Terms and Conditions | Lee Hecht Harrison

Latest update:17 March 2023

Index

1. General information

2. Our contact details as the Data Controller of your personal data

3. What categories of personal data does LHH collect and use?

4. Why do we process your personal data and on what legal basis?

5. How do we get your personal data and do you have to give them to us?

6. How long do we keep your personal data for?

7. What marketing communications do we send?

8. Do we use artificial intelligence?

9. Do we share your data with third parties?

10. Do we transfer or store your data outside of your home country?

11. What data security measures do we have in place?

12. What are your rights regarding your personal data?

13. How do we handle changes to this Privacy Notice?

14. Getting in touch with us

1. General information

Welcome to LHH. We look forward to connecting with you.

LHH is part of Adecco Group AG, based in Zürich, Switzerland.

This Privacy Notice tells you what to expect us to do with your personal data when you contact us or use one of our services, when you visit this website or when you access or use any applications or features made available by us (collectively, the “Website”).

This Privacy Policy may be supplemented by other more specific privacy policies depending on the services performed by LHH Recruitment Solutions (a brand of "Badenoch and Clark", "Spring Professional", "ADO").

For instance, if:

- you are working on an interim assignment, a consulting assignment or
- you are participating in a recruitment process
we invite you to consult the Privacy Policy for the services concerned.

2. Our contact details as the Data Controller of your personal data

The legal entity of LHH, Lee Hecht Harrison LLC (based in the US), that provides career transition services to you is the data controller of your personal data.

For interim, consulting or recruitment services, the data controller in Luxembourg is either Spring Professional Luxembourg S.A. or Badenoch and Clark Luxembourg S.à r.l.

You can ask your Data Controller any questions regarding data protection by filling in our Request Form or by e-mail to
- At global level: globalprivacy@adecco.com or
- At local level (Luxembourg): privacy_lu@lhh.com.

3. What categories of personal data does LHH collect and use?

Personal data includes any information relating to an identified or identifiable natural person. It does not include data that cannot be linked in an individual (such as anonymous data).

We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us:

a) Identity Data includes your first name, last name, and documents evidencing your identity if needed.

b) Contact Data includes your email address, telephone number and postal address.

c) Professional Data includes your job title, job level, your company name, details on your company and your company’s business needs, your location, your professional qualifications, educational and professional background, and salary where applicable, experience working with our brands, purpose of attendance (at an event), and other information that could be on your business card or that you choose to provide to us.

d) Marketing Communications Data includes your preferences on content type, frequency of communications and preferred language.

e) Social Media Data includes your profile data and other information you made public on or otherwise share with us from social media and/or job boards.

f) Profile Data includes information about you, provided by you on our electronic portals or platforms including your username and password, services or products ordered by you, your system preferences, your user-generated content (for example job searches, job applications), your feedback including your survey responses.

g) Usage Data includes information about how you use our Website, systems, products, and services.

h) Technical Data includes technical information collected when you access our electronic portal or platform, and includes your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.

i) Sensitive data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. When you visit or interact with our Website, you are not required to submit Sensitive Data. However, if you decide to provide us with Sensitive data, we will handle the information according to the practices identified in the applicable Privacy Notice. We reserve the right to delete the information from our databases in accordance with applicable law.

4. Why do we process your personal data and on what legal basis?

We normally collect personal data from you only where we need it to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so.

If you are from a region that requires a legal basis for processing personal data (such as the EEA or the UK), our legal basis for collecting and using your personal data will vary depending on the personal data concerned and the specific context in which we collect it.
Please note that some information below may not apply to you depending on your relationship with us and/or the legislation of your home country.

Purposes of the processing	Type of personal data	Legal basis to process your personal data
To provide you with ourservices and to attempt toestablish or strengthen abusiness relationship with you.	a) Identity Data b) Contact Data c) Professional Data e) Social Media Data f) Profile Data	- Performing a contract or taking steps prior to entering a contract in respect of the contract with or related to you - Consent where we are required under the law to obtain consent to provide you with our services - Fulfilment of our legitimate interests to provide our products and services
To keep you informed aboutour services, via email,messaging, phone, social mediaor any other channel. Thisincludes information such asevents or newsletters that maybe of interest to you.	a) Identity Dat b) Contact Data d) Marketing Communications Data e) Social Media Data if applicable	- Consent where we are required under the law to obtain consent for marketing - Performing a contract or taking steps prior to entering a contract in respect of the contract with or related to you - Fulfilment of our legitimate interests to promote our products and services where we are not obliged to obtain consent by law
To respond to your request orquestions or provide informationwhen you contact us or make arequest to us.	a) Identity Data b) Contact Data f) Profile Data	Fulfilment of our legitimate interests to respond to you
- To allow you to participate ininteractive features of theWebsite, when you choose to doso; - To further develop andimprove the Website andsystems to better serve you - To best tailor content, theWebsite and resourcesaccording to your preferences, toimprove them and to present it inthe most effective manner foryou.	a) Identity Data b) Contact Data c) Professional Data f) Profile Data g) Usage Data h)Technical Data	Fulfilment of our legitimate interests to administer our websites and provide you with relevant information about our products and services
Where necessary, to complywith any legal obligation.	All types of personal data mentioned in section 3 as necessary.	Compliance with a legal or regulatory obligation
To investigate or respond to incidents and complaints and/or to comply with investigations carried out by the police, government or regulators.	All types of personal data mentioned in section 3 as necessary.	- Compliance with a legal or regulatory obligation - Performance of a task carried out in the public interest

5. How do we get your personal data and do you have to give them to us?

We use different methods to collect data from and about you including through:

a) Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you:

create an account on our website;

subscribe to our service or publications;

request marketing to be sent to you;

enter a competition, promotion or survey; or

give us feedback or contact us.

b) Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies and from the communications we receive from your browser.

c) Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Public information made available by you on social media and similar websites and apps;

Public information about you in directories, for example of professional memberships or qualifications.

You are not obliged to provide your personal data to us, but it would not be possible for us to work with you, or provide our services to you, if you do not provide us with a required minimum.

6. How long do we keep your personal data for?

We keep your personal data only as long as necessary to provide you with the LHH Service and for LHH's legitimate and essential business purposes, such as carrying out the LHH Service, complying with our legal obligations, and resolving disputes.

In some circumstances, we might anonymize your personal data so that it can no longer be associated with you, and use this indefinitely, without further notice.

7. What marketing communications do we send?

Communication with Individuals

We will only send marketing communications to you, as an individual, if you have consented to us doing so.

To receive marketing or promotional communications, you can opt-in by checking the relevant box located on the form on which we collect your data.

Communication with Businesses

We process your data within the scope of an existing business relationship with you or your company because:

We have a contract with you (or are considering entering into a contract with you).
In this case, the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship; or
It is in our legitimate interests for the conduct of our business activities (for example, to communicate with you in a 'business to business' capacity in order to promote our products and services that we believe will be of interest to you or your company).
In that regard, we may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company; or

You consented to receive our marketing communications via e-mail as an individual at our clients/companies.
In this case, we will send you marketing communications to develop or maintain a business relationship in accordance with applicable electronic and marketing communications laws. These communications may include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click on.
We will usually offer you a check box on the forms we use to collect your personal data. If you agree to receive the communications, you must click the box.

How to unsubscribe?

In any case, where we send marketing communications to you via email, you may opt out of receiving any further marketing communications by clicking the ‘unsubscribe’ or ‘opt-out’ function in the bottom of the marketing email. You can also exercise your opt-out right at any time by contacting us here (please indicate the marketing communications you would like to opt out of receiving in the Request Details field).

Please note that it may take up to three days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make your request. Your opt out will not affect transactional / service emails from us, such as password reset emails or notifications of updates to our terms. You will still receive these as part of your services.

8. Do we use artificial intelligence?

Yes, we do use artificial intelligence (AI) at times. However, we do not use your personal data in any automated decision making (a decision made solely by the creation and application of technologies without any human intervention) or profiling (processing of personal data with a range of technologies that reduce human intervention to evaluate certain conditions about an individual) that produces a legal effect or similarly significant effect concerning you.

We use a range of technologies to analyze data. In case of our websites, we might use your search terms to recommend particular job offerings. In all cases, there is always human intervention in these processes, as we use these tools to support our expert human decision makers.

9. Do we share your data with third parties?

We share personal data with a carefully selected list of trusted business partners to provide our services, and to fulfil our contractual obligation to our customers for the purpose set out at section 4 above.

The table below outlines the category of third parties we might need to share your personal data with, and business purpose for doing so. We will obtain your consent to any disclosure of your personal data where required by law.

Recipients	Reason for sharing
Adecco Group Companies	To provide IT support by the relevant Adecco Group companies who provide IT functions globally For the purposes previously described or to propose offers to you adapted to your profile where you have expressed an interest in local or international opportunities in that market, or Adecco Group companies identify that you may have particular skills required or helpful in that market.
Service Providers	To enable third parties to provide services to you on behalf of LHH as necessary: administrative and operational work in support of our relationship with you, IT providers to host or support our IT systems.
Corporate Transaction Partners and related professional advisors	In connection with the sale, assignment or other transfer of all or part of our business.
Government authorities or lawenforcement	If we in good faith believe we are compelled by any applicable law, regulation, legal process or government authority, or where necessary to exercise, establish or defend legal rights, including to enforce our agreements and policies.
Other third parties	To protect LHH’s rights or property; To protect LHH, our other customers, or the public from harm or illegal activities; To respond to an emergency which we believe in good faith requires us to disclose personal data to prevent harm; or With your consent, such as for social events hosted by LHH or The Adecco Group.

10. Do we transfer or store your data outside of your home country?

We have put in place security measures to prevent your information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed while it is under our control.In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

While we take appropriate technical and organizational measures and have in place physical and electronic procedures necessary to safeguard the personal data that you provide to us, no transmission to or from us by post, email, phone, SMS (text) message or over the internet can ever be guaranteed as entirely secure.
Communications over the web are not completely secure and for this reason, any transmission is at your own risk.

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

11. What data security measures do we have in place?

We have put in place security measures to prevent your information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed while it is under our control.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Communications over the web are not completely secure and for this reason, any transmission is at your own risk.

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

12. What are your rights regarding your personal data?

Under applicable data protection laws, you have the following rights:

Right to be informed about collection or disclosure of your personal data

You have the right to be informed of the categories of personal data that we collect about you as well as the categories of sources from which the personal data was collected.You also have the right to be informed of the business or commercial purposes for which we use, disclose your personal data as well as the categories of third parties with whom we share that personal data, as mentioned in this Privacy Notice.

Right to access and obtain a copy of your personal data

You have the right to request to have access to the personal data that we collected about you and obtain a copy of them under certain circumstances.

Right to correct your personal data

If you can demonstrate that the personal data we hold about you is not correct, you can ask that this information is updated or otherwise corrected.

Right to be forgotten or to delete personal data

In certain circumstances, you have the right to have your personal data deleted. You may make such a request at any time and we will evaluate if your request should be granted, however this right is subject to any legal obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal data deleted must be granted, we will do so within the time limit set by the applicable data protection laws.

Right to restrict or object to the processing of your personal data

In certain circumstances, you have the right to obtain restriction of the processing of your personal data, or to object to certain processing thereof on grounds relating to your particular situation.

Right to data portability

This only applies to the information you have given us. You have the right to ask that we transfer the information you gave us from one organization to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering a contract and the processing is automated.

Right to opt-out from marketing communications and newsletters

Where we send marketing or other communications to you, you may opt out of receiving any further communications by contacting us or using the ‘unsubscribe’ or ‘opt-out’ function when available.

Right to withdraw consent

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to lodge a complaint

You have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your personal data has arisen.

You are not required to pay any charge for exercising your rights. If you want to exercise any of your rights, please fill in our Request Form or send an e-mail to

- At global level: globalprivacy@adecco.com or
- At local level (Luxembourg): privacy_lu@lhh.com.

13. How do we handle changes to this Privacy Notice?

The terms of this Privacy Notice may change from time to time. We shall publish any material changes to this Privacy Notice through appropriate notices either on this Website or contacting you using other communication channels.

14. Getting in touch with us

If you have questions about data protection or if you wish to contact our Data Protection Officer, fill in our Request Formor send an e-mail to

- At global level: globalprivacy@adecco.com or

- At local level (Luxembourg): privacy_lu@lhh.com.

Candidates Privacy Information Statement