- Your consent.
- What PII we collect about you.
- Cookies (information we collect from your visiting our website).
- How we use your PII.
- How we protect your PII.
- How we share your PII.
- Additional information for users in the European Economic Area , Switzerland, and Other Non-U.S. Locations.
- Social Media Features and Social Media Websites.
- Links to Other Sites; Transactions with Third Parties.
- How you can access, correct, and request to delete your PII.
- Your California Privacy Rights; California Do Not Track Disclosures.
- Changes to this Policy.
- How to contact us.
- Terms of service.
- California Consumer Privacy Rights
Depending on where you reside, if you choose to submit PII through the Sites, you may have the right to access, change, modify or delete your information, at any time, as described below.
Your IP Address. You may browse our executive opportunities and review certain information on the Website without providing us with PII, although your internet protocol (“IP”) address will be collected. An IP address is often associated with the portal you used to enter the Internet, like your Internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. However, we may link the last IP address you used to access the Website to the PII you provide us. Where, according to local law, IP addresses and the like are considered PII, then we treat them as such.
Subscribers To The Site & To Newsletters. When you subscribe to the Website, we collect your email address. When you sign up for our newsletters, we collect your first and last name, email address, title, department and company and add it to our list of subscribers so you can receive our email newsletters.
Candidates. When you express interest as a candidate or to apply for a job, we collect your first, last and middle name, physical address, phone number and email address. When you submit your resume or C.V., we collect your email address plus a copy of your resume, which may include additional PII and other information such as career and compensation history. We request that you do not provide sensitive PII on your resume/CV or other documents you share with us, for example: racial or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sex life, criminal history, Social Security or National Insurance numbers, or payment card information, as defined by applicable law.
Voluntary EEO Disclosure. We may have certain clients in the U.S. that collect demographic information about potential applicants in order to meet U.S. federal or state legal requirements or to maintain a diverse workforce. Providing this information is purely voluntary and generally done directly to our clients. Applicants who reside outside the U.S. should not provide this information.
Other Sources. Caldwell may collect information about you from other sources. The other sources might include information that you provide other than through our Sites, for example, from prior employers, other references, pre-employment screening providers, behavioral assessments, etc. or from third party social sites such as LinkedIn.
Contacts With Us. When you contact us by email or phone, we will collect your email address or phone number, as applicable, in order to respond to you.
Cookies are small data files that are placed on your device when you visit a website. The cookie then sends information back to the originating website on each subsequent visit or to another website that recognizes the cookie. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu.
What Cookies Do We Use?
Cookies can be categorized by who puts the cookie on the user’s computer (or other device the user uses to browse the website). First-party cookies are cookies placed by the party operating the website. For example, any cookies we (Caldwell) place on your device from our Website are first-party cookies. Third-party cookies are cookies placed from a website by a party that does not own or operate that website.
Essential cookies –These cookies are necessary to enable you to move around the website and use its features, such as accessing secure areas of the website.
Functionality and performance cookies – These cookies are used to enhance our Website’s functionality performance.
Analytics cookies – These cookies collect information that is used in aggregate form (and therefore anonymous) to help us understand how our Website is being used or how effective our marketing campaigns are. They provide information about which pages you visit and how often, but do not collect information that identifies you. The cookies provided by each third-party service provider send the information they collect to that third-party service provider. For example, the cookies provided by Google Analytics send information about your Website interactions to Google Analytics. Each third-party service provider then compiles aggregated data using the information received and sends us reports on the aggregated data. These reports are not shared with other parties. We use the reports to offer better Website experiences and tools in the future.
We may also perform IP lookups to determine which domain you are coming from to more accurately gauge our users’ demographics.
Targeting/Advertising cookies – Targeting/advertising cookies are cookies used to deliver advertisements relevant to the user. They remember that a user has visited a website and share this information with other organizations, such as advertising vendors.
Cookies in this category may include Remarketing Cookies. These are cookies that remember that you visited our Site after you leave. Sometimes they collect information about what pages of our Sites you visited. They then share this information with our third-party vendors, such as Google. Based on this information, the third-party vendor shows you advertisements on third-party websites for Caldwell products that we think may interest you based on what you viewed on our Site.
Cookies can also be categorized by how long they remain on your device. There are two broad categories of duration:
Persistent cookies –Persistent cookies remain on your device until deleted manually or automatically.
Session cookies – Session cookies remain on your device until you close your browser when they are automatically deleted.
We use both session and persistent cookies on our Sites.
Location of information processing- The information collected by our cookies is processed in servers located in the United States.
Users in the European Union (E.U.) have the right to refuse to allow cookies to be placed on the device they use to access the Sites. We describe below how E.U. users can reject cookies used by our Website.
Rejecting Cookies Through Browser Settings:
The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. For more information on using browser settings to reject cookies, please visit www.allaboutcookies.org.
You should note that rejecting cookies in your browser settings may mean that any preferences you set on the Website will be lost and that the Website may not work as well. In addition, using the browser settings to reject cookies may also cause your browser to reject cookies from all websites, not just our Website.
Caldwell uses your PII to:
- Reply to your request for information, including newsletters;
- Evaluate your credentials for available executive level positions now and in the future;
- Conduct applicant background checks and credit checks, check work history and compensation history (in accordance with applicable local laws), and contact references for job applicants;
- Communicate with you about the status of your application(s);
- Create your candidate profile and maintain it in our candidate database;
- Send you promotional emails about Caldwell if you have opted in to receive future communications from us;
- Market to current and potential clients;
- Create de-identified aggregated information for statistical purposes, to improve our Website and Services, and to improve user experience.
- Enhance network and information security and prevent fraud through authenticating your identity prior to disclosing or changing your PII.
- Reporting suspected criminal acts
We take appropriate technical and organizational safeguards to protect PII from theft, other loss, misuse, and any unauthorized access, copying, collection, use, disclosure, alteration, forgery, destruction or technical errors. We follow generally accepted standards to protect the PII submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.
Therefore, we cannot guarantee its absolute security.
We retain your PII as long as needed to provide you Services. Even if you only use our Services when looking for a new job occasionally, we will retain your information and keep your profile open until you decide to close your account and notify us to delete your information or you have been inactive longer than our record retention policies. Additionally, we will retain and use PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will not sell or license your PII. We may disclose your PII to third parties in the following limited circumstances:
- Client Companies. We disclose your PII to our client companies who hire us to find executive level candidates for their open positions, if your qualifications meet their requirements.
- Service Providers. We disclose users’ PII to third parties who provide services that you request such as third party newsletters; to third party vendors who help us operate the Sites (such as our database support provider). These third parties may be located in the U.S. the UK and Canada, and are contractually obligated to maintain the confidentiality of your PII consistent with the terms of this Policy and to comply with the applicable data protection laws.
- Legal Matters. We will disclose your information in response to valid legal process, for example, in response to a court order, a subpoena or other legal request for information, and/or to comply with applicable legal and regulatory reporting requirements.
- Law Enforcement. We may disclose your information in response to a law enforcement agency’s request or other request for information from the U.S. or other government entities, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, and situations involving potential threats to the physical safety of any person.
- Protect Our Company. We may disclose your information to verify or enforce compliance with the policies governing our products and/or services and with applicable laws, or as otherwise required or permitted by law or consistent with legal requirements.
- Corporate Transactions. We may transfer your information to an entity or individual that acquires, buys, or merges with Caldwell, or our other business units.
7. Additional information for users in the European Economic Area , Switzerland, and Other Non-U.S. Locations
- All locations
The PII collected through the Sites is stored on a server maintained by Caldwell in Canada. Caldwell is located at 79 Wellington Street West, Suite 2410, Toronto, ON M5K 1E7, Canada. Caldwell will comply with requests to exercise individual data rights in accordance with applicable law. PII is also stored on a server maintained by Amazon Web Services in the state of Virginia in the United States. You can contact firstname.lastname@example.org to request to exercise your data rights.
- European Economic Area, the United Kingdom and Switzerland
The information in this section, as well as the information in the section above titled “All locations”, applies to users in the European Economic Area and Switzerland (collectively, the “EEA”) and the United Kingdom (the “UK”).
Individuals in the EEA (“EEA Individuals”) and the UK (“UK Individuals”) are not required by statute or by contract to provide any PII to the Sites. Caldwell sometimes uses EEA and UK Individuals’ PII submitted through the Sites for certain automated decision-making. For example, Caldwell may display advertisements and send emails to you containing content automatically chosen based on characteristics such as your industry, function or indicated interests. However, Caldwell will not use EEA Individuals’ or UK Individuals’ PII submitted through the Sites for other automated decision-making, including profiling, which produces legal effects or similarly significantly affects the individual.
Cross-Border Data Transfers
The PII collected through the Sites will be transferred to the United States and Canada and accessed from the United States and Canada. The recipients of PII collected through the Sites are located in Canada, the U.S., or in the country where the data was collected. Caldwell will handle PII transferred to Canada in accordance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA). The European Commission has determined that PIPEDA ensures an adequate level of protection for your PII.
To ensure an adequate level of protection for PII transferred to the U.S., Caldwell previously certified to the EU-U.S. and Swiss–U.S. Privacy Shield Frameworks and relied on that certification for cross-border data transfers from the EU and Switzerland. On July 16, 2020, the EU-U.S. Privacy Shield Framework was invalidated as a result of the decision by the Court of Justice of the European Union in “Schrems II.” On September 8, 2020, Switzerland’s Federal Data Protection Information Commissioner announced that the EU-Swiss Privacy Shield Framework no longer provides an adequate level of protection for transfers of personal data from Switzerland to the United States.
For transfers of personal information after July 16, 2020, from the European Union or the United Kingdom, and after September 8, 2020, from Switzerland, to Caldwell in the United States, the Company will rely on (a) a transfer mechanism deemed adequate by the relevant data protection authority, or (b) an applicable derogation from the general prohibition on cross-border data transfers under the relevant data protection law, such as your consent.
Basis to process information and your right to reject to processing
Caldwell relies on your consent to process your PII. Caldwell also processes your PII with legitimate interests as necessary for the performance of the Services. Importantly for you, this includes current job opportunities with our clients under existing contract as well as opportunities that may arise in the future in betterment of your career. Caldwell cannot facilitate its Services with users unless users provide their PII. Caldwell also processes PII as necessary for its legitimate interests as follows:
- Marketing and advertising: Unless you opt out as described below, we use your PII regarding the Services we offer, as necessary to provide you information that we think might interest you in accordance with applicable law.
- Network and information security, fraud prevention, and reporting suspected criminal acts: In the event of fraud, a security incident, or a suspected criminal act, we would examine PII that appeared to be linked to the incident as necessary to determine what happened, remediate, report to the authorities, and prevent a recurrence.
- Right to Object to Processing for Direct Marketing or Legitimate Interests: EEA Individuals have the right to object to the processing of their PII for purposes of Caldwell’s direct marketing or legitimate interests by contacting Caldwell at email@example.com.
EEA and UK Individuals have the right to access their PII collected by the Sites and to request that Caldwell update, correct, or delete their PII as provided by applicable law. EEA and UK Individuals also have the right to object to, or restrict, Caldwell’s processing of their PII.
In addition, EEA and UK Individuals have the right to data portability concerning their PII. Subject to certain limitations, the right to data portability allows EEA and UK Individuals to obtain from Caldwell, or to ask Caldwell to send to a third party, a digital copy of the PII maintained that they provided to the Sites. EEA and UK Individuals’ right to access their PII includes their right to receive a copy of all, or a portion, of their PII in Caldwell’s possession as long as Caldwell’s providing the PII would not adversely affect the rights and freedoms of others.
EEA and UK Individuals can exercise these rights by contacting firstname.lastname@example.org. Caldwell will respond to such requests in accordance with applicable data protection law. If EEA and UK Individuals believe that their PII has been processed in violation of applicable data protection law, they have the right to lodge a complaint with the relevant data protection authority in the country where they reside, where they work, or where the alleged violation occurred.
EEA and UK Individuals may use the email address above, at any time, to withdraw their consent for the processing of their PII where Caldwell requires their consent as a legal basis for processing their PII. Any withdrawal will apply only prospectively, and Caldwell will continue to retain the PII that EEA and UK Individuals provided before they withdrew their consent for as long as allowed or required by applicable law.
In addition, you may cancel or modify the email communications you have chosen to receive from Caldwell by following the instructions contained in emails from us. Alternatively, you may email Caldwell at email@example.com with your request, stating ’Unsubscribe‘ in the header and what email addresses you wish not to receive Caldwell emails. Within a reasonable period, we shall ensure that such email addresses are unsubscribed.
Caldwell’s representative in the European Union is The Caldwell Partners International Europe Ltd. You can reach our representative at firstname.lastname@example.org
Caldwell is not responsible for and will not be a party to any transactions between you and a third party provider of products, information or services, or a client company with which you have an interview or exchange or that may consider you for or offer you a job, even if we introduce you to the client company. Caldwell does not monitor such transactions or ensure the confidentiality of your PII for any third party dealings. Any separate charges or obligations you incur in your dealings with these third parties linked to the Website or to which we refer you are solely your responsibility.
Our Website is directed to individuals who are the age of majority or older in their jurisdiction. If you are not the age of majority or older in your jurisdiction, you are not authorized to use the Site. We do not knowingly collect information from children. If you believe your child has provided information to the Site please contact us using the information provided below.
If you are an EEA or UK Individual, you may send us a request by email if you wish to access, review, change, correct, update, cancel or delete your PII, request information about our collection, use and disclosure of such information, and request information on our policies and practices relating to disclosure of information to our service providers, by contacting us at email@example.com. We will respond to these requests in accordance with the laws that apply to you. You can help us maintain the accuracy of your information by notifying us of any changes to your information.
You may revoke your consent, and/or object to or block processing of your PII by emailing a request to us at firstname.lastname@example.org. We will respond to your request in accordance with the law that applies to you. Your PII that we processed prior to your request may not be deleted from our Sites’ system records unless we are legally required to do so but will be blocked from further processing without your permission. A request to revoke consent or block processing of your PII may not apply to information collected by cookies or used internally to recognize you and/or facilitate your visits to the Website, or information we may keep to comply with legal requirements.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your PII by Caldwell or its subsidiaries to a third party for the third party’s direct marketing purposes. Since we do not make such disclosures, we are exempt from these reporting requirements. In addition, we currently do not honor Do Not Track signals.
Caldwell commits to resolving complaints about your privacy and our collection or use of your PII. If you believe your privacy rights have been violated or you disagree with any action Caldwell has taken with regard to your PII you may file a complaint with Caldwell by emailing us at email@example.com.
If you have questions or suggestions, or wish to correct your PII, please email us at firstname.lastname@example.org.
You may contact us at:
Attention: Privacy Officer
79 Wellington Street West, Suite 2410
Toronto, ON M5K 1E7
By Phone: +1 (888) 366-3827
For the privacy policies of brand-licensed entities that are separate legal entities operating independent Sites, please contact the applicable entity:
- New Zealand Operations
Simon Monks, Managing Partner, The Caldwell Partners International New Zealand Limited; email@example.com
- Australia Operations
Darryl Mills, Privacy Officer, Hattonneale Pty Ltd; firstname.lastname@example.org.
Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our website at www.caldwellpartners.com/terms-of-service/.
Caldwell’s Collection and Use of Personal Data. Caldwell receives Personal Data about individuals in the EU, UK and Switzerland, including vendors, business contacts, users of Caldwell’s Sites, event registrants, and candidates. The Personal Data collected and its uses are described in Sections 2 through 4, above.
Caldwell’s Disclosure of Personal Data. Caldwell may disclose the Personal Data of individuals located in the EU, UK and Switzerland, subject to written agreement, to authorized service providers who provide services related to the purposes for which Caldwell collects that Personal Data. The identity of third-parties to whom Caldwell may disclose Personal Data is described in Section 6, above. The purpose for which Caldwell may disclose Personal Data is described in Section 6, above. Caldwell may be liable for the onward transfer of Personal Data to third parties. Caldwell may be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.
Choices for Limiting the Use and Disclosure of Personal Data. Caldwell will provide the opportunity for individuals to opt out from: (a) the disclosure of their Personal Data to a non-agent third party; and (b) the use of their Personal Data for purpose(s) that are materially different from the purpose(s) for which the Personal Data was originally collected or subsequently authorized by the individual. Caldwell will provide individuals with clear, conspicuous and readily available mechanisms to exercise their choices regarding Personal Data should such circumstances arise. Individuals who wish to limit the use or disclosure of their Personal Data as described in this Policy should submit their requests to email@example.com.
Individuals’ Right to Access Their Personal Data. Upon request, Caldwell will grant individuals access to their Personal Data. Caldwell will permit individuals to correct, amend, or delete Personal Data that is inaccurate or incomplete or that is being processed in violation of the Privacy Shield Principles. Individuals who wish to exercise these rights can do so by contacting firstname.lastname@example.org. For security purposes, Caldwell may require verification of the requester’s identity before providing access to Personal Data.
In compliance with the Privacy Shield Principles, Caldwell commits to resolve complaints about its collection or use of the Personal Data of individuals located in the EU, UK and Switzerland. Any such individual who has a complaint regarding this Policy should submit the complaint to email@example.com. Caldwell will promptly investigate, and attempt to resolve, such complaints in accordance with this Policy and the Privacy Shield Principles. Any individual who is not satisfied with the internal resolution of a complaint may seek redress with JAMS, an alternative dispute resolution provider based in the United States. You can contact JAMS at 3800 Howard Hughes Parkway, 11th Floor, Las Vegas, NV 89169 USA or by e-mail at firstname.lastname@example.org. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint. The services of JAMS are provided at no cost to you. In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles. The Federal Trade Commission has jurisdiction over Caldwell’s compliance with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks.
Caldwell complies with the California Consumer Privacy Act (“CCPA”). If you are a California resident, you have certain privacy rights under the CCPA (“CCPA Rights”). This section describes those rights and how you can exercise them with Caldwell.
CCPA Rights Requests
Right to Know and Right to Deletion
You can request what personal information we have collected, used, disclosed, and sold in the preceding 12 months.
You can also request that we delete your personal information. We may not delete all of your personal information if one of the following exceptions applies:
Transactional: to complete a transaction for which the personal information was collected, provide a good or service requested by you, or perform a contract we have with you;
Security: to detect data security incidents;
Error Correction: to debug or repair any errors;
Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
Internal Use: to use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).
Please note that if we delete your personal information, many of our services will not work the same. This includes our ability to access your information for consideration for client employment positions for which we are engaged as well as our ability to share marketing communications content we believe is relative to your interests.
To submit a request to know or a request to delete, please email email@example.com or contact us at +1 (888) 366-3827. For security purposes, Caldwell may require verification of the requester’s identity before providing access to Personal Data. If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information. We will maintain a record of your request to know or request to delete.
Non-Discrimination: We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you future goods or services or provide you with a lesser quality of goods or services if you exercise any of your CCPA Rights, other than your not appearing in our candidate database for consideration of potential employment opportunities.
Last updated November 11, 2020 (California Consumer Privacy Rights section added January 2, 2020)