PRIVACY POLICY

Privacy Policy

Last updated on March 29, 2019

This Privacy Policy applies to the website(s) and mobile applications (together, the “Sites”) provided by Keystone Strategy Inc., a company headquartered in Boston, Massachusetts, USA, and/or the other companies of Keystone Strategy (“Keystone”, “we”, “us”) who act as data controllers with respect to the personal data you share with Keystone under this Policy.

The Sites include www.keystonestrategy.com and additional websites or mobile applications produced and managed by Keystone. Please note that this Privacy Policy does not apply to the following websites:

Keystone knows that your privacy is important to you and takes user privacy very seriously. We are committed to protecting your personal data (i.e. any information you provide to us from which you can be identified) in accordance with this Privacy Policy.

Keystone reserves the right, at its sole discretion, to alter and update this Privacy Policy from time to time. We, therefore, invite you to review the current version of the Privacy Policy each time you return to our Sites.

Some terms are defined throughout this Policy.

Keystone might collect personal data from you such as your name, contact details, occupation, company or university affiliation, industry, region/country, relationship to Keystone, reason for contacting Keystone, topics you are interested in and any other information you choose to share. By browsing our Sites or sending us information, you explicitly consent to Keystone processing your personal data in accordance with this Privacy Policy. Keystone might use your personal data to fulfill your request, send you marketing communications or process your job application.

Keystone collects personal data from you when you request information from Keystone and/or supply, information through the Sites, such as when you fill out a subscription form or consulting expertise inquiry, opt in to receive emails from Keystone, agree to participate in surveys, join our Alumni network or apply for a role at Keystone.

Personal data we collect might include your name, e-mail address, title, occupation, company or university affiliation, industry, region/country, relationship to Keystone, reason for contacting Keystone, topics you are interested in, any other background information provided with an application and any other information contained in messages you send us. By browsing our Sites and submitting this information to us, you explicitly agree to Keystone using your personal data for the purposes and in the manner described in this Privacy Policy. Please do not send us any information you do not wish Keystone to use.

Keystone will use your personal data to fulfil your request, provide you with the information you requested and/or send you marketing communications. If you have applied for a job at Keystone, your data will be processed for the purposes of evaluating and processing your application and candidacy for the position to which you have applied. We may also use your information to analyze and improve our recruiting and onboarding processes as well as to communicate with you about Keystone events and to send you publications that we think may be of interest to you. More detail can be found in the Job Applicants section.

Keystone may collect personal data and may disclose such information to third party service providers in aggregate for marketing and promotional purposes. However, in these situations, we do not disclose to these entities any information that could be used to personally identify you.

You do not have to provide us with any personal data. However, if you do not, we may be unable to handle your request or to provide you with the services you are requesting. Keystone will keep your personal data for as long as needed to handle your request or for as long as we have a relationship with you. If you have applied for a role with Keystone will keep your personal data associated with your application for a period of up to five years.

Please note that Keystone is not responsible for any information you may disclose publicly in any chat rooms, message boards, or similar web pages, including those hosted on or linked to our Sites. You should keep in mind that, whenever you publicly disclose information about yourself online (for example, via message boards or chat rooms), such information could be collected and used by people whom you do not know. In addition, certain message boards and similar user forums may display IP addresses along with the message poster's name and message. Keystone bears no responsibility for any action or policies of any third parties who collect any information users may disclose on the message boards, chat areas or other user forums, if any, on the Sites.

Our Sites may use cookies or other technology to obtain certain types of information about you. You can disable or delete cookies by going to the Help section of your browser but certain functionalities of our Sites might not work properly if you do so.

We may use cookies or other technology (“cookies”) to obtain certain types of information when you browse our Sites. "Cookies" are small text files that are stored by your browser on your computer's hard drive. Cookies can be placed on your computer directly by one of our Sites (first party cookies) or by another website (third party cookies).

We may use cookies to keep track of your visit to our Sites, speed up navigation and improve your experience of the site, (for instance by remembering some of your preferences or choices, the last pages you visited or searches you carried out or by keeping you logged in).

Our Sites may use cookies such as Google Analytics to carry out some analytics on and enhance our Sites. These cookies help us understand, for example, how you use our Sites, which pages are the most visited or where people visiting our Sites are located.

We may also use cookies to enable you to share content on networking or social media sites or for marketing and promotional purposes where you have subscribed to our marketing communications from Keystone Strategy.

The "help" section of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies, and how to disable or delete cookies altogether.

If you choose to disable cookies, certain functionalities of our Sites might not work.

We may share your personal data with other third parties that might be located in a different country than your country of residence. Keystone will not share or sell your data to any third party for their own use.

We may share your personal data with others, such as:

  • carefully selected third party service providers, such as marketing service providers (if you have subscribed to our marketing communications), IT systems providers, recruitment service providers, background check providers, data cleansing providers or event organizers, so they can provide services to Keystone;
  • our advisors;
  • law enforcement authorities or other government bodies when we are required to do so.

Third parties, other than law enforcement authorities or government bodies, will only handle your personal data on behalf of Keystone for the purposes described in this Policy. Keystone will not sell or otherwise share your personal data with such third parties for their own use.

Keystone and other third parties we share your information with may be located in other countries, including countries that do not offer the same protection to your personal data as the country in which you reside. Where that is the case, Keystone ensures that your personal data is protected by using appropriate legal mechanisms. If you reside in the European Union, such mechanisms include using contracts or wording approved by the European Commission (called “Standard Contractual Clauses”)[3] or, in the case of US-based companies, working with companies that are Privacy Shield certified.

Our Sites may contain links to third party websites that are governed by their own terms and privacy policies. Keystone does not bear any liability and responsibility for the content or your use of these websites.

The Sites may contain links to third party websites, including social network sites. Such websites are governed by their own terms of use and privacy policies, which you should review before browsing or submitting information to them. Keystone is not responsible for the privacy practices of such websites. In addition, a link to a third party website does not mean that Keystone endorses or accepts any responsibility for the content or the use of such web site. Keystone shall not bear any liability and responsibility for such content or for your use of these websites.

Keystone has implemented appropriate technical and organizational security measures in order to protect your personal data from loss, misuse, alteration, or destruction.

Keystone has implemented appropriate technical and organizational security measures in order to protect your personal data from loss, misuse, alteration, or destruction. Such measures include anonymizing or pseudonymizing data where possible. Authorized Keystone personnel and third parties mentioned above will only have access to your personal data to the extent they need it to do their job or provide their services. Despite these precautions, however, Keystone cannot guarantee that unauthorized persons will not obtain access to your information.

Depending on where you reside you might have the right to request access to, rectification or erasure of your personal data and to object to or ask for the restriction of the processing of your personal data. You might also have the right to withdraw your consent and request that we stop processing or delete your personal data.

Depending on where you reside, you may be entitled to certain rights regarding the personal data Keystone holds about you. For instance, you may have the right to request access to your information, obtain a copy of it as well as information about how we use it. You have the right to request that we correct incorrect, inaccurate or out-of-date information about you. You may also have the right to request that we stop processing your information and/or withdraw your consent to such processing and to ask us to delete your information.

In the event that you have applied for a consulting role at Keystone and you no longer wish your data to be processed as described in this Policy, or if you wish to access, rectify, cancel or oppose such processing, please contact us at info@keystonestrategy.com respectively. If you have applied for a corporate role at Keystone and wish to exercise the rights described above, please contact the person you sent your application to or info@keystonestrategy.com.  If you receive marketing communications from Keystone, you can opt out of receiving future emails from Keystone or unsubscribe from participating in our programs through the "preferences" page, which is accessible in every marketing email you receive from Keystone.

If you wish to make a request about your personal data, other than your consultant application data, please contact us at info@keystonestrategy.com. Please note that we will take reasonable steps to check your identity before handling your request.

If you think we are handling your information unlawfully, we encourage you to get in touch with us at info@keystonestrategy.com. You may also have the right to lodge a complaint with your national supervisory authority.

If you apply for a job at Keystone, you will be asked to submit information to Keystone such as your name, contact details, information about your education and work history and any other background information that might be relevant for your application or that you choose to share with Keystone. If you do not provide this information to us, we might not be able to process your application.

Keystone will use this information to assess your application and candidacy for the position to which you have applied. Without limiting the generality of the foregoing, this may include: (i) evaluating your skills and experience in relation to the qualification required for the job to which you have applied; and (ii) tracking feedback and interactions we have with you throughout the recruiting process. We may also use your information when analyzing our internal recruiting processes to determine (i) which recruit sources to focus on; (ii) how to improve integration and training programs for new hires with different educational backgrounds and work experience; and (iii) how to enhance our interview model to improve hiring quality. The information you provide may also be used to communicate with you about Keystone events and to send you publications that we think may be of interest to you.

We might share your personal data with other companies in the Keystone group as well as with third parties such as recruitment service providers, background check providers and IT system providers. These Keystone companies and third parties might be located in a different country than your country of residence. We will keep your application data for up to five years. If you no longer wish for Keystone to process your data or if you wish to exercise your rights, please contact info@keystonestrategy.com if you applied for a consulting role and info@keystonestrategy.com if you applied for a corporate role.

Definitions

1. The data controller is the person or company that, together or jointly with others, determines the purposes (why) and means (how) of the processing of personal data.

2. Personal data is any information that relates to an individual who is identified or identifiable, for instance by reference to a name, an identification number or an online identifier.

3. Standard Contractual Clauses are an agreement that can be entered into by companies for transfers of personal data outside of the European Union. They are a mechanism approved by the European Commission to ensure adequate safeguards to personal data when it is transferred outside of the European Union.

4. Anonymizing means transforming data in such a way that it is no longer identifiable, i.e. the data can no longer be linked to an individual, even if combined with other information. Anonymous data is not considered “personal data”.

5. Pseudonymizing means transforming data in such a way that it is no longer identifiable without the use of additional information. Pseudonymous data is still considered “personal data”.

Contact

If you have any questions about this Privacy Policy or how Keystone handles you

personal data, please contact Keystone at:

Email: info@keystonestrategy.com

Post: 185 Dartmouth Street, Floor 1005, Boston, MA 02116

Telephone: +1-617-224-9100

 

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