Last updated: 17 April 2021
Lucioles takes the privacy and security of your information seriously. This Policy describes how Lucioles collect, use, transfer, and disclose your information.
This Policy covers information Lucioles collects in connection with our Executive and Professional Search, IT Recruitment and Corporate Training services (collectively, the “Services”).
This Policy also covers information collected through:
• Web sites we operate from which you are accessing this Policy (the “Site”),
• The software applications we make available for use on or through computers or mobile devices (the “Apps”),
• Our social media pages and apps to which the Site links (collectively, our “Social Media Pages”), and
HTML-formatted or text email messages we send to you that link to this Policy (collectively, including the Site, Apps, and our Social Media Pages, the “Online Systems”).
This Policy also covers other means by which we collect information. For example, it also covers how we collect information from in person discussions, telephone conversations, and through non-electronic communications (i.e., collection through other means than our Online Systems).
PERSONAL INFORMATION WE COLLECT
Lucioles collects information that identifies you as an individual or relates to an identifiable individual (“Personal Information”) to provide Services to you, our clients and to operate our business. The type of Personal Information we collect about you depends on the situation at hand.
• We may collect your name, contact details and your preferred means of communication. We may also collect your responses to survey and assessment questions.
• In the course of our Recruitment Services, we may collect the following types of information about you as a potential candidate: name, address, telephone number, e-mail address, resume information (employment history, education, professional credentials, memberships in professional organizations, skills, etc.), citizenship, information from former employers and other references, and additional information to the extent we have acquired or you have provided us with such information. We also use photos of you that you provide to us or that you make publicly available on the Internet (e.g., LinkedIn). As permitted by applicable laws, we obtain background verification information.
• When you are utilizing our Online Systems, we may collect login user credentials like user names, passwords, and password hints.
• Where permitted by law, we may collect compensation and benefits information about you to consult with you or our clients on rewards and benefits.
• In certain cases, we request sensitive Personal Information about you. We may use this information to ensure that our Services conform with legal requirements, including equal opportunity laws. Our assessments and surveys may include demographic survey questions like questions about gender, race, age, or country of origin. Except in these limited cases, we encourage you not to provide any other sensitive Personal Information to us, such as government identification numbers, payment card numbers, information related to racial or ethnic origin, political opinions, religious or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership.
Please do not provide us with any Personal Information if you do not agree with this Policy.
HOW WE COLLECT PERSONAL INFORMATION
As you interact with Lucioles, you provide some Personal Information directly
• We may collect Personal Information when you register to use our Online Systems, submit or build a resume, respond to employment opportunities, complete online assessments or surveys, participate in online courseware, provide Personal Information about yourself to our coaches or contact us via e-mail, electronic forms, telephone or postal mail.
• If you submit any Personal Information about other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy. Personal Information about you may also come from our clients to whom we provide Services. We may also obtain Personal Information about you from third parties.
• When someone participates in an assessment or coaching experience, they may share Personal Information about you.
When providing our Recruitment Services we may also obtain Personal Information about you from referrals, networking activities, public databases, joint marketing partners, licensed databases, and social media platforms. The information we collect from these third parties includes information about the identity of potential candidates (e.g., an individual’s name, address, telephone number, e-mail address), information about their background and qualifications (employment history, education, professional credentials, memberships in professional organizations, skills, etc.), citizenship, information from former employers and other references. We also use photos of you that you provide to us or that you make publicly available on the Internet (e.g., LinkedIn). As permitted by applicable laws, we obtain background verification information.
HOW WE USE THE PERSONAL INFORMATION WE COLLECT
Lucioles uses the Personal Information it collects in several ways. The summary below provides additional details about the ways we use the Personal Information we collect.
We use your Personal Information to provide our Services.
We use Personal Information to render Services to you and our clients. We do this to fulfill our contractual relationships with you and our clients and where we have a legitimate, beneficial interest in using Personal Information to conduct our business.
In the course of our Recruitment Services, we may use Personal Information that we have collected to create a profile about you. This profile may be used to identify professional opportunities that we think may be of interest to you.
• We may contact you from time to time regarding those opportunities. We may also contact individuals from time to time for referrals. We may solicit names of, or additional Personal Information regarding, potential candidates in connection with our Recruitment Services to understand the market and provide other advisory services to our clients.
You can always object to our creating a profile about you, see the ‘Choices and Access’ section below on how you can object.
• If you object, we will remove your profile from our database, but this will also mean that you will not be considered for opportunities in the future.
In the course of our Recruitment Services, we also use your Personal Information to confirm references and conduct education and background checks as appropriate.
• We further use your Personal Information that we collect to aggregate and disclose diversity and other statistical information regarding our candidates and placement activities. We do so to manage our contractual relationship with you, with your consent, or because we have a legitimate business interest.
We use your Personal Information to respond to your inquiries, to verify your information, or to share information with you.
• We use your Personal Information to respond to your inquiries and fulfill your requests. If you contact us, we keep a record of your contact information and correspondence, and we use information you provide in your message to respond to your inquiry. We do so to manage our contractual relationship with you.
From time to time we use your Personal Information to send you important information regarding the Online Systems, changes to our terms, conditions, policies, and other administrative information.
• We may also contact you to verify that the Personal Information we collected about you is accurate and current. We use the Personal Information to manage our contractual relationship with you or to comply with a legal obligation.
We use your Personal Information to operate our business.
We use your Personal Information for our business purposes, such as audits, internal communication regarding candidates and clients, determining the effectiveness of our promotional activities, administering our Services, maintaining and securing our infrastructure, and for procurement and financial transactions.
• We use this Personal Information to manage our contractual relationship with you and our clients, to comply with a legal obligation, and because we have a legitimate beneficial business interest.
We may use Personal Information to conduct analytics and thought leadership materials. Any published product will refer only to larger aggregations of individuals and will not identify you personally or include any results attributable to you. We perform analytics because we have a legitimate beneficial business interest in doing so.
We may retain and use Personal Information about you for research, publication, development, benchmarking and norms, validation, longitudinal studies, trend analysis, to improve and enhance our Services or to develop and market new Services. We may use Personal Information about you to ensure that our Services conform with legal requirements like equal opportunity laws. We also use your name and other personal identifiers to associate and combine information about you that is collected from one Service with information about you collected through other Services.
• We often pseudonymize or key-code your Personal Information, meaning that the personal is stripped of all information that may directly identify you and is replaced with a code to minimize unwanted or unintended identification. Such key-coded information can be de-coded by using the key so that it identifies you again.
• We may also anonymize, aggregate or de-identify Personal Information so the end-product does not identify you or any other individual. For example, we may use this information to generate norms by industry, geography, level, etc., enable us to understand where our Services are being utilized, conduct ongoing validation studies, compile reports, and publish journal articles to further the knowledge base of organizational and leadership science. Such aggregated, anonymized or de-identified information is not considered Personal Information for purposes of this Policy and we may use it for any purpose.
We may use your Personal Information to send you information or marketing materials. Please note that if we obtained your Personal Information because of a consulting engagement with our client, or you are using our Products at the request of your employer, you will not receive marketing materials as a result of the Personal Information we obtained from those Services.
Lucioles sends informational e-mails, articles, white papers, proposals, engagement letters, and information regarding our Services. We also use your Personal Information to conduct surveys.
• We do so either with your consent or because we have a legitimate beneficial business interest.
• Occasionally, we may desire to use your Personal Information in press releases and direct marketing materials. Before we use your Personal Information in that way, we will obtain consent from you.
WHO HAS ACCESS TO YOUR PERSONAL INFORMATION
How your Personal Information is disclosed will depend upon the situation.
We use your Personal Information to provide our Services.
While providing our Services, we may disclose your Personal Information to clients who have engaged our services.
• In the course of our Recruitment Services, we disclose Personal Information regarding candidates, including the results of assessments and related data, to prospective employers that have engaged Lucioles to fulfill recruitment requests, or to reference sources.
• In the course of our Consulting Services and in providing our Products, we disclose Personal Information to our client. Our client can be your employer or an organization with whom you are seeking employment.
• If you have completed an assessment or survey at our client’s request as part of our Consulting Services or related to a Product, we will not share your assessment results with other clients without obtaining the appropriate consent.
As a global organization, we have affiliates and subsidiaries around the world. To the extent permitted by law, we may share Personal Information with our affiliates and subsidiaries to provide seamless Services for you and our clients. Lucioles is responsible for managing jointly-used Personal Information.
From time to time, we also disclose Personal Information to our strategic alliance partners and to our network of independent consultants who provide services on Lucioles’ behalf for the purposes stated above.
Lucioles discloses Personal Information to third parties who provide support for our Services or business operation.
• Lucioles works with third parties who provide services that may include, but are not limited to, assessment services, including assessment validation services, data analysis, resume verification, background checking and marketing services.
Lucioles may disclose or transfer all or part of your Personal Information in the event of a sale of our company or one or more of our affiliates. We may also disclose or transfer all or part of your Personal Information in the event of a merger or consolidation involving our company or one or more of our affiliates. This may also occur if there is a sale or transfer of assets or of any portion of our business or the business of one or more of our affiliates.
There may be other times that we disclose your Personal Information.
• Lucioles may also use or disclose Personal Information (to comply with a legal obligation or because we have legitimate interest to do so) in order to: (i) comply with applicable laws, (ii) respond to inquiries, requests or orders from public or government authorities, including those outside of your country of residence, or (iii) protect the rights, privacy, safety or property, of Lucioles and our affiliates, you or others.
We cannot and do not assume any responsibility for the actions or omissions of third parties, such as clients, including the way they use Personal Information received either from Lucioles or from other independent sources.
OTHER INFORMATION WE COLLECT
Lucioles collects other information that does not reveal your specific identity (“Other Information”), such as:
• Information collected through cookies, pixel tags, and other technologies,
• App usage data,
• Demographic information and other information provided by you, and
• Aggregated information.
Because Other Information does not reveal your specific identity, we may use it for any purpose. If we combine Other Information with Personal Information that identifies you directly (like combining your name with your location), we will treat the combined information as Personal Information for as long as it is combined.
If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose your Personal Information as detailed in this Policy.
We and our third-party service providers may collect Other Information in a variety of ways.
We use “cookies” (small text files placed on a visitor’s computer hard drive) and other similar technologies to help us determine information like the type of content a visitor to the Site consumes, and the length of time each visitor spends at any area of the Site. Cookies and similar technologies enhance your experience on the Site.
You can configure your browser settings to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie(s) from a particular site. If you disable cookies and similar technologies, your experience on the Site may be diminished and some features may not work as intended.
CHOICE AND ACCESS
Your provision of Personal Information to us is voluntary, although if you do not provide certain Personal Information you may not be able to participate in our Services.
Contact us firstname.lastname@example.org if you would like to:
• Ask questions about how we handle your Personal Information,
• Withdraw your consent to our use of your Personal Information,
• Object to our use of your Personal Information for our legitimate business interests, or
• Request an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law),
• Request to review, correct, update, suppress or restrict the use of your Personal Information,
• To review, correct, update, suppress or restrict the use of your Personal Information, please include all relevant User IDs and e-mail addresses as well as the names of any Lucioles products, or services you may have accessed in your communication to email@example.com.
• Although we strive to maintain accurate Personal Information, if it is determined the Personal Information is not accurate, we will work quickly to correct it.
Request that your Personal Information be removed from Lucioles’ databases,
• To remove your Personal Information from Lucioles’ databases, please include all relevant User IDs and e-mail addresses as well as the names of any Lucioles products, or services you may have accessed in your communication to firstname.lastname@example.org.
• Lucioles will make reasonable attempts to delete Personal Information upon your request.
• Please note that to maintain consistency in our Services and operations, we retain backup systems. When you ask that your information be removed from Lucioles’ databases, we may not be able to delete residual copies from our systems or from our backup systems, but they will continue to be protected as required under this Policy.
If you would like to opt-out of receiving marketing communications from us, please contact us at email@example.com to have your contact information removed from our marketing databases.
• If you request to have your information removed from our marketing databases through an email request, please include “Remove User” in the subject line of the e-mail, and include your full name, User ID, and telephone number in the body of the e-mail message.
• You can also forward a copy of the e-mail or marketing communications from which you want to opt-out.
• We will respond to your request consistent with applicable law. We may decline to process requests that in our reasonable opinion may jeopardize the privacy of others or put our intellectual property at risk.
• Please note that when we perform Services at the specific request of our client, your request may need to be directed to that client. We may only be able to provide you with a non-confidential summary of our final assessment report because these reports contain confidential client personal information that we are not allowed to disclose.
• For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will comply with your request as soon as reasonably practical and may need to contact you to be sure that we understand your request.
We also may need to retain certain Personal Information about you such as your e-mail address to honor opt-out or similar requests. Please keep in mind that this residual Personal Information will remain within Lucioles databases, access logs, and other records, which may or may not contain identifiable Personal Information about you. The residual Personal Information will not be used for commercial purposes. However, Lucioles reserves the right, from time to time, to recontact former users of its Services as appropriate.
LOCATION OF PERSONAL INFORMATION COLLECTED AND MAINTAINED
Depending on the Product or Service we are providing to you, your Personal Information may be collected, used, processed, disclosed, and transferred to and within Mexico, the United States and other countries where we have facilities or in which we engage service providers. By using our Online Systems, Services, you understand that your Personal Information may be transferred to countries outside of your country of residence, which may have different data protection rules than your country.
Lucioles has reasonable organizational, technical, and administrative measures in place to protect against the loss, misuse, and alteration of Personal Information about users of the Online Systems which is under our control. Unfortunately, however, no security system, or system of transmitting information over the Internet can be guaranteed to be 100% secure.
• If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised or your user credentials are no longer secure), please immediately notify us of the problem by contacting us as described in the “Questions” section below.
We retain your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained.
The criteria used to determine our retention periods include:
• The length of time we have an ongoing relationship with you or our client (e.g., for as long as you have an account with us or keep using the Services),
• A period beyond the time of the ongoing relationship if we have a legitimate internal operations need, such as a need to retain such information for analysis, record-keeping and compliance with data retention schedules,
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them), or
• Whether retention is advisable considering our legal position (such as regarding applicable statutes of limitations, litigation or regulatory investigations).
LINKS TO OTHER WEBSITES
This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any other third parties.
• The inclusion of a link on our Online Systems does not imply our endorsement of the linked site. Because these other websites may not be hosted or controlled by Lucioles, this Policy does not address the privacy practices of those websites. We encourage you to review the privacy policies of each of those websites.
• Please note that we are not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of other organizations, such as LinkedIn, Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
UPDATES TO THIS POLICY
Lucioles reviews its privacy practices regularly, and those practices are subject to change. You can determine when this Policy was last revised by checking the “Revised Date” legend at the bottom of the Policy. Any changes to the Policy will become effective upon posting of the revised Policy on the Internet, accessible through the Site.
USE OF ONLINE SYSTEMS BY CHILDREN
The Online Systems are not directed to individuals under the age of sixteen (16), and we request that these individuals do not provide their personal information through the Online Systems.
SUMMARIES OF POLICY
This Policy is the sole authorized statement of Lucioles’ practices with respect to the online collection of Personal Information through the Online Systems and the usage of Personal Information. Any summaries of this Policy generated by third party software or otherwise (for example, in connection with the “Platform for Privacy Preferences” or “P3P”) have no legal effect, are in no way binding upon Lucioles, cannot be relied upon in substitute for this Policy, and neither supersede nor modify this Policy.
Liucioles is responsible for collection, use, and disclosure of your Personal Information under this Policy.
Questions regarding this Policy should be directed to Lucioles at firstname.lastname@example.org or, if by postal mail, at Lucioles, Av. Paseo de la Reforma 180, p.14, Col. Juárez, Alc. Cuauhtémoc, Mexico City 06600, Mexico, Attn: Privacy Office.
ADDITIONAL INFORMATION REGARDING MEXICO
Lucioles uses your Personal Information for the purposes outlined above in the “How We Use The Personal Information We Collect” section. All these purposes, except for marketing, are necessary for maintaining your relationship with Lucioles. If you would like to opt-out of receiving marketing communications from us, please email email@example.com to have your contact information removed from our marketing databases.
Lucioles transfers Personal Information to third parties inside and outside Mexico, as described in the “Who has Access to your Personal Information” section of the Policy. Such transfers do not require your consent, with the exception of a transfer of Personal Information in the case of a merger, consolidation, or sale of assets of Lucioles. Lucioles will transfer your Personal Information in the event of a merger, consolidation, or sale of assets. Your use of the Services means you accept this transfer. If you disagree, please email firstname.lastname@example.org and inform us of your preference.
ARCO Rights: You may exercise your ARCO Rights by contacting the Lucioles Privacy Office by email at email@example.com or by telephone at (+52) 56-1208-6485. Your ARCO Rights are:
• Right of Access: You have the right to request to know what Personal Information Lucioles holds about you and the purposes for which it is processed.
• Right of Rectification: You have the right to request the correction of your Personal Information if it is outdated, inaccurate, incorrect, or incomplete.
• Right of Cancellation: You have the right to request the removal of your Personal Information from Lucioles’ systems if you believe that it is not being used under the principles, duties and obligations set forth in the Law. If your cancellation request is granted, your ability to use the Services and Online Systems may be limited. Please note that to maintain consistency in our Services and operations, we retain backup systems. When you ask that your information be removed from Lucioles’ databases, we may not be able to delete residual copies from our systems or from our backup systems, but they will continue to be protected as required under this notice. We may also need to retain certain Personal Information about you such as your e-mail address to honor opt-out or similar requests.
• Right of Objection: You have the right to object to Lucioles’ use of your Personal Information for specific purposes. If your objection request is granted, your ability to use the Services and Online Systems may be limited.
To exercise your ARCO rights, you may:
• Send your request via email to firstname.lastname@example.org with the subject “Exercise of ARCO Rights”; or
• Submit a printed request, with your handwritten signature, at the address indicated in this section.
Please specify what right(s) you would like to exercise and include sufficient detail to validate your identity and locate your information in our systems. To that end, please provide in your request:
• Your name and a photocopy of your official ID;
• The name and email address you used to register for Lucioles services;
• Your user ID for Lucioles services and products, if applicable;
• Your interactions with Lucioles, including what Lucioles services you used, and whether you took an assessment or survey, as well as a link to the assessment or surveys, if applicable;
• The names of Lucioles consultants or other personnel with whom you worked or corresponded; and
• A clear description of the Personal Information to which your request pertains.
If we require additional information to validate your identity or understand what information you would like to access, rectify, cancel, or object to, Lucioles may ask you to provide it within 10 working days after receiving your request. You will have 10 working days to respond to our request, starting from the day following the day you receive it. If you do not respond within that period, your request will be deemed not received. We will respond by email within 20 days of receiving your request or the additional information, as applicable. If applicable, we will fulfill your request within 10 working days after our response.
Right to Revoke Consent to Processing: You may also revoke your consent where Lucioles’ processing of your Personal Information is based on consent. To do so, send your request via email providing the same information as for ARCO Rights requests, to email@example.com with the subject “Revocation of Consent,” or submit a printed request, with your handwritten signature, to the address indicated at the beginning of this section, stating your request succinctly and clearly. If you revoke consent, your ability to use the Services and Online Systems may be limited.
We will respond to your request(s) consistent with applicable law. We may decline to process requests that in our reasonable opinion may jeopardize the privacy of others or put our intellectual property at risk. Please also note that when we perform Services at the specific request of a Lucioles client, your request may need to be directed to that client. For example, we may only be able to provide you with a non-confidential summary of our final assessment report because these reports contain confidential client personal information that we are not allowed to disclose.
Last Updated: 1 February 2021