Privacy Policy

USA

LHi Group Limited , our ultimate holding company, as defined in section 1159 of the UK Companies Act 2006 and our group, including all LHi Group subsidiary companies together (which includes LHi Group GmbH, LHi Group Inc., LHi Group SA and Expert Project Solutions Limited) (collectively "We", “Us”, “LHi Group” or similar) are committed to protecting and respecting your privacy in accordance with your local data protection legislation in each applicable jurisdiction.

This policy (together with our Terms of Use and any other documents referred to on it) sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it. By communicating with Us or visiting www.wearelhi.com or any other website operated by Us at which this or a similar policy is published (“Our Sites”) you are accepting and consenting to the practices described in this policy.

As We also operate in the United States, We have ensured that We are following the California Consumer Privacy Act (CCPA). For all our employees, candidates or applicants working in the United States, please review any changes to this general Privacy Policy in the addendum below. For any areas where the terms of our Privacy Policy differ for our employees, candidates or applicants in the United States, we have highlighted those areas with an Asterix (*) by way of indication in the addendum.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For further inquiries regarding your personal data, please contact data@wearelhi.com or data@wearexps.com. Our dedicated Data team will address all queries.

WHO WE ARE AND WHAT WE DO.

We are a recruitment agency, recruitment business and consultancy. We collect the personal data of the following types of people to allow Us to undertake our business;

· Prospective and placed candidates for permanent or temporary roles;

· Prospective and live client contacts;

· Supplier contacts to support our services;

· Employees, consultants, temporary workers;

We collect information about you to carry out our core business and ancillary activities.

INFORMATION YOU GIVE TO US OR WE COLLECT ABOUT YOU.

This is information about you that you give Us by filling in forms on our site www.wearelhi.com or www.wearexps.com or by corresponding with Us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our

services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site.

The information you give Us, or that We collect about you, may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the relevant country, curriculum vitae and photograph, links to your professional profiles available in the public domain; for example: LinkedIn, Twitter, Indeed, Anyleads, Zoom Info, business Facebook or corporate websites.

INFORMATION WE COLLECT ABOUT YOU WHEN YOU VISIT OUR WEBSITE.

With regard to each of your visits to our site We will automatically collect; technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), roles you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as clicks), and methods used to browse away from the page.

INFORMATION WE OBTAIN FROM OTHER SOURCES.

This is information We obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case We will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact We hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose We intend to retain and process your personal data.

We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.

PURPOSES OF THE PROCESSING AND THE LEGAL BASIS FOR THE PROCESSING.

We use information held about you in the following ways:

· To carry out our obligations arising from any contracts We intend to enter into or have entered into between you and Us and to provide you with the information, products and services that you request from Us or we think will be of interest to you because it is relevant to your career or to your organisation.

· To provide you with information about other goods and services We offer that are similar to those that you have already purchased, been provided with or enquired about.

· The core service We offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.

· Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.

· We will rely on contract if We are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

· We will rely on legal obligation if We are legally required to hold information on to you to fulfil our legal obligations.

· We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.

OUR LEGITIMATE BUSINESS INTERESTS.

Our legitimate interests in collecting and retaining your personal data is described below:

· As a recruitment business, recruitment agency or consultancy We introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.

· In order to support our candidates’ career aspirations and our clients’ resourcing needs We require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

· To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.

CONSENT.

Should We want or need to rely on consent to lawfully process your data We will request your consent orally, by email or by an online process for the specific activity We require consent for and We will record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

OTHER USES WE WILL MAKE OF YOUR DATA.

· Use of our website;

· to notify you about changes to our service;

· to ensure that content from our site is presented in the most effective manner for you and for your computer.

We will use this information:

· to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

· to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

· to allow you to participate in interactive features of our service, when you choose to do so;

· as part of our efforts to keep our site safe and secure;

· to measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you;

· to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

COOKIES.

Our website uses cookies to distinguish you from other users of our website. This helps Us to provide you with a good experience when you browse our website and allows Us to improve our site. For detailed information on the cookies We use and the purposes for which We use them see our Cookie notice.

DISCLOSURE OF YOUR INFORMATION INSIDE AND OUTSIDE OF THE EEA.

We will share your personal information with:

· Any member of our group both in the EEA and outside of the EEA.

· Selected third parties including:

o clients for the purpose of introducing candidates to them;

o candidates for the purpose of arranging interviews and engagements;

o clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;

o subcontractors including email marketing specialists, event organisers, payment and other financial service providers;

o advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;

o analytics and search engine providers that assist us in the improvement and optimisation of our site;

o credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

· In the event that We sell or buy any business or assets, in which case We will disclose your personal data to the prospective seller or buyer of such business or assets.

· If LHi Group or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

· If We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms of business and other agreements; or to protect the rights, property, or safety of LHi Group, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The lawful basis for the third-party processing will include:

· Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;

· satisfaction of their contractual obligations to us as our data processor;

· for the purpose of a contract in place or in contemplation;

· to fulfil their legal obligations.

WHERE WE STORE AND PROCESS YOUR PERSONAL DATA.

The data that We collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (” EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers. Where We have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

RETENTION OF YOUR DATA.

We understand our legal duty to retain accurate data and only retain personal data for as long as We need it for our legitimate business interests and that you are happy for us to do so. Accordingly, We have a data retention notice and run data routines to remove data that We no longer have a legitimate business interest in maintaining.

We do the following to try to ensure our data is accurate:

· Our website enables you to manage your data and to review whether the details We hold about you are accurate

· prior to making an introduction We check that We have accurate information about you

· We keep in touch with you so you can let Us know of changes to your personal data

We segregate Our data so that We keep different types of data for different time periods. The criteria We use to determine whether We should retain your personal data includes:

· the nature of the personal data;

· its perceived accuracy;

· our legal obligations;

· whether an interview or placement has been arranged; and

· our recruitment expertise and knowledge of the industry by country, sector and job role.

We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system.

Our current retention notice is available upon request.

YOUR RIGHTS*

You have the right to ask Us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes and We will collect express consent from you if legally required prior to using your personal data for marketing purposes.

You can exercise your right to accept or prevent such processing by checking certain boxes on the forms We use to collect your data. You can also exercise the right at any time by contacting us at data@wearelhi.com or data@wearexps.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

YOUR LOCAL DATA PROTECTION LEGISLATION PROVIDES YOU WITH THE FOLLOWING RIGHTS.

· Request correction of the personal information that We hold about you. This enables you to have any incomplete or inaccurate information We hold about you corrected.

· Request erasure of your personal information. This enables you to ask Us to delete or remove personal information where there is no good reason for Us continuing to process it. You also have the right to ask Us to delete or remove your personal information where you have exercised your right to object to processing (see below).

· Object to processing of your personal information where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where We are processing your personal information for direct marketing purposes.

· Request the restriction of processing of your personal information. This enables you to ask Us to suspend the processing of personal information about you, for example if you want Us to establish its accuracy or the reason for processing it.

· Request the transfer of your personal information to another party in certain formats, if practicable.

· Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns.

ACCESS TO INFORMATION*

Your local Data Protection legislation gives you the right to access information held about you. We also encourage you to contact Us to ensure your data is accurate and complete. A subject access request should be submitted to data@wearelhi.com or data@wearexps.com.

CHANGES TO OUR PRIVACY NOTICE*

Any changes We make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

CONTACT.

Questions, comments and requests regarding this privacy notice are welcome and should be addressed to data@wearelhi.com or data@wearexps.com.

Addendum for the United States

While our general Privacy Policy addresses the majority of compliance with the California Consumers Privacy Act (CCPA), there are a few changes that we have implemented to ensure compliance. And whilst the CCPA relates to California only, we have adopted this approach for the whole of the United States.

As explained in the Privacy Policy, We only collect data that You have given to us, consented to or that We have a legal basis to collect.

In California the legal basis to collect data is as follows:

(1) Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

(2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

(3) Debugging to identify and repair errors that impair existing intended functionality.

(4) Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

(5) Performing services on behalf of Us or our service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of Us or our service provider.

(6) Undertaking internal research for technological development and demonstration.

(7) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Us.

We identify the types of information collected in the last 12 months, the sources of the information, the purpose of the information, and how the data is shared and why. We do not sell any personal data to third parties.

This specific privacy policy is reviewed and updated every 12 months to ensure it accurately addresses the CCPA as well as any changes within our organization.

What is considered Your personal data?

While We have identified the information that We may collect from you in the Privacy Policy, We wanted to specifically highlight to You all information which may be considered your personal data:

· Personal identifiers, including name, address, email, social security number, driver’s license number and passport number.

· Biometric information.

· Geolocation data.

· Internet browsing history.

· Professional and employment-related information.

· Inferences from personal information to create a profile.

While the above is all considered personal data, any of the above that is publicly available is not considered personal data.

Consumer Rights under the CCPA

· Know what personal information is being collected about You and for it to be deleted.

· Know whether Your personal information is sold or disclosed and to whom.

· Say no to the sale of personal information.

· Access Your personal information.

· Equal service and price, even if You exercise your privacy right

ACCESS TO YOUR PERSONAL DATA

At any time, you may request the right to view or exercise any of the above rights pertaining to any personal data that We may hold for You. We may require a verifiable proof of identity prior to allowing access to any records. For access to your data, contact data@wearelhi.com or data@wearexps.com.

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