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.
(b) Clickstream Information
- In common with many websites, when you read, browse, or download information from our Site, we or our internet service provider may also collect information, such as the date and time of your visit to the Site, the pages accessed, and any information downloaded. This information is used for statistical reporting and website administration, maintenance, and improvement purposes only.
5.3 Cookies may also be used to record nonpersonal information, such as the date, time, or duration of your visit, or the pages accessed for website administration, statistical, and maintenance purposes and to enhance the content and services offered on our Site. Any such information will be aggregated and not linked to particular individuals.
5.4 Cookies may also be used for other purposes on our Site, but in such cases none of the information collected can be used to identify you. The default settings of browsers like Internet Explorer generally allow cookies, but users can easily erase cookies from their hard drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of the Site may not function fully for users that disallow cookies.
6. Using Your Personal Data
6.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- In connection with the performance of a binding contract;
- Where it is necessary for our legitimate interests (or those of a third party) and where your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation.
6.2 We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
6.3 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To manage our relationship with you, which will include:
(b) Asking you to leave a review or take a survey
(c) Providing services
(a) Performance of an applicable contract
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)
To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, and reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business, and to inform our marketing strategy)
To use data analytics to improve our Site, products and services, marketing, and customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business, and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(b) Contact(c) Technical
Necessary for our legitimate interests (to develop our products and services and grow our business)
To evaluate you for a job opportunity.
Necessary for our legitimate interests (to evaluate potential job applicants)
6.4 Change of purpose: We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.
6.5 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7.1 Promotional offers from us: We may use your personal data to try to understand what you may want or need or what may be of interest to you. You may receive marketing communications from us where this is permitted under Applicable Data Protection Law, including where you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
7.2 Third-party marketing: Where required by Applicable Data Protection Law, we will get your opt-in consent before we share your personal data with any other company for marketing purposes.
7.3 Opting out: You can ask us to stop sending you marketing messages at any time by contacting us at email@example.com at any time. Opting out of receiving these marketing messages will not delete any personal data provided to us.
8. Disclosures of Your Personal Data
8.1 We do not disclose your personal data without your permission unless the disclosure is:
- To our related companies;
- To third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; or
- Required or authorised by law.
8.2 We may disclose or provide access to your personal data to third parties in connection with the purposes described in the table above.
8.3 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9. International Transfers
9.1 We share your personal data with RHR International LLP, the parent company of RHR International Consultants Ltd. This will involve transferring your data outside the European Economic Area (“EEA”).
9.2 Whenever your personal data is transferred out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe. For further details, see the European Commission's website.
- Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield, which requires them to provide a similar level of protection to personal data shared between Europe and the U.S.
9.3 Please contact us at firstname.lastname@example.org if you want further information about the specific mechanisms we use when transferring your personal data outside of the EEA.
10. Data Security
10.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
10.2 While we take great care to protect your personal data, unfortunately no information transmission over the internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us.
10.3 We have put in place procedures to deal with any personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. Data Retention
11.1 We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
11.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we process your personal data; whether we can achieve those purposes through other means; and the applicable legal requirements.
12. Your Legal Rights
12.1 You have the right to make a complaint at any time to your national data protection authority or other public authority governing the protection of your personal data in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by us infringes Applicable Data Protection Law. However, we would appreciate the chance to address your concerns first, so we would be grateful if you would contact us at email@example.com before you take such action.
12.2 Under certain circumstances, you may have rights under Applicable Data Protection Laws in relation to your personal data. You may have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data that override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the data to perform a contract.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at: firstname.lastname@example.org.
13. No Fee Usually Required
Where you are entitled to exercise such a right under Applicable Data Protection Law, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
14. What We May Need From You
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
15. Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
16. Third-Party Links
17. Contact Us
Please contact us using our details below:
Email address: email@example.com
Registered address: One New Change, London, EC4M 9AF