Lee Hecht Harrison LLC (“LHH”, “we” or “us”) is committed to protecting and respecting your privacy.
This Policy (together with other documents referred to herein) describes what personal information we collect from you and how we process and protect your personal information when you visit ecommerce (the “Website”).
This policy also describes certain choices you have regarding use, access to and correction of your information.
Personal information we may collect from you
We will collect personal information on your visits to the Website including, but not limited to, traffic data, location data, weblogs, content from surveys and contact forms and other communication data and the resources that you access. Our collection of this personal information will make your visit to the Website easier in the future as we will be able to suggest Content that is relevant to you based on the location from which you access the Website.
We will collect any information that you provide to us when you contact us or submit an order for services or products including name, mailing address, telephone number, email address and payment information. We use this information to maintain your account, fulfill your order(s) and provide customer service.
How we use your personal information
Your personal information will be collected and handled by us for the following purposes:
• To fulfill your order, provide customer services and respond to your request or questions when you contact us.
• To send you information about other related LHH products or services that we believe may be of interest to you.
• To help us create, publish, and improve Content most relevant to you.
• To ensure that the Content provided through the Website is presented in the most effective manner for you and for your device.
• To allow you to participate in interactive features of our Website when you choose to do so.
• To further develop and improve the Website, our services, products, and systems to better serve you.
Our use of your information as described above is permitted by applicable data protection law because it is:
• Necessary for the performance of our agreement with you; or
• Necessary for our legitimate interests in pursuing the purposes set out above, and such interests in each case not being overridden by your privacy interests; or
• In some cases, necessary to meet our legal or regulatory responsibilities, such as disclosures to authorities, regulators or government bodies; or
• In limited circumstances, processed with your consent which we obtain from you from time to time, such as when you opt-in to receive marketing communications and news via email.
Do we process information about you without human intervention at all?
We may use automated systems / processes and automated decision-making to better tailor our service delivery to you and ensure you have a bespoke experience. However, we do not make any automated decisions solely through automated means without implementing suitable measures to safeguard your rights, freedoms and legitimate interests.
How long do you keep my Personal Data?
The retention periods of your Personal Data depend on the respective purpose the information is processed for and the respective tool such Personal Data are processed in. It is not possible to provide the various retention periods in a reasonably intelligible format under this Policy. The criteria used to determine the applicable retention period are that we will retain the Personal Information set out in this policy for as long as (i) necessary for the respective purpose, (ii) necessary to carry out our business relationship with you, (iii) you have consented to, and/or (iv) required by applicable statutory retention laws.
Sharing with third parties
To facilitate our efficient use of your information, and to provide you with the content and/or resources, we may disclose your information to third parties. However, this disclosure will only occur in the following circumstances:
• To payment processors, shipping providers, service support providers: we share this data with service providers who offer shipping, payment processing, marketing and analytics, cloud storage, and operational support services to help us fulfill our services and orders. All such recipients will only have access to your personal information as required by them to perform their functions; they are not permitted to use such personal information for any other purposes. These recipients will be subject to contractual confidentiality obligations.
• To other members of The Adecco Group. We are part of “The Adecco Group”, an organization of related companies located across the world who are all subsidiaries of the same ultimate parent company, Adecco Group AG (a legal entity based in Switzerland). The Adecco Group companies perform a range of services including but not limited to temporary staffing and direct hire placement services, payroll services, recruitment and selection services, testing solutions services, career transition services, talent development services, training and education services, outplacement and international mobility services. We may share your Personal Data with other members of The Adecco Group for different reasons:
⁕ Information is shared with members of The Adecco Group that provide IT functions for The Adecco Group companies world-wide.
⁕ information may be shared with other affiliate companies of The Adecco Group locally and/or globally in furtherance of the services we or The Adecco Group provides. A list of the countries in which we operate is available in the ‘choose your country’ function of our website at www.adeccogroup.com.
• To government, police, regulators or law enforcement We may share your Personal
Data with government, regulators or law enforcement agencies if, at our sole
discretion, we consider that we are legally obliged or authorized to do so or we believe
it would be prudent to do so.
• Corporate reorganization. As part of due diligence relating to (or implementation of) a merger, acquisition or other business transaction, we may need to disclose your Personal Data to the prospective seller or buyer and their advisers.
• We will only send marketing communications to you, as an individual, if you have explicitly consented to us doing so. If you do give explicit consent, you have the right to withdraw such consent. You may easily opt out of receiving any further marketing communications at any time. Simply click the ‘unsubscribe’ or ‘opt-out’ function at the bottom of the email. In addition, you can also exercise your opt-out right at any time by contacting us at click here and providing the following information: your name, your email address, a contact telephone number, the marketing communications you would like to opt out of receiving.
• B2B Communications. If you represent our prospect, partner or customer, either prior to entering into an agreement with Adecco or during a business relationship between Adecco and the legal entity which you represent, we may process your basic contact details (e.g. your name, surname, job position, company name, e-mail, and phone number) so far as necessary to carry out our joint business relationship. When we can legally do so, we may augment this information in order to assure that it is accurate. This processing of your personal data is based on our legitimate interest in maintaining and developing our business relationship and customer base, promoting our products, services, and customer loyalty programs. Generally, you cannot opt out of these sorts of communications which are not marketing-related but merely required for the relevant business relationship.
Cookies and automated technology
Automatic Data Collection. In addition to collecting Personal Data, we may use automatic data collection technologies to collect certain statistical (non-identifiable) information about your equipment, browsing actions, and patterns. This includes (i) details about your visits to our Website, which may include traffic data and location data, date and time of access, frequency and other communication data; and (ii) information about your computer and internet connection, which may include your IP address, operating system, browser type, and host domain; and (iii) details of referring website actions and patterns.
Web Beacons. We use a technology known as web beacons to collect your web log information. A web beacon is a small graphic used on a website or within an e-mail message designed to track pages viewed or messages opened. Web log information is gathered by the computer that hosts our Website (called a “webserver”) when you visit our Website. Web beacons in e-mails help us determine which of our e-mail messages were opened and whether a message was acted upon. They also help us analyze the effectiveness of our web pages by measuring the number of visitors to certain pages of our Website and how many visitors click on key elements of it.
If your computer is shared with other people, we advise that you do not select the ‘remember my details’ option when that option is offered by the Website.
Do we transfer or store your Personal Data outside your home country?
Our business operates globally and therefore your Personal Data may be transferred and processed in multiple countries, in or outside the European Union. We shall only transfer your Personal Data countries which the European Commission believes offers an adequate level of protection to you, or where we or the Adecco Group has put in place appropriate safeguards to seek to preserve the privacy of your Personal Data.
For example, all transfers of Personal Information from the European Economic Area, the United Kingdom, or Switzerland to the United States are done pursuant to the European Commission’s standard contractual clauses or, when possible, the binding corporate rules of our third-party vendors, suppliers, or service providers, if applicable.
Continued Compliance and Protection, Though No Longer a Transfer Mechanism
Before July 16, 2020, we relied on our EU-U.S. Privacy Shield certification to transfer Personal Data that we receive from the EU and the UK to LHH in the U.S. On July 16, 2020, the European Court of Justice ruled that the EU-U.S. Privacy Shield is no longer available for these data transfers. Before September 8, 2020, we relied on our Swiss-U.S. Privacy Shield certification to transfer Personal Data that we received from Switzerland to the U.S. but on September 8, 2020 the Swiss Federal Data Protection and Information Commissioner determined that the Swiss-U.S. Privacy Shield is no longer available for these data transfers. We continue to comply with the Privacy Shield Principles described under the preceding paragraph as required by the U.S. Department of Commerce.
In compliance with the Privacy Shield Principles, LHH commits to resolve complaints about our collection or use of your personal information. European Union, UK, and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at firstname.lastname@example.org.
LHH has further committed to refer unresolved Privacy Shield complaints to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit https://bbbprograms.org/programs/all-programs/bbb-eu-privacy-shield-consumers/ProcessForConsumers for more information or to file a complaint. The services of BBB are provided at no cost to you.
LHH commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
You may also have the option to choose binding arbitration under certain circumstances in order to resolve complaints not resolved by any other means. For more information, please visit the Privacy Shield website.
In compliance with the Privacy Shield framework, individuals have the right to access the personal information about them and be able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.
LHH will not sell, share, or rent your personal information to any third party. If we change this policy in the future, we will alert you and also provide individuals with an opt-out or opt-in choice before we share their data with third parties, or before we use it for a purpose other than which it was originally collected or subsequently authorized.
In the context of an onward transfer, LHH has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. LHH shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless LHH proves that it is not responsible for the event giving rise to the damage.
In some cases, LHH may be required to disclose personal information in response to lawful requests from public authorities, including for national security or law enforcement purposes.
The Federal Trade Commission has jurisdiction over LHH’s compliance with the Privacy Shield.
Although we will do our best to protect your personal information, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to the Website or any third party; for this reason, any transmission is at your own risk. We will use strict operational procedures and adequate, technical and organizational security measures to prevent any unauthorised access, change, deletion or transmission of this personal information.
Your choices regarding your Personal Data
You have certain legal rights with respect to the Personal Data that you provide and/or which we obtain about you depending on the country/state where you reside. For example, if you are a resident of the State of California, the California Consumer Privacy Act (“CCPA”) (Civil Code § 1798.100, et seq.) provides you with specific rights regarding your Personal Data depending on the nature of your relationship with us. Additionally, by way of example, if you are a resident of the European Union, the General Data Protection Regulation (“GDPR”) provides you with specific rights regarding your Personal Data depending on the nature of your relationship with us.
Where applicable, your rights include, among others:
- Right to access and obtain a copy of your personal information: You are entitled to request confirmation whether we process any of your personal information. Where this is the case, you may have access to your personal information and to certain information about how it is processed. In some cases you can ask us to provide you with an electronic copy of your information.
- Right to correct your personal information: If you can demonstrate that personal information we hold about you is not correct, you can ask that this information is updated or otherwise corrected.
- Right to be forgotten/have data deleted: 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 rights or obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so without undue delay.
- Object to Processing. In certain circumstances you have the right to object to the manner in which we process your Personal Data, including where we are relying on a legitimate business interest for such Processing or engaging in direct marketing.
- Right to restrict processing: You may be entitled to request that we restrict the Processing of your Personal Data, for example, in circumstances in which the accuracy of the Personal Data is contested.
- California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. Please note that we do not sell your Personal Data to third parties.
To exercise your rights, click here.
To the extent our processing of your personal information is based on your consent, you also have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of such withdrawal.
You can also lodge a complaint about our processing of your Personal Data with your local data protection authority or regulator, as applicable, of your habitual residence, of your place of work, or of an alleged infringement of your rights.
Verifying Your Identity
To exercise the rights described above, it may be necessary for us to verify your identity or authority to make the request and confirm the Personal Data relates to you. To exercise your rights, we will collect your name, e-mail and/or telephone to verify your identity. Upon receiving your request, we may also contact you via e-mail and/or other secured communication channel to verify your identity by asking you additional security questions in order to match your identity with the data we maintain about you.
For residents of California, you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. Your authorized representative may be required to submit a declaration or affidavit demonstrating that they have the authority to act on your behalf.
Once we have verified your identity, if applicable, we will disclose the specific pieces of Personal Data we collected about you, by mail or electronically, at your option, in a readily usable format that allows you to transmit the information from one entity to another entity without hindrance.
Please note that if we cannot verify your identity, we may not be obligated to provide you or your authorized representative information regarding your Personal Data.
Our Website is designed and intended for adults. By accessing and/or using our Website, you represent that you are a legal adult. If you are not a legal adult, you must have your parent or legal guardian access and use the Website for you. If you want to purchase any goods or services that may be offered on our Website, such purchase(s) must be made by your parent or legal guardian on your behalf.
Our Website is not intended for, and we do not knowingly collect information from or otherwise market our website or other materials to children under thirteen (13) years of age. If you are a parent or guardian of a child under the age of thirteen (13) and believe that he or she has disclosed Personal Data to us, please contact us using the information listed in the “Contact” section below. You may review and request the deletion of your child’s Personal Data or prohibit the further use of such information.
Questions, comments and requests regarding this Policy are welcomed and should be addressed to us by mail at: Lee Hecht Harrison LLC, 1209 Orange Street, Wilmington 19801, Delaware; or click here.
You can reach our Data Protection Officer or request a copy of mechanisms relating to a specific transfer of your personal information by clicking here.
Date: 1 July 2021