Special Counsel, Inc., DBA EQ, DBA SCI, D4, Parker + Lynch Legal (“Special Counsel”, “we” or “us”) is committed to protecting and respecting your privacy.
This Policy (together with other documents referred to herein) describes what personal information we collect from you and how we process your personal information when you use the eqconsulting.com website (“Website”).
Personal information we may collect from you
- We may collect personal information on your visits to the Website including, but not limited to, your IP address, browser, timestamp, traffic data, location data, weblogs, content from surveys and contact forms and other communication data and the resources that you access. Our collection of this personal information will make your visit to the Website easier in the future as we will be able to suggest content that is relevant to you based on the location you access the Website from, what content you access and how you interact with it.
- We may also collect information for marketing purposes and analysis, including information on how you respond to email, sms, phone and other marketing campaigns.
- We will collect any information you provide to us when you use our contact forms (for example “Contact”, “Contact us today”, “Send us a message”, “Get in Touch” or “Contact us about working together”). The provision of your personal information via our contact forms is not a statutory or contractual requirement; however, please note that fields marked with an asterisk (*) are mandatory fields, because we need this information to comply with or respond to your request, or to improve your future experiences with us and our Website. Other information or personal information you share with us when completing our contact forms is at your sole discretion. If you contact us, we will keep a record of that correspondence.
- Fields we may request include but are not limited to: your First name, Last name, Company name, Job title, Business email address, Telephone number, Job function, Job level, Industry, Biggest challenge, Current recruitment model, Your location, type of services need, career opportunities, general opportunities
- We use your personal information to send you direct marketing via email and other communication means when you opt-in for this purpose in the relevant contact form or when applicable law otherwise permits. You may opt-out of receiving future marketing communications at any time by contacting firstname.lastname@example.org.
How we use your personal information
Your personal information will be collected and handled by us for the following purposes:
- to provide you with the services you expect us to
- to best tailor content and resources according to your preferences.
- to respond to your request or questions when you contact us.
- with your consent we may also use your contact data for direct marketing to inform you about services/products/events etc that might be of interest to you (we will communicate by email, telephone, mail and/or other communication methods)
- to send to you other information – such as our upcoming events or newsletters – that may be of interest to you.
- to help us create, publish, and improve content most relevant to you.
- to ensure that the content provided through the Website is presented in the most effective manner for you and for your device.
- to allow you to participate in interactive features of our Website, when you choose to do so.
- to further develop and improve the Website and systems to better serve you. This mainly takes place in the context of new IT systems and processes so that information about you may be used in the testing of those new IT systems and processes where dummy data cannot fully replicate the operation of the new IT system.
- to perform analytical research on our prospective client and candidate base, including the content, and the services/products they are interested in
- to transfer data to third parties (see below)
- where necessary, to comply with any legal obligation; and
- we may also process your information to:
- investigate or respond to incidents and complaints
- comply with obligations and rights and cooperate with investigations carried out by the police, government or regulators.
Do you have to give us the personal information we ask for?
You are not obliged to provide your personal information to us when generally navigating our website, however we cannot fulfil any specific requests for information or provide you with a tailored service unless you do so.
Do we process information about you without any human intervention at all?
Yes, at times we may use automated systems/processes to ensure we give you a bespoke experience with us.
How long do you keep my personal information for?
We will keep your information for as long as you wish to receive our communications and thereafter for the longer of the period required in order to meet our business, legal or regulatory responsibilities.
Sharing with third parties
To facilitate our efficient use of your information, and to provide you with content and/or resources, or to fulfil a request you make of us, we disclose your information to third parties. However, this disclosure will only occur in the following circumstances:
- To suppliers, contractors and agents: from time to time we may engage or employ other companies and individuals to perform functions on our behalf. Examples include the hosting and/or maintaining of website content, or the provision of certain features contained on the Website, and the provision of marketing services.
- Such recipients will only have access to your personal information as required by them to perform their functions, and are not permitted to use such personal information for any other purposes. These recipients will be subject to contractual confidentiality obligations.
- To other entities belonging to the Adecco Group (i.e. any companies directly or indirectly controlled by the Adecco Group). A list of the Adecco Group companies is included here. We share your data with them so that we can better serve you or, simply, to fulfil your requests (e.g. when you use contact us forms).
- To government or law enforcement authorities if we determine in our sole discretion that we are under a legal obligation to do so.
- To our clients: we will share your data with clients of ours who are offering jobs/assignments you may be interested in, or who are interested in your profile. They owe contractual and other confidentiality obligations in relation to your data to us, and to you.
IP addresses and cookies
We collect information about your computer, including (where available) your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and we will not use it in isolation to identify you or any individual. If you provide us with personal data, such as your name, we will then match your IP address and browsing history (for example) with that personal data.
If your computer is shared with other people, we advise that you do not select the ‘remember my details’ option when that option is offered by the Website.
Where your personal information is stored and processed
As explained in the “Sharing with third parties” paragraph above, we share your personal information with the following:
- Third party suppliers, contractors or agents: where we use a third party supplier, contractor or agent, your personal information remains under our control and we have controls in place to ensure your personal information is adequately protected.
- Other companies in the Adecco Group: we have entered into a groupwide arrangement to ensure your personal information continues to be subject to an adequate level of protection.
- To our clients/prospective employers: where we provide your information to a client/prospective employer, we have entered into contractual arrangement for protection of your personal information.
We endeavor to take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.
Do we transfer your data outside your home country?
Your personal information can be transferred and processed in multiple countries, in or outside the European Union. We shall only transfer your data countries which the European Commission believes offers an adequate level of protection to you, or where the Adecco Group has put in place appropriate safeguards to seek to preserve the privacy of your information. Those countries include the United States, among others.
For EU and Swiss Individuals: Privacy Shield Notice for Personal Data Transfers to the United States
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Special Counsel is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Special Counsel’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Special Counsel remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Special Counsel proves that it is not responsible for the event giving rise to the damage.
Special Counsel has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
INDEPENDENT RECOURSE MECHANISMS FOR HUMAN RESOURCES DATA
EU individuals whose HR data we receive can first address questions or comments regarding the handling of that information directly to us at (provide contact info here or refer to it in another part of your document). We resolve to deal with all questions regarding this data and potential grievances arising from it in a timely manner. Note that under certain conditions we may, as a data processor, have to refer you to our client who is the data controller.
In the event Special Counsel is unable to accommodate the individual’s request regarding HR data received by us within the context of the work relationship, we further commit to working with the Data Protection Authorities (DPA’s) who cover the jurisdiction the data originated from. For information on how to contact your EU jurisdiction’s DPA, visit http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. For information on how to contact your Swiss jurisdiction’s DPA, visit https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection---switzerland.html
Although we will do our best to protect your personal information, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to the Website or any third party; for this reason, any transmission is at your own risk. We will use strict operational procedures and adequate, technical and organizational security measures to prevent any unauthorized access, change, deletion or transmission of this personal information.
For EU Individuals: Your Rights under the General Data Protection Regulation
Upon your request, Special Counsel will – to the extent applicable law mandates – provide you with the following, among others:
- Right to access and obtain a copy of your personal information: You may request confirmation whether we process any of your personal information. Where this is the case, you may have access to your personal information and to certain information about how it is processed. In some cases you can ask us to provide you with an electronic copy of your information.
- Right to correct your personal information: If you can demonstrate that personal information we hold about you is not correct, you can ask that this information is updated or otherwise corrected.
- Right to be forgotten/have data deleted: In certain circumstances you have the right to have your personal data deleted. You may make such a request at any time and Adecco will evaluate if your request should be granted, however this right is subject to any legal rights or obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so without undue delay.
To exercise your rights, you can contact us at the following address: email@example.com
To the extent our processing of your personal information is based on your consent, you also have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of such withdrawal.
You can also lodge a complaint about our processing of your personal information with your local data protection authority.
We will only send marketing communications to you via email or other communication means where you have consented that we may do so or as otherwise permitted by applicable law.
We will usually offer you a check box on the forms we use to collect your personal information where, if you agree to receive marketing communications, you have to click the box. Where we send marketing communications to you via email, you may opt out of receiving any further marketing communications by clicking the ‘unsubscribe’ or ‘opt-out’ function in the email. In addition, you can also exercise your opt-out right at any time by contacting us at firstname.lastname@example.org and providing the following information: your name, your email address, a contact telephone number, the marketing communications you would like to opt out of receiving.
Changes to this Policy
The terms of this Policy may change from time to time. We shall publish any material changes to this Policy through appropriate notices either on this Website or contacting you using other communication channels.
You can request a copy of mechanisms relating to a specific transfer of your personal information by contacting email@example.com
You can also contact our local data protection representative at the following address: firstname.lastname@example.org