We are committed to ensuring that all Personal Data, is processed and protected in compliance with the relevant Regulations. The Company takes reasonable technical, physical, and administrative measures to help secure and protect any Personal Data in its custody or control and this page informs you of our policy regarding the collection, use and disclosure of personal information/data. We reserve the right to amend this Policy from time to time.

A. WEBSITE

1. Our website is for informational purposes only and does not collect information such as your name, mailing address, IP address, browsing pattern on the website, click stream data, HTTP protocol elements, and the status of cookies.
2. Notwithstanding the above, all information personally submitted by you, through our website, shall be used by us, in compliance with the Regulations. Your use of the website to contact us implies consent to the Company to use your Personal Data.

B. USE OF DATA

1. The Company is a partner to the Paradigm for Parity and CEO for action group committed to promoting equality in the job market. The Company conducts research to identify candidates suitable for an assigned search, based on the specification and criteria provided by a Client. Personal Data is used for recruitment purposes only.
2. Information that is made available on professional networking websites (‘Public Information’) is migrated to and stored on Ezekia and used to identify candidates suitable for the role.
3. Public Information including contact details, social and professional profiles, education, trainings, and certifications, published works, and work experience is used to evaluate suitability of a Data Subject by Company or Client for relevant roles and stored on the Company database.
4. If further data, not publicly available on professional networking websites is processed or obtained, the Company shall seek active consent from the Data Subject through Ezekia or verbally, to use and process said data.

C. DATA SUBJECT RIGHTS

1. If you wish to identify the source of data related to you, and review the data held by the Company, kindly email compliance@augustleadership.com, title the e-mail ‘Subject Access Request’ and provide relevant details for the Compliance Officer to identify you, trace your records and share a copy with you.
2. Consent granted by you to use data, may be withdrawn at any time by emailing compliance@augustleadership.com.
3. If you wish to have your information removed from our database, but would like to maintain contact with us to hear of job opportunities relevant to you, kindly email compliance@augustleadership.com, title the e-mail ‘Not Actively Looking’ and we shall send an invitation via Not Actively Looking (NAL), a platform designed for executives to share their CV only with executive search firms they chose to follow, to stay connected with the Company.
4. If you wish to have your data amended, kindly email compliance@augustleadership.com, title the e-mail ‘Data Amendment’ and provide relevant details for the Compliance Officer to amend your data.
5. If you would like to ensure that the Company does not maintain your data on its secure database and you do not wish to hear of relevant career opportunities, kindly email compliance@augustleadership.com, title the e-mail ‘Right to be Forgotten’. Alternatively, you may follow the Email Choices and Right to Erasure Request Process and Form.
6. To report any suspected breaches/violation of the Policy, kindly email compliance@augustleadership.com, title the e-mail ‘Policy Violation’ and provide relevant details of the breach including the facts and dates that led you to suspect that a violation occurred along with your contact detail for the Compliance Officer to follow up with you.
7. All requests (‘Data Requests’) received on compliance@augustleadership.com shall be acknowledged by the Compliance Officer within 2 business days and processed within one calendar month of receipt. Notwithstanding the above, investigation of violation of the Policy shall begin within 2 business days of receipt of the report. Every effort shall be made to investigate and resolve reports promptly.

D. DATA PROTECTION MEASURES.

1. While communications over the internet are not completely secure, and no storage system is impenetrable, the Company takes a number of measures to ensure that data is maintained in compliance with the Regulations. The Company does not guarantee that any communications, or any information that you submit or that we collect, in connection with the services or otherwise, will be completely secure.
2. To ensure data security and protection, the Company uses the following service providers:
   1. Ezekia: Ezekia is a UK Customer Relationship Management (CRM) and ATS which includes candidate management, collaboration tools, internal HR, interview management, resume parsing, resume search, job board posting, and interaction tracking capabilities.
   2. Microsoft 365: The Company utilizes Microsoft 365 licenses and its features for the ongoing daily work.
   3. AppRiver: The Company has engaged AppRiver, a US headquartered technology services firm, to enhance security and protection measures at the domain level. AppRiver is providing businesses of all sizes with office productivity, security, and endpoint protection technology and services.

E. COMPLIANCE OFFICERS’ DUTIES.

Compliance officers shall use their best efforts to:

1. investigate thoroughly and with consideration all reports of suspected violations and annually report to the board of the Company on the submissions and resolution of Policy.
2. Process Data Requests within one calendar month and communicate with the Data Subject accordingly

F. DEFINITIONS

1. Data Subject(s).Individuals suitable for a particular role (Candidate); Client representatives; or business development contacts.
2. Client(s). Individuals or companies which require executive search, leadership, and consultancy services.
3. Company. August Leadership LLC, having its registered office at 275 Madison Av, Suite 1500, New York, New York 10016, including its subsidiaries, sub-contractors, and affiliates across the globe.
4. Personal Data. To the Company, Personal Data includes any information that identifies, directly or through reasonably available means, an individual, and shall, without limitation, include their name, email address, address, telephone number, other contact details, details of the required candidate and the nature of a client’s business, salary ranges for the role and any minimum requirements or expectations.
5. Policy. Data Privacy and Protection Policy.
6. Applicant Tracking Systems (ATS).A data processing tool through which all Personal and Public Information is processed, in accordance with the Regulations. Applicable ATS for the Company is Ezekia.

7. Regulations including but not limited to:
   1. California Consumer Privacy Act (CCPA)
   2. General Data Protection Regulation (GDPR)
   3. The California Online Privacy Protection Act (CalOPPA)
   4. The German Bundesdatenschutzgesetz (BDSG)
   5. The United Kingdom General Data Protection Regulation (UK-GDPR)
   6. Mexican Data Privacy Laws

G. OTHER LAW.

Nothing in this policy may be construed in a way that conflicts with any reporting obligations or protections afforded by state or federal law.

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