This Policy is provided by AMROP HISPANO S.L. (“AMROP HISPANO S.L.”, “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, AMROP HISPANO S.L. 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

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.

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.

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.

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.

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:

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;
• 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.

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 (R) 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.

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.

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.

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.

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.

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).

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 (R) 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.

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.

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

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.

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.

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 AMROP HISPANO S.L., please contact us: Amrop Spain I Calle Jorge Juan 35, 28001 Madrid, Spain I info@amrop.es I +34 910 053 517.