Privacy policy

This Notice

This Notice explains how we may Process your Personal Data. This Notice may be amended or updated from time to time, so please check it regularly for updates. This Notice is issued by Laurel Agency.® on behalf of itself, its subsidiaries and its affiliates (together, “LAUREL AGENCY”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including but not limited to customers, visitors to our Sites, visitors to our offices and other users of our services (together, “you”). Defined terms used in this Notice are explained in Section (S) below. For the purposes of this Notice, LAUREL AGENCY 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.

Collection of Personal Data

We may collect or obtain Personal Data about you: directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you’re a client, a candidate, or apply to be a Network Member); when you make your Personal Data public (e.g., via social or business networking sites); when you visit our Sites; when you register to use any of our Sites, or services; when you interact with any third party content or advertising on a Site; or when you visit our offices. We may also receive Personal Data about you from third parties. Collection of Personal Data: We may collect Personal Data about you from the following sources:

- Data you provide: We may obtain your Personal Data when you provide it to us (e.g., when you contact us via email or telephone, apply for a position with LAUREL AGENCY or provide your details on our office visitor log).

- Relationship data: We may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you or to your employer, or you visit our offices).

- Network Member data: We may collect or obtain your Personal Data if you apply to become a Network Member.

- Data you make public: We may collect or 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 or business networking profile(s)).

- Site data: We may 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.

- Registration details: We may collect or obtain your Personal Data when you use, or register to use, any of our Sites or services.

- Third-party information: We may 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 create Personal Data about you (e.g., records of your interactions with us). We may also create Personal Data about you, such as records of your interactions with us, our clients, or our Network Members.

Categories of Personal Data we may Process

We may Process your personal details (e.g., your name, biographical information); demographic data; your contact details (e.g., your address); records of your consent; payment details; information about our Sites (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.
We may Process the following categories of Personal Data about you:

- Personal details: given name(s); preferred name; and photograph (if provided).

- Demographic information: date of birth; salutation; title; and language preferences.

- Network Member data: With respect to Network Members (in addition to any other applicable category set out in this Notice), we also collect wireless device addresses (including text message addresses), payment information, professional biography, and other profiling information pertaining to your experience and expertise.

- Contact details: address; telephone number; email address; and details of your public business networking profile(s) or online biographies.

- Consent records: records of any consent 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).

- Payment details: invoice records; payment records; billing address; payment method; bank account number; card or account security details; BACS details; SWIFT details; IBAN details; payment amount; and payment date.

- Data relating to our Sites: 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; internet service provider (ISP) details; referring and exit pages; and clickstream data.

- Employer details: 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.

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

Legal basis for Processing Personal Data

We may Process your Personal Data where: you have given your prior, express consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the Processing.
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 bases, depending on the circumstances:

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

-Contractual necessity: We may Process your Personal Data where the Processing is necessary for connection with any contract that you may enter into with us (for instance if you are a LAUREL AGENCY Network Member, have applied for Network Membership, or are a LAUREL AGENCY client);

-Compliance with applicable law: We may Process your Personal Data where the Processing is required by applicable law or fulfilling our health and safety obligations to employees);

-Vital interests: We may Process your Personal Data where the Processing is necessary to protect the vital interests of any individual; or

-Legitimate interests: We may Process your Personal Data where we have a legitimate interest in the Processing. The balancing test we have conducted in each case is as follows:

• we have ensured that the Processing is lawful, proportionate, and conducted in accordance with the terms of this Notice;

• we have ensured that we have a legitimate business need to perform the Processing; and

• we have ensured that there is no material likelihood of any adverse impact on your interests, fundamental rights, or freedoms, as a result of the Processing.

Sensitive Personal Data

We do not seek to collect or otherwise Process your Sensitive Personal Data. Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.
We do not seek to collect or otherwise Process 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:

-Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations or fulfilling our health and safety obligations to employees);

-Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);

-Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise, or defence of legal rights; or

-Consent: We may 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 Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, including ensuring that one of the legal bases set out above is available to us with respect to the Processing of those Sensitive Personal Data.

Purposes for which we may Process your Personal Data

We may Process your Personal Data for the following purposes: providing services to you; compliance checks; operating our Sites; communicating with you; managing our IT systems; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law or fulfilling health and safety obligations to employees; and improving our Sites, and services.
We may Process your Personal Data for the following purposes, subject to applicable law:

-Provision of services: providing our Sites or services; providing services on request; and communicating with you in relation to those services.

-Our Sites: operating and managing our Sites; 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.

-Network Members: communicating with you regarding your Network Membership (or prospective Network Membership), where applicable, to provide you with opportunities to participate in the LAUREL AGENCY Network, and to keep you up to date with new developments at LAUREL AGENCY. Additionally, as a Network Member, in accordance with the applicable Terms and Conditions, we may share your information with Clients and non-Client third parties for the purpose of providing services and promoting LAUREL AGENCY’s business, including without limitation by displaying such information on LAUREL AGENCY websites, print media and other materials (collectively, “Marketing Materials”). You may opt out of this promotional use by contacting your LAUREL AGENCY Member Solutions Associate or through the opt-out tool located on your profile page.

-Communications: communicating with you via any means (including via email, telephone, text message, social media, post, or in person) information in which you may be interested (e.g., upcoming LAUREL AGENCY events, new product offerings, information relevant to you as a LAUREL AGENCY client or Network Member), 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.

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

-Financial management: sales; finance; corporate audit; and vendor management.

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

-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).

-Investigations: detecting, investigating, and preventing breaches of policy, fraud, and violations of law, in accordance with applicable law.

-Legal Proceedings: establishing, exercising, and defending legal rights.

-Legal compliance: compliance with our legal and regulatory obligations under applicable law or fulfilling our health and safety obligations to employees).

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

-Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.

Disclosure of Personal Data to third parties

We may disclose your Personal Data to legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting, or preventing criminal offenses; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites. We may disclose your Personal Data to other entities within the LAUREL AGENCY 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:

-you and, where appropriate, your appointed representatives;

-legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

-accountants, auditors, lawyers and other outside professional advisors to LAUREL AGENCY, subject to binding contractual obligations of confidentiality;

-third party Processors (such as payment services providers; survey partners, marketing outreach providers, cloud service providers, etc.), located anywhere in the world, subject to the requirements noted below in this Section (H);

-any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;

-any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

-any relevant party if we believe disclosure is necessary and appropriate to prevent physical, financial, or other harm, injury, or loss;

-any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and

-any relevant third party provider, where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. Additionally, if you are a Network Member:

-We may disclose your information to Clients, to whom we have certain confidentiality obligations which may prevent us from disclosing their identity;

-We may disclose your information to third parties, such as current and former employers and companies that you have provided services to or contracted with, for the purpose of confirming any consents or approvals that you may need to participate in the LAUREL AGENCY Network or in specific project(s);

-To providers with whom we have partnered to facilitate surveys, compliance checks, and screenings;

-Our Clients (to the extent required by law, or by the relevant Client’s compliance policies) may disclose information about projects in which you were involved, for example your name and the amount you were paid on the project.

International transfer of Personal Data

We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses. Because of the international nature of our business, we may need to transfer your Personal Data within the LAUREL AGENCY group, 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 Standard Contractual Clauses. You may request a copy of our Standard Contractual Clauses using the contact details provided in Section (R) below. If you are located outside of the United States, you should be aware that the Personal Data you provide to us is being transmitted to us and Processed in the United States, and will be protected subject to this privacy policy and United States laws, which may not be as protective as the laws in your country. Please note that when you transfer any Personal Data directly to a LAUREL AGENCY entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.

Data security

We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely 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.

© 2023 by Laurel Agency.