Privacy Notice
This privacy policy applies to the services and websites of Executive Action LLC and those of any subsidiaries, affiliates, agents and contractors that the Company may utilize in the course of its business (collectively, the “Company” or “Executive Action” or “we” or “us”), including without limitation www.execaction.com and other related websites that may be added from time to time (collectively, the “Web Site”). The Company understands and appreciates that Web Site visitors (or “they” or “you”) are concerned about their privacy and about the confidentiality and security of information we may obtain about them online. We want you to understand the steps we have taken to safeguard the information we receive online about visitors who access or interact with the Company and its services (the “Services”).
Please read the following policy (the “Privacy Policy”) to understand how your personal information will be treated as you make full use of the Web Site. Your use of the Web Site is subject to your acceptance of this Privacy Policy and our Terms of Use referenced elsewhere on this Web Site. If you do not agree with this Privacy Policy, please do not use the Web Site.
This Notice describes how we will collect and use your information both from your use of this website and through any services that we may provide to you and the rights you have in relation to your information.
We may collect information from you about your preferences through your use of this Web Site when you request information from us or engage with our services.
By using any of our services, including this Web Site, and by providing us with any personal information, you acknowledge the use of your personal information as set out in this Notice. Please do not further browse our website or send us any personal information if you do not want that information to be used in this way.
References in this Notice to “your information” are also to personal information and data that you provide to us. Executive Action is the data controller of any information provided via this Web Site and in the course of our relationship with you.
Information we collect
Executive Action may ask for and collect from you personally identifiable and other information, including personal data, at certain points via this Web Site and in the course of your relationship and interactions with us. Depending on the information and/or services you request, you may be asked to provide your name, email address and other related information including identification documents.
In addition to the information you knowingly provide, Executive Action may collect the domain names and IP addresses of its Web Site visitors, along with usage statistics (e.g., types of web browsers and operating systems used) and browsing history. This data may be used to promote our services. For such purpose, Executive Action may combine this information with the personally identifiable and other information it collects.
How we use your information – Legal basis for processing
At Executive Action we are committed to protecting and respecting your privacy and will only use your personal information:
- to provide our services to you, on the basis of the performance of our contract with you;
- to improve our services to you, on the basis of our legitimate interest to better understand your requirements and to adapt our offering accordingly;
- to compile anonymous statistics, for example, Web Site usage statistics, on the basis of our legitimate interest to analyze the reach of our Web Site;
- to market our services, on the basis of our legitimate interest to develop our business or your consent;
- to manage our relationship with you, on the basis of our legitimate interest to develop our business or your consent;
- to fulfil our legal obligations, on the basis of our obligation to comply with mandatory legal provisions, in particular relating to anti-money laundering regulations regarding knowing our clients;
- to provide you with personalized content, on the basis of our legitimate interest to market and promote our products and services;
- to process and respond to enquiries, on the basis of our legitimate interest to develop our relationship with you;
- to alert you to new features, special events, and service offerings, on the basis of our legitimate interest to develop our relationship with you or your consent; and
- For other legitimate business purposes.
How and why we share your information
In order to achieve said purposes, your personal information may be communicated to the relevant authorized persons within Executive Action in charge of marketing, business development, client servicing, information technology, legal and compliance, depending on the processing purpose concerned.
Please note that we may on occasion be required to share your information with other Executive Action group related companies or branches around the world and other third parties who provide services to us or on our behalf. This may entail a transfer of your information on occasion. However, we are implementing procedures and safeguards to ensure the protection of your information and we are taking steps to ensure that all such entities keep your personal information confidential and secure and only use it for the purposes that we have specified and have informed you of.
Executive Action may disclose your personal information to another entity (i) for purposes of outsourcing one or more of the functions described above; (ii) to confirm or update information provided by you; (iii) to inform you of events, information about our services, and other important information; or (iv) for other purposes disclosed at or before the time the information is collected. We may also share your information when legally required to do so.
Please note that we may on occasion be required to share your information with other Executive Action group related companies or branches around the world and other third parties who provide services to us or on our behalf. This may entail a transfer of your information on occasion. However, we are implementing procedures and safeguards to ensure the protection of your information and we are taking steps to ensure that all such entities keep your personal information confidential and secure and only use it for the purposes that we have specified and have informed you of.
Executive Action may disclose your personal information to another entity (i) for purposes of outsourcing one or more of the functions described above; (ii) to confirm or update information provided by you; (iii) to inform you of events, information about our services, and other important information; or (iv) for other purposes disclosed at or before the time the information is collected. We may also share your information when legally required to do so.
Retention of personal data
How long Executive Action holds personal data for will vary. The retention period will be determined by various criteria including:
- the purpose for which the Company is using it – Executive Action will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which the Company has to retain personal data.
Transferring information when there is a change to our business
If in the future we re-organize or transfer all or part of our business we may need to transfer your information to new Executive Action entities or to third parties through which the business of Executive Action will be carried out, on the basis of our legitimate interest to develop and restructure our business.
How we protect information
The Company is committed to protecting your personal information against loss, misuse, and alteration. Executive Action has implemented appropriate administrative, technical, and physical measures to protect your personal information.
Confidentiality
We acknowledge that the information you provide the Company may be confidential. We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except that we may share information with our service providers for the purposes set out in this Notice. We endeavor to maintain the confidentiality of and protect your information in accordance with this Notice and all applicable laws. However, notwithstanding the measures to provide a secure environment for users accessing this Web Site, the Company cannot guarantee the confidentiality or security of the personal and other information being provided and we make no warranty whatsoever, express or implied, in that regard.
Your rights
You have the right to apply for a copy of the information we hold about you. This is called a data subject access request and you can make a request by writing to us using the contact details referenced elsewhere on this Web Site. We may require further information from you in order to verify your identity before disclosing any personal information to you.
You also have the right to have any inaccurate information about you corrected. We want to make sure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is no longer up to date. Please contact us using the contact details provided elsewhere on this Web Site if you would like any corrections made to your information or would like the Company to erase your personal data. Please note that there may be circumstances where you ask Executive Action to erase your personal data, but we are legally entitled to retain it.
You also have the right to object to Executive Action’s processing of your personal information or request that Executive Action restricts the processing of your personal information. When your personal information is processed on the basis of your consent, you may withdraw it at any time without affecting the lawfulness of processing based on consent before its withdrawal.
In some circumstances, you also have the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that Executive Action transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to Executive Action.
You have the right to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by Executive Action.
You also have the right to have any inaccurate information about you corrected. We want to make sure that your information is accurate and up to date. You may ask us to correct or remove any information that you think is no longer up to date. Please contact us using the contact details provided elsewhere on this Web Site if you would like any corrections made to your information or would like the Company to erase your personal data. Please note that there may be circumstances where you ask Executive Action to erase your personal data, but we are legally entitled to retain it.
You also have the right to object to Executive Action’s processing of your personal information or request that Executive Action restricts the processing of your personal information. When your personal information is processed on the basis of your consent, you may withdraw it at any time without affecting the lawfulness of processing based on consent before its withdrawal.
In some circumstances, you also have the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that Executive Action transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to Executive Action.
You have the right to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by Executive Action.
Email marketing lists and marketing messages
We operate an email mailing list program that you can subscribe to, used to inform you about services and/or news we supply or publish – such processing purpose is based on your consent. You can change your preferences for receiving group marketing emails, news/updates and other information from us at any time. You can unsubscribe at any time through an automated online service or, if this is not available, by contacting us.
Please note that we may use your marketing and content preferences, and other information you provide to us in order to build a profile for you. We may supplement this profile with information about how you use our websites, review our content and interact with us. We use this profile to try and ensure that you only receive information that you are likely to find of interest.
Please note that we may use your marketing and content preferences, and other information you provide to us in order to build a profile for you. We may supplement this profile with information about how you use our websites, review our content and interact with us. We use this profile to try and ensure that you only receive information that you are likely to find of interest.
If you do not want to receive information from us
If you receive marketing materials from us, you may withdraw your consent for us to send these to you at any time and free of charge using the contact information located elsewhere on this Web Site.
Cookies
We use cookies (small files that remember a user’s electronic device) to help improve this Web Site, and improve our services to you, in a variety of different ways.
Changes to this notice
From time to time, we may change this Notice. Unless as provided otherwise, changes to this Notice are effective as of the effective date listed above and indicates the last time this Notice was revised or materially changed.
