Updated: November 2020

1. Introduction

1.1 Krauthammer is an international group of companies, all operating under the name of 'Krauthammer', however, consisting of the various legal entities that are included in Appendix I to this Statement. These entities will be referred to as “KH Entities”.

1.2 This External Privacy Statement (“Statement”) applies to you if you or the entity you work for have entered into an agreement with one of the KH Entities, where you or the entity you work for may enter into an agreement with one of the KH Entities and furthermore in every situation where one of the KH Entities processes data that identifies you or may be used to identify you with (“Personal Data”) as a ‘data controller’ as defined in the General Data Protection Regulation (“GDPR”).

1.3 This Statement applies to all processing of Personal Data in relation to the services of the KH Entities, the conducting of its business, and day-to-day activities in the field of leadership and management, sales excellence, change and transformation, and culture and collaboration. In particular, this Statement applies to all Personal Data that is processed during the performance of services by the KH Entities, such as but not limited to (open) training, coaching sessions, and consulting meetings (jointly: “Services”).

1.4 Unless stated otherwise below, the relevant data controller in your situation is the KH Entity that you or the entity you work for has entered into an agreement with or might enter into an agreement with. This KH Entity is hereinafter referred to as “KH”. Should you have any questions as to which KH Entity is the ‘data controller’ in your situation, or you have any further questions, please contact KH by the details as provided in this Statement.

1.5 KH and any of the KH Entities may amend this Statement at any time. In case the Statement is amended, the amended Statement will be made available to you through the publication of the amended Statement on the website of the KH Entities.

2. Personal Data

2.1 KH may process Personal Data that relates to you in the following situations:
2.1.1 You are a customer of KH or take part in the Services in any way;
2.1.2 You are a supplier of products or services to KH;
2.1.3 You work for a customer or supplier of KH, based on an employment contract or otherwise;
2.1.4 You apply for a job at KH;
2.1.5 You are somebody or you work for an entity that KH would like to offer Services to, based on an employment contract or otherwise;
2.1.6 You are visiting the website of the KH Entities, currently located at (“Website”).

2.2 The Personal Data that may be processed by KH is:
2.2.1 Your first and last name;
2.2.2 Your contact details;
2.2.3 Your address details;
2.2.4 Data relating to the business or legal entity that you work for;
2.2.5 Your email address;
2.2.6 Your nationality;
2.2.7 Your resume, CV, and further information about your career, functioning, skills, and education;
2.2.8 All Personal Data that is collected during your participation in Services;
2.2.9 Any other Personal Data, depending on the nature of the relationship you have with KH;
2.2.10 Personal Data as is processed via the Website.

2.3 In addition to the aforementioned Personal Data, it is possible that you provide us with other Personal Data in the course of your contact with KH. This may concern the following Personal Data:
2.3.1 The Personal Data that you provide to KH when contacting KH in any way;
2.3.2 The Personal Data that is collected in case of any emergencies that may occur during the provision of Services by KH.

2.4 The provision of the requested Personal Data under 2.2 is, in principle, mandatory and a necessary requirement to enter into an agreement with KH. Where such Personal Data is not provided, KH may not be able to comply with obligations that KH is subject to or perform the agreement that has been or will be entered into. The provision of the Personal Data as described under 2.3 is, in principle, not mandatory and is not a necessary requirement to enter into an agreement with KH. Where such Personal Data is not provided, KH however may not be able to perform the services and obligations as intended.

3. Website

3.1 The Website is controlled by the Krauthammer International Services N.V., the KH Entity in Belgium. Therefore, the relevant ‘data controller’ under the GDPR for the processing of Personal Data via the Website is Krauthammer International Services N.V.

3.2 On the Website, Personal Data is automatically processed via cookies and similar techniques. For more information, please consult the Krauthammer Cookie Statement.

4. Sources

4.1 In principle, KH obtains Personal Data through you. This is not the case in the following situations:
4.1.1 Where KH has received Personal Data from your employer or other parties that have arranged the Services to be provided to you, in which case this entity provides KH with the relevant Personal Data;
4.1.2 Where KH has engaged an employment agency, head-hunter or similar service to recruit new employees;
4.1.3 Where KH has hired an external assessment agency or a service of the like to assist KH in providing the requested Services to you, and such company provides with Personal Data.

5. Legal grounds for the processing

5.1 KH collects Personal Data based on the following legal grounds for processing:
5.1.1 The processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into an agreement;
5.1.2 The processing is necessary for compliance with a legal obligation to which KH is subject;
5.1.3 The processing is necessary for the purposes of legitimate interests pursued by KH, i.e. the commercial interest to perform its business activities, such as limited to the performance of the agreement as entered into with your business, your employer, or any party that has arranged our Services to be provided to you on your behalf, and in addition our legitimate interest to promote our Services to prospective customers and, in addition, Personal Data is processed to maintain and further develop the Website and review the use thereof, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child;
5.1.4 Where necessary, KH will request your consent for the processing of your Personal Data.

6. Purposes

6.1 KH is processing the Personal Data mentioned for the following purposes:
6.1.1 To allow KH to enter into an agreement with you or the business that you represent or that you work for and to perform this agreement, such as but not limited to the agreement to perform the Services as requested, the agreement for the supply of products and services to KH or to register and manage the suppliers and customers;
6.1.2 To allow KH to comply with legal obligations to which KH is subject;
6.1.3 To allow KH to recruit new employees, assess them and hire them;
6.1.4 To allow KH to communicate and interact with its partners and Krauthammer group companies;
6.1.5 To allow KH to perform direct marketing activities, such as but not limited to informing you about our services, events, and possibilities and to verify the effectiveness of such activities;
6.1.6 To allow KH to maintain and develop the Website and review the use thereof.

7. Retention times

7.1 KH retains your Personal Data for as long as necessary in order to fulfill the associated purposes as set out above. After that, we may retain your Personal Data if this is required or necessary in order to comply with applicable law or in order to be able to satisfy any legal, reporting, or audit requirements and/or obligations. Where possible we anonymize or pseudo-anonymized your Personal Data or retain it in an aggregated form only.

7.2 The retention periods for the following categories of Personal Data are as follows:
7.2.1 Personal Data of (persons employed by or otherwise working for) customers and suppliers: two years after the relevant agreement has ended;
7.2.2 Personal Data of (persons employed by or otherwise working for) prospects: two years after the last contact with KH;
7.2.3 Personal Data of job applicants: four weeks after the end of an application procedure where such was unsuccessful unless the applicant has provided for one year after the end of the application (where the applicant is hired, the processing of Personal Data shall fall under the internal privacy policy of KH).

8. Recipients and transfer

8.1 KH may transfer your Personal Data to third parties and recipients, being
8.1.1 Suppliers: when such is necessary to enable the performance of Services we may transfer your Personal Data to suppliers, subcontractors, and business partners, such as but not limited to our digital agencies and partners in the field of assessments and further evaluation services
8.1.2 Group companies: we may provide Personal Data to other companies within the KH group of companies if this is necessary for compliance, internal reporting, auditing, or security purposes 8.1.3 Law enforcement agencies: we may be under an obligation to provide your information to law enforcement, regulators, courts or other public authorities in relation to an official (court) order. In addition, we may provide your data to law enforcement agencies, regulators, courts, or otherwise in order to exercise our rights
8.1.4 Fraud prevention: we may engage third parties in order to investigate or prevent any fraudulent acts or to protect our assets and/or rights

9. Possible recipients and transfer

9.1 In addition to the recipients as referred to in article 8, it is possible that KH discloses Personal Data in the below-mentioned situations, in which case you will be informed by KH:

9.1.1 KH is the subject of a merger or acquisition, in which case it is possible that Personal Data is transferred to a prospective buyer or seller and the Personal Data is disclosed under this Statement;
9.1.2 Where KH will substantially or fully be the subject of an acquisition, in which case the Personal Data will be transferred as an asset

9.1.3 Where KH is legally obliged to provide Personal Data or to perform the Statement, the general terms and conditions of KH or the agreement with you, to protect the rights, property, and freedoms of KH or her clients or other third parties, KH will transfer Personal Data as well

10. International transfer

10.1 KH in principle does not transfer Personal Data outside of the European Union or to international organizations.

10.2 Where such is necessary, KH will transfer Personal Data to one of the KH Entities or partners of KH in performing our Services. The relevant parties have entered into an agreement containing the relevant ‘Standard Contractual Clauses’ as provided by the European Commission. A copy of these clauses can be retrieved via KH. If KH transfers Personal Data outside of the European Union in any other way or to international organizations, KH will determine whether an adequacy decision as stated in the relevant legislation applies and, where such is not the case, the transfer will only be conducted if adequate safeguards apply. At your request, you can receive a copy of the adequate safeguards.

11. Security

11.1 We highly value the security of your Personal Data. Therefore we have implemented technical and organizational measures to protect your Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. To keep your Personal Data safe, the following measures are implemented:

Malware protection on all servers and endpoints;
State of the art firewalls with Advanced Threat Protection;
State of the art datacenter;
Secured and restricted data access;
Encrypted cloud backup.

12. Rights

12.1 The GDPR provides data subjects, depending on the situation, with the following rights:
12.1.1 The right to access to Personal Data;
12.1.2 The right to rectification of Personal Data;
12.1.3 The right to request from KH the erasure of Personal Data;
12.1.4 The right to request KH whether the processing of the Personal Data may be restricted;
12.1.5 The right to object to processing
12.1.6 The right to data portability
12.1.7 Where the processing is based on consent: the right to withdraw such consent at any time, without such withdrawal having an effect on the legitimacy of the processing prior to withdrawal;
12.1.8 The right to lodge a complaint at a supervisory authority.

12.2 When performing these rights, KH may request specific additional information. Such additional information will only be processed for the purpose of performing the rights mentioned.

Appendix I – KH Entities

(Belonging to the Krauthammer External Privacy Policy)

1. Krauthammer Group B.V., having its registered office in Amsterdam, The Netherlands, and having its business offices in (1097 BA) Amsterdam at the Stephensonstraat 19, recorded in the registry of the Dutch Chamber of Commerce under registration number 90107985. This entity can be contacted via privacy@krauthammer.com
   
2. Krauthammer International Netherlands B.V., having its registered office in Amsterdam, The Netherlands, and having its business offices in (1097 BA) Amsterdam at the Stephensonstraat 19, recorded in the registry of the Dutch Chamber of Commerce under registration number 28086930. This entity can be contacted via privacy@krauthammer.com
   
3. Krauthammer International Services N.V., having its registered office in Zaventem, Belgium, and having its business offices in (B-1930) Zaventem at the Corporate Village Building Elsinore, Leonardo Da Vincilaan 9, recorded in the registry of the Dutch Chamber of Commerce under registration number 809396804. This entity can be contacted via privacy@krauthammer.com
   
4. Krauthammer International SARL, having its registered office in Paris, France, and having its business offices in (75009) Paris at the 7, rue Meyerbeer, recorded in the trade register of Paris under registration number 432657070. This entity can be contacted via privacy@krauthammer.com
   
5. Krauthammer International GmbH, having its registered office in Hamburg, Germany, and having its business offices in (20457) Hamburg at the Willy-Brandt-Straße 23, recorded in the register of the magistrates court Hamburg under registration number HRB 95242. This entity can be contacted via privacy@krauthammer.com
   
6. Krauthammer Training, Coaching & Consulting (Shanghai) Ltd., having its registered office in Shanghai, People's Republic of China, and having its business offices in (200233) Xu Hui District, Shanghai at the Room 601, DOBE Century WE No.6 Pu Bei Road, recorded in the Register of Shanghai Administration for Industry & Commerce under registration number 9131000059042665XD. This entity can be contacted via privacy@krauthammer.com
   
7. Krauthammer International SA, having its registered office in Zurich, ‎Switzerland, and having its business offices in (CH-8048) Zurich at the Max-Högger-Strasse 6, recorded in the trade register of Zurich under registration number CHE-106.077.786. This entity can be contacted via privacy@krauthammer.com