Welcome to the ICEO Community Portal of LHH.
This portal is available to our ICEO community members worldwide (current clients, alumni, advisors, mentors, experts and current ICEO and LHH staff). This portal has been designed by LHH in order to help you developing your professional network, and providing you with resources and tools for your career path.

This Privacy Notice tells you what to expect us to do with your personal data when you contact us or use or visit our LHH ICEO Community Portal, or when you access or use any applications or features made available by us (collectively, the “ICEO Community Portal”).

LHH is part of Adecco Group AG, based in Zürich, Switzerland.
The ICEO Community Portal is hosted by our service provider, PeoplePath Inc., who is acting as a data processor on behalf of LHH.

2. Our contact details as the Data Controller of your personal data

The LHH entity which provides you the LHH services is the Data Controller of your personal data.
You can address any privacy related queries to your Data Controller by completing our Privacy Request Form or via email to privacy@lhh.com.

3. What categories of personal data does LHH collect and use?

We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us:

Identity Data includes your first name, last name, gender, nationality, date of birth, age.
Contact Data includes your personal and/or professional address(es), email address(es) and telephone number(s).
Professional Data includes your job title, your company name, information on your resume including your professional qualifications, educational and professional background, and other information that you choose to provide to us.
Communications Data includes your preferences on content type, frequency of communications and preferred language.
Social Media Data includes your social media links.
Profile Data includes information about you, provided by you on our ICEO Community Portal including the information you provide to participate in our programmes and other offerings within our member benefits, your profile picture (optional), information you provide to us to publish in our materials (e.g. photo for the Alumni newsletter), your ICEO history, your feedback including your survey responses.
Technical Data, to the extent that it constitutes personal data, includes technical information collected when you access our ICEO Community Portal, and includes your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the ICEO Community Portal.

4. Why do we process your personal data and on what legal basis?

Your participation in the LHH ICEO Community Portal is voluntary.
We normally collect personal data from you only where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so.

If you are from a region that requires a legal basis for processing personal data (such as the EEA or the UK), our legal basis for collecting and using your personal data will vary depending on the personal data concerned and the specific context in which we collect it.

Please note that some information below may not apply to you depending on your relationship with us and/or the legislation of your home country.

Purposes of the processing	Type of personal data	Legal basis to process your personal data
To provide you with our services and to attempt to establish or strengthen a relationship with you.	a) Identity Data b) Contact Data c) Professional Data e) Social Media Data f) Profile Data	- Consent where we are required under the law to obtain consent to provide you with our services - Fulfilment of our legitimate interests to provide our products and services
To keep you informed about our services, via email, messaging, phone, social media or any other channel. This includes information such as events or newsletters that may be of interest to you.	A) Identity Data b) Contact Data d) Communications Data e) Social Media Data if applicable f) Profile Data	- Consent where we are required under the law to obtain consent for marketing - Fulfilment of our legitimate interests to promote our products and services where we are not obliged to obtain consent by law
To respond to your request or questions or provide information when you contact us or make a request to us.	a) Identity Data b) Contact Data f) Profile Data	Fulfilment of our legitimate interests to respond to you
- To allow you to participate in interactive features of the ICEO Community Portal, when you choose to do so; - To further develop and improve the ICEO Community Portal and systems to better serve you; - To best tailor content, the ICEO Community Portal and resources according to your preferences, to improve them and to present it in the most effective manner for you.	A) Identity Data b) Contact Data c) Professional Data f) Profile Data g) Technical Data	Fulfilment of our legitimate interests to administer our ICEO Community Portal and provide you with relevant information about our products and services
Where necessary, to comply with any legal obligation.	All types of personal data mentioned in section 3 as necessary.	Compliance with a legal or regulatory obligation
To investigate or respond to incidents and complaints and/or to comply with investigations carried out by the police, government or regulators.	All types of personal data mentioned in section 3 as necessary.	- Compliance with a legal or regulatory obligation - Performance of a task carried out in the public interest

5. How do we get your personal data and do you have to give them to us?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
This includes personal data you provide when you:
- register to our ICEO Community Portal;
- subscribe to our service or publications;
- request communications to be sent to you; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our ICEO Community Portal, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies and from the communications we receive from your browser.

You can create your account on the ICEO Community Portal by using your LinkedIn or Google’s accounts, or by providing us with the necessary information to create your account: first name, last name and email address.

Except for the necessary information specified above, you are not obliged to provide your personal data to us.

6. How long do we keep your personal data for?

If you have not access to the LHH ICEO Community Portal for two (2) years, we will send you a reminder checking to see if you are still interested to be part of the LHH ICEO ICEO Community. After fifteen (15) days, we will send you a final reminder and then close your account if there is no answer after fifteen (15) days. Once your account is closed, we will delete your personal data, unless we have a legal reason for retaining it.

You will be able to update your own online profile, sign up or remove yourself from mailing lists and groups in the ICEO Community Portal in your profile settings. If you want to leave the LHH ICEO Community Portal or if you want to request any changes to your profile, you can email us at alumni@lhhiceoalumni.com.

7. What communications do we send?

Communication with Individuals

We will only send communications to you, as an individual, if you have consented to us doing so.

To change your communications preferences, you can opt-in or opt-out by checking the relevant box located in your profile (Settings > Notifications).

You may opt out of receiving any further communications by clicking the ‘unsubscribe’ or ‘opt-out’ function in the bottom of the email. You can also exercise your opt-out right at any time in your profile (Settings > Notifications).

Please note that it may take up to three days to remove your contact information from our communications lists, so you may receive correspondence from us for a short time after you make your request. Your opt out will not affect transactional / service emails from us, such as password reset emails or notifications of updates to our terms. You will still receive these as part of your services.

8. Do we share your data with third parties?

The LHH ICEO Community Portal’s Community

The LHH ICEO Community Portal’s community will be able to see the information on your profile for networking purposes. It includes all ICEO clients, advisors, mentors, experts, alumni and LHH’s colleagues part of the ICEO Community Portal.

Unless you request otherwise in your Profile settings, your name, profile picture, current and past professional data, degrees, and social media links will be accessible to other members of the LHH ICEO Community Portal.

The rest of the information you provide for your profile will not be shared with other members of the ICEO Community Portal until you provide consent for such sharing through the privacy settings in your Profile.

As part of the services available on the ICEO Community Portal, your name may be displayed if you choose to (i) RSVP for events (both in person and virtual); (ii) submit your own alumni news or story; (iii) interact on the ICEO Community Portal.

PeoplePath GmbH

To provide the LHH ICEO Community Portal, your data will be processed by PeoplePath GmbH, our trusted business partner acting on our behalf.

Within the LHH and Adecco family

Your information may also be disclosed for business purposes to other members of the LHH and Adecco Group family which are supporting your service delivery, for example:

To benefit from group shared Support and IT services.

We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do it. They will not share your personal data with any organization apart from us. They will hold it securely and retain it for the period we instruct.

9. Do we transfer or store your data outside of your country of residence?

Your personal data will be stored in the European Union.

As a global multinational group, we leverage shared services to increase efficiencies for our business and customers. For example, we share IT services and after-hours service support with other Adecco Group companies. A full list of the countries in which we operate is available on our website at Adecco Global.

We shall only transfer your Personal Data to countries that provide an adequate level of data protection as defined by the European Commission, or where we have put in place appropriate safeguards to preserve the privacy of your Personal Data. When we transfer your information to recipients in these countries, we will protect that information as described in this Privacy Notice and will comply with applicable legal requirements.

For residents of the European Union (EU), United Kingdom (UK), and Switzerland: Data Privacy Framework Notice for personal data transfers to the United States

Lee Hecht Harrison LLC (LHH USA, LHH) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. LHH has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. LHH has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

LHH is responsible for the processing of personal data it receives, under the Data Privacy Framework, and subsequent transfers to a third party acting as an agent on its behalf. LHH complies with the Data Privacy Framework Principles for all onward transfers of personal data from the EU, United Kingdom, and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over LHH’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-US Data Privacy Framework (Swiss-U.S. DPF). In certain situations, LHH may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.

In compliance with EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DP, LHH commits to resolve DPF Principles-related complaints about our collection and use of your personal data. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, or the UK Extension to the EU-U.S. DPF or the Swiss-U.S. DPF should first contact LHH at privacy@lhh.com.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, LHH commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC)} with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

Under certain conditions, more fully described on the Data Privacy Framework website at https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

10. What data security measures do we have in place?

We have put in place security measures to prevent your information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed while it is under our control.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

While we take appropriate technical and organizational measures and have in place physical and electronic procedures necessary to safeguard the personal data that you provide to us, no transmission to or from us by post, email, phone, SMS (text) message or over the internet can ever be guaranteed as entirely secure.

Communications over the web are not completely secure and for this reason, any transmission is at your own risk.

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

11. What are your rights regarding your personal data?

Under applicable data protection laws, you have the following rights:

Right to be informed about collection or disclosure of your personal data
You have the right to be informed of the categories of personal data that we collect about you as well as the categories of sources from which the personal data was collected.
You also have the right to be informed of the business or commercial purposes for which we use, disclose your personal data as well as the categories of third parties with whom we share that personal data, as mentioned in this Privacy Notice.
Right to access and obtain a copy of your personal data
You have the right to request to have access to the personal data that we collected about you and obtain a copy of them under certain circumstances.
Right to correct your personal data
If you can demonstrate that the personal data we hold about you is not correct, you can ask that this information is updated or otherwise corrected. Depending on the information you may be able to update your personal data directly in the ICEO Community Portal.
Right to be forgotten or to delete personal data
In certain circumstances, you have the right to have your personal data deleted. You may make such a request at any time and we will evaluate if your request should be granted, however this right is subject to any legal obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal data deleted must be granted, we will do so within the time limit set by the applicable data protection laws.
Right to restrict or object to the processing of your personal data
In certain circumstances, you have the right to obtain restriction of the processing of your personal data, or to object to certain processing thereof on grounds relating to your particular situation.
Right to data portability
This only applies to the information you have given us. You have the right to ask that we transfer the information you gave us from one organization to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering a contract and the processing is automated.
Right to opt-out from marketing communications and newsletters
Where we send marketing or other communications to you, you may opt out of receiving any further communications by contacting us or using the ‘unsubscribe’ or ‘opt-out’ function when available.
Right to withdraw consent
You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right to lodge a complaint
You have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your personal data has arisen.

You are not required to pay any charge for exercising your rights.

If you want to exercise any of your rights, please use our form by clicking here.

For residents of the United States: California & Other U.S. State Privacy Rights

Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have rights to:

Access the categories and specific pieces of personal data LHH has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom LHH has shared personal data;
Delete personal data under certain circumstances;
Correct personal data under certain circumstances; and
Opt out of the “sale” of personal data or “sharing” of personal data for targeted advertising purposes.
We do not sell your personal data in the conventional sense. However, like many companies, we may use analytics services that are intended to analyze your interactions with our website, based on information obtained from cookies or other trackers, including for delivering interest-based content to you.

You can opt out of the use of cookies on our website by using your browser
Most browsers allow you to view, manage, delete, and block cookies for a website. You can find specific guidance on how to control cookies for common browsers linked below:

Google Chrome
Mozilla Firefox
MacOS Safari Desktop or Mobile
Microsoft Edge
For information on additional browsers and device types please see http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/

To learn more about certain cookies used for interest-based advertising by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit:

Managing Analytics cookies

You can opt-out of having your anonymized browsing history within our websites or applications recorded by analytics cookies. We use the following service provider on certain of our websites and you can learn more about their privacy policies and how to opt-out of their analytics cookies by clicking on the link:

Google Analytics: Google’s Opt-Out page

You will need to set your preferences from each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-select your preferred settings.

Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. You can do so by replying directly to our denial or filling in the applicable form in the section “Getting in touch with us” below.

LHH will not discriminate against you for exercising any of these rights.

Sensitive Information. In limited instances, LHH receives information that may be considered sensitive under some laws.

Under CPRA, "Sensitive personal Information" means any personal information that reveals:

a consumer's social security, driver's license, state identification card, or passport number;
a consumer's account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
a consumer's precise geolocation;
a consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership;
the contents of a consumer's mail, email and text messages, unless the business is the intended recipient of the communication;
a consumer's genetic data; and
the processing of biometric information for the purpose of uniquely identifying a consumer;
personal information collected and analyzed concerning a consumer's health; or
personal information collected and analyzed concerning a consumer's sex life or sexual orientation.

Sensitive personal information that is "publicly available" is not be considered sensitive personal information or personal information.

LHH processes sensitive personal information to provide LHH products and services, for product research and development, for authentication, integrity, security, and safety reasons, to communicate with you, for legal reasons, and with your consent. LHH does not use or disclose sensitive personal information (as defined under CCPA) for purposes of inferring characteristics about a consumer, or in any way that would require LHH to provide a right to limit under the CCPA.

Profiling
Under certain laws, residents may also be permitted to opt out of certain profiling relating to automated processing analyzing certain categories of an individual’s information that would produce a legal or similarly significant effect. LHH does not engage in this type of profiling of individuals.

To exercise your rights, please fill in this form or email privacy@lhh.com.

To opt out of the use of cookies on our sites, follow the instructions above.

If you would like to submit an opt-out request for personal information that is not collected by cookies – such as your email address - please fill in this form.

These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.

Disclosure of Privacy Rights Requests
The CCPA requires businesses to disclose the number of requests received, complied with in whole or in part, or denied.

Between January 1, 2021, and December 31, 2021, LHH received 67 privacy rights requests from USA data subjects which were fulfilled in whole or in part, and 1 privacy rights request which was denied. On average, all privacy rights requests were responded to within 10 days.

Examples of denied requests include requests that were not verifiable, requests that were not made by the consumer, and requests that were exempt from disclosure.

California’s Shine the Light Law
California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

12. For residents of California: Notice at Collection

If you reside in California, we are required to provide additional information to you about how we use and disclose your information. We have included this California-specific information below.

Categories of Personal Information LHH Receives: LHH may collect, or process on behalf of our customers, the following categories of personal data, as described above, in the “What categories of personal data does LHH collect and use?” section: identifiers (such as in Identity Data, Contact Data); commercial information (such as in Professional Data); internet or other electronic network activity information (such as in Technical Data); audio, electronic, and visual information (such as in Profile and Technical Data); education information (such as in Professional Data); inferences we derive from the preceding or other information we collect. The categories of data that LHH collects and discloses for a business purpose may also include “sensitive personal information” as defined under the California Privacy Rights Act. However, LHH does not use or disclose sensitive personal information for any purpose not expressly permitted by the California Privacy Rights Act.

Sources: We receive information from sources as described in the “How do we get your personal data and do you have to give them to us?” section, including: from you (including through your use of our products and services), from publicly available sources and from trusted third-party partners as described in the “Do we share your data with third parties?” section.

LHH’s business and commercial purposes for use: LHH uses personal data for the following business and commercial purposes: to provide LHH Products and Services; for Product Research and Development; for Marketing and Promotions; for Authentication, Integrity, Security, and Safety; to Communicate with You; and for Legal Reasons. For more information, and the Categories of third parties to whom we disclose Personal Information for business purposes, please see the “Do we share your data with third parties?” section.

LHH may permit analytics services to analyze your interactions with our website, which may constitute a “sale” or “sharing” of data under California law. See our “California & Other U.S. State Privacy Rights” section for more information regarding your right to opt-out.

Retention: LHH retains personal data for as long as required to engage in the uses described in this Privacy Notice unless a longer retention period is required by applicable law.

13. How do we handle changes to this Privacy Notice?

The terms of this Privacy Notice may change from time to time. We shall publish any material changes to this Privacy Notice through appropriate notices either on this ICEO Community Portal or contacting you using other communication channels.

14. Getting in touch with us

If you have questions about data protection or if you wish to contact our Data Protection Officer, email us at privacy@lhh.com.

To exercise any of your rights related to your personal data, please fill in this form.