Dated Aug 1, 2018
1. Who We Are and What this Policy Is
Welcome to Fuller International LLC New York (“Fuller International,” “we,” “us” and “our” etc.) and its global website https://www.fullerinternational.com. We are a leading executive search firm and trusted advisor to many of the world’s most respected organizations. We provide a variety of services to these clients and other parties, including, but not limited to: (i) executive search (e.g., helping clients recruit executives for their organizations). For additional information on our Services please visit https://www.fullerinternational.com. Our consultants provide these Services globally from offices in several countries.
Fuller International is responsible for the processing of your personal data and information on its website.
In addition to terms defined elsewhere in this Policy, the following terms shall have the following meaning throughout this Policy:
“Personal Information” means any information that either (a) personally identifies a natural person; or (b) pertains to an identifiable natural person, i.e. someone who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity, or (c) constitutes individually identifiable information about an individual consumer collected by us online through our website and that we maintain in an accessible form, or that (d) we are otherwise required to protect under applicable data privacy laws (including, but not limited to, national, international and supranational data protection and privacy laws, directives, regulations and comparable legal acts). Examples of Personal Information include your contact details such as your name, email address, birthday or phone number as well as information about your professional education and experience, skills, preferences, membership in professional organizations, etc.;
“Processing” (and variations such as “Process”) means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, restriction, erasure or destruction;
“Sensitive Personal Information” means Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation;
“Site” means https://www.fullerinternational.com/ and all web pages hosted at that domain (such as the “Home” page at https://www.fullerinternational.com).
3. Processing of Your Personal Information
Depending on your interaction with the Site, your Personal Information is processed as follows:
(i) Your Career – Declaration of Consent
As part of our Services, we specialize in the global search, placement and integration of candidates for executive and similar management positions (each a “Candidate”) on behalf of our clients (“Client Services”).
In the event you are interested in becoming a Candidate, you can provide us with information on your personal and professional background (“Candidate Information”) that we will, subject to our sole discretion, take into consideration as part of the Client Services. To do so, please visit www.fullerinternational.com. Via our REGISTER HERE page you may answer our questions regarding your personal and professional background and upload your CV or resume in Microsoft Word or PDF format.
Providing any Candidate Information is purely voluntary on your part. Although it is generally true that, the more information you share with us, the better we are able to assess your potential suitability for an open executive or similar management position, we urge you not to disclose to us any Candidate Information that is likely of little or no relevance or may not even be legally considered as part of common hiring processes. This applies, in particular, to Sensitive Personal Information.
If and to the extent you share Candidate Information with us through the Site, we might follow up with you using the contact details you may have provided in order to clarify any questions we might have or obtain complementary information from you. In addition, we might conduct assessments of your professional profile and perform searches for information on your personal and professional life publicly available via social media services (e.g. Facebook, Google, LinkedIn, Twitter, etc.), on the Internet or within data you have previously disclosed to us, provided that such information might be of importance to your qualification for a particular executive or similar management position. Any resulting information will be considered Candidate Information and be processed as described below together with the Candidate Information you initially provided us with through the Site.
Your Candidate Information will mainly be processed by and on behalf of Fuller International. However, depending on how and where the Client Services need to be performed in your individual case, your Candidate Information might, in addition, be processed by and on behalf of our affiliated companies in countries throughout the world (the “Fuller International Network”).
Your Candidate Information Processed by Fuller International and/or other companies of the Fuller International Network might contain (a) your contact details (name, address, phone number, email address, etc.), (b) your biographical data, (c) information on your professional education, and (d) your educational credentials, professional diplomas and certificates. In addition, it may contain (e) your employment and compensation history, (f) data on your suitability for client opportunities we compile as part of our assessments of your professional profile, (g) information on your personal and professional life publicly available via social media services (e.g. Facebook, Google, LinkedIn, Twitter, etc.) or otherwise on the Internet that might be of importance to your qualification for a particular executive or similar management position, and (h) any Sensitive Personal Information you might choose to disclose to us.
Your Candidate Information will be shared with third parties as follows:
Your Candidate Information will be stored in databases. The servers hosting the databases are operated by and accessible to members of ZohoRecruit.com or third-party service providers acting on their behalf and as per their instruction in order to operate the servers.
Via the databases, your Candidate Information will be available to the consultants and administrative staff of the different companies in the Fuller International Network for the purposes of providing the Client Services;
Subject to our discretion, we might disclose excerpts of your Candidate Information such as your professional education and employment history with particular clients in order to confirm whether they might be interested in you as a Candidate with respect to an opening for an executive or similar management position they have informed us of. The information disclosed will be limited to what is necessary for this purpose. We will not disclose the entirety of your Candidate Information or otherwise introduce you to any client in detail without first obtaining separate and specific consent from you.
In this context, please be aware that various companies of the Fuller International Network, most of the third-party service providers operating the database servers and some of our clients we might disclose excerpts of your Candidate Information to are located in countries outside of the European Economic Area (EEA) that have not been found by the European Union to provide an adequate level of protection of personal data, i.e. a level of protection of fundamental rights and freedoms that is essentially equivalent to that guaranteed within the European Union. Similarly, the countries your Candidate Information, or parts thereof, might be transferred to in accordance with the above may not be found to provide an adequate level of protection by jurisdictions outside of the European Union. By declaring your consent as set forth below you therefore explicitly and unambiguously (a) agree that your Candidate Information, or parts thereof, may be disclosed or otherwise transferred, as described above, to recipients in countries that may provide different, less or even inadequate protection of personal data as compared to the standards applicable in the jurisdiction you reside or work in or you contact us from, and (b) waive protection according to such standards with respect to the information so disclosed or transferred.
As part of the Client Services, your Candidate Information may be Processed for the purposes of (a) executing searches for potential Candidates on behalf of clients that have an opening for an executive or similar management position, (b) assessing your suitability for client opportunities, (c) informing you of open executive or similar management positions potentially suitable for you, (d) introducing you to clients as a Candidate and potential future member of their management, and of (e) verifying your educational credentials, professional diplomas and certificates. In addition, your Candidate Information may be Processed for the purposes of (f) performing searches for information on your personal and professional life publicly available via social media services (e.g. Facebook, Google, LinkedIn, Twitter, etc.), on the Internet or within data you have previously disclosed to us, provided that such information might be of importance to your qualification for a particular executive or similar management position, (g) providing integration services on behalf of a client you have been placed with by monitoring your integration with the client, speaking with all parties involved and lending support for you to reach full effectiveness in your new role as soon as possible, (h) approaching you, after you have been placed with a client, as a client contact for the placement of other Candidates or as a source of information about potential Candidates for third-party clients, (i) ensuring that, after your placement with a client, you will not be recruited on behalf of another client unless you request consideration for other opportunities, and of (j) operating the databases your Candidate Information is stored in.
At no point will your Candidate Information be matched, linked or otherwise connected with Personal Information collected through other components of the Site for purposes other than providing Client Services. Your Candidate Data will be Processed until you revoke your declaration of consent given when sharing Candidate Data with us. Upon the revocation of your declaration of consent, we will delete your Candidate Data from all databases.
By sharing your Candidate Information with us, you explicitly consent to the Processing of your Candidate Information, including any Sensitive Personal Information you might choose to disclose to us, as described above. This includes, without limitation, the transfer of your Candidate Information, or parts thereof, to countries not providing an adequate level of protection of personal data. You acknowledge that you are under no obligation to provide your consent and that, if you choose to do so nonetheless, you may revoke your declaration of consent at any time with future effect by using the following contact details: firstname.lastname@example.org.
The cookies we use can be categorized as follows:
Session Cookies: These are cookies that allow our Site to collect information about what you do during a browsing session each time you visit the Site. When connecting to our server, your device will be allocated a session ID, which enables our server to identify your device during the session and facilitates Site usability. These cookies are temporary and are set to be deleted when you leave the Site;
Persistent Cookies: These are cookies that are stored by your Internet browser for more than a session and are set to expire within a defined time period. Persistent cookies enable us to remember your settings and information, so you do not have to keep re-entering them whenever you visit our Site. They also measure how you use and interact with the Site and enable us to personalize the Site. For example, they may allow us to alter the rotation of images on the Site so that different images will be displayed on your next visit;
First-Party Cookies: These are cookies that we store and access on your device in our capacity as controller of your Personal Information when you visit our Site. They might include cookies related to third-party service providers, provided that we control and determine the purposes and means of the Processing of your Personal Information logged by such cookies. As a result, first-party cookies might log user-related Personal Information accessible to and Processed by third parties on our behalf and subject to our instructions.
Third-Party Cookies: These are cookies that are stored and accessed on your device by third parties determining the purposes and means of the Processing of your Personal Information logged by such cookies.
However, please be aware that this might render certain functions of our Site inoperable or more difficult to use. Depending on the Internet browser you use, you might also be able to specifically reject third-party cookies. In this context, please note, however, that third parties might still have access to your Personal Information to the extent that such information is logged by first-party cookies.
For additional information on first-party and third-party cookies used on our Site in the context of third-party services and for information on how you might stop such cookies from being stored on your device, please see “Third-Party Services” below.
(iii) Third-Party Services
On our Site, we use the following services provided by third parties:
Our Site uses Google Analytics, a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help analyze how users use the Site.
The information generated by the cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. The United States has not been found by the European Union to provide an adequate level of protection of personal data, i.e. a level of protection of fundamental rights and freedoms that is essentially equivalent to that guaranteed within the European Union. Similarly, the United States may not be found to provide an adequate level of protection by jurisdictions outside of the European Union.
On our behalf, Google will use the information collected for the purpose of evaluating your use of the Site, compiling reports on website activity for us and providing other services relating to website activity and Internet usage to us. Google will not associate your IP address with any other data held by Google. Neither will we match, link or otherwise connect any information received from Google with Personal Information collected through other components of the Site.
Disable Google Analytics
An opt-out cookie will be set on your device, which prevents the future collection of your data when visiting this Site. Be aware, however that the opt-out cookie may only be effective within the Internet browser you used and only for as long as you do not delete the opt-out cookie.
Further information concerning the terms and conditions of use and data privacy can be found at https://www.google.com
Additionally, we use the following Social Media Platform Cookies, all intended to facility linking and following by or from the respective platforms:
1, Hacker Way, Menlo Park, CA 94025, USA
2029 Stierlin Ct. Ste. 200, Mountain View, CA 94043, USA
1355 Market Street, San Francisco, CA 94103, USA
(iv) Do-Not-Track Disclosure
Laws such as California Business and Professions Code § 22575 may require us to disclose how our Site responds to Internet browser “Do Not Track” signals and/or other mechanisms that seek to provide consumers with the ability to control the collection of their Personal Information through online tracking for certain purposes, such as targeted or behavioral advertising.
However, in “Cookies” and “Third-Party Services” above, we describe how you may use mechanisms similar to the “Do Not Track” technology of certain Internet browsers in order to effectively prevent us or third parties from collecting your Personal Information through online tracking. To the extent that you make use of these mechanisms, your preference not to be tracked or to be tracked only to a limited extent will be honored by us and the third parties providing services to us.
(v) Personal Information Pertaining to Children
Our Site and Services are not intended to be used by minors and we do not want to collect information from minors. If a child’s parent or a guardian believes their child may have provided Personal Information to us, please write us using the contact details provided in “How to Contact Us” below and we will delete that Personal Information, subject to the applicable law and this Policy.
4. Data Security
Protecting your Personal Information is important to us. We use appropriate technical and organizational measures and safeguards designed to help prevent unauthorized access, unlawful Processing, and unauthorized or accidental loss of your Personal Information. This includes, for example, the encryption of your communication with us over the Site based on the Secure Socket Layer (SSL) protocol.
5. Your Right to Information
Subject to the applicable law, you have the right to (a) obtain information about your Personal Information we Process, and to (b) request the correction, deletion or blocking of incorrect Personal Information or Personal Information not Processed in line with the applicable legal requirements. To make a respective request, please use the contact details provided in “How to Contact Us” below.
6. Amendments to This Policy
From time to time we may change our business activities and/or our policies and procedures with respect to the Processing of Personal Information. Where appropriate in these cases, we will, subject to applicable law, revise, supplement, or replace this Policy. When the Policy changes, we will post the substitute version and change the effective date listed at the beginning of the Policy.
When required by applicable law, however, we may provide you with advance notice of any changes to this Policy and with an opportunity to object to such changes. If you exercise your right to object, the changes will not become effective with respect to your Personal Information, but your ability to use our Services may be terminated or impaired. We will explicitly notify you of the consequences of the objection or non-objection to the extent and in the manner required by law.
7. How to Contact Us
We encourage your questions and comments about this Policy and our privacy practices. Please contact us using the information below, and we will respond to you as soon as reasonably possible:
Fuller International LLC New York