Dated July 26, 2018

1. Who we are and what our policy states

Welcome to Chaberton Partners SA, Via Canova 1, Piazza Riforma, 6900 Lugano (Switzerland) (“Chaberton Partners,” “we,” “us” and “our” etc.) and its global website (http://www.chabertonpartners.com). Chaberton Partners is an International Human Capital firm. From our headquarters in Switzerland we are committed to providing globally a complete portfolio of high quality human capital solutions. The Company is structured in three divisions; Chaberton Partners Executive Search, Chaberton Professionals and Chaberton Advisor. We provide a variety of services to these clients and other parties, including, but not limited to:

• executive search (leads the efforts of executive search supporting our clients in sourcing and selecting exceptional executives and supervisory board members.);
• advisory (e.g., offers a portfolio of Human Capital Solutions through consultants with solid experience at the highest ranks of the corporate world in a varied spectrum of industries)
• Professional service (focuses on finding and selecting the best professional and managerial profiles while enriching our clients’ leadership pipeline.)

Our consultants provide these Services globally from our office in Switzerland.

We respect the privacy of the users of our website (“you”, “your”) and are committed to protecting 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.

Chaberton Partners is responsible for the processing of your personal data and information on its website.

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 consumer collected by us online through our website and that we maintain in an accessible form, or that (d) we are otherwise required to protect under applicable data privacy laws (including, but not limited to, national, international and supranational data protection and privacy laws, directives, regulations and comparable legal acts). Examples of Personal Information include your contact details such as your name, email address, birthday or phone number as well as information about your professional education and experience, skills, preferences, membership in professional organizations, etc.

“Processing” 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, 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 uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

“Site” means http://www.chabertonpartners.com/ and all web pages hosted at that domain.

3. Processing of Your Personal Information

Chaberton Partners complies with General Data Protection Regulation (GDPR) in EU and with Swiss Federal Data Protection Act (DPA), based on the principle that the processing of personal data is prohibited.

Depending on your interaction with the Site, your Personal Information is Processed as follows:

(i)  Career / Job openings – 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 as part of the Client Services. To do so, visit www.chabertonpartners.comand submit your Resume including your personal and professional background 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 can 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 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 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 or within data you have previously disclosed to us, provided that such information might be of importance to your qualification for a 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 Chaberton Partners. Your Candidate Information Processed by Chaberton 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.

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

Your Candidate Information will be stored in databases located in the United Kingdom and the United States. The servers hosting the databases are operated by and accessible to members of the Chaberton Partners employees or third-party service providers acting on their behalf and as per their instruction to operate the servers. The third-party service providers include MindSCOPE Staffing Software, Verisign SSL;

Subject to our discretion, we might disclose excerpts of your Candidate Information such as your professional education and employment history with 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 via phone contact or email. That consent will be recorded and stored in our data base for each and every specific project.

In this context, please be aware that various companies of the Chaberton Partners Network, most of the third-party service providers operating the database servers and some of our clients we might disclose excerpts of your Candidate Information to are located in countries outside of the European Economic Area (EEA) that have not been found by the European Union to provide an adequate level of protection of personal data, i.e. a level of protection of fundamental rights and freedoms that is essentially equivalent to that guaranteed within the European Union. Similarly, the countries your Candidate Information, or parts thereof, might be transferred to in accordance with the above may not be found to provide an adequate level of protection by jurisdictions outside of the European Union. By declaring your consent as set forth below you therefore explicitly and unambiguously (a) agree that your Candidate Information, or parts thereof, may be disclosed or otherwise transferred, as described above, to recipients in countries that may provide different, less or even inadequate protection of personal data as compared to the standards applicable in the jurisdiction you reside or work in or you contact us from, and (b) waive protection according to such standards with respect to the information so disclosed or transferred.

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 declaration of consent given when sharing Candidate Data with us. Upon the revocation of your declaration of consent, we will delete your Candidate Data from all databases.

By sharing your Candidate Information with us, 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. This includes, without limitation, the transfer of your Candidate Information, or parts thereof, to countries not providing an adequate level of protection of personal data. 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: dataprivacy@chabertonpartners.com.