May 23th, 2018

Welcome to SteinmetzPartners - Executive Consultants GmbH, Thorwaldsenplatz 1, 60596 Frankfurt, Germany (“SteinmetzPartners”) and our websites (http://www.steinmetzpartners.com and https://www.recruitercloud.eu ).

We are a executive search and sales consulting company and advise some of the world's largest companies in the IT and management consulting sectors. We provide the following services to these and other clients, including:

• Executive search (e.g., helping clients recruit executives for their IT and consulting organizations)
• Expert search (e.g., helping clients recruit business and IT professionals for their IT and consulting organizations )
• Sales consulting (e.g., helping clients to optimize their sales strategies and processes)

Our consultants provide these services in Germany and Switzerland.

SteinmetzPartners greatly values your privacy and is committed to protecting your personal data.

In this Privacy Policy, we describe how we collect, use, and disclose information relating to individuals (“Personal Information”) who

• visit our website,
• who register in our CareerPortal https://www.recruitercloud.eu ,
• are involved as candidates in our Executive Search projects,
• who have provided us with their contact details so that we can contact them about open positions.

We communicate our data protection declaration to all employees and strictly implement the security precautions within SteinmetzPartners.

Your rights as a party concerned

You can exercise the following rights at any time using the contact details provided by our data protection officer:

• Information about your data stored with us and their processing,
• Correction of incorrect personal data,
• Deletion of your data stored with us,
• Limitation of data processing if we are not yet allowed to delete your data due to legal obligations,
• Objection to the processing of your data with us
• Data transferability, provided you have consented to data processing.

If you have given us your consent, you can revoke it at any time with effect for the future.

You can contact your local supervisory authority at any time with a complaint. Your competent supervisory authority depends on your state of residence, your work or the alleged infringement. A list of supervisory authorities (for the non-public sector) with address can be found at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

The most important elements of our privacy policy

Collection of Personal Information

The extent of the personal data that we store depends on the use of our services. At a minimum, we collect names, contact, employment and education data as well as your industry, technical and management skills, as far as we have these data. If you use our services in their entirety or participate as a candidate in an executive search project, we collect further personal information, such as can usually be found in CVs, competence profiles and project lists.

Indirect Data and Cookies

We collect device information such as your IP address and your browser in order to optimally display information. We only use cookies to store data between dialog steps.

Use of Personal Information and Legal Bases of Processing

We use personal information to provide you with positions that we believe may fit into your career strategy. We also use your personal data so that you can use our online services to create CVs, project lists and competence profiles. If necessary, we are dependent on your consent in order to be able to carry out a transaction or to be able to fulfil our legal obligations.

Disclosure of Personal Information

We will only pass on your personal data to our clients and only if you have given us your consent to introduce you to a client as a candidate for an open position. Your consent only refers to one client and to an explicitly defined position with this client. Under no circumstances will we submit your data (CV, competence profile, project list, certificates) to several clients in parallel.

Security of Personal Information

We maintain reasonable technical and organizational measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Retention

We adhere to the principles of data avoidance and data economy. We therefore only store your personal data for as long as is necessary to achieve the purposes stated here or as provided for in the various storage periods provided for by law. After the respective purpose or expiry of these periods, the corresponding data will be blocked or deleted as a matter of routine and in accordance with statutory regulations.

Access to your data

You have the right and the opportunity to access your personal information at any time to correct, delete, expand or revoke your consent to share it with a specific client by logging into our career portal https://www.recruitercloud.eu or contacting us as described below.

Contact Us

Please contact us with any questions as described below.

Personal information we collect

We store various categories of personal information we need to provide our services. If you are a client or potential client, we collect your name, contact details, title or position, products or services requested, or other information that you provide including via online forms or email correspondence.

If you register via our online form in our career portal https://www.recruitercloud.eu , if you provide us with your contact details in career portals or social networks or if you send us an e-mail, we collect your name, your e-mail address, your contact and address details or other personal information contained in your correspondence. If you as a user of our career portal use the functions for the administration of your CV, your competence profile or your project list, we naturally also store the information that is usually contained in CVs (education, professional stations, hobbies, awards, certificates), competence profiles (technical expertise, industry competence, management experience) or in project lists (project name and subject matter, customer, project duration, assignment, technologies used, methods, procedures, etc.).

When you participate in our executive search consulting services as a candidate and provide a CV, we collect your name, title, professional and personal contact information, date of birth, nationality, family status, results of evaluations, sales performance, employment goals, motivation to switch, desired salary, notice periods, Memberships, awards, details in your CV (careers, educational background, certificates, language skills), reputation, answers to interview questions and financial details (to coordinate and reimburse travel expenses) that we collect from you or third parties such as Career Portals or Social Networks and professional contacts.

In all cases, we ask you by e-mail to give us permission to store this data by clicking a confirmation link and delete the data again if you do not give us your consent within 4 weeks. Unless required or authorized by law, we do not process sensitive Personal Information about you, unless you have affirmatively consented to this processing.

Indirect Data Collection and Cookies

In our career portal https://www.recruitercloud.eu we automatically collect certain device information such as your IP address, unique device identifier, cookies (as described below), geographic data, country, browser, device operating system, application version, language settings and pages displayed to you. Please note, however, that we do not regard this device information as personal information. With the exception of the IP address, we store this information solely for technical reasons to ensure the functioning of the CareerPortal.

Like many other websites, we also use so-called "cookies". Cookies are small text files that are transferred from a website server to your hard drive. This automatically provides us with certain data such as IP address, browser used, operating system and your connection to the Internet.

Cookies cannot be used to start programs or to transmit viruses to a computer. Based on the information contained in cookies, we can make navigation easier for you and enable the correct display of our web pages.

Under no circumstances will the data collected by us in the cookies be passed on to third parties or a link to personal data established without your consent.

You can view our website without cookies. Internet browsers are regularly set to accept cookies. In general, you can deactivate the use of cookies at any time via the settings of your browser. Please use the help functions of your Internet browser to find out how you can change these settings. Please note that some functions of our career portal https://www.recruitercloud.eu may not work if you have deactivated the use of cookies because we use cookies to store dialog data temporarily.

How we use personal information

We use your personal data to offer you positions that we believe might fit into your career strategy. We also use your information to identify you as a suitable candidate for an open position, to respond to your inquiries and to answer your questions about our services. If you are involved in an executive/expert search project as a candidate, we use your personal data to present them professionally to the respective client. We also use your personal data to provide and improve online services, such as the creation of CVs, competence profiles and project lists. We may also use personal data for the purpose of securing our website and our IT systems and other business purposes, including to the extent necessary to fulfill our legal and compliance obligations or in connection with government inquiries, audits, legal claims, subpoenas, representations or other governmental/judicial procedures or inquiries.

Disclosure of personal information

We share personal information with our sister company in Switzerland and with our executive search consultants in connection with the provision of our services in accordance with the terms of this Privacy Policy.

We also disclose personal information to our clients with your consent in order to present you professionally and completely as a candidate. We reserve the right to disclose personal information in connection with the sale, assignment or other transfer of all or part of the business. We also disclose personal information when such disclosure is required by law or appropriate in connection with legal claims, subpoenas, representations or other state/court procedures or inquiries, including to protect the Company or comply with applicable law. We do not sell or rent your personal data.

Security of Personal Information

SteinmetzPartners maintains appropriate technical and organisational measures to protect personal data from loss, misuse and unauthorised access, disclosure, alteration and destruction. If we disclose personal information to clients or our Executive Search Consultants, we require that they also comply with appropriate security and confidentiality measures and use the personal information in accordance with our instructions and applicable law.

To protect the security of your data during transmission, we use state-of-the-art encryption methods (e.g. SSL) via HTTPS in our career portal https://www.recruitercloud.eu .

Retention

We store your personal data for as long as you accept our services or use our online services. Upon request, we will securely delete your personal data so that you can no longer be identified in accordance with applicable law. If you are registered as a user in our career portal https://www.recruitercloud.eu , you can also delete your data yourself at any time. For personal information that we collect and process for other purposes, as described above, we will generally store that personal information for no longer than the time necessary to fulfill the purposes set forth in this Privacy Policy and as otherwise necessary to resolve tax, corporate, compliance, litigation and other legal rights and obligations whereby we will securely delete your personal information and/or take steps to make it properly anonymous.

Access to Personal Information

SteinmetzPartners wishes the personal data to be correct, up-to-date and complete. If the personal data you have previously provided has changed, please enter your new data here .

You have the right to access, modify, supplement or completely delete the personal data that we have about you at any time online. We would be happy to set up an account for you in our CareerPortal https://www.recruitercloud.eu if this account has not yet been set up. Of course you can also contact us by e-mail or telephone and ask us to delete your data. You may revoke your prior consent to the disclosure of your personal data to a client at any time (without prejudice to the legality of the processing due to the consent before its revocation) by contacting us as described below. In particular, you have the right to object to the use of your personal data. Please contact us as described below to exercise these rights. Please note that we must store certain personal data as required or permitted by applicable law.

Links to Other Internet Sites

This data protection declaration applies exclusively to our services. SteinmetzPartners is not responsible for the data protection guidelines of third parties to which we refer with links.

Changes to Our Privacy Policy

SteinmetzPartners reserves the right to amend or supplement the data protection declaration from time to time at its own discretion. If we make a material change to this Privacy Policy, we will post the revised Policy on this website and seek your consent if required by applicable law. Nothing in this data protection declaration is intended to conclude an agreement or contract between SteinmetzPartners and any natural or legal person using this website or providing personal information.

Contact Information

If you have any questions regarding this data protection declaration, if you wish to receive information about your data or if you wish to have your data deleted, please contact our data protection officer, Mr. Herbert K. Schmoll at the email address hks@steinmetzpartners.com or by post:
SteinmetzPartners - Executive Consultants GmbH
Thorwaldsenplatz 1
60596 Frankfurt am Main