Last updated: October 6th, 2022

1. What We Are and What This Policy Is

Welcome to Brandt & Partners GmbH, Max-Josefs-Platz 12a, 83022 Rosenheim, Germany (“Brandt & Partners“, “we“, “us“, and “our” etc.). We are an international management consultancy constituted by a network of independent partners that provides a variety of services to customers and candidates worldwide, including, but not limited to: (i) executive search; (ii) executive assessment, development, and coaching; (iii) board advisory; (iv) C-Suite succession; (v) team development; (vi) organizational design (collectively, and among others, our “Services“). For additional information on our Services, please visit this website’s “What We Do” section.

We respect the privacy of our customers and candidates and are committed to protecting your personal data and information according to the applicable laws. This privacy policy (“Policy“) explains how, to what extent, and for what purposes we collect and subsequently process personal data and information.

Brandt & Partners takes its responsibility for processing your personal data and information very seriously, whether provided to us on our website, via email, social media, in person or otherwise.

For the purpose of this Policy, the controller of personal data is Brandt & Partners GmbH. Our main contact details are set out in the “How to Contact Us” section at the end of this Policy.

2. Definitions

In addition to the terms defined elsewhere in this Policy, the ones listed below shall have the following meaning throughout this Policy:

“Candidate” means any candidate, interested person, customer employee, or board member, who is considered, evaluated, assessed, coached, or developed by Brandt & Partners in connection with the Services;

“Customer” means any of the organizations or individuals who contract our Services;

“Personal Information” means any information that either (a) personally identifies a natural person; or (b) pertains to an identifiable natural person, i.e. someone who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity, or (c) constitutes individually identifiable information about an individual consumer collected by us online through our website and that we maintain in an accessible form, or that (d) we are otherwise required to protect under applicable data privacy laws (including, but not limited to, national, international, and supranational data protection and privacy laws, directives, regulations, and comparable legal acts). Examples of Personal Information include your contact details such as your name, email address, birthday, or phone number as well as information about your professional education and experience, skills, preferences, membership in professional organizations, etc.;

“Processing” means any operation or set of operations in which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, restriction, erasure or destruction; 

“Sensitive Personal Information” means Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sexual orientation;

“Site” means http://brandtpartners.com/ and all web pages hosted at that domain.

3. How We Process Your Personal Information

We perform our Services based on data held by or made available to us and our independent partners.

If you are interested in becoming a Candidate for one of our Services, you can provide us with information on your personal and professional background (“Candidate Information“) that we may take into consideration as part of the relevant Services. For example, you may provide this information directly to one of our consultants, or upload your CV through our Site.

Providing any Candidate Information is purely voluntary on your part. Although it is generally true that, the more information you share with us, the better we are able to assess you and/or your potential suitability for or within an executive or similar management position, we urge you not to disclose to us any Candidate Information that is likely of little or no relevance for the respective Service.

If and to the extent you share Candidate Information with us, we might follow up with you using the contact details you may have provided in order to clarify any questions we might have or obtain complementary information from you. If you are a Candidate for Services related to executive search, we might in addition (i) conduct assessments of your professional profile and perform searches for information on your personal and professional life publicly available via social media services (e.g. Facebook, Google, LinkedIn, Twitter, etc.), on the internet, or within data  data you have previously disclosed to us, provided that such information might be of importance for the relevant Services; and (ii) source Personal Information about you from third party data providers, whereby we take appropriate measures to ensure that such third party data providers are legally permitted or required to disclose such information to us. Any resulting information will be considered Candidate Information and be Processed as described below together with the Candidate Information you initially provided us with.

Depending on your interaction with us, your Candidate Information Processed by us or one of our selected partners may therefore contain (i) your contact details (name, address, phone number, email address, etc.), (ii) your biographical data, (iii) information on your professional education, (iv) your educational credentials, professional diplomas and certificates, (v) information and responses you may provide to evaluative measures, surveys and interviews, and (vi) any Sensitive Personal Information you might choose and explicitly consent to disclose to us. If you are a Candidate for Services relating to executive search, your Candidate Information may in addition contain (vii) your employment and compensation history, (viii) data on your suitability for Client opportunities we compile as part of our assessments of your professional profile, (ix) information on your personal and professional life publicly available via social media services (e.g. Facebook, Google, LinkedIn, Twitter, etc.) or otherwise on the Internet, or from third party data providers, that might be of importance in connection with the relevant Services, (x) information related to your travels for interviews within a recruitment process, if such travel arrangements are facilitated by us via our selected partners, such as your name, email address, phone number, passport number and date of birth (if mandatory), travel destination(s), and means of transportation, and (xi) in appropriate circumstances and in accordance with applicable local law, information about you which may be classified as ”diversity information” (such as your racial or ethnic background, gender, disability, age, sexual orientation, religion or beliefs, and/or socioeconomic background). Some of this information is considered Sensitive Personal Information (or protected legal characteristics under certain laws) and as such, stricter data and other protection measures, as required by applicable law, will apply.

Our legal basis for collecting and using your Candidate Information for the Services will depend on the Processing activity involved and the context in which it was obtained and therefore can either be based on our legitimate business interest or on your consent.

As part of Services, your Candidate Information may be Processed for the business purposes of:

• providing Services on behalf of our Clients, which may include Processing of your Candidate Information within your own integration, assessment, coaching or development as part of respective assignments for our Clients;
• operating the databases your Candidate Information is stored in; and
• analyzing your information using analytical tools and comparing the results against other Candidates or potential Candidates, including categorization of Candidates through profiles developed by the software, to assist us in conducting Services.

If you are a Candidate for Services relating to executive search, your Candidate Information may be Processed for the additional business purposes of:

• executing searches for potential Candidates on behalf of Clients that have an opening for an executive or similar management position or for a board directorship, including, but not limited to, (i) assessing your suitability for Client opportunities, (ii) introducing you to Clients as a Candidate, (iii) verifying your educational credentials, professional diplomas and certificates, (iv) where appropriate and in accordance with applicable law, using your diversity information to provide Clients with diverse pools of qualified Candidates, and (v) ensuring that you will not be recruited on behalf of another Client unless you request consideration for other opportunities;
• informing you of open executive or similar management positions potentially suitable for you;
• sending you information or materials that we believe you may find interesting, such as reports, research, invitations to networking events, or information regarding our Services, publications and surveys; and
• approaching you as a Client contact for the introduction of other Candidates or as a source of information about potential Candidates for third-party Clients.

At no point will your Candidate Information be used for purposes other than providing the Services for which your Candidate Information has been intended. Your Candidate Information will mainly be Processed by and on behalf of Brandt & Partners. However, depending on how and where the Services need to be performed in your individual case, your Candidate Information may be shared with:

• Consultants and administrative staff: Via our proprietary databases, your Candidate Information will be available to the consultants and administrative staff of Brandt & Partners for the purposes of providing the Services;
• Customers: If you are a Candidate for Services relating to executive search, subject to our discretion, we might disclose excerpts of your Candidate Information such as your professional education and employment history with particular Customers in order to confirm whether such Customers might be interested in you as a Candidate with respect to an opening for an executive or similar management position they have informed us of. The information disclosed will be limited to what is necessary for this purpose. We will not disclose the entirety of your Candidate Information or otherwise introduce you to any Customer in detail without first obtaining consent from you;
• Selected partners: Your Candidate Information might be Processed by selected partners with whom we may work on specific projects when providing Services, including third-party travel agencies;
• Software service and application providers: Your Candidate Information may be Processed by the software service and application providers as our Processors (such as Microsoft Corporation, Google, or Zoom Video Communication, Inc), located anywhere in the world, subject to binding contractual obligations to only Process your Candidate Information in accordance with our prior written instructions and to apply measures to protect the confidentiality and security of your Candidate Information, together with any additional requirements under applicable law; and
• IT infrastructure service providers: Your Candidate Information will be stored on servers located in the European Union. The servers are operated by and accessible to designated employees of Brandt & Partners as well as third-party service providers acting on behalf and as per instruction of Brandt & Partners, for the purposes of website management, information technology and related infrastructure provision.