awexia privacy policy 

Who we are and this Policy

We Are Awexia, Regeringsgatan 52, 111 56 Stockholm, SWEDEN (“Awexia,” “we,” “us” and “our” etc.) are an Executive Search and Interim Management company. We respect the privacy of our clients, candidates and other users of our services (“you”, “your”) and are committed to protecting your personal data and information according to the applicable law. This privacy policy (“Policy”) explains how, to what extent and for what purposes we are collecting and subsequently processing personal data and information.

This Policy is issued by Awexia (“Awexia”, “we”, “us” and “our”) and is addressed to candidates, referees, sources, clients and other individuals outside our organisation with whom we interact, including clients, visitors to our Sites, and other users of our services (together, “you”).

Definitions

In addition to terms defined elsewhere in this Policy, the following terms shall have the following meaning throughout this Policy:

a) Personal Data means any information that either:

• personally, identifies a natural person; or
• pertains to an identifiable natural person, i.e. someone who can be identified, directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity, or
• constitutes individually identifiable information about an individual consumer collected by us online through our website and that we maintain in an accessible form, or that
• we are otherwise required to protect under applicable data privacy laws (including, but not limited to, national, international and supranational data protection and privacy laws, directives, regulations and comparable legal acts). Examples of Personal Information include your contact details such as your name, email address, birthday or phone number as well as information about your professional education and experience, skills, preferences, membership in professional organizations, etc.;

b) Process, Processing or “Processed means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, restriction, erasure or destruction;

c) Sensitive Personal Information means Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation;

d) Site means http://www.awexia.se/ and all web pages hosted at that domain.

e) EEA means the European Economic Area.

f) Processor means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller). For the purposes of this Policy, Awexia is the Controller. Contact details are provided in Section (17) below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law.

Collection of Personal Data

Personal Data may be collected from the below mentioned sources:

a) Provided data is obtained when you provide it to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your CV or business card).

b) Relationship data is collected or obtain your Personal Data in the ordinary course of our relationship with you (e.g., if you purchase a service from us).

c) Public Data concerns the situation/situations where we obtain your Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s)).

d) Site data in relevant situations, we will collect or obtain your Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.

e) Registration details This concerns the collection of your Personal Data when you use, or register to use, any of our Sites, or services.

f) Third party information: We collect or obtain your Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

Creation of Personal Data

We may also create Personal Data about you, such as records of your interactions with us, and any interactions we have with clients on your behalf.

Categories of Personal Data we may Process

We may Process the following categories of Personal Data about you:

a) Personal details containing given name(s); preferred name; photograph; employment history; education; and other relevant typical CV content

b) Demographic information constructed by gender; date of birth / age; nationality; salutation; title; and language preferences.

c) Contact details: address including telephone number; email address; and details of your public social media profile(s).

d) References from current and/or former employers, colleagues, subordinates etc.

e) Consent records  is records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).

f) Data relating to our Sites, for example device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; usage data; aggregate statistical information.

g) Employer details  are where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant.

h) Views and opinions  are any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

Lawful basis for Processing Personal Data

In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

a) Consent is in regard to Process of your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Process that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);

b) Legitimate interests cover when we will Process your Personal Data where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms;

c) Contractual necessity  stipulate that we may Process your Personal Data where the Processing is necessary in connection with any contract that you may enter into with us;

d) Compliance with applicable law: handle when we Process your Personal Data where the Processing is required by applicable law; or

e) Vital interests are the aspect when we Process your Personal Data where the Processing is necessary to protect the vital interests of any individual.

Sensitive Personal Data

We do not seek to collect or otherwise Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

a) Law Compliance relates to when we Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);

b) Detection and prevention of crime relates to Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);

c) Establishment, exercise or defence of legal rights  is concerning the Process of your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or;

d) Consent gives us clearance to Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Process that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Purposes for which we may Process your Personal Data

The purposes for which we may Process Personal Data, subject to applicable law, include:

a) Providing our Sites, or services to you; providing you with services that you have requested; providing you with promotional items at your request; and communicating with you in relation to those services.

b) Providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites; and notifying you of changes to any of our Sites, or our services.

c)  Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.

d) Communications and IT operations: management of our communications systems; operation of IT security systems; and IT security audits.

e) Financial management: sales; finance; corporate audit; and vendor management.

f) Surveys: engaging with you for the purposes of obtaining your views on our services.

g) Security: physical security of our premises (including records of visits to our premises; and CCTV recordings); and electronic security (including login records and access details).

h) Legal proceedings when establishing, exercising and defending legal rights.

i) Compliance with our legal and regulatory obligations under applicable law.

j) Improving our Sites, services: identifying issues with our Sites, or our services; planning improvements to our Sites, or our services; and creating new Sites, or services.

Disclosure of Personal Data to third parties

We may disclose your Personal Data to other entities within the Awexia group, for legitimate business purposes (including operating our Sites, and providing services to you), in accordance with applicable law. In addition, we may disclose your Personal Data to:

a) Clients for whom we have ongoing assignments

b) Accountants, auditors, lawyers and other outside professional advisors to Awexia, subject to binding contractual obligations of confidentiality;

c) Third party Processors (such as providers of assessment tools and tests), subject to the requirements noted below in this Section;

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to:

a) only Process the Personal Data in accordance with our prior written instructions; and

b) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

International transfer of Personal Data

Awexia is operating in several countries and since we may need to transfer your Personal Data within the Awexia international network, and to third parties as noted in Section (9) above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in Sweden.

Data

a) We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

b) We take every reasonable step to ensure that:

• Your Personal Data that we Process are accurate and, where necessary, kept up to date; and
• Any of your Personal Data that we Process that are inaccurate are erased or rectified without delay.

c) We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

d) We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy.

The criteria for determining the duration for which we will keep your Personal Data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

Your legal rights

Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:

a) the right not to provide your Personal Data to us (however, please note that we may be unable to include you in search assignments or offer you the full benefit of our services, if you do not provide us with your Personal Data);

b) the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;

c) the right to request rectification of any inaccuracies in your Relevant Personal Data;

d) the right to request

• erasure of your Relevant Personal Data; or
• restriction of Processing of your Relevant Personal Data;

e) the right to object to the Processing of your Relevant Personal Data by us or on our behalf;

f) the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;

g) where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and

h) the right to raise complaints with a Data Protection Authority regarding the Processing of your Relevant Personal Data by us or on our behalf.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (17) below. Please note that:

a) we require proof of your identity before we can give effect to these rights; and

b) where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

Cookies and similar technologies

Our Site makes use of cookies. Cookies are small text files downloaded by your Internet browser and stored on the device you use to access the Site (e.g., your desktop computer, tablet or smartphone). Depending on their purpose, cookies log specific user-related information such as your user preferences, authentication information, security parameters, data concerning the device you access the Site with and statistical information regarding your use of the Site. Where necessary during your visit of the Site or when revisiting the Site, your Internet browser transmits the cookies including the contained information back to the servers they were initially downloaded from. The analysis and Processing of such information allows us to ensure the functionality of the Site, improve your online experience and optimize the structure and content of the Site.

The cookies we use can be categorized as follows:

a) Session Cookies: These are cookies that allow our Site to collect information about what you do during a browsing session each time you visit the Site. When connecting to our server, your device will be allocated a session ID, which enables our server to identify your device during the session and facilitates Site usability. These cookies are temporary and are set to be deleted when you leave the Site;

b) Persistent Cookies: These are cookies that are stored by your Internet browser for more than a session and are set to expire within a defined time period. Persistent cookies enable us to remember your settings and information, so you do not have to keep re-entering them whenever you visit our Site. They also measure how you use and interact with the Site and enable us to personalize the Site. For example, they may allow us to alter the rotation of images on the Site so that different images will be displayed on your next visit;

c) First-Party Cookies: These are cookies that we store and access on your device in our capacity as controller of your Personal Information when you visit our Site. They might include cookies related to third-party service providers, provided that we control and determine the purposes and means of the Processing of your Personal Information logged by such cookies. As a result, first-party cookies might log user-related Personal Information accessible to and Processed by third parties on our behalf and subject to our instructions.

d) Third-Party Cookies: These are cookies that are stored and accessed on your device by third parties determining the purposes and means of the Processing of your Personal Information logged by such cookies.
You may influence the scope and extent to which we use cookies when you visit our Site. In particular, you may prevent cookies from being stored on your device by adjusting the respective settings on your Internet browser. For more information on how to do so in the settings of your particular 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 certain functions of our Site inoperable or more difficult to use. Depending on the Internet browser you use, you might also be able to specifically reject third-party cookies. In this context, please note, however, that third parties might still have access to your Personal Information to the extent that such information is logged by first-party cookies.

For additional information on first-party and third-party cookies used on our Site in the context of third-party services and for information on how you might stop such cookies from being stored on your device, please see “Third-Party Services” below.

Third-Party Services

On our Site, we use the following services provided by 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 your computer, to help analyze how users use the Site.

The information generated by the cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. The United States has not been found by the European Union to provide an adequate level of protection of personal data, i.e. a level of protection of fundamental rights and freedoms that is essentially equivalent to that guaranteed within the European Union. Similarly, the United States may not be found to provide an adequate level of protection by jurisdictions outside of the European Union.

On our behalf, Google will use the information collected for the purpose of evaluating your use of the Site, compiling reports on website activity for us and providing other services relating to website activity and Internet usage to us. Google will not associate your IP address with any other data held by Google. Neither will we match, link or otherwise connect any information received from Google with Personal Information collected through other components of the Site.

You may refuse the use of cookies by selecting the appropriate settings on your Internet browser. However, please note that if you do this, you may not be able to use the full functionality of our Site. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB. Lastly, you can refuse the use of Google Analytics by clicking on the following link:

Disable Google Analytics

In the latter case, an opt-out cookie will be set on your device, which prevents the future collection of your data when visiting this Site. Be aware, however that the opt-out cookie will only be effective within the Internet browser you used to access the above link and only for as long as you do not delete 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/.

Additionally, we use the following Social Media Platform Cookies, all intended to facilitate linking and following by or from the respective platforms:

a) Facebook
1, Hacker Way, Menlo Park, CA 94025, USA
b) LinkedIn
2029 Stierlin Ct. Ste. 200, Mountain View, CA 94043, USA

In addition to the above, you can manage the cookies of various third-party service providers by setting respective opt-out cookies on http://www.aboutads.info/choices/ or http://www.youronlinechoices.com/uk/your-ad-choices.

When you visit one of our Sites, we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies, in accordance with our policy for cookies.

Terms of use

All use of our Sites, or our services is subject to our general terms and conditions. 

Direct marketing

We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

Contact details

We encourage your questions and comments about this Policy and our privacy practices. Please contact us using the information below, and we will respond to you as soon as reasonably possible:

Regeringsgatan 52
111 56 Stockholm
Sweden
+46 (0)8 505 353 00
policy@awexia.se