プライバシー及びクッキー（Cookie）ポリシー

Last updated: July 12th, 2023

1. Who We Are and What this Policy Is

Welcome to Egon Zehnder International Ltd., Wiesenstrasse 17, 8008 Zurich, Switzerland and its subsidiaries in countries throughout the world (collectively ''Egon Zehnder'', ''we'', ''us'' and ''our'' etc.). We are a leading talent advisory firm 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; (ii) executive assessment, development and coaching; (iii) board advisory (e.g. board evaluation and board succession assistance); (iv) C-Suite succession; (v) team development; (vi) organizational design; (vii) diversity and inclusion; and (viii) digital transformation (collectively, and among others, our ''Services''). For additional information on our Services please visit https://www.egonzehnder.com/what-we-do. Our consultants provide these Services globally from offices in more than 36 countries.

We respect the privacy of our clients, candidates and other users of our Services (''you'', ''your'') and are committed to protecting your personal data and information according to the applicable laws. This privacy policy (''Policy'') explains how, to what extent and for what purposes we are collecting and subsequently processing personal data and information.

Egon Zehnder takes its responsibility for the processing of your personal data and information very seriously, whether provided to us on our website, via email, via social networking sites, in person or otherwise.

For the purpose of this Policy, the controller of personal data is Egon Zehnder International Ltd and any of its subsidiaries as listed at https://www.egonzehnder.com/office, as the case may be. Our main contact details are set out in the ''How to Contact Us'' section at the end of this Policy.

2. Definitions

In addition to terms defined elsewhere in this Policy, the ones listed below shall have the following meaning throughout this Policy:

''Candidate'' means any candidate, interested person, or Client employee or board member, who is considered, evaluated, assessed, coached or developed by Egon Zehnder in connection with the Services;

''Client'' means any of the organizations or individuals who contract our Services;

''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.egonzehnder.com/ and all web pages hosted at that domain (such as the ''career'' page at http://career.egonzehnder.com).

3. How We Process Your Personal Information

3.1 For our Services

We perform our Services based on data held by or made available to Egon Zehnder.

In the event you are interested in becoming a Candidate for one of our Services, you can provide us with information on your personal and professional background (''Candidate Information'') that we may take into consideration as part of the relevant Services. For example, you may provide this information directly to one of our consultants, or upload your CV through our Site.

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 you and/or your potential suitability for or within an executive or similar management position, we urge you not to disclose to us any Candidate Information that is likely of little or no relevance for the respective Client Service.

If and to the extent you share Candidate Information with us, 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. If you are a Candidate for Services relating to executive search, we might in addition (i) 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 for the relevant Services; and (ii) source Personal Information about you from third party data providers (e.g. BoardEx), whereby we take appropriate measures to ensure that such third party data providers are legally permitted or required to disclose such information to us. Any resulting information will be considered Candidate Information and be Processed as described below together with the Candidate Information you initially provided us with.

Depending on your interaction with us, your Candidate Information Processed by Egon Zehnder and/or selected Egon Zehnder partners may therefore contain (i) your contact details (name, address, phone number, email address, etc.), (ii) your biographical data, (iii) information on your professional education, (iv) your educational credentials, professional diplomas and certificates, (v) information and responses you may provide to evaluative measures, surveys and interviews, and (vi) any Sensitive Personal Information you might choose and explicitly consent to disclose to us. If you are a Candidate for Services relating to executive search, your Candidate Information may in addition contain (vii) your employment and compensation history, (viii) data on your suitability for Client opportunities we compile as part of our assessments of your professional profile, (ix) 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, or from third party data providers, that might be of importance in connection with the relevant Services, (x) information related to your travels for interviews within a recruitment process, if such travel arrangements are facilitated by us via our selected partners, such as your name, email address, phone number, passport number and date of birth (if mandatory), travel destination(s), and means of transportation, and (xi) in appropriate circumstances and in accordance with applicable local law, information about you which may be classified as ''diversity information'' (such as your racial or ethnic background, gender, disability, age, sexual orientation, religion or beliefs, and/or socioeconomic background). Some of this information is considered Sensitive Personal Information (or protected legal characteristics under certain laws) and as such, stricter data and other protection measures, as required by applicable law, will apply.

Our legal basis for collecting and using your Candidate Information for the Services will depend on the Processing activity involved and the context in which it was obtained and therefore can either be based on our legitimate business interest or on your consent.

As part of Services, your Candidate Information may be Processed for the business purposes of:

• providing Services on behalf of our Clients, which may include Processing of your Candidate Information within your own integration, assessment, coaching or development as part of respective assignments for our Clients;
• operating the databases your Candidate Information is stored in; and
• analyzing your information using analytical tools and comparing the results against other Candidates or potential Candidates, including categorization of Candidates through profiles developed by the software, to assist us in conducting Services.

If you are a Candidate for Services relating to executive search, your Candidate Information may be Processed for the additional business purposes of:

• executing searches for potential Candidates on behalf of Clients that have an opening for an executive or similar management position or for a board directorship, including, but not limited to, (i) assessing your suitability for Client opportunities, (ii) introducing you to Clients as a Candidate, (iii) verifying your educational credentials, professional diplomas and certificates, (iv) where appropriate and in accordance with applicable law, using your diversity information to provide Clients with diverse pools of qualified Candidates, and (v) ensuring that you will not be recruited on behalf of another Client unless you request consideration for other opportunities;
• informing you of open executive or similar management positions potentially suitable for you;
• sending you information or materials that we believe you may find interesting, such as reports, research, invitations to networking events, or information regarding our Services, publications and surveys; and
• approaching you as a Client contact for the introduction of other Candidates or as a source of information about potential Candidates for third-party Clients.

At no point will your Candidate Information be used for purposes other than providing the Services for which your Candidate Information has been intended.
Your Candidate Information will mainly be Processed by and on behalf of Egon Zehnder. However, depending on how and where the Services need to be performed in your individual case, your Candidate Information may be shared with:

• Consultants and administrative staff: Via our proprietary databases, your Candidate Information will be available to the consultants and administrative staff of Egon Zehnder in various countries worldwide for the purposes of providing the Services;
• Clients: If you are a Candidate for Services relating to executive search, 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 such Clients 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 a consent from you;
• Selected partners: Your Candidate Information might be Processed by selected partners with whom we may work on specific projects when providing Services, including third party travel agencies;
• Software service and application providers: Your Candidate Information may be Processed by the software service and application providers as our Processors (such as Microsoft Corporation or Zoom Video Communication, Inc), located anywhere in the world, subject to binding contractual obligations to only Process your Candidate Information in accordance with our prior written instructions and to apply measures to protect the confidentiality and security of your Candidate Information, together with any additional requirements under applicable law; and
• IT infrastructure service providers: Your Candidate Information will be stored on servers located in the European Union, Singapore and in the United States. The servers are operated by and accessible to designated employees of Egon Zehnder as well as third-party service providers acting on behalf and as per instruction of Egon Zehnder, for the purposes of website management, information technology and related infrastructure provision. Physical support of the servers is provided by Amazon Web Services, Inc. and Microsoft Corporation (India) Pvt. Ltd.

In this context, please be aware that various Egon Zehnder companies, most of the third-party service providers operating the servers and some of our Clients or selected partners 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 of the European Union. However, we have taken appropriate safeguards to require that your Candidate Information will remain protected in accordance with this Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Information within the Egon Zehnder group of companies and our third party service providers and selected partners, which require all of them to protect Personal Information they Process from the EEA in accordance with the European Union General Data Protection Regulation.

3.2 Personal Information Pertaining to Children

Our 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. Use of our Site

You can also manage the cookies of various third-party service providers by setting respective opt-out cookies on http://www.aboutads.info/choices/ or http://www.youronlinechoices.com/uk/your-ad-choices.

5. Our 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 Sockets Layer (SSL) protocol.

6. Your Rights

Subject to the applicable law, you have the right: (i) to obtain information about your Personal Information we Process; (ii) to request the correction or completion of incorrect Personal Information we Process; (iii) to request the deletion of Personal Information we Process; (iv) to object to our Processing of your Personal Information or to restrict the way we Process such Information; and (v) to request to receive Personal Information in a structured, commonly used and machine-readable format and to ask us to transmit that Personal Information to you or directly to a third party. To make a respective request, please use the contact details provided in ''How to Contact Us'' below.

7. How we Retain Your Personal Information

We will retain your Personal Information where we have an ongoing consent or legitimate interest to do so. Kindly note that once our relationship with you has ended, your Personal Information may still be relevant for our current or future legitimate business purposes. For example we may be required to retain certain Personal Information: (i) for our business records; (ii) to be able to establish, exercise or defend our legal rights; (iii) to show that we are compliant with applicable laws; or (iv) to show that we have fulfilled or continue to fulfill our obligations towards our Clients in relation to Services you may have been involved in.

8. 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.

9. Additional Information if you are a Resident of California

9.1 Notice at Collection

We collect the categories of Personal Information (as defined in the California Consumer Privacy Act (CCPA) listed in the table below:

As further described in Section 3 (How we process your Personal Information), we generally collect and use the listed categories of Personal Information for the business purposes of providing the Services on behalf of our Clients.  We retain your Personal Information as described in Section 7 (How we retain your Personal Information) . The sources of the Personal Information are from you, from our Clients, from publicly available online sources, from referees and from third party data providers (e.g., BoardEx).  

Certain data collection on our website by third parties for purposes of interest-based advertising and other marketing or analytics tools may constitute a “sale” or “sharing” under California privacy law.  We may “sell” and “share” your Personal Information associated with use of the Site with third parties offering these tools, including ad tech vendors, analytics providers, and social media companies. You may opt-out at any time.  We do not knowingly ''sell'' or “share” (as these terms are defined under the CCPA) Personal Information of persons under 16 years of age.

9.2 Your Rights

If you are a resident of California, you can take advantage of the following rights:

(a) You may request, up to two times each year, that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information that we sold about you, the categories of third parties with whom we have shared your Personal Information, and the business or commercial purpose for selling your Personal Information, if applicable. 

(b) You may request that we delete any Personal Information that we have collected from or about you. If we cannot delete all of your information, we will let you know the reason for non-deletion, such as if we need to complete a transaction for you, or for a legal reason.

(c) You may request that we correct inaccurate Personal Information that we maintain about you upon presentation of documentation supporting the correction.

Your authorized agent may submit a request on your behalf, after submission of proof of authorization in accordance with California law.

To take advantage of any of the foregoing rights, or if you have questions about your rights, please contact us at dataprivacy@egonzehnder.com or by toll-free number at +1-833-622-0373. We will respond to your request within 45 days unless we need additional time, in which case we will let you know. We may take steps to verify your identity before responding to your request. If you exercise any of the foregoing rights, we will not discriminate against you, such as by denying you access to our Services or restricting your access to Services of certain pricing or quality.

9.3 Sales and Sharing of Personal Information

Certain data collection on our website by third parties for purposes of interest-based advertising and other marketing or analytics tools may constitute a “sale” or “sharing” under California privacy law or “targeted advertising” under local data protection laws. You or your authorized agent may request to opt out at any time using the Do Not Sell or Share My Personal Information link at the bottom of this page. You may choose to enable an online tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). When detected, we will process such signals as a request to opt out of sales and sharing of Personal Information.

We will not discriminate against you for the exercise of your opt-out rights.  Your authorized agent may submit an opt-out request on your behalf after submission of proof of authorization in accordance with California law.

9.4 Sensitive Personal Information

To the extent that we collect, use, or share Sensitive Personal Information, we limit our use or disclosure of the Sensitive Personal Information for permitted business purposes in accordance with California law.

10. Additional Information regarding South Africa

If and to the extent the Protection of Personal Information Act 4 of 2013 (“POPIA”) is applicable, the terms “Personal Information” and “Sensitive Personal Information” shall have the following meaning throughout this Policy: 

“Personal Information” means any information that either (a) personally identifies a natural person and/or a juristic person; or (b) pertains to an identifiable natural person and/or a juristic person, i.e. someone who can be identified or a company that can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, company logo, 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 or a juristic person who is a consumer, which Personal Information is 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, company logo, birthday or phone number as well as information about your professional education and experience, skills, preferences, membership in professional organizations, etc.;

''Sensitive Personal Information'' (also known as Special Personal Information in terms of the Protection of Personal Information Act 4 of 2013), 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; or the criminal behavior of a person subject to the extent that such information relates to (a) the alleged commission by the person of any offence or (b) any proceedings in respect of any offence allegedly committed by a data subject or the disposal of such proceedings .

11. 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:

Egon Zehnder International Ltd.
Wiesenstrasse 17
8008 Zurich
Switzerland
Email: dataprivacy@egonzehnder.com