Privacy Policy

Website Privacy Policy

BACKGROUND

Imperium Global is a leading executive search and assessment firm that has successfully placed in over 53 countries worldwide. Imperium Global (“Imperium Global”) take data privacy seriously and maintain a Privacy Policy (“Policy”) to explain how, to what extent and for what purposes we are collecting and subsequently processing personal information on individuals who visit this website or participate in our board and executive search and assessment services.

Imperium Global is the responsible entity for processing of your personal data and information on this website, and we are committed to protecting the privacy of your personal data. This Policy is effective as of January 1st, 2018. We reserve the right to change, modify, add or remove portions of this Policy at any time, at our sole discretion, and will inform you if we make material changes by indicating on the Policy the date it was last updated or otherwise. When you visit the website or are engaged with us in connection with our board and executive search and assessment services, you are accepting the current version of this Policy as posted on the site at that time.

OUR VALUES

We take the utmost care in storing and using the sensitive information entrusted to us by our business partners. We are committed to protecting the reasonable privacy expectations of everyone with whom we do business, including our clients, candidates and employees.

We are privy to a great deal of sensitive information, including confidential information about our clients’ businesses and the professional aspirations of executives. The foundation of all our services and advice of our candidates and clients trusting us with sensitive information and understanding that we only share information consistent with our intentions. They trust us to protect their information and use and maintain it according to our published policies. We cannot continue to serve as a trusted advisor unless we are able to clearly demonstrate our conscientious handling of confidential information and our ability to protect it fully.

THE INFORMATION WE COLLECT

Imperium Global is an executive search firm and collects a variety of personal data necessary to provide such services in a proprietary and highly confidential database accessible on by Imperium Global Consultants. To provide our clients with board and executive search and assessment services and communication and collaboration among employees of Imperium Global, Imperium Global collects and processes information relating to individuals (referred to as “Personal Information”) which typically includes information in a standard curriculum vitae (e.g., name, address, telephone number, e-mail address, employment history, degree(s) and other qualifications, languages and other skills). It may also include, without limitation: age, nationality and race (only to the extent allowed by law), compensation details, a record of our contact history with you and comments from third parties. Our records derive from information collected directly from you, publicly available sources and third parties.

By submitting your information to Imperium Global, by whatever means, you indicate your willingness to disclose information to Imperium Global and to be considered, when appropriate, for one of Imperium Global’s confidential executive searches. If you do not wish to disclose your personal information, Imperium Global will be unable to provide you the services offered by this website, since employment, educational and other personal information is necessary in order to asses your employment opportunities. If you object to your information being shared and transferred in such manner or if you do not wish to participate in this service and benefit from the executive career searches that Imperium Global provides, please do not enter your personal information into the website.

HOW WE PROCESS PERSONAL INFORMATION

We will use Personal Information to contact you about board and executive search or assessment assignments conducted for our clients that involve the identification, evaluation and/or selection of qualified candidates. In order to present you as a potential candidate to potential employers (Imperium Global clients), your personal information may be shared with clients and/or transferred between Imperium Global’s national office and Consultants. Each Imperium Global office entity is committed to implementing the appropriate data integrity and security measures required of the country in which it resides in order to protect your information.

DATA STORAGE

Your information is maintained on Imperium Global’s CRM database, which is secure and accessible only to Imperium Global employees. Outside the Imperium Global network, your information may also be disclosed on a confidential basis to (a) clients who will also need to process your information for the purposes we have described in this Policy; (b) third parties when required by law; and (c) service providers, but only to the extent necessary to perform work directed by us (such as security services, web hosting, background checking and other administrative services). Personal Information is retained until the purposes have been fulfilled or otherwise required by law.

HOW LONG WE KEEP YOUR DATA

We will retain your information for up to 4 years or until you directly request for us not to, in order to handle any outstanding or future enquiries. After this time, it will be destroyed.

DISCLOSURES OF PERSONAL INFORMATION

We are not in the business of selling or renting your information to third parties and do not share your personally identifiable information with others, except as follows: we freely share your information within Imperium Global; we may share your information as required by law or in the interest of protecting or exercising our or others’ legal rights, for example, in connection with court proceedings or requests from law enforcement officials. Also, we reserve the right to use and disclose any information collected via the website that is not in personally identifiable form. SMS opt-in or phone numbers for the purpose of SMS are not being shared.

YOUR RIGHTS

You have the right to withdraw your consent at any time or to access and request that we rectify or remove your record from our system(s). When asked to remove a record from our database, Imperium Global will retain minimal Personal Information in order to prevent future contact, to keep a record of the information disclosed to our clients and to preserve Imperium Global’s interests in accordance with any applicable legal requirements. If you withdraw your consent to our Policy you will not be able to be a part of a Imperium Global search or assessment project. You may exercise these rights by contacting your Imperium Global Consultant. Imperium Global will comply with any request as required by law.

SMS COMMUNICATION

Consent for SMS Communication
Information obtained as part of the SMS consent process will not be shared with third parties

Types of SMS Communications

If you have consented to receive text messages from Imperium Global, you may receive text messages related to job application, information about your application status, onboarding materials, or other employment-related updates. Message and data rates may apply. You can opt-out at any time by texting “STOP.” For assistance, text “HELP”

CONTACT US

Please feel free to contact us with any comments, questions, complaints or suggestions you might have regarding the information or practices described in this Policy. You may contact us by sending a message to info@imperial-global.com or write to us at Imperium Global, 9th Floor, 33 Cavendish Square, London W1G 0PW. Attention: Managing Director

Client Privacy Policy

Scope and Overview

Imperium Global Search Ltd. is committed to protecting the privacy and security of your personal data.  This Privacy Notice describes how Imperium and its subsidiaries, affiliates, and related entities (collectively, “Imperium,” “we,” or “us”) collect and process personal data about you as clients and prospective clients of Imperium.  This Privacy Notice applies to current, past and prospective clients and customers of Imperium.  This privacy notice applies to data subjects located in in all jurisdictions and territories where they are based.

This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction.  This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.

We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law.  We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

Collection of Personal Data

For the purposes of this Privacy Notice, personal data means any information about an identifiable individual.  Personal data excludes anonymous or de-identified data that is not associated with a particular individual.  To carry out our activities and obligations as a recruiter, we may collect, store, and process the following categories of personal data, some of which we require to administer the services and relationship with you or the organisation(s) you represent:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• Gender
• Start date and job title
• Location of place of work
• Education and training
• Employment records (including professional memberships, references, work history, and proof of work eligibility)
• Photograph
• Voice recordings e.g. telephone calls
• Video recordings e.g. meetings

The personal data listed in this notice is information we may obtain in the ordinary course of our business relationship.

We will collect the majority of the personal data that we process directly from you or from your organisation(s).  In limited circumstances third parties may provide your personal data to us, such as referral bodies, social media (such as LinkedIn), public organisation information (such as websites) and data service providers.

Use of Personal Data

We only process your personal data where applicable law permits or requires it, including where the processing is necessary for the performance of our contractual obligations with you or your organsiation(s), to offer our services to you, to demonstrate the services that were performed or offered to be performed, where the processing is necessary to comply with a legal obligation that applies to us as a service provider, and for our legitimate interests or the legitimate interests of third parties.  

We may process your personal data for the following legitimate business purposes and for the purposes of performing the employment contract with you:

• To offer legitimate business services to you and/or the organisation(s) you represent
• Business management and planning
• Accounting, invoicing and auditing
• Gathering evidence for claims as may be necessary
• Complying with applicable law
• Education, training, and development requirements

We will only process your personal data for the purposes we collected it for or for compatible purposes.  If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent.  We may process your personal data without your knowledge or consent where required by applicable law or regulation.

We may also process your personal data for our own legitimate interests, including for the following purposes:

• To prevent fraud
• To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution
• To support internal administration with our affiliated entities
• To conduct data analytics analyses to review and better understand client retention and attrition rates and feedback

You will not be subject to decisions based on automated data processing without your prior consent.

Collection and Use of Special Categories of Personal Data

The following special categories of personal data are considered sensitive under the laws of your jurisdiction and may receive special protection:

• Racial or ethnic origin.
• Political opinions.
• Religious or philosophical beliefs.
• Trade union membership.
• Genetic data.
• Biometric data.
• Data concerning health.
• Data concerning sex life or sexual orientation.

Data relating to criminal convictions and offences may also receive special protection under the laws of your jurisdiction.

We do not intend to process special categories of data but some information may be processed incidentally in the ordinary course of business conversations and dealings:

• Physical or mental health information or disability status 
• Race or ethnic origin, religious affiliation, health information and sexual orientation

Where we have a legitimate need to process special categories of personal data for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

We will always treat special categories of personal data as confidential and we will only share such data internally where there is a specific and legitimate purpose for sharing the data.  As set out below, we have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.

We will only retain special categories of personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. 

Data Sharing

We will only disclose your personal data to third parties where required by law or to our group entities, employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the relationship with you and the organisation(s) you represent, including third-party service providers who provide services to us or on our behalf.  Third-party service providers may include, but are not limited to, CRM processors, administration providers, and data storage or hosting providers. These third-party service providers may be located outside of our or your home jurisdiction.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us as your employer. We do not permit our third-party service providers who process your personal data on our behalf to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.

We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:

• To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to perform our employment contract with you.
• As part of our regular reporting activities to other members of our group of companies.
• To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
• To protect the rights and property of Imperium.
• During emergency situations or where necessary to protect the safety of persons.
• Where the personal data is publicly available.
• If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible.
• For additional purposes with your consent where such consent is required by law.

Cross-Border Data Transfers

Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Notice. If you are located in the EU, we have implemented appropriate data protection mechanisms to secure the transfer of your personal data to the United States and other jurisdictions.

Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.  In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means. 

Under some circumstances we may anonymise your personal data so that it can no longer be associated with you.  We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.  

Rights of Access, Correction, Erasure, and Objection

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes.  By law you may have the right to request access to, correct, and erase the personal data that we hold about you, or object to the processing of your personal data under certain circumstances.  You may also have the right to request that we transfer your personal data to another party.  If you want to review, verify, correct, or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us at lelegal@imperium-global.com. Any such communication must be in writing.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Right to Withdraw Consent

Where you have provided your consent to the collection, processing, or transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at legal@imperium-global.com 

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose.  We may process your personal data without your knowledge or consent where required by applicable law or regulation.

Contact Us

If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us at: legal@imperium-global.com

If you are unsatisfied with our response to any issues that you raise, you have the right to make a complaint with the data protection authority in your jurisdiction.

Candidate Privacy Policy

Scope and Overview

Imperium Global Search Ltd. is committed to protecting the privacy and security of your personal data.  This Privacy Notice describes how Imperium and its subsidiaries, affiliates, and related entities (collectively, “Imperium,” “we,” or “us”) collect and process personal data about you as a candidate or prospective candidate for employment with the clients or prospective clients of Imperium.  This Privacy Notice applies to current, past and prospective candidates.  This privacy notice applies to data subjects located in in all jurisdictions and territories where they are based.

This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction.  This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.

We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law.  We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

Collection of Personal Data

For the purposes of this Privacy Notice, personal data means any information about an identifiable individual.  Personal data excludes anonymous or de-identified data that is not associated with a particular individual.  To carry out our activities and obligations as a recruiter, we may collect, store, and process the following categories of personal data, some of which we require to administer the services and relationship with you and our clients:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• Date of birth
• Gender
• Marital and dependent status, only when needed to administer benefits such as health insurance or pension benefits
• Beneficiary and emergency contact information
• Government identification numbers such as social insurance or other national insurance number, driver’s license number, or other identification card number
• Bank account details and payroll information
• Wage and benefit information
• Compensation history
• Performance information
• Insurance enrollment information
• Start date and job title for current and past employment
• Location of employment
• Education and training
• Employment records (including professional memberships, references, work history, and proof of work eligibility)
• Photograph
• Other personal details included in a CV, resume, application form or cover letter or that you otherwise voluntarily provide to us
• Voice recordings e.g. telephone calls
• Video recordings e.g. meetings

The personal data listed in this notice is information we may obtain in the ordinary course of our business relationship as a recruiter.

We will collect the majority of the personal data that we process directly from you or from third parties may provide your personal data to us, such as referral bodies, social media (such as LinkedIn), public organisation information (such as websites) and data service providers.

Use of Personal Data

We only process your personal data where applicable law permits or requires it, including where the processing is necessary for the performance of our contractual obligations with clients  and prospective clients, to promote you to our clients and prospective clients for employment, engagement, hiring, to offer our services to clients and prospective clients, to demonstrate the services that were performed or offered to be performed, where the processing is necessary to comply with a legal obligation that applies to us as a recruitment service provider, and for our legitimate interests or the legitimate interests of third parties.  

We may process your personal data for the following legitimate business purposes and for the purposes of performing the employment contract with you:

• To offer legitimate business services to you, our clients and prospective clients
• Business management and planning
• Accounting, invoicing and auditing
• Gathering evidence for claims as may be necessary
• Complying with applicable law
• Education, training, and development requirements

We will only process your personal data for the purposes we collected it for or for compatible purposes.  If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent.  We may process your personal data without your knowledge or consent where required by applicable law or regulation.

We may also process your personal data for our own legitimate interests, including for the following purposes:

• To prevent fraud
• To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution
• To support internal administration with our affiliated entities
• To conduct data analytics analyses to review and better understand client retention and attrition rates and feedback

You will not be subject to decisions based on automated data processing without your prior consent.

Collection and Use of Special Categories of Personal Data

The following special categories of personal data are considered sensitive under the laws of your jurisdiction and may receive special protection:

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• Genetic data
• Biometric data
• Data concerning health
• Data concerning sex life or sexual orientation

Data relating to criminal convictions and offences may also receive special protection under the laws of your jurisdiction.

We do not intend to process special categories of data but some information may be processed incidentally in the ordinary course of business conversations and dealings:

• Physical or mental health information or disability status 
• Race or ethnic origin, religious affiliation, health information and sexual orientation

Where we have a legitimate need to process special categories of personal data for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

We will always treat special categories of personal data as confidential and we will only share such data internally where there is a specific and legitimate purpose for sharing the data.  As set out below, we have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.

We will only retain special categories of personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. 

Data Sharing

We will only disclose your personal data to third parties where required by law or to our clients and prospective clients, our group entities, employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the relationship with you and our clients and prospective clients, including third-party service providers who provide services to us or on our behalf.  Third-party service providers may include, but are not limited to, CRM processors, administration providers, and data storage or hosting providers. These third-party service providers may be located outside of our or your home jurisdiction.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us as your employer.  We do not permit our third-party service providers who process your personal data on our behalf to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.

We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:

• To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to perform our employment contract with you.
• As part of our regular reporting activities to other members of our group of companies.
• To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
• To protect the rights and property of Imperium.
• During emergency situations or where necessary to protect the safety of persons.
• Where the personal data is publicly available.
• If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible.
• For additional purposes with your consent where such consent is required by law.

Cross-Border Data Transfers

Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Notice.  If you are located in the EU, we have implemented appropriate data protection mechanisms to secure the transfer of your personal data to the United States and other jurisdictions.

Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.  In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means. 

Under some circumstances we may anonymise your personal data so that it can no longer be associated with you.  We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.  

Rights of Access, Correction, Erasure, and Objection

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes.  By law you may have the right to request access to, correct, and erase the personal data that we hold about you, or object to the processing of your personal data under certain circumstances.  You may also have the right to request that we transfer your personal data to another party.  If you want to review, verify, correct, or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us at legal@imperium-global.com.  Any such communication must be in writing.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Right to Withdraw Consent

Where you have provided your consent to the collection, processing, or transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at legal@imperium-global.com

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose.  We may process your personal data without your knowledge or consent where required by applicable law or regulation.

Contact Us

If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us at: legal@imperium-global.com 

If you are unsatisfied with our response to any issues that you raise, you have the right to make a complaint with the data protection authority in your jurisdiction.