Stackelberg Consultant (“we”) are committed to safeguarding your privacy. In this Online Privacy Notice (“Notice”) we explain to you what information we may collect, use, share, and store about you, and the choices and rights that are available to you. If you have any questions about this Notice, please contact us using the contact details provided below at ‘Contacting Us’.
We participate in and comply with the relevant laws as supervised by the Indian Department of Commerce regarding the collection, use, and retention of personal information transferred. You can find out more about our Privacy Shield commitments below.
1.When this Notice Applies
Personal information” consists of information which may directly or indirectly identify you.This Notice applies to our collection, use, and disclosure of your personal information:
∙ Through our website(s) and related applications and content that link or refer to this Notice; and Stackelberg Consultant computer or mobile software applications (“apps”) and content made available to you) (collectively the “Sites”);
∙ In connection with any of our events or sales, marketing, advertising and recruitment activities, or in the course of providing other services to you; and
∙ When receiving services from you.
This Privacy Notice does not apply to the practices of third parties that Stackelberg Consultant does not own or control.
2.Collection of Personal Information
Stackelberg Consultant collects and maintains personal information from the following categories of individuals:
∙ Visitors: Individuals who visit or use our site(s) or any other services, so that we can provide them with the site(s) or our services they require;
∙ Job seekers: Individuals that apply for job opportunities with Stackelberg Consultant to fill our internal positions or as part of our staffing and recruiting services or Stackelberg Consultant customers through our search, workforce management, or talent advisory services (in each case, whether such applications are made online or offline);
∙ Customers, vendors, service providers, and other suppliers: Employees, representatives and/or agents of our customers, service providers, vendors, and other suppliers with whom we have a business relationship and/or manage on behalfof our customers.
∙ Referees and others who advise on the suitability of job seekers for particular positions. If you submit any personal information relating to other people to us orour service providers in connection with Stackelberg Consultant, you confirm thatyou have the authority to do so and to permit us to use the information in accordance with this Notice.
3.Types of information we collect include the following:
3.a. Information submitted to us:
Stackelberg Consultant collects personal information that individuals provide to us, such as when they visit one of our Sites, post on our forums or blogs, sign up for a Stackelberg Consultant account to access certain services, like a job board, or if they subscribe to our marketing, register for an event or webinar, or otherwise contact us. We may also collect personal information from individuals’ offline, for example when individuals provide information to us by telephone or in-person at events or one of our recruitment offices.
3.b. Types of personal information we may collect include:
∙ Contact information (such as name, postal address, email address, and telephone number);
∙ Username and password when you register on our Sites;
∙ Professional information, such as your job title, department, or job role;
∙ Information you provide about others you would like us to contact (for example referrals or references) or information regarding your emergency contacts;
∙ Resume or C.V. information, such as employment and education history, language proficiencies, security clearance information, and other work-related skills, awards and honours, membership in clubs and organizations, personal interests and activities, and information regarding your career interests and other qualifications ordesires regarding future employment opportunities, including information regarding desired compensation and benefits; and
∙ Citizenship and work authorization status. Where we request information from you,we will let you know prior to collection whether the provision of the personal information we are requesting is required either by employers as a term of their employment or by law, or whether the information may be provided on a voluntary basis and the
consequences of not providing the information.
3.c. Information we collect automatically:
We automatically collect certain technical information from visitors to our site(s), such as the Internet protocol (IP) address of their device, their login information, device type and unique identification numbers, browser type and version, time zone setting, browser plug-intypes and versions, operating system and platforms. We may also automatically collect certain
information about their visits to our site(s), such as download errors experienced and length of visits to certain pages. When you download, install, or use Stackelberg consultant apps, we and our service providers may track and collect certain device-related information (such as your type and device unique ID) and certain app usage data (such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device ID.
3.d. Information we obtain from other sources or third parties:
∙ We may receive or acquire information about our visitors, job seekers, customers,and suppliers from third-party partners (such as background check providers) or other third-party sources (such as information from publicly available sites (like Monster.com, CareerBuilder.com, or LinkedIn), or a job seeker’s third-party reference.
∙ You may also choose to provide us with access to certain personal information stored by third parties, like social media sites. For example, if you register for an account to access some of our sites, you can choose to import your LinkedIn basic profile data (such as your name, experience, location, photo, and contact information). By authorizing Stackelberg Consultants to have access to this information, in collecting, storing, and using this information, in accordance with thisPrivacy Notice, we will only pursue the legitimate interests set out below under Use of Personal Information.
∙ We collect publicly available information from job boards or professional socialmedia websites where career data is made available by individuals and can be viewed by recruiters.
4.Sensitive Personal Information:
In connection with the various services we provide, or if you are applying for a job opportunity with us or one of our customers, you may be asked for types of personal information that are viewed by some countries as sensitive personal information. Sensitive personal information includes, for example, government-issued identification numbers (such as national insurance numbers), information relating to a person’s race or ethnic origin, political opinions or religious or philosophical beliefs, physical or mental health or condition, sexual orientation, trade union membership, genetic data and any related legal actions, or the processing of biometric data for the purposes of uniquely identifying an individual. It also includes
information about an individual’s criminal offences or convictions,
as well as any other information deemed sensitive under applicable data protection laws (collectively “Sensitive Personal Information”).
Although we aim to minimize the amount of Sensitive Personal Information we process, we may process such information in certain circumstances, such as where we are required to or permitted to do so by law (e.g. information about your racial/ethnic origin, gender, and disabilities for equal opportunity monitoring or affirmative action programs), or where it is necessary to provide you with a service, or if we need to perform a criminal background check,
drug/alcohol test or fitness-for-duty testing. If required by applicable data protectionlaws, we will obtain your express consent to our collection and use of your sensitive personal information.
5.Use of Personal Information:
The personal information we collect will be used only as described in this Notice and/or in the way we specify at the time of collection. For the most part, we collect and use personal information to effectively provide to comply with applicable laws and government regulations (such as, to comply with mandatory employment, tax, and insurance requirements).
More specifically, we may use your personal information for the following purposes:
∙ Providing and administering Stackelberg services and for internal operations (for example, troubleshooting, data analysis,statistical, and survey purposes);
∙ Protecting Stackelberg Consultant (for example, fraud monitoring, and prevention); ∙ Responding to your communications;
∙ Complying with applicable laws and government regulations;
∙ To fulfil your needs if you are a job seeker:
∙ Gauging the number of users and usage of the Site(s), so we can plan Site bandwidth and capacity accordingly;
∙ Recognizing you when you return as a repeat visitor to our Site(s);
∙ Providing information on goods and services you have requested;
∙ For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, services and offerings, enhancing, improving or modifying our Sites, products and services, and operating and expanding our business activities; and
∙ Notifying you about changes to our Site(s).
Personal information collected online through the Stackelberg Consultant sites may also be supplemented with information you provide to us through other services, as well as other online and offline sources (such as recruitment fairs, social media platforms (like LinkedIn), trade shows, or other events) and other data appending methods (such as spot tags, tracking, and cookies as referenced below).
We may also use the personal information we receive for the purposes of creating anonymized and aggregated statistics that do not reveal the specific identity of any person.
In most cases, Stackelberg will process personal information for a variety of business purposes which are in our legitimate interests (for example, to operate its business and provide you with services you have requested), in order to enter into or perform a contract with you and/or for compliance with our legal obligations (as described above). However, insome cases, and always where required by applicable law, we will seek your consent to process your personal information (including any Sensitive Personal Information).
6.Cookies and Online Tracking
Stackelberg Consultant website use “cookies” and similar technologies (like web bugs) tohelp personalize your online experience and for analytics purposes.
∙ A cookie is a small data file placed on the hard drive of your computer when you visit certain websites. A cookie file can contain information such as a user ID that the site uses to track the pages you have visited.
∙ A web bug is a graphic on a web page or email that gathers information about the computers used to view the web page or email. A web bug can collect your computer’s IP address and the time you viewed the website or email.
Some parts of our websites use cookies and web bugs to track user traffic patterns on the Stackelberg sites. Stackelberg does this tracking in order to determine the usefulness of our website information to our users and to see how effective our navigational structure is in helping users reach that information. If you prefer not to receive cookies or web bugs while browsing our website, you can set your browser to warn you before accepting cookies or web bugs and refuse them when your browser alerts you to their presence.
You can also refuse all cookies and web bugs by turning them off in your browser, althoughyou may not be able to take full advantage of our website if you do so. You do not need to have cookies turned on to use/navigate through many parts of the Stackelberg website, except that access to certain Stackelberg Consultant web pages requires a login ID and password.
7.Sharing Your Personal Information
7.a Sharing Your Personal Information within Stackelberg Consultant.
Stackelberg may disclose your personal information to any affiliate within the Stackelberg family, for use in accordance with this Privacy Notice. This sharing of personal informationwith Stackelberg affiliates may include combining the personal information gathered by certain Stackelberg Sites with information independently gathered on other Stackelberg Sites as well as information gathered offline into one or more database(s) useable by Stackelberg Consultants, including all of its affiliates. Again, this combined information will only ever be used for the purposes disclosed within this Privacy Notice.
7.b Sharing Your Personal Information with Third Parties:
Stackelberg may share and disclose personal information about you with the following typesof third parties and in the following circumstances:
7.b.1 Potential Employers or Potential Clients:
We may share your personal information if you are a job seeker with a client for the purpose of providing our staffing and recruiting services, or search, workforce management,or talent advisory services. In connection with the above, we may need to disclose certain data about your previous employment (such as your C.V. and corresponding information or to the extent permitted by law, the results of any criminal background checks or other specific employee data such as SSN/National ID) with that client or other service providers or agents acting on our behalf to facilitate and enable the potential placement or employment. To the extent you are employed by a client of Stackelberg Consultant through our search, workforce management, or talent advisory services, the Stackelberg client will process such personal information in accordance with its policies and procedures.
7.b.2 Compliance with Laws:
We may disclose personal information to a third party where we are legally required to doso in order to respond or comply with any applicable law, regulation, court orders, legal process, or government requests, including in response to public authorities to meet national security or law enforcement requirements.
7.b.3 Vendors, Consultants, and other service providers:
We use third-party vendors, consultants, and other service providers to assist us in providing our services, including to support us in areas such as recruiting and reviewing responses to job advertisements, managing resume/C.V. data, IT platform management or support services, infrastructure and application services, marketing, data analytics, skills and assessments training, occupational health and safety screening, drug and background screening. In providing these services on behalf of us, it may be necessary for us to provide these third parties with access to your personal information. In case of onward transfer to third parties data of individuals resident in India received according to the Indian Privacy Shield, Stackelberg is potentially liable under the Privacy Shield Principles if our agents process your personal information in a manner inconsistent with the principles unless we prove that we are not responsible for the event giving rise to the damage.
7.b.4 Business Transfers:
Circumstances may arise, whether for strategic or other business reasons, Stackelberg decides to sell, buy, merge, or otherwise reorganize businesses. Such a transaction may involve, in accordance with applicable law, the disclosure of personal information to prospective or actual purchasers, or the receipt of it from sellers. It is Stackelberg practice to seek appropriate protection for information in these types of transactions.
7.b.5 Vital Interests and Legal Rights:
We may collect and possibly share personal information and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Stackelberg terms of use, or as otherwise required by law, including without limitation to meet national security or law enforcement requirements. We also may disclose your personal information to third parties when we choose to establish or exercise our legal rights or defend against legal claims.
8.With your Consent:
We may disclose your personal information for other purposes with your consent. Your personal information is never sold, rented, or leased to any external company unless youhave permitted us to do so.
9.Your Privacy Rights
In some regions, you have certain rights under applicable data protection laws in certain circumstances, which include the following rights:
∙ To request access to a copy of your personal information,
∙ To request rectification or erase of data held about you;
∙ To restrict the processing of your personal information; and
∙ To data portability.
In certain circumstances, you may also have the right to object to the processing of your personal information. If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you would like to exercise any of the above rights, please contact us, so that we may assess your request and determine, under applicable law,whether we are in a position to comply with your request.
To protect your privacy and security, we may take steps to verify your identity, such as a password and user ID, before granting access to data.
You also have the right to complain to a data protection authority about our collection anduse of your personal information. For more information, please contact your local data protection authority.
10.Your Choices
Marketing Communications: It is in accordance with your marketing preferences and applicable data protection laws, we may periodically send you updates via e-mail about promotional opportunities or services we think may interest you, such as jobs in our database that match your selection criteria, newsletters, white papers, surveys and eventinformation. You can opt out of receiving marketing emails from us. When we request personal information about you, our sites also allow you to decide which communicationsyou receive.
11.Security of Your Personal Information
Stackelberg is committed to protecting the personal information you share with us. We use appropriate physical, technical, organizational and administrative security measures to help protect your personal information from unauthorized or unlawful access, use, or disclosure, and from accidental loss, destruction, or damage.
Stackelberg supports online security using secure server technology because we want your data to be safe. We use state-of-the-art security arrangements and facilities on our sites to maintain data security. Unfortunately, the transmission of information via the internet cannot be guaranteed to be 100% completely secure and we cannot guarantee the security of your personal information that is transferred over the internet.
If you have reason to believe that your interaction with us is no longer secure (for example,if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
12.Data Retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the service you have requested orto comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information,we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
13.Children’s Privacy
This site is not intended for use by children under the age of 18. Stackelberg does not knowingly collect personal information from children under the age of 18. If we learn that we have collected personal information from a child under the age of 18, we will delete thatdata from oursystems.
14.Links to Other Sites and Public Forums
Stackelberg sites may contain links to other sites for your convenience and information. If you access those links, you will leave the Stackelberg Site. We do not control those sites or their privacy practices, which may differ from our practices. Stackelberg is not responsible for the privacy practices or the content of other websites outside of Stackelberg. The personal information you choose to provide or that is collected by these third parties is not covered by this Notice. We encourage you to review the policies of such third parties before submitting your personal information. We may make message boards, newsgroups, and/or public forums available to users on its sites. Any information that you disclose in these areasbecomes public information that may be accessed by third parties; therefore, you should use caution before
deciding to disclose any personal information in these forums.
15.Contacting Us
If you have any questions about this Notice or if you wish to exercise your Privacy Rights, please send an e-mail to privacy@stackelberg.in.
16.Changes to this Notice
If we change this Notice, we will post the revised Notice on our sites, with an updated revision date. If we make significant changes to our Notice, we may also notify you by othermeans, such as sending an email or posting a notice on our home page. We will update the “Effective Date” at the top of this page to indicate the date from which any changes take effect.
17.Additional Notices
Some Stackelberg services may have additional privacy notices about how such websites, products, and services process personal information. In addition, sometimes Stackelberg acts as a data processor, for example when processing personal information, it receives from one of its clients as part of its staffing and recruiting services, including IT staffing and consulting solutions, workforce management or talent advisory services. Any time that Stackelberg acts as a data processor, it will process personal information according to the contractual obligations it has with the applicable data controller. To the extent Stackelberg receives requests from individuals regarding the processing of their personal information by Stackelberg, it will refer them to and coordinate with the appropriate data controller.