(A) This Notice
This Notice is issued by the Association of Executive Search and Leadership Consultants (together, the “AESC”, “we”, “us” and “our”) and is addressed to anyone who is using, or has access to, the BlueSteps service (together, “you”). Defined terms used in this Notice are explained in Section (S) below. For the purposes of this Notice, the AESC is the Controller. Contact details are provided in Section (R) below. This Notice 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. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.
(B) Collection of Personal Data
We may collect Personal Data about you from the following sources:
(C) Creation of Personal Data
We may also create Personal Data about you, such as records of your interactions with us, and details of your purchase history.
(D) Categories of Personal Data we may Process
Where appropriate, in accordance with the provisions of this Notice, we may Process the following categories of Personal Data about you:
(E) Lawful basis for Processing Personal Data
In Processing your Personal Data in connection with the purposes set out in this Notice, we may rely on one or more of the following legal bses, depending on the circumstances:
(F) 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:
(G) Purposes for which we may Process your Personal Data
We may process your personal data for the following purposes, subject to applicable law:
(H) Disclosure of Personal Data to third parties
We may disclose your Personal Data within the AESC, 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:
(I) International transfer of Personal Data
Because of the international nature of our business, we may need to transfer your Personal Data within the AESC, and to third parties as noted in Section (H) above, in connection with the purposes set out in this Notice. 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 the country in which you are located.
Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of providing services to you under the contract entered into when you signed up to the BlueSteps service.
(J) Data security
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.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
(K) Data accuracy
We take every reasonable step to ensure that:
From time to time we may ask you to confirm the accuracy of your Personal Data.
(L) Data minimisation
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 Notice.
(M) Data retention
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 Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
(N) Your legal rights
Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that:
(O) Cookies and similar technologies
(Q) 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 managing your email preferences within BlueSteps, or 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.
(R) Contact details
If you have any comments, questions or concerns about any of the information in this Notice, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact: