Latest Update: June 2020

 Badenoch + Clark Luxembourg S.à. r.l. (“Badenoch + Clark”, “we” or “us”) is committed to protecting and respecting your privacy.

This privacy policy (together with other documents referred to herein) describes what personal information we collect from you and how we process your personal information. 

There is an index below, so you can go straight to the bits you want if you prefer. 

Index: 

Personal data we collect from you 

How we use your information 

Sharing with third parties

IP addresses and cookies

Where your personal data is stored and processed 

Do we transfer your data outside of Switzerland?

Data Security 

Your rights: How we can access, correct and delete your data 

Marketing communications 

Changes to this Policy 

Contact 

Personal information we collect from you

• We will collect personal information on your visits to the Website including, but not limited to, 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. 
• We will collect any information you provide to us when you use our contact forms (for example “Contact”, “Send us a Message”, “Get financial updates”; 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. Other information or personal information you share with us when completing our contact forms is in your sole discretion.. If you contact us, we will keep a record of that correspondence. We use your personal information to send you direct marketing via e-mail when you opt-in for this purpose in the relevant contact form. You may opt-out of receiving future marketing communications at any time. 
• When you use our online services, we also store cookies as set out in more detail in our Cookies Policy.

How we use your personal information?

 Your personal information will be collected and handled by us for the following purposes:

• to best tailor Content and resources according to your preferences.
• to respond to your request or questions when you contact us.
• to send to you other information – such as Badenoch +Clark 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.

Our use of your information as described above is permitted by applicable data protection law because it is: 

• necessary for our legitimate interests in pursuing the purposes set out above, and such interests in each case not being overridden by your privacy interests, 
• in some cases, necessary to meet our legal or regulatory responsibilities, such as disclosures to authorities, regulators or government bodies, or 
• in some cases, necessary for the performance of a task carried out in the public interest and, when we use special categories of personal information, necessary for establishing. exercising or defending legal claims or where the processing relates to personal information manifestly in the public domain,
• in limited circumstances, processed with your consent which we obtain from you from time to time, such as when you opt-in to receive marketing communications and news via email.

We do not make any automated decisions solely on automatic processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

We will keep your information for the longer of the period required in order to meet our legal or regulatory responsibilities. Typically this is for 3 years.

Sharing with third parties

 To facilitate our efficient use of your information, and to provide you with the content and/or resources, 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 engage or employ other companies and individuals to perform functions on our behalf. This category of third-parties includes : 

o Impleo, for IT. This supplier is located in Luxembourg. 
o Davidson, for IT. This supplier is located in Luxembourg 
o TCS, for IT. This supplier is located in India

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 Adecco). A list of Adecco Group companies is included here including their suppliers, contractors and agents, which can be involved in the provision of the Website or the content, so that we can better serve you or, simply, to give response to 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.

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 does not identify you or any individual.

For the same reason, we obtain information about your general internet usage by using a cookie file which is stored on your device. Cookies help us to improve the Website and to deliver a better and more personalised content. For more information about our use of cookies on the Website, please refer to our Cookies Policy.

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.

We endeavour 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 the European Union?

 Your personal information can be transferred and processed in one or more other countries, in- or outside the European Union. We shall only transfer your data outside the EU to 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.

Data Security

 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 unauthorised access, change, deletion or transmission of this personal information.

Your rights: How you can access, correct and delete your personal information

 Under applicable data protection laws, you have the following rights:

• Right to access and obtain a copy of your personal information: You are entitled to 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. In some limited circumstances, you also have the right to request portability of your personal 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 Badenoch + Clark 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, Badenoch + Clark will do so without undue delay.
• Right to restrict or object to processing of your data: In certain circumstances you have the right to obtain restriction of the processing of your personal information, or to object on certain processing thereof on grounds relating to your particular situation. 

To exercise your rights, please fill in the form available here

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 the data protection authority of the Member State of your habitual residence, of your place of work, or of an alleged infringement of your rights.  

Marketing communications

We will only send marketing communications to you via email where you have consented that we may do so.

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 filling in the form available here

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. 

Only the French version of this Policy shall have the force of law. 

Contact

Questions, comments and requests regarding this Policy are welcomed and should be addressed to Badenoch and Clark Luxembourg S.à. r.l. at the following e-mail address: privacy@badenochandclark.lu. 

You can request a copy of mechanisms relating to a specific transfer of your personal information by contacting privacy@badenochandclark.lu 

You can also contact our data protection representative at the following address: privacy@badenochandclark.lu