PRIVACY POLICY

1. Introduction

The MENITY GROUP (furthermore as "MG") which includes MENITY GROUP LLC and its subsidiaries values you and respect your privacy and recognizes that privacy is important to you. We are committed to protecting, confidentiality and security of the personal data you share with us, or that we collect about you when you use our website www.menity-group.com ("Website") or our mobile applications ("the Apps"), or our Social Media Pages, or HTML-formatted email messages that we send you that link to this Privacy Policy, or when you visit us or otherwise interact with us. ("Offline") We refer to the "Website", the Apps and our Social Media Pages, as the “Online Services". We handle your personal data with utmost care. We have implemented various technical, organisational and operational measures to keep your data safe and secure and protect them from any loss or misuse.

This Privacy Policy explains our personal data privacy practices and the choices you can make about the way your personal data is used. This Privacy Policy confirms our commitment to protect your personal data.

MENITY GROUP is a private owned company and is the sole Controller of all information via "Online Services" and "Offline". MG is management consulting firm. MG offers executive search services to help companies recruit new employees. MG offers as well as leadership development solutions, management consulting, succession planning solutions, and other Human Resources related consulting services. We may collect information about you in connection with these services.

By using our "Online Services" you agree to the terms and conditions set out within this Policy.

If the terms set forth within this Privacy Policy are not acceptable for you for any reason, please do not use www.menity-group.com and "Online Services". Otherwise your continued use of the www.menity-group.com and "Online Services" will constitute your deemed consent to the terms of this Privacy Policy.

II. PERSONAL DATA WE COLLECT

2.1. Personal Data we collect

Personal data are data that identify you as an individual or relate to an identifiable individual.MG is management consulting firm, and for these purposes we collect a variety of personal data necessary to provide such services in a secure and highly confidential way. MG treats all Personal Information in a manner consistent with the requirements GDPR regulation (EU) 2016/679 of the European Parliament. Information we collect about you, when you provide it to us by submitting your CV, such as: your full name, nationality, e-mail address or postal address, telephone number, employer details, employment history, education, certificates, professional credentials, memberships in professional organizations, skills, assessments and interview records, work experience, testimonials, background checks, financial compensation, personal preferences, interests and hobbies, and all information You choose to share with us. We also collect personal information about you from third parties, including social media account ID, images and video and audio and other data publicly available. We may collect your reviews, feedback and opinions about our services any other personal data you choose to provide to us.

If you submit any Personal Data about other people to us, you represent that you have the authority to do so.

We may collect other data that generally do not reveal your specific identity such as: Apps usage information, browser and device data, data collected through cookies, pixel tags and other technologies, demographic data, Aggregated data.



2.2. How we collect Personal Data

We collect Personal Data when you upload your CV or purchase our services from our "Website" or communicate with us, or otherwise connect with us, or participate in a survey. We also collect Personal Data when you attend promotional events that we host or in which we participate. We collect Personal Data when you communicate with us by email, or via online chat or via "the App". We collect Personal Data from companies with whom we partner to provide you with services (e.g. Business Partners include professional social media platform, sourcing platforms).We collect Personal Data from other public sources, marketing partners and other third parties.



2.3. Sensitive data

We request that you do not send us, and you do not disclose to us sensitive data, such as: biometric characteristics, information related to your health background, criminal records, racial related information, religious beliefs, ethnic origin, political opinions, sexual orientation, gender identity or gender expression, trade union membership, social security numbers, credit cards details.



2.4. Minors

Our Services are not directed to individuals under the age of eighteen(18). We do not knowingly collect personal data from minors. We request that they not provide Personal Data through "Website".

III. USE-DISCLOSURE-TRANSFER-CHOICES-ACCESS-RETENTION-REMOVAL OF PERSONAL DATA

3.1 Use of Personal Data

We use Personal Data in support of our Services. To provide you with Services you request. We may use Personal Data to provide you with access to the content on our "Website". We may use personal data to respond to your inquiries. We may keep a record of your contact information in order to provide you with requested services. We use Personal Data to facilitate administrative information, confirmations or to assist you with meetings or events. We will use Personal Data to manage our relationship with you, because we have a legitimate interest to do so. We use Personal Data to personalize the services for you and to improve your service experiences. To understand how our products and services impact you, provide you with a better level of service, and further develop our services. We may use Personal Data to send you marketing communications, offers, customer satisfaction surveys, articles, white papers and other information regarding our Services. We may use your Personal Data with your consent, in press releases and marketing materials. We use Personal Data for data analysis. We may verify that the Personal Data we have collected about you is accurate and current.We may monitor your use of our "Website" and conduct analysis of the use in order to evaluate and improve our "Website" and our services. We use Personal Data to comply with legal obligations to which we are subject. We may use Personal Data collected to identify professional opportunities that we deem relevant and of interest for the candidate and the perspective employer - our customer.We may contact potential candidates from time to time to solicit names in connection with an Executive Search we conduct.

We provide your Personal Data to prospective employers - our customers, only if you authorized us to do so.

Our consulting and leadership development services may require your Personal Data collected about you through assessments. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.



3.2 Disclosure of Personal Data

Our goal is to provide you with the highest level of services. For this purpose, we may disclose your Personal Data between and among MENITY GROUP subsidiaries, for the purposes described in this Privacy Statement. A list of our subsidiaries is provided here.

We may disclose collected Personal Data to our clients via secured portal to which our clients will have access only during conducting our services. We will not disclose your Personal Data including assessments without your consent.

We may disclose Personal Data with select Business Partners who provide services that may include, but not limited to webpage hosting, cyber security, data analysis, information technology and related infrastructure, marketing, attorneys and other services.

We may disclose Personal Data in order to comply with applicable laws, respond to requests from government authorities or public authorities or regulatory authorities including those outside of your country of residence and in accordance with, or required by, any applicable law. We may disclose Personal Data in order to protect the rights, trade marks and privacy of MENITY GROUP, to enforce our Terms of Use.

MENITY GROUP cannot and do not assume any responsibility for the actions or omissions of third parties, such as clients or candidates, including the manner in which clients use Personal Data received from MENITY GROUP. We may disclose aggregate or de-identified data that is not personally identifiable with third parties.

This Privacy Policy does not address, and MENITY GROUP is not responsible for the privacy, data or other practices of any entities outside of the MENITY GROUP. We have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Data. MENITY GROUP is not responsible for the data collection, use, disclosure or security of other organizations, such as Facebook, Google, Microsoft, Linkedin or any other app provider, developer, or social media provider.



3.3 Transfer of Personal Data

MENITY GROUP is an international consulting firm. Sharing data cross-border may be essential to the Services you may receive at the same high-quality wherever you are located. As a result, we may, subject to law, transfer Personal Data. We may transfer Personal Data in order to comply with applicable laws, respond to requests from government authorities or public authorities including those outside of your country of residence and in accordance with, or required by, any applicable law. For the purposes of providing our Services we may transfer your Personal Data between and among MENITY GROUP subsidiaries. Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries can be found here.



3.4 Choices, Access and Removal of Personal Data

You have the choice to provide your Personal Data to us, voluntary. If you would like to ask how we handle your Personal Data, or you wish to review, adjust, correct, update or suppress your Personal Data or if you would like to receive an electronic copy of your Personal Data please contact us at privacypolicy@menity-group.com.

If you wish to remove your Personal Data that you have previously provided to us, please inform us at the privacypolicy@menity-group.com. We will comply with your request as soon as reasonably practicable. We will remove your Personal Data from our database. If you wish no longer to receive marketing-related emails, you may unsubscribe, or follow the instructions in any such email you receive from us or inform us by email at the privacypolicy@menity-group.com



3.5 Retention of Personal Data

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement. We may retain your Personal Data during an ongoing relationship with you and provide the Services to you (for example, considering you for the potential employement, provide assessment services, individual consulting services etc.) We do not retain your Personal Data for longer than five (5) years, subject to local laws and regulations. To the extent required by law, we take reasonable steps to destroy, or de-identify or redact, personal data in a secure manner.



IV. OUR COMMITMENT TO SECURITY

4.1 Security

MENITY GROUP is Data Controller. MENITY GROUP is Data Controller. Unfortunately, no data transmission over network or information system or storage system can be guaranteed to be 100% secure. To protect your Personal Data MG have in place reasonable technical and organisational measures to prevent unauthorized or accidental access or unlawful destruction or loss, alteration, unauthorized disclosure or erasure of your Personal Data. MENITY GROUP cannot guarantee that our „Website“ will function faultless and without any interruptions. We shall not be liable for damages that may result from the use of electronic means of communication.



4.2. Data Processing

MENITY GROUP uses specialized data processing service provided by third party partner (Microsoft Corporation) allowing us to protect your data by Data Loss Prevention (DLP) that can identify over 80 common sensitive data. In addition, DLP allows us to configure actions to be taken upon identification to protect sensitive information and prevent its accidental disclosure. MG use Advanced Data Governance intelligence and machine-assisted insights that help us to find, classify, set policies on, and take action to manage the lifecycle of the data that is most important to protect. MG use Customer Lockbox that can help us meet compliance obligations for explicit data access authorization during service operations and actions taken are logged and accessible to us so that they can be audited.

MG use system that safeguard data and identify when a data breach occurs include, also MG use Advanced Threat Protection that helps protect our email communication. MG use Microsoft Threat Intelligence that helps us proactively uncover and protect against advanced threats and help us quickly and effectively enable alerts, dynamic policies, and security solutions. Advanced Security Management enables us to identify high-risk, potential breaches. MG use system that allows us to monitor and track user and administrator activities across Online platform, which help with early detection and investigation of security and compliance issues.



4.3. SSL encryption

To prevent unauthorized access, maintain accuracy of data and ensure proper use of information, www.menity-group.com has put in place appropriate physical, electronic and managerial security procedures to safeguard all information collected Online by implementing industry-standard SSL encryption.



V. LINK TO OTHER INTERNET WEBSITES, COOKIES, TRACKING

5.1 Third party websites redirection

MG “Website” includes links to third party websites, apps, content, services or resources operated by third parties. Please be aware when you leave www.menity-group.com and visit third party websites, apps, content, services, they may have their own privacy policy. This Privacy Policy applies solely to information collected by the MG “Website”. Information collected by third party websites are not covered by the statements made in this Privacy Policy and may be subject to other less strict policies. This Privacy Policy does not apply to, nor is MG responsible for, any content, privacy practices, or conduct of such web sites. We encourage our users to be aware when they leave our "Website" to read the privacy policies of each and every web site, including those that collect personally identifiable information.



5.2 Cookies Policy

Please be aware that certain sections of the MG "Website" do contain cookies. Cookies are packets of information that are stored on your computer’s hard drive. Cookies allow us to keep track of the areas of the "Website" you visit and thereby offer you easy access to the information you find most relevant. No secure information or information about your personal identity is ever contained within our cookies. For more details please visit our Cookies Policy.



5.3 Tracking data

MG monitors visitor traffic patterns throughout the "Website" by logging Tracking Data, which is collected automatically from each "Website" visitor. Tracking Data may include personal information such as the IP address of the visitor’s computer, its browser type and operating system, the referring site, which pages of the "Website" were visited, the order in which they were visited, and which hyperlinks were “clicked.” MG uses Tracking Data in aggregate form to perform statistical analyses of the collective characteristics and behavior of our visitors, and by measuring demographics and interests regarding specific areas of the "Website".



5.4 Google analytics

MG website uses Google analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the "Website" analyse how users use the site. The information generated by the cookie about your use of the "Website" (including your IP address) will be transmitted to and stored by Google on servers in the United States. The data collected by Google for its subsequent analysis includes:

A) technical data regarding your device (model, operating system, specific device identifiers, and mobile network information, including any phone number associated to the device, etc.)

B) logging on data (search enquiries, phone numbers used to make, receive & forward calls, time, date, length & type of calls, etc.)

C) internet protocol address

D) device activity (settings, browser types, languages, system operations, dates & times of URL request & referral

E) cookies specifically linked to your browsers or accounts

F) location (IP address, GPS, Wi-Fi access points and cellular towers)

G) application installation data (installing & uninstalling certain services)

H) localized device storage (browsing history, caches, etc.)

This information is used for the purpose of evaluating your use of the "Website", compiling reports on "Website" activity for "Website" operators and providing other services relating to "Website" activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this "Website". By using this "Website", you consent to the processing of data about you by Google in the manner and for the purposes set out above.



VI. Changes & questions

6.1 Changes & updates of privacy policy

MG reserves the right to modify or amend the Privacy Policy at any time and for any reason. If there are material changes to the Privacy Policy, we will post those changes here. Please revert to this Privacy Policy from time to time to be informed. If you do not wish to continue using this "Website" after reading the revised Privacy Policy, you will be given an opportunity to opt-out. Nothing contained in this Privacy Policy is intended to create a contractual agreement or legal relationship between MG and any user visiting the "Website" or provide identifying information in any form.



6.2 Questions

If you have any questions about this Privacy Policy, please e-mail us at privacypolicy@menity-group.com





Last update: May 25, 2018