Privacy & Data Protection

 

EXECUTIVE SEARCH BALTICS SIA

PRIVACY POLICY

 

(A) This Policy

This Policy is provided by Executive Search Baltics SIA (“Executive Search Baltics SIA”, “we” or “us”), and is addressed to individuals outside our organisation with whom we interact, including (but not limited to) Candidates, Participants and Sources, visitors to our Sites, personnel of Clients and vendors, applicants for employment, and visitors to our premises (together, “you”). Defined terms used in this Policy are explained in Section (S) below.

For the purposes of this Policy, Executive Search Baltics SIA is the Controller. Contact details are provided in Section (R) below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

This Policy was last updated on August 1, 2024.

 

(B) Collection of Personal Data

We collect or obtain Personal Data about you, such as your name, address and contact details. Examples of sources from which we may collect Personal Data include the following:

• Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
• Data we obtain in person: We obtain Personal Data during meetings, at trade shows, during visits from sales or marketing representatives, or at events we attend.
• Collaborations: We obtain Personal Data when you collaborate with us in research or in an advisory/consultancy capacity.
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., if we offer to connect you with our Clients we may collect your Personal Data that are related to such Client opportunities, such as your résumé).
• Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).
• We may receive your Personal Data from third parties who provide it to us (e.g., past employers; referees; and law enforcement agencies).
• Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site. When you visit a Site, your device and browser will automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.
• Third party information: We may receive Personal Data from other members of the Amrop Partnership network, to the extent that those members provide it to us, or from third parties who provide it to us (e.g., past employers; referees; and law enforcement agencies). We may, with your prior express written consent, conduct background checks, in accordance with the protections provided by applicable law.

                                       

(C) Creation of Personal Data

Personal Data we create: We may also create Personal Data about you, such as records of any interviews you attend. This Personal Data helps us to conduct our operations and manage our legitimate business interests.

Personal Data you provide about others: In some circumstances, you may provide us with Personal Data about others. For example, you might act as a Source and provide comments on a Candidate or Participant. Whenever you provide any such Personal Data, we rely on you to ensure that you have a lawful basis for providing such Personal Data to us, and that you have complied with applicable law and with the terms of this Policy. If you are unable to do so, please refrain from providing the Personal Data of third parties to us.

 

(D) Categories of Personal Data we Process

The categories of Personal Data about you that we may Process include:

• Personal details: given name(s); preferred name; and photograph.
• Contact details: correspondence address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
• Correspondence: records and copies of your correspondence if you contact us.
• Professional details: your CV; salary and compensation details; passport number (where applicable); visa number (where applicable); and work authorization number (where applicable); records of your expertise; professional history; practising details and qualification details; information about your experience; participation in meetings, seminars, advisory boards; former employers; of employment; job titles; job locations; conferences; information about your professional relationship with other individuals or institutions; language abilities; and other professional skills.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Visitor logs: records of visits to our premises.
• Consent records: records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter experience; and details of any employment disciplinary issues or incidents).
• Details of referees: details of referees you may provide, including the relationship that you may have with each such referee, and the duration for which you have known each such referee.
• Background checks: details revealed by background checks conducted in accordance with applicable law and subject to your prior express written consent, including details of past employments, details of residence, credit reference information, and criminal records checks.
• Data relating to our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; registration details; security details; usage data; and aggregate statistical information.
• Employer details: where you interact with us in your capacity as an employee of a third party; and the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
• Cookie data: we collect information via cookies and similar technologies. Please see our Cookie Policy for more details.
• Views and opinions: responses to surveys, responses to testing, any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

 

(E) Sensitive Personal Data

We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:

• the Processing is required or permitted by applicable law (e.g., to comply with diversity reporting obligations);
• the Processing is necessary for the detection or prevention of crime;
• the Processing is necessary for the establishment, exercise or defence of legal rights; or
• we have, in accordance with applicable law, obtained your prior explicit consent before Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

 

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

 

(F) Purposes of Processing and legal bases for Processing

The purposes for which we Process the categories of Personal Data identified in Section (D) above, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

Purpose of Processing	Categories of Personal Data	Legal basis for Processing
·  Recruitment and job applications: Amrop recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.	· Personal details · Contact details · Correspondence · Professional details · Demographic information · Visitor logs · Consent records · Details of referees · Background checks · Data relating to our Sites · Employer details · Content and advertising data · Views and opinions	· The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or · We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the Processing (e.g., where this is necessary for the purposes of criminal records checks, in accordance with applicable law).
·  Provision of Sites, and services: recruitment operations; advertising Client opportunities; providing services to our Clients; enabling Clients to understand which Candidates are interested in their opportunities; record-keeping; providing leadership consulting services to Clients; conducting Leadership Assessments; providing our Sites, or services; providing you with coaching and training and preparation for interviews; providing promotional items upon request; and communicating with you in relation to those Sites, or services.	· Personal details · Contact details · Correspondence · Demographic information · Consent records · Details of referees · Background checks · Payment details · Data relating to our Sites · Employer details · Content and advertising data · Cookie data · Views and opinions	· The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or · We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
·  Operating our business: operating and managing our Sites, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, or our services; and notifying you of changes to any of our Sites, or our services.	· Personal details · Contact details · Correspondence · Consent records · Details of referees · Background checks · Payment details · Data relating to our Sites · Content and advertising data · Cookie data · Views and opinions	· The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or · We have a legitimate interest in carrying out the Processing for the purpose of operating our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
·  Planning: organisational planning; succession planning; making changes to the nature and scope of our operations or our business; mergers, acquisitions, dissolutions demergers, liquidations, asset sales, divestitures, reorganisations and similar corporate structuring arrangements.	· Personal details · Contact details · Professional details · Details of referees · Demographic information · Data relating to our Sites · Employer details · Content and advertising data · Views and opinions	· We have a legitimate interest in carrying out the Processing for the purpose of planning the future operation of our operations or our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
·  Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalising our Sites, products and services for you; maintaining and updating your contact information where appropriate; obtaining your prior, opt-in consent where required; and enabling and recording your choice to opt-out or unsubscribe, where applicable.	· Personal details · Contact details · Correspondence · Demographic information · Consent records · Data relating to our Sites · Content and advertising data · Cookie data · Views and opinions	· The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or · We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
·  Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.	· Personal details · Contact details · Professional details · Demographic information · Consent records · Details of referees · Background checks · Payment details · Data relating to our Sites · Employer details · Content and advertising data · Cookie data · Views and opinions	· The Processing is necessary for compliance with a legal obligation; or · We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
·  Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.	· Personal details · Contact details · Correspondence · Visitor logs	· The Processing is necessary for compliance with a legal obligation; or · We have a legitimate interest in carrying out the Processing for the purpose of ensuring a safe environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · The Processing is necessary to protect the vital interests of any individual.
·  Financial management: sales; finance; corporate audit; and vendor management.	· Personal details · Contact details · Payment details	· We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
·  Surveys: engaging with you for the purposes of obtaining your views on our Sites, or our services.	· Personal details · Contact details · Correspondence · Consent records · Views and opinions	· We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
·  Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).	· Personal details · Contact details · Visitor logs	· The Processing is necessary for compliance with a legal obligation; or · We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
·  Background checks: conducting checks necessary to provide our services to you and to our Clients; employment background checks; and education background checks.	· Personal details · Contact details · Correspondence · Consent records · Details of referees · Background checks · Payment details · Employer details	· The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or · We have a legitimate interest in carrying out the Processing for the purpose of providing our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the Processing (in particular, where it is not lawful to conduct background checks without your prior consent).
·  Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.	Each category of Personal Data identified in Section (D) above, to the extent necessary in the context of the relevant legal obligation or regulatory requirements or guidance.	· The Processing is necessary for compliance with a legal obligation; or · We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
·  Legal compliance: compliance with our legal and regulatory obligations under applicable law.	Each category of Personal Data identified in Section (D) above, to the extent necessary in the context of the relevant legal obligation or regulatory requirements or guidance.	· The Processing is necessary for compliance with a legal obligation, where applicable; or · We have a legitimate interest in carrying out the Processing for the purpose of compliance with regulatory requirements or guidance (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
·  Improving our Sites, and services: identifying issues with our Sites, or our services; planning improvements to our Sites, or our services; and creating new Sites, or services.	· Personal details · Contact details · Correspondence · Demographic information · Consent records · Data relating to our Sites · Content and advertising data · Views and opinions	· We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
·  Establishment, exercise and defence of legal claims: management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defence of legal rights and claims, including formal legal proceedings.	Each category of Personal Data identified in Section (D) above, to the extent necessary in the context of the relevant legal obligation or regulatory requirements or guidance.	· The Processing is necessary for compliance with a legal obligation; · We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · The Processing is necessary for the establishment, exercise or defence of legal claims.

 

(G) Disclosure of Personal Data to third parties

We disclose Personal Data to other members of the Amrop Partnership network, for legitimate business purposes (including providing services to you and operating our Sites), in accordance with applicable law. We may also share aggregate demographic information with our Clients, trusted affiliates and advertisers for the purposes outlined in this Policy. While we make all reasonable efforts to ensure that such information is anonymized, it is possible that small amounts of Personal Data may be included.

In addition, we disclose Personal Data to:

• you and, where appropriate, your appointed representatives;
• accountants, auditors, consultants, lawyers and other outside professional advisors to the Amrop Partnership network, subject to binding contractual obligations of confidentiality;
• third party Processors (such as payment services providers; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• any relevant third-party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• any relevant third-party provider, where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

 

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

 

(H) International transfer of Personal Data

Because of the international nature of our business, we may need to transfer your Personal Data to other entities within the Amrop Partnership network, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. In particular, your Personal Data may be disclosed to other members of the Amrop Partnership network, to the extent appropriate, in connection with any Client opportunities in respect of which you are a Candidate, or any Leadership Assessment in which you are a Participant.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses or the UK equivalent (i.e., [the UK International Data Transfer Agreement / UK addendum to the Standard Contractual Clauses) as applicable. You are entitled to request a copy of our Standard Contractual Clauses or UK equivalent using the contact details provided in Section (S) below.

Please note that when you transfer any Personal Data directly to any member of the Amrop Partnership network established outside the UK or the EEA (as applicable), we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Policy.

 

(I) Data security                                                        

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

 

(J) Data accuracy                                               

Your Personal Data that we Process will be kept accurate and, where necessary, kept up to date. We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up-to-date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

 

(K) Data minimisation                                                      

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy.

 

(L) Data retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:

(1)    we will retain Personal Data in a form that permits identification only for as long as:

(a)    we maintain an ongoing relationship with you (e.g., where you are Participant in a Leadership Assessment; or you are a Candidate for a role with a Client); or

(b)    your Personal Data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where you are a Candidate whose Personal Data is stored in our databases, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

plus:

(2)    the duration of:

(a)    any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and

(b)    an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

and:

(3)    in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

 

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

 

(M) Your legal rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (i.e., in relation to the UK, the Information Commissioner’s Office (https://ico.org.uk/) or in relation to the EU, the Data Protection Authority for EU Member State in which you live, or in which you work, or in which the alleged infringement occurred (see the list here: https://edpb.europa.eu/about-edpb/about-edpb/members_en)).

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data: · the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR / UK GDPR; and · the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (S) below. Please note that:

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

 

(N) Cookies

A cookie is a small file that is placed on your device when you visit a website (including our Sites). It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through cookie technology, in accordance with our Cookie Policy.

 

(O) Terms of Use

All use of our Sites, or services is subject to our Terms of Use and to our Privacy Policy.

 

(P) Your obligations

If, and to the extent that, you are a Candidate or Participant, we rely on you to provide us with complete and accurate Personal Data about you, so that we can provide appropriate services to you and to our Clients.

If, and to the extent that, you are a Source, we rely on you to ensure that you are lawfully able to disclose Personal Data to us, as set out in this Policy.

 

(Q) Direct marketing

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, opportunities, or services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, or services. If we provide Sites, or services to you, we may send or display information to you regarding our Sites, or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

As the case may arise, you may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send or by unsubscribing online. Please note that it may take up to 2 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, or services you have requested.

 

(R) Contact details

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data by Executive Search Baltics SIA, please contact us by email riga@amrop.com or phone +371 67210408.

 

(S) Definitions

• ‘Adequate Jurisdiction’ means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
• ‘Candidate’ means a candidate, or potential candidate, for a position with a Client.
• ‘Client’ means a client of [AMROP MEMBER FIRM], or any other member of the Amrop Partnership network.
• ‘Cookie’ means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a ‘Cookie’ includes analogous technologies such as web beacons and clear GIFs.
• ‘Controller’ means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• ‘Data Protection Authority’ means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• ‘EEA’ means the European Economic Area.
• ‘GDPR’ means the General Data Protection Regulation (EU) 2016/679.
• ‘Leadership Assessment’ means any leadership assessment service (including, but not limited to, any management audit, leadership consulting service, coaching, team development, team effectiveness analysis, or succession planning) provided by the Controller to the Client for the purposes of assessing the leadership potential of its own Personnel or other individuals selected by the Client.
• ‘Participant’ means any individual participating in a Leadership Assessment.
• ‘Personal Data’ means information that is about any individual, or from which any individual is directly or indirectly identifiable, 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 the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• ‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• ‘Processor’ means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• ‘Relevant Personal Data’ means Personal Data in respect of which we are the Controller.
• ‘Sensitive Personal Data’ means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.
• ‘Source’ means any person that provides any view or opinion regarding the qualities of any Candidate or Participant, for any purpose, including but not limited to the suitability of a Candidate or Participant for a particular role.
• ‘Standard Contractual Clauses’ means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
• ‘Site’ means any website operated, or maintained, by us or on our behalf.
• ‘UK GDPR’ means the GDPR as it forms part of the laws applicable in the UK by virtue of section 3 of the European Union (Withdrawal) Act 2018 and the Data Protection Act 2018, and as applied and modified by Schedule 2 of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419) or as modified from time to time.
• ‘UK International Data Transfer Agreement’ means the template transfer agreement adopted by the UK Information Commissioner’s Office on 21 March 2022.