Data Privacy Policy

1. About us and this Policy

Welcome to CE Interim s.r.o., Ukrajinska 8, 831 02 Bratislava, Slovakia, its subsidiaries, and related parties in countries throughout the world (collectively ''CE Interim'', ''we'', ''us'' and ''our'' etc.).

We are a leading executive interim management and executive search consulting firm for Central and Eastern Europe to many of the world’s most respected organizations all over the world. We provide a variety of services ("Services") to these clients and other parties, including, but not limited to:

interim management
confidential executive search
advisory board mandates
urgent vacancies
board members' onboarding, development and mentoring

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.

CE Interim 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 CE Interim s.r.o. and any of its related parties as listed at https://www.ceinterim.com, as the case may be. Our main contact details are set out in the ''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 CE Interim 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, photo, 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.ceinterim.com/ and all web pages hosted at that domain

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 CE Interim.

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. 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, 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 CE Interim and/or selected CE Interim 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. 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 selection 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 your Candidate Information within your own integration, onboarding, 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.

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, interim, advisory board, 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, interim, advisory board, or similar management positions potentially suitable for you;
sending you information or materials that we believe you may find interesting, such as reports, research, insights, 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 CE Interim. 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 CE Interim in various countries worldwide for the purposes of providing the Services;
Clients: If you are a Candidate for Services relating to executive search, interim management, or advisory board mandates, 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. The servers are operated by and accessible to designated employees of CE Interim as well as third-party service providers acting on behalf and as per instruction of CE Interim, for the purposes of website management, information technology and related infrastructure provision.

In this context, please be aware that various CE Interim 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 outside 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 CE Interim 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.

4. Use of our Site
(a) Cookies
Cookie Consent. CE Interim uses cookies and location services for analytics and to enhance site functionality and overall experience. Cookies are small text files that can be used by websites to make a user's experience more efficient.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the Cookie Declaration on our website.

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 ''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. 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:

CE Interim s.r.o.

Ukrajinska 8

831 02 Bratislava
Email: lipovsky@ceinterim.com