OCM General Privacy Statement

General information
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ADO Professional Solutions, Inc., dba OCM and OCM Recruitment Solutions (“OCM,” “we,” “us,” “our”) has a strong commitment to respecting your privacy and protecting your personal information. In this privacy statement ("Statement"), we provide you with details about how we collect, use, disclose, and protect your personal information when you visit our website (https://www.lhh.com/us/en/) or when you access or use any applications, services, or features made available by us through or in connection with our website. This General Privacy Statement applies to OCM, its subsidiaries, and all entities within OCM.OCM is a part of Adecco Group AG, based in Zürich, Switzerland, the largest Human Resources services provider in the world. OCM includes all entities within the Adecco group which operate under the OCM brand name. Our portfolio of brands and business lines includes OCM Career Transitions & Mobility, OCM Leadership Development, the OCM International Center for Executive Options (ICEO), OCM Consulting, OCM Insights, OCM Recruitment Solutions (including Accounting Principals, Ajilon, Paladin, Parker + Lynch, Spring Professional, Badenoch & Clark, Hired), Ezra, and General Assembly.OCM may supplement this General Privacy Statement with other privacy notices, for example, if you register for services seeking an interim staffing placement, you will receive the OCM Recruitment Solutions Candidate Privacy Notice. If you are receiving OCM Career Transition services through your employer, you will receive the OCM Career Transitions Candidate Privacy Notice.

‍Our contact details as the data controller of your personal information
The Data Controller of your personal information is the OCM entity that provides you with the OCM services (“Services”). You can contact the Data Controller for each OCM entity or service by emailing privacy@lhh.com or by using the applicable form below.OCM Career Transition & MobilityOCM Leadership Development & EzraOCM International Center for Executive Options (ICEO)OCM InsightsOCM ConsultingOCM Recruitment SolutionsGeneral Assembly

‍Information we collect about you.
We need to collect information about you to provide you with the Services or the support you request. The type of information we collect can vary depending on the Services that you are accessing, and the country from which you access them.

‍Information You Provide to Use or Purchase our Services.
We collect the following categories of information about you when you purchase or register for our Services, request information on our website, communicate with us, answer our surveys, or otherwise use our Services, including:

‍Identification Information, such as: Your name. In some instances, we will also collect additional proof of identity such as government-issued identification like a passport or driving license.

‍Contact Information, such as: email address, phone number, and postal address. With your consent, we collect your mobile phone number to send you text messages via automated means including 10DLC numbers.

‍Location Information, such as: Country and city of residence; office location.

‍Employment Information, such as: information relating to your current, past, or prospective employment or professional experience (e.g. job history, performance evaluations), and educational background, qualifications, references, training data, salary data, benefits information, survey responses, dependent and beneficiary information.

‍Financial Information, such as: account information, customer correspondence, purchase, or transaction orders.

‍Usage Information, such as: marketing preferences, transactions, products, or services purchased/used.

‍Information You Provide to Enhance Your Experience
You can choose to provide us with additional information to improve your user experience when using our Services:
We collect information that you voluntarily provided to us, including survey responses and suggestions for improvements.

‍Information We Collect from Your Use of our Services
We collect information about you and the devices you use to access the Services, such as your computer, mobile phone, or tablet. The information that we collect includes:

‍Geolocation Information. The location of your device, including your IP address, device language, and location of your network provider. This may include precise geolocation information. For more information and to learn how to disable collection of precise geolocation information, please see below.

‍Device Information. Information about your device, including your hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device’s interaction with our Services.

‍Internet or other electronic network activity information. Information about how you use our Services, including your access time, browser type and language, country and language setting on your device, IP address, the domain name of your Internet service provider, other attributes about your browser, mobile device and operating system, any specific page you visit on our platform, content you view, features you use, the date and time of your use of the Services, your search terms, and the website you visited before you visited or used the Services, if applicable.

‍Inferences drawn from any of the information we collect to create a profile about you that may reflect, for example, your preferences, characteristics, and behavior, including for account security purposes or to enhance our Services to you such as to help prevent fraud.

‍How We Use Your Personal Information & For what legal Basis
We only collect and use your personal information when we have a legal basis to do so, which may include the following scenarios:

‍Consent: When you have given consent for one or more specific purposes. For example, OCM may require your consent to process your data for electronic marketing activities under applicable laws. With your consent, we collect your mobile phone number to send you text messages via automated means including 10DLC numbers with information related to our Services, including account updates, promotional offers, and other relevant information. You can withdraw your consent at any time by contacting us.

‍Contractual Necessity: When processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract. For example, to allow OCM to provide a service to you, such as career transition, leadership development, or recruitment solutions.

‍Legal Obligation: When processing is necessary for compliance with a legal obligation to which OCM is subject. For example, OCM may need to disclose your personal information to a regulator or law enforcement agency, or to verify your identity with government-issued identification.

‍Vital Interests: When processing is necessary to protect your vital interests or those of another natural person. For example, in medical emergencies where OCM needs to process personal information to ensure the health and safety of individuals.

‍Public Interest or Official Authority: When processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in OCM. For example, OCM may process personal information to comply with applicable laws or regulations, or to respond to lawful requests for information from the government or through legal process.

Legitimate Interests: When processing is necessary for the purposes of the legitimate interests pursued by OCM, except where such interests are overridden by your fundamental rights and freedoms. For example, OCM may process personal information to provide, maintain, and improve our Services, to develop new products and services, to measure, track, and analyze trends and usage in connection with your use or the performance of our Services, to conduct surveys and collect feedback about our Services, to protect our Services and comply with our legal obligations, or to communicate with you about opportunities, products, services, offered by us and our affiliated companies. When OCM requests personal information directly from you, you are not obligated to provide it. However, if you choose not to provide this information, in some circumstances, OCM or our clients may be unable to provide certain products or services. For example, we may be unable to process your service delivery or employment.When and with whom we share your informationWe may share the information described in the "Information We Collect About You" section with the following categories of service providers and third parties:

‍With our Affiliates and Group Companies
With our group companies and corporate affiliates, for the reasons outlined above, and as it is necessary to provide our Services to you. For example, we may share your information internally for our legitimate business interests to provide you with enhanced services from OCM, to understand how you engage with our Services to help make our Services better for you, and to help us provide Services tailored to your preferences.

‍With Third Parties
No mobile information will be shared with third parties for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.With service providers who help us provide, maintain, and improve our Services (e.g., service providers who host or support our IT systems; premises management companies; call center service providers; security providers; video conferencing providers; suppliers of service-related tools such as assessments, or practice interviews, virtual job try outs, etc.)With our advertising/analytic partners that run advertising campaigns, analyze our site, and track metrics on our behalf or in connection with our Services. We do not share your mobile number with these third parties.

‍Business Transfers and Corporate Changes
To a subsequent owner, co-owner, or operator of one or more of the Services; or
If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.

‍Safety and Compliance with Law
If we believe that disclosure is reasonably necessary (i) to comply with applicable law, regulation, legal process or governmental request; (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with applicable agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.

‍With Others with Your Consent
With your consent. For example:
At your direction or as described at the time you agree to share.
When you authorize a third-party application or website to access your information.

‍Aggregated and Anonymized Information
We also may share (within our group of companies or affiliates, or with service providers or other third parties) aggregated and/or anonymized information that does not specifically identify you or any individual user of our Services.How long we retain your information.We retain your information only as long as is necessary for the purposes identified in the Privacy Statement, including providing you with the Services, complying with applicable law and legal obligations, and defending our legal rights.

Right to Opt-Out of “sharing” / “sale” – Do Not Sell My Personal Information
Residents of California, Colorado, Connecticut, Utah, and Virginia may request that we not disclose their personal information to third parties in certain circumstances. Specifically, these states’ laws allow you to opt out of (1) the use of your personal information to serve you interest-based, targeted advertisements (referred to as “sharing” for cross-context behavioral advertising in California), and (2) the “sale” of your personal information. If you would like to make a request for us to delete or to stop “selling” your personal information, please fill in the applicable form:OCM Career Transition & MobilityOCM Leadership Development & EzraOCM International Center for Executive Options (ICEO)OCM InsightsOCM ConsultingOCM Recruitment SolutionsGeneral AssemblyYou also may call our toll-free telephone number: 1-800-611-4LHH, email privacy@ocm.com or send a letter to the Privacy Office at 4800 Deerwood Campus Parkway, BLDG 800, Jacksonville, FL 32246.When the privacy office receives your request, they may ask you to verify your identity by asking you to provide your name, the email address and/or phone number associated with your OCM services. Once they have verified your identity, they will promptly fulfill your request.If you would like, you may designate an authorized agent to make a request on your behalf. To designate an authorized agent, please submit an order issued by a court, a document submitted by a barred attorney, or a formal certified document issued by an official governmental agency.

‍Sensitive Personal InformationWe limit the use of your personal information to that use which is necessary to perform reasonably expected services or as required by law.

‍The Right to Non-DiscriminationThe CCPA (California Consumer Privacy Act) prohibits a business from treating a consumer differently because the consumer exercised a right conferred on him/her by the CCPA. We welcome you to exercise your rights under the CCPA, and we will not discriminate against you for doing so.

‍Financial Incentive NoticeOCM does not offer a financial incentive for the collection, sale, or deletion of personal information. As detailed in this Statement, OCM collects personal information from users to fulfill their service requests. OCM also collects personal information for marketing and other purposes as permitted by applicable law.

‍ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF BRAZIL RESIDENTS OR CITIZENS

‍To the extent you are located within Brazil or in any way subject to the Brazilian General Data Protection Law – Federal Law no 13709/18 (“LGPD”), the provisions indicated below should be read and applied to the processing of your personal information accordingly. Unless stated otherwise in this Annex, the remainder of the Privacy Statement shall not vary and shall remain in full force and effect.Data Subjects RightsUnder certain circumstances, you have the following rights under the LGPD in relation to your personal information:

‍Right to Information: right to obtain clear, transparent, and understandable information on how we use your personal information;

‍Right of confirmation and access: right to receive confirmation and access your personal information held by us about you;

‍Right of rectification: right to have your personal information corrected if they are outdated, inaccurate or incorrect and/or to complete them;

‍Right of anonymization, blocking or deletion: Anonymize, block, or eliminate any unnecessary or excessive data or data processed in noncompliance with the applicable law;

‍Right to withdraw consent at any time for consent-based data processing: right to withdraw your consent to the processing of your personal information when such processing is based on consent;

‍Right to data portability: right to request copying, transferring your personal information to another database in accordance with further regulation of the local authority;

‍Right to receive information about public and private entities: right to receive information about public and private entities with which your personal information is shared;

‍Right to object: right to oppose any processing activity based on a legal basis other than consent in case there is violation of the LGPD;

‍Right to review automated decisions: right to review of decisions, whenever they are based only on automated processing of personal information, by a natural person, whenever it affects your interests;

‍Right to file a complaint with your local Data Protection Authority or consumer protection entities.If you have questions about data protection or if you wish to contact our Data Protection Officer, or to exercise any of your rights related to your personal information, please fill in the applicable form:OCM Career Transition & MobilityOCM Leadership Development & EzraOCM International Center for Executive Options (ICEO)OCM InsightsOCM ConsultingOCM Recruitment SolutionsGeneral AssemblyYou also may email privacy@ocm.com.

‍Legal BasesOCM usually relies on one of the following legal bases when processing your personal information for the purposes indicated in the Global Privacy Statement in accordance with Article 7 of the LGPD:Data subject’s consent (art. 7, I)For compliance of a legal or regulatory obligation (art. 7, II)Whenever necessary for the performance of a contract or preliminary procedures relating to contracts in which the data subject is a party (art. 7, V)Whenever necessary for the legitimate interests of the controller or of third parties, except in the prevalence of fundamental rights of the data subject (art. 7, IX).

‍International Transfers

‍Where we transfer information that originates in Brazil to a country outside of Brazil, we will take steps to make sure such transfer is carefully managed to protect your privacy rights:Transfers within the OCM Group of Companies may be covered by an agreement entered into by members of OCM (an intra-group agreement) which contractually obliges each member to ensure that your information receives an adequate and consistent level of protection wherever it is transferred within OCM in accordance with the LGPD.Where we transfer your data outside of the OCM Group of Companies, including to other companies providing us with a service, we will obtain contractual commitments and assurances from them to protect your information, such as standard contractual clauses or binding corporate rules. In the lack of instructions from the local supervisory authority, we may follow the standard models adopted under the European Union or by other competent authorities until then.We can also transfer personal information to countries recognized as providing adequate legal protection or where alternative arrangements are in place to protect your privacy rights.If you want further information on the specific mechanism used by us when transferring your personal information out of Brazil, or you have questions about data protection or if you wish to contact our Data Protection Officer, or to exercise any of your rights related to your personal information, please fill in the applicable form:OCM Career Transition & MobilityOCM Leadership Development & EzraOCM International Center for Executive Options (ICEO)OCM InsightsOCM ConsultingOCM Recruitment SolutionsGeneral Assembly

You also may email privacy@ocm.com.