Welcome to CastLight Search (collectively ''Castlight'',''we'', ''us'' and ''our'' etc.). We are a retained searchfirm to many of the world’s most demanding organizations.
We respect the privacy of our clients, candidates andother users of our Services (''you'', ''your'') and are committedto protecting your personal data and information according to the applicablelaws. This privacy policy (''Policy'') explains how, to what extent andfor what purposes we are collecting and subsequently processing personal dataand information.
Castlight takes its responsibility for the processing ofyour personal data and information very seriously, whether provided to us onour website, via email, via social networking sites, in person or otherwise.
For the purpose of this Policy, the controller ofpersonal data is Strategic Solutions International (dba Castlight search) and anyonecan click the “Contact Us” button on our website to reach us.
In addition to terms defined elsewhere in this Policy,the ones listed below shall have the following meaning throughout this Policy:
''Candidate'' means any candidate, interestedperson, or Client employee or board member, who is considered, evaluated,assessed, coached or developed by Castlight in connection with the Services;
''Client'' means any of the organizations orindividuals who contract our Services;
''Personal Information'' means any informationthat either (a) personally identifies a natural person; or (b) pertains to anidentifiable natural person, i.e. someone who can be identified, directly orindirectly, in particular, by reference to an identifier such as a name, anidentification number, location data, an online identifier or to one or morefactors specific to his or her physical, physiological, genetic, mental,economic, cultural or social identity, or (c) constitutes individuallyidentifiable information about an individual consumer collected by us onlinethrough our website and that we maintain in an accessible form, or that (d) weare otherwise required to protect under applicable data privacy laws(including, but not limited to, national, international and supranational dataprotection and privacy laws, directives, regulations and comparable legalacts). Examples of Personal Information include your contact details such asyour name, email address, birthday or phone number as well as information aboutyour professional education and experience, skills, preferences, membership inprofessional organizations, etc.
''Processing'' (and variations such as ''Process'')means any operation or set of operations which is performed on PersonalInformation or on sets of Personal Information, whether or not by automatedmeans, such as the collection, recording, organization, structuring, storage,adaptation or alteration, retrieval, consultation, use, disclosure bytransmission, dissemination or otherwise making available, alignment orcombination, blocking, restriction, erasure or destruction;
''Sensitive Personal Information'' means PersonalInformation revealing racial or ethnic origin, political opinions, religious orphilosophical beliefs, or trade union membership, and the Processing of geneticdata, biometric data for the purpose of uniquely identifying a natural person,data concerning health or data concerning a natural person's sex life or sexualorientation;
''Site'' means http://www.castlightsearch.com/ and all web pages hosted at that domain.
We perform our Services based on data held by or madeavailable to Castlight.
In the event you are interested in becoming a Candidatefor one of our Services, you can provide us with information on your personaland professional background that we may take into consideration as part of therelevant Services.
Providing any Candidate Information is purely voluntaryon your part. Although it is generally true that, the more information youshare with us, the better we are able to assess you and/or your potentialsuitability for or within an executive or similar management position, we urgeyou not to disclose to us any Candidate Information that is likely of little orno relevance for the respective Client Service.
If and to the extent you share Candidate Information withus, we might follow up with you using the contact details you may have providedin order to clarify any questions we might have or obtain complementaryinformation from you. If you are a Candidate for Services relating to executivesearch, we might in addition (i) conduct assessments of your professionalprofile and perform searches for information on your personal and professionallife publicly available via social media services (e.g. Facebook, Google,LinkedIn, Twitter, etc.), on the Internet, or within data you have previouslydisclosed to us, provided that such information might be of importance for therelevant Services; and (ii) source Personal Information about you from thirdparty data providers (e.g. BoardEx), whereby we take appropriate measures toensure that such third party data providers are legally permitted or requiredto disclose such information to us. Any resulting information will beconsidered Candidate Information and be Processed as described below togetherwith the Candidate Information you initially provided us with.
Depending on your interaction with us, your CandidateInformation Processed by Castlight Search and/or selected Castlight partnersmay therefore contain (i) your contact details (name, address, phone number,email address, etc.), (ii) your biographical data, (iii) information on yourprofessional education, (iv) your educational credentials, professionaldiplomas and certificates, (v) information and responses you may provide toevaluative measures, surveys and interviews, and (vi) any Sensitive PersonalInformation you might choose and explicitly consent to disclose to us. If youare a Candidate for Services relating to executive search, your CandidateInformation may in addition contain (vii) your employment and compensationhistory, (viii) data on your suitability for Client opportunities we compile aspart of our assessments of your professional profile, (ix) information on yourpersonal and professional life publicly available via social media services(e.g. Facebook, Google, LinkedIn, Twitter, etc.) or otherwise on the Internet,or from third party data providers, that might be of importance in connectionwith the relevant Services, (x) information related to your travels forinterviews within a recruitment process, if such travel arrangements arefacilitated by us via our selected partners, such as your name, email address,phone number, passport number and date of birth (if mandatory), traveldestination(s), and means of transportation, and (xi) in appropriatecircumstances and in accordance with applicable local law, information aboutyou which may be classified as ''diversity information'' (such as your racialor ethnic background, gender, disability, age, sexual orientation, religion orbeliefs, and/or socioeconomic background). Some of this information isconsidered Sensitive Personal Information (or protected legal characteristicsunder certain laws) and as such, stricter data and other protection measures,as required by applicable law, will apply.
Our legal basis for collecting and using your CandidateInformation for the Services will depend on the Processing activity involvedand the context in which it was obtained and therefore can either be based onour legitimate business interest or on your consent.
As part of Services, your Candidate Information may beProcessed for the business purposes of:
· Providing Services on behalf of our Clients, which mayinclude Processing of your Candidate Information within your own integration,assessment, coaching or development as part of respective assignments for ourClients;
· Operating the databases your Candidate Information isstored in; and
· Analyzing your information using analytical tools andcomparing the results against other Candidates or potential Candidates,including categorization of Candidates through profiles developed by thesoftware, to assist us in conducting Services.
If you are a Candidate for Services relating to executivesearch, your Candidate Information may be Processed for the additional businesspurposes of:
· Executing searches for potential Candidates on behalf ofClients that have an opening for an executive or similar management position orfor a board directorship, including, but not limited to, (i) assessing yoursuitability for Client opportunities, (ii) introducing you to Clients as aCandidate, (iii) verifying your educational credentials, professional diplomasand certificates, (iv) where appropriate and in accordance with applicable law,using your diversity information to provide Clients with diverse pools ofqualified Candidates, and (v) ensuring that you will not be recruited on behalfof another Client unless you request consideration for other opportunities;
· Informing you of open executive or similar managementpositions potentially suitable for you;
· Sending you information or materials that we believe youmay find interesting, such as reports, research, invitations to networkingevents, or information regarding our Services, publications and surveys; and
· Approaching you as a Client contact for the introductionof other Candidates or as a source of information about potential Candidatesfor third-party Clients.
At no point will your Candidate Information be used forpurposes other than providing the Services for which your Candidate Informationhas been intended.
Your Candidate Information will mainly be Processed by and on behalf of CastlightSearch. However, depending on how and where the Services need to be performedin your individual case, your Candidate Information may be shared with:
· Consultants and administrative staff: Via our proprietarydatabases, your Candidate Information will be available to the consultants andadministrative staff of Castlight Search in various countries worldwide for thepurposes of providing the Services;
· Clients: If you are a Candidate for Services relating toexecutive search, subject to our discretion, we might disclose excerpts of your Candidate Information such as your professional education and employmenthistory with particular Clients in order to confirm whether such Clients mightbe interested in you as a Candidate with respect to an opening for an executiveor similar management position they have informed us of. The informationdisclosed will be limited to what is necessary for this purpose. We will notdisclose the entirety of your Candidate Information or otherwise introduce youto any Client in detail without first obtaining a consent from you;
· Selected partners: Your Candidate Information might beProcessed by selected partners with whom we may work on specific projects whenproviding Services, including third party travel agencies;
· Software service and application providers: YourCandidate Information may be Processed by the software service and applicationproviders as our Processors (such as Microsoft Corporation or Zoom VideoCommunication, Inc), located anywhere in the world, subject to bindingcontractual obligations to only Process your Candidate Information inaccordance with our prior written instructions and to apply measures to protectthe confidentiality and security of your Candidate Information, together withany additional requirements under applicable law; and
· IT infrastructure service providers: Your CandidateInformation will be stored on servers located in the United States. The serversare operated by and accessible to designated employees of Castlight Search aswell as third-party service providers acting on behalf and as per instructionof Castlight Search, for the purposes of website management, informationtechnology and related infrastructure provision.
In this context, please be aware that most of thethird-party service providers operating the servers and some of our Clients orselected partners we might disclose excerpts of your Candidate Information toare located in countries outside of the European Economic Area (EEA) that havenot been found by the European Union to provide an adequate level of protectionof personal data, i.e. a level of protection of fundamental rights and freedomsthat is essentially equivalent to that guaranteed within the European Union.Similarly, the countries your Candidate Information, or parts thereof, might betransferred to in accordance with the above may not be found to provide anadequate level of protection by jurisdictions outside of the European Union.However, we have taken appropriate safeguards to require that your CandidateInformation will remain protected in accordance with this Policy. These includeimplementing the European Commission’s Standard Contractual Clauses fortransfers of Personal Information within the Castlight Search group ofcompanies and our third party service providers and selected partners, whichrequire all of them to protect Personal Information they Process from the EEAin accordance with the European Union General Data Protection Regulation.
Our Services are not intended to be used by minors and wedo not want to collect information from minors. If a child’s parent or aguardian believes their child may have provided Personal Information to us,please write us using the contact details provided in ''How to Contact Us''below and we will delete that Personal Information, subject to the applicablelaw and this Policy.
Our Site makes use of cookies. Cookies are small textfiles downloaded by your Internet browser and stored on the device you use toaccess the Site (e.g., your desktop computer, tablet or smartphone). Dependingon their purpose, cookies log specific user-related information such as youruser preferences, authentication information, security parameters, dataconcerning the device you access the Site with and statistical information regardingyour use of the Site. Where necessary during your visit of the Site or whenrevisiting the Site, your Internet browser transmits the cookies including thecontained information back to the servers they were initially downloaded from.The analysis and Processing of such information allows us to ensure thefunctionality of the Site, improve your online experience and optimize thestructure and content of the Site.
The cookies we may use can be categorized as follows:
· Session Cookies:These are cookies that allow our Site to collect information about what you doduring a browsing session each time you visit the Site. When connecting to ourserver, your device will be allocated a session ID, which enables our server toidentify your device during the session and facilitates Site usability. These cookies are temporary and are set to be deleted when you leave the Site;
· Persistent Cookies:These are cookies that are stored by your Internet browser for more than asession and are set to expire within a defined time period. Persistent cookiesenable us to remember your settings and information, so you do not have to keepre-entering them whenever you visit our Site. They also measure how you use andinteract with the Site and enable us to personalize the Site. For example, theymay allow us to alter the rotation of images on the Site so that differentimages will be displayed on your next visit;
· First-Party Cookies:These are cookies that we store and access on your device in our capacity ascontroller of your Personal Information when you visit our Site. They mightinclude cookies related to third-party service providers, provided that wecontrol and determine the purposes and means of the Processing of your PersonalInformation logged by such cookies. As a result, first-party cookies might loguser-related Personal Information accessible to and Processed by third partieson our behalf and subject to our instructions.
· Third-Party Cookies:These are cookies that are stored and accessed on your device by third partiesdetermining the purposes and means of the Processing of your PersonalInformation logged by such cookies.
You may influence the scope and extent to which we usecookies when you visit our Site. In particular, you may prevent cookies frombeing stored on your device by adjusting the respective settings on yourInternet browser. For more information on how to do so in the settings of yourparticular Internet browser, please see the following information:
Internet Explorer:
https://privacy.microsoft.com/en-us/internet-explorer-ie11-preview-privacy-statement
Chrome:
https://www.google.com/intl/en/chrome/browser/privacy/
Firefox:
https://support.mozilla.org/en-US/products/firefox/protect-your-privacy
Safari:
http://www.apple.com/privacy/manage-your-privacy/
However, please be aware that this might render certainfunctions of our Site inoperable or more difficult to use. Depending on theInternet browser you use, you might also be able to specifically rejectthird-party cookies. In this context, please note, however, that third partiesmight still have access to your Personal Information to the extent that suchinformation is logged by first-party cookies.
For additional information on first-party and third-partycookies used on our Site in the context of third-party services and forinformation on how you might stop such cookies from being stored on yourdevice, please see ''Third-Party Services'' below.
(b)Third Party Services
On our Site, we may use the following services providedby third parties:
· Google Analytics
Our Site uses Google Analytics, a web analytics service provided by Google,Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (''Google'').Google Analytics uses ''cookies'', which are text files placed on yourcomputer, to help analyze how users use the Site.
The information generated by the cookies about your use of the Site (includingyour IP address) will be transmitted to and stored by Google on servers in theUnited States. The United States has not been found by the European Union toprovide an adequate level of protection of personal data, i.e. a level ofprotection of fundamental rights and freedoms that is essentially equivalent tothat guaranteed within the European Union. Similarly, the United States may notbe found to provide an adequate level of protection by jurisdictions outside ofthe European Union.
On our behalf, Google will use the information collected for the purpose ofevaluating your use of the Site, compiling reports on website activity for usand providing other services relating to website activity and Internet usage tous. Google will not associate your IP address with any other data held byGoogle. Neither will we match, link or otherwise connect any informationreceived from Google with Personal Information collected through othercomponents of the Site.
You may refuse the use of cookies by selecting the appropriate settings on yourInternet browser. However, please note that if you do this, you may not be ableto use the full functionality of our Site. Furthermore you can prevent Google’scollection and use of data (cookies and IP address) by downloading andinstalling the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
In the latter case, an opt-out cookie will be set on your device, whichprevents the future collection of your data when visiting this Site. Be aware,however that the opt-out cookie will only be effective within the Internetbrowser you used to access the above link and only for as long as you do notdelete the opt-out cookie.
Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/gb.html or at https://www.google.de/intl/en_uk/policies/.
We may decide to use the following Social Media Platform Cookies, all intended to facilitate linking and following by or from the respective platforms:
Facebook
1, Hacker Way, Menlo Park, CA 94025, USA
LinkedIn
2029 Stierlin Ct. Ste. 200, Mountain View, CA 94043, USA
Twitter
1355 Market Street, San Francisco, CA 94103, USA
You can also manage the cookies of various third-partyservice providers by setting respective opt-out cookies on http://www.aboutads.info/choices/ or
http://www.youronlinechoices.com/uk/your-ad-choices.
Laws such as California Business and Professions Code §22575 require us to disclose how our Site responds to Internet browser ''Do NotTrack'' signals and/or other mechanisms that seek to provide consumers with theability to control the collection of their Personal Information through onlinetracking for certain purposes, such as targeted or behavioral advertising.
Please note that we do not use Personal Informationcollected on our Site through cookies or other technologies for targeted orbehavioral advertising. If your Internet browser gives our Site a ''Do NotTrack'' signal, the Site may not honor it to the extent that the Site usescookies or other tracking technologies as described in ''Cookies'' or''Third-Party Services'' above. We do not make any promises or guarantees aboutthe effects of any ''Do Not Track'' signal we receive from your Internetbrowser because (a) the ''Do Not Track'' technology is not necessarilyeffective for any or all Internet browsers, mechanisms or technologies, (b) thirdparties we cooperate with may not honor your ''Do Not Track'' signal; and (c)technologies, Internet browsers and access devices may change from time to timeand efforts to honor your ''Do Not Track'' signal might or might not beeffective for each technology or across all platforms.
However, in ''Cookies'' and ''Third-Party Services''above, we describe how you may use mechanisms similar to the ''Do Not Track''technology of certain Internet browsers in order to effectively prevent us orthird parties from collecting your Personal Information through onlinetracking. To the extent that you make use of these mechanisms, your preferencenot to be tracked or to be tracked only to a limited extent will be honored byus and the third parties providing services to us.
Protecting your Personal Information is important to us.We use appropriate technical and organizational measures and safeguardsdesigned to help prevent unauthorized access, unlawful Processing, andunauthorized or accidental loss of your Personal Information. This includes,for example, the encryption of your communication with us over the Site basedon the Secure Sockets Layer (SSL) protocol.
Subject to the applicable law, you have the right: (i) toobtain information about your Personal Information we Process; (ii) to requestthe correction or completion of incorrect Personal Information we Process;(iii) to request the deletion of Personal Information we Process; (iv) toobject to our Processing of your Personal Information or to restrict the way weProcess such Information; and (v) to request to receive Personal Information ina structured, commonly used and machine-readable format and to ask us totransmit that Personal Information to you or directly to a third party. To makea respective request, please use the “Contact Us” button on the website.
We will retain your Personal Information where we have anongoing consent or legitimate interest to do so. Kindly note that once ourrelationship with you has ended, your Personal Information may still berelevant for our current or future legitimate business purposes. For example wemay be required to retain certain Personal Information: (i) for our businessrecords; (ii) to be able to establish, exercise or defend our legal rights;(iii) to show that we are compliant with applicable laws; or (iv) to show thatwe have fulfilled or continue to fulfill our obligations towards our Clients inrelation to Services you may have been involved in.
If you are a resident of California, you can takeadvantage of the following rights:
(a) You may request, up to two times each year, that wedisclose to you the categories and specific pieces of Personal Information thatwe have collected about you, the categories of sources from which your PersonalInformation is collected, the business or commercial purpose for collectingyour Personal Information, the categories of Personal Information that wedisclosed for a business purpose, any categories of Personal Information thatwe sold about you, the categories of third parties with whom we have sharedyour Personal Information, and the business or commercial purpose for sellingyour Personal Information, if applicable. We will respond to your requestwithin 45 days unless we need additional time, in which case we will let you know.
(b) You may request that we delete any PersonalInformation that we have collected from or about you. If we cannot delete allof your information, we will let you know the reason for non-deletion, such asif we need to complete a transaction for you, or for a legal reason.
(c) You may direct us to not ''sell'' your PersonalInformation as this term is very broadly defined under the California ConsumerPrivacy Act (''CCPA''): it means the sharing of Personal Information with thirdparties who are not acting as our service providers. This may in particularinclude our sharing of your Personal Information with our Clients in relationto Services. If you would like to opt out of such sharing, you may do so here.
Your authorized agent may submit a request on yourbehalf, after submission of proof of authorization in accordance with California Law.
To take advantage of any of the foregoing rights, or ifyou have questions about your rights, please contact us at snilsen@csatlightsearch.com. We may take steps to verify your identity before responding to your request. If you exercise any of the foregoing rights, wewill not discriminate against you, such as by denying you access to ourServices or restricting your access to Services of certain pricing or quality.
This section states the categories of PersonalInformation pursuant to the CCPA that we have collected and disclosed withinthe last 12 months:
(a) We collect the following categories of PersonalInformation: identifiers and personal details, characteristics of protectedclassifications under California or federal law, internet or other electronicnetwork activity information, education information, professional oremployment-related information, and inferences drawn from other PersonalInformation to develop a profile about a Candidate.
(b) We disclose the following categories of PersonalInformation for a business purpose: identifiers and personal details,characteristics of protected classifications under California or federal law,internet or other electronic network activity information, educationinformation, professional or employment-related information, and inferencesdrawn from other Personal Information to develop a profile about a Candidate.
(c) We do not ''sell'' (as this term is defined under theCCPA) Personal Information of persons under 16 years of age.
From time to time we may change our business activitiesand/or our policies and procedures with respect to the Processing of PersonalInformation. Where appropriate in these cases, we will, subject to applicablelaw, revise, supplement, or replace this Policy. When the Policy changes, wewill post the substitute version and change the effective date listed at thebeginning of the Policy.
When required by applicable law, however, we may provideyou with advance notice of any changes to this Policy and with an opportunityto object to such changes. If you exercise your right to object, the changeswill not become effective with respect to your Personal Information, but yourability to use our Services may be terminated or impaired. We will explicitlynotify you of the consequences of the objection or non-objection to the extentand in the manner required by law.
We encourage your questions and comments about this Policy and our privacy practices. Please contact us by sending us an email to snilsen@castlightsearch.com and we will respond to you as soon as reasonably possible.
