Privacy Policy

RHR collects various categories of personal data. The personal information we collect may depend on the Services you participate in, the products you use, and the information you provide. We collect personal information directly from you, including if you interact with our website, attend an event, or participate in any of our Services. We also collect personal information from other businesses or individuals, such as our clients or publicly available resources. We use cookies and related technologies to collect personal information from you, including from and across the internet or your devices when you interact with our Services. The personal information we collect includes the following:

• Contact Information and other Identifiers. We may collect your first and last name, email address, postal address, phone number, employer, and other similar contact data. We may also collect account username and password, alias, social media account handles, and date of birth.
  
  
• Commercial, Customer Records, and Preference Information. We may collect comments and information you provide in connection with the questionnaires, assessments, surveys, and simulations available through the Service. We may collect information from feedback or questions you ask our representatives.
  
  
• Device, Internet, and Network Activity Information. If you use our Services we may collect information about the browser, device, and operating system you are using, device identifiers, MAC address, and your IP address. We might collect information at the site you came from, or the site you visit when you leave us. We may collect and record page and site interaction information and other electronic communications and content from your use of the Service and methods used to browse away from the page. We may also embed technologies (which may include, for example, web beacons, tags, and pixels) in the emails and other communications we or our vendors send to you to help us understand how you interact with those messages, such as whether and when you opened a message or clicked on any content within the message. We may engage or otherwise permit other parties to also collect information in these ways on our behalf.
  
  
• Location Information. We may collect information about your general location using your zip code or postcode and/or IP address.
  
  
• Demographic Information. We may collect demographic information like your race, ancestry, national origin, ethnicity, sex, gender, gender identity, birth date, age, language spoken, disability, household size, household type, family members, marital status, annual household income, and/or citizenship.
  
  
• Sensitive Personal Information. Some of the information we collect may be considered sensitive information in certain jurisdictions, including, for example, racial or ethnic origin, gender, gender identity, citizenship or immigration status, or sexual orientation.
  
  
• Inferences drawn from other personal information. Using the other pieces of personal information collected about you, we may draw inferences about you, such as information reflecting what we believe to be your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, abilities, and aptitudes.

You may elect whether or not to provide certain information or to interact with us in a manner that provides such information to us — understanding that declining to provide information may impact our ability to provide Services.

We may, to the extent not prohibited by applicable law, collect, use, and disclose the above-referenced categories of personal information for the following purposes:

Provide our Services: We use personal information to carry out our transactions and to provide Services. This can include carrying out actions consistent with the purposes for which you provided the personal information, conducting the business relationship between us and you or your organization, engaging in pre-contractual business evaluations and vetting, and carrying out our obligations arising from and fulfilling any contracts entered into by you and us (or by your employer and us). We may use your IP address to customize services to your location.

Provide support and to respond to your requests or questions: We use personal information to communicate in connection with, and to provide support for our Services. This can include contacting you in response to our relationship with you as well as addressing problems with the Services and providing other customer and support services, including at your request.

Marketing: We might use personal information to communicate with you about products or services that may be of interest to you, including new features or services. We may also use your information to send you email newsletters, which you may opt out of as may described in more detail in the communication. To learn about your choices for these communications, read the “YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION” section below.

Test, develop, analyze, and improve our products and services: We may use your personal information to make our websites, services, and products better. We might use your information to customize your experience with us and to conduct research and analysis. We use data to continually improve our Services, including adding new features or capabilities. We will collect and utilize any data files you send to us for troubleshooting and improving our Services. During our interviews, we may occasionally collect Demographic Information and/or Sensitive Personal Data provided. This information helps us tailor our services, including to your organization’s specific needs, for example, by assessing leadership strengths, identifying opportunities, and understanding team dynamics. Where required by applicable law, we process this personal information based on our legitimate interests. When relying on this legal basis, we carefully assess and balance our interests against potential impacts on your rights and freedoms, to help ensure that they are not overridden.

Comply with our obligations, administer our websites and services, and for internal operations: We use personal information to administer the websites, such as troubleshooting, data analysis, and testing. We also use personal information when onboarding and interacting with vendors. Where required by applicable law, we process this personal information on the basis of our legitimate interests.

Administrative, security, safety, compliance, and due diligence purposes: We use personal information to detect and investigate activities that may be fraudulent, or otherwise illegal or prohibited, including, in connection with cybersecurity and physical security. We also use such information to assess any other risks arising from any relationship or prospective relationship with you or otherwise, where permissible by law. We may also process this personal information to comply with our legal obligations.

Research, statistical, and development purposes: We also process personal information in an anonymized, pseudonymized, or non-attributable form to maintain, improve, and train our Services. In those instances when we use the data in a way that does and cannot identify you personally, this Policy will not apply to that information. Information that can be used to re-identify you (even if we do not intend to use it in that way) would continue to be considered personal information subject to this Policy. We may also process this personal information on the basis of our legitimate interests.

We may disclose your personal information to:

The RHR family of companies. For example, we may share information with RHR-controlled affiliates and subsidiaries, located in and outside your country;

Service providers, contractors, and third parties. We may share your personal information with entities that provide us with services or perform functions on our behalf, such as website hosting and analytics.

As directed by you. We may share personal information with anyone expressly authorized by you to receive personal information about you.

For safety and legal reasons. We may disclose your personal information to anyone to whom we are required by law to disclose personal information, for example pursuant to a valid and enforceable request or order by government agencies, law enforcement, a regulator, court, or other legal authority or process. We will also disclose personal information when we have a good faith belief that doing so is necessary to comply with applicable law or pursuant to judicial proceedings, or in connection with a criminal or civil investigation or administrative proceeding. We may also disclose personal information if we believe it is necessary to operate and maintain the security of our business, Services, property, employees, suppliers, clients, partners, or others.

Potential purchasers and their authorized agents and investors and others related to a transaction, financing, due diligence, or other business needs. We may disclose your personal information in connection with a corporate transaction or reorganization. For example, we may disclose personal information to prospective or actual purchasers and their personnel engaged to facilitate such a transaction. We may also disclose personal information to our investors to enable them to exercise oversight of our operations, or to potential investors as part of purchase-related diligence.

Third party marketing partners. We may disclose personal information to others in connection with our advertising and marketing efforts, including third-party social media networks, advertising networks, and websites, so that we can market and advertise, including on third party platforms and websites.

Our clients. We may also share your responses to questionnaires, assessments, and simulations in connection with the consulting and advisory services we provide to a client. The client with whom we share your responses may be your employer or prospective employer.

To other entities for other reasons, we may disclose to you from time to time or as permitted or required by law.

We store personal information in our information systems, the information systems of service providers, or in some cases physical files. We deploy procedural and technical measures that are designed to help protect your personal information from loss, unauthorized access, disclosure, alteration, or destruction, including identity and access management technologies, information security policies, information security training, and information security program reviews.

Storage and Transfer of Personal Information

Personal information collected by or on behalf of RHR may be stored and processed in your region, in the United States, or in any other country where RHR, its affiliates, or contractors maintain facilities.

Where we transfer your personal information out of the UK/European Economic Area, our policy is to ensure a similar degree of protection is afforded to your personal information by using safeguards required by applicable laws, such as only transferring personal information to countries that have been deemed by the UK Information Commission or European Commission to provide an adequate level of protection for personal information, or by using specific contractual protections, such as approved standard contractual clauses. Please contact us if you would like more information about our safeguards for data transfers.

In addition, we may transfer information that we collect about you, including personal information, to affiliates, or to other third parties outside Canada to other countries such as United States of America and United Kingdom These countries have different privacy laws that may or may not be as comprehensive as Canada. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country.

Retention of Personal Information

RHR retains personal information for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements, and as required or otherwise permitted by law. We are required by law to keep certain types of information for certain periods of time (e.g. statute of limitations). We may anonymize or deidentify personal information where we do not delete such information.

You can unsubscribe from our marketing emails by clicking on the unsubscribe link located at the bottom of marketing emails or by contacting us with your unsubscribe request. Please note that opting out of marketing communications does not opt you out of receiving business communications related to your current relationship with us, such as communications about Services or security information.

Certain jurisdictions may provide their residents with additional rights regarding personal information. The following Section applies to individuals who reside in specific jurisdictions that provide such additional privacy rights, subject to certain exceptions under applicable law.

• Right to Know/Access: You can request that we disclose to you the categories of personal information we collected about you; the categories of sources from which we collected the personal information; the categories of personal information we sold, shared, or disclosed, our business, or commercial purpose for collecting, selling, or sharing the personal information; the categories of third parties to whom we disclose, sell, or share the personal information; and the specific pieces of personal information we collected about you.
• Right to Correct Information: You can request that we correct personal information about you that we maintain about you that is incorrect.
• Right to Delete: You can request that we delete any personal information we maintain about you, subject to certain exceptions.
• Right to Opt-Out of Sale or Sharing for Targeted or Behavioral Advertising Purposes: Some disclosures of Personal Information may constitute a “sale” or “sharing” under applicable law, including the use of cookies and other technologies for certain advertising purposes.
  
  

  You can request to opt-out of the sale of your Personal Information and from the sharing of your personal information to an outside party for the purposes of cross-context behavioral advertising by sending us a written request by letter or email to the addresses set out in the “How to Contact Us” section. If you would like to opt-out of cookie-based tracking for advertising purposes, you can update your cookie preferences as indicated in our Cookies Policy.

Additional rights applicable to residents of Canada

If you reside in Canada, you may make certain requests with respect to your personal information in accordance with applicable law, including the following:

You have the right to request access to and to correct the personal information that we hold about you. Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision. If you want to review, verify, correct, or withdraw consent to the use of your personal information, you may use one of the two methods described below in the “How Exercise these Rights” section. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Additional rights applicable to residents in the United Kingdom (“UK”) or the European Economic Area

If you reside in the UK or the European Economic Area, you may make certain requests with respect to your personal information in accordance with applicable law, including the following:

• Right to restrict: In certain circumstances, you may request that we limit the way we use your personal information.

• Right to portability: You may request your data in a usable format or ask us to transfer it directly to another provider.

• Right to object: You can object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your right to object.

• Right to revoke consent: You can withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We can advise you if this is the case at the time you withdraw your consent.

• Right to complain: You have the right to make a complaint at any time to the data protection authority in your jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the regulator – we kindly ask you to please contact us in the first instance.
  • If you are in the EU, further information about how to contact your local data protection authority is available here.
  • If you are in the UK, the relevant data protection authority is the UK Information Commission.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

To submit a request to exercise these rights you may use one of these two methods:

• Email: dataprotection@rhrinternational.com
• Phone: +1 (888) 355-3855

For all requests, please clearly state that the request is related to “Your Privacy Rights,” indicate which type of request you are making, and provide your name, street address, city, state or province, postal code, and an e-mail address or phone number where we may contact you. We are not responsible for notices that are not labeled or sent properly or that do not include complete information. Where appropriate or required by law, we will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the personal information. We cannot respond to certain requests if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Certain individuals may also designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent and ensure the agent has the necessary information to complete the verification process, where required. We may require written proof of the agent’s permission to make a request on your behalf, and we may need to verify your identity directly with you. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.

To appeal a decision regarding a consumer rights request, please submit your appeal using one of the two methods above. Your appeal should include an explanation of the reason you disagree with our decision.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded and not prohibited by applicable law. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Please note, we will not discriminate against you because you exercised any of your lawful rights.

Additional rights applicable to residents of California

For purposes of California residents exercising these rights, please note the following regarding how we collect, use and disclose your personal information, including in the previous 12 months:

We may collect, use, and disclose for our business and commercial purposes, the following categories of personal information as set forth in applicable California law: identification, professional or employment information, commercial information, billing and payment information, Internet and other network activity information, audio and visual information, education information, inferences, and location information. We may collect categories of sensitive personal information as set forth in applicable California law, including racial or ethnic origin, citizenship or immigration status, or sexual orientation.

We collect and use the above categories of personal information for the business and commercial purposes described in “PERSONAL INFORMATION WE COLLECT AND OUR SOURCES” and “HOW WE USE PERSONAL INFORMATION” sections of this Policy. We use and disclose sensitive personal information to provide our services, for security purposes and as otherwise permitted by applicable law.

We collect these categories of personal information from the sources described in the “PERSONAL INFORMATION WE COLLECT AND OUR SOURCES” section of this Policy, as well as from business partners, third party data providers, advertising networks, internet service providers, data analytics providers, government entities, and social media networks.

We may disclose each of these categories of personal information for our business and commercial purposes to the extent permitted by applicable law with the categories of parties described in the “HOW WE USE PERSONAL INFORMATION” and “HOW WE SHARE PERSONAL INFORMATION“ sections of this Policy.

We may “sell”, or “share” for the purposes of cross-context behavioral advertising, the following categories of personal information: Internet and other network activity information such as your IP address, mobile advertising identifiers, browser and system versions, browsing history, location data, identification and contact information.

Categories of third parties to whom personal information may be “sold”, or “shared” for the purposes of cross-context behavioral advertising include: business partners, advertising and marketing partners, data analytics providers, and social media networks.

RHR does not knowingly “sell” or “share” the personal information of individuals under the age of 16. For additional information please see our practices as set forth in the “SERVICES ARE NOT INTENDED FOR CHILDREN” section.

You must be at least the age of majority in your place of residence to use the Services. The Services are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information to inform the child (or his or her parent or legal guardian) that he or she cannot use the Services.

We may update this Privacy Policy based upon evolving laws, regulations, and industry standards, or as we may make changes to our business including our Services. We will post changes to our Privacy Policy on this page and encourage you to review our Privacy Policy when you use our Services to stay informed. If we make changes that materially alter your privacy rights, RHR will provide additional notice, such as via email or through the Services as required by applicable law. If you disagree with the changes to this Privacy Policy, you should discontinue your use of the Services.

We understand that you may have questions or concerns about this Privacy Policy or our privacy practices or may wish to file a complaint. In such case, please contact RHR in one of the following ways:

Email: dataprotection@rhrinternational.com

Phone: +1 (888) 355-3855

Mail: Legal Department

RHR International LLP

233 South Wacker Drive, 95th Floor

Chicago, IL 60606