Privacy Policy

Kincentric is committed to protecting the privacy of your personal data. This statement summarizes our policy regarding the collection, use and transfer of your personal data, the security measures Kincentric employs to protect such data and your rights in relation to it.

Kincentric provides services in the field of Leadership Advisory Services related to employee engagement and culture benchmarking, leadership development, HR assessment, and human capital strategy. In providing these services to our clients Kincentric is required to collect, store, use and analyze a variety of personal data.

The categories of personal data we collect may include the following information and identifiers: name, contact information (e-mail address, telephone number), career history, education history, qualifications, social activities, compensation details (where permitted by applicable legislation), human resources details (such as business unit, tenure), individual capabilities and preferences, as well as your perceptions and opinions about working for your employer. Depending on the scope of services our client has requested we may collect certain demographic data, or protected legal characteristics under California or federal law (such as gender, age, and racial or ethnic background) as well as psychometric data (i.e. the raw scores of tests and questionnaires that you have participated in).

This data may be obtained directly from you, or from your employer. One of the methods we will use for obtaining data directly from you will be through the use of surveys so we will also be collecting any information you provide as a response to such surveys. Please be assured, however, that your responses will be treated confidential and your employer will not see any individual results without your prior consent.

If you are a Kincentric client or supplier, we will collect and use information about your company and individuals within your company for the purposes of fulfilling our obligations to you and furthering our business relationship. Data collected will typically comprise your contact details (such as name, telephone number, email address, job title, and business record related to our services).

Collected personal information is stored primarily in the EU, however, data may also be processed locally outside the EU in office(s) from which consultants will be working. Please note that your personal information may be transferred outside of the country where you are located. However, for employee engagement services provided by Kincentric’s China office, collected personal information will be stored and processed in Mainland China.

If necessary, data may be processed by our IT Support Team in the US for the purposes of providing technical assistance and, for a limited time going forward, data may be transferred to Kincentric’s Operations Team in India for benchmarking purposes. Please note that such data will be pseudonymized or anonymized, which means that it cannot be directly attributed to a specific person.

In order to further guarantee that appropriate and suitable safeguards are in place for the transfer of data outside EU, Kincentric has EU model clauses in place with both its US and India affiliates, in addition to the privacy practices set out in this policy.

We will not process your personal information in a way that is incompatible with what is outlined in this Privacy Policy and we will use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use. We will not sell your personal information.

The data is used in the usual course of our business to provide our services to clients. This may include asking you to complete certain surveys and respond to questions that have been designed to meet the specific insight requests of your employer regarding matters such as engagement and performance, gathering feedback on levels of satisfaction; and assessing talent and skills to accelerate the development of leaders and high potential talent within a firm using designated tools as well as reporting and benchmarking.

Your personal information may be shared with our clients as well as with third parties whom we have engaged to provide services. This includes our third party service providers who perform functions on our behalf such as consulting or data services during a project, or outsourced document storage providers, all of whom will be required to process your personal information in accordance with applicable data protection laws and this Privacy Policy.

Finally, your information may also be shared with any competent law enforcement, regulatory or governmental body, or a court of law if necessary to exercise our legal rights, protect your interests or as required by applicable law.

Client or Supplier data collected will be used in the context of the provision of our or your services. We may also use the data for other business purposes, including data analytics, benchmarking and statistical purposes. We may use the personal data collected to contact you in relation to any of our services that we believe may be of interest to you.

Convening
From time to time we may contact you with an invitation to attend an industry- or role-specific event, such as a dinner or charity event. You may opt out of receiving these invitations at any time.

Market Intelligence
We may retain and use personal information for research, benchmarking, and market norms in order to provide and develop our services and intellectual capital and remain aligned with market standards. We may also share your data with vetted third-party vendors for analytics purposes in the context of improving our service offerings.

Business Purpose
In addition to the above, in certain limited cases, we may disclose a minimum degree of personal information for internal business purposes. Such business purposes include, but are not limited to audit procedures, security processes, maintenance of our systems and infrastructure, internal research of our business and services, performance of our services, tests of our services, and other short-term uses.

Kincentric's legal basis for collecting and using the personal information described in this policy will depend on the personal information and processing activity involved and the context in which it was obtained.

We will process basic personal information about you, such as your contact details (name, email, phone number) and information that would contained in survey responses on the basis of legitimate interest, or other legal grounds (such as consent) where required by applicable local legislation, provided the processing of such information is not overridden by your own privacy interests or your rights and freedoms as provided by law.

If you require any further information concerning the legal basis on which we process your personal information, you may contact us at privacy@kincentric.com.

To prevent unauthorized access, maintain accuracy of data and ensure the proper use of information, Kincentric has implemented appropriate legal, physical, technical and security procedures to protect the confidentiality of and safeguard the personal information collected, and prevent against accidental loss, unauthorized access, or unlawful processing. These measures will be reviewed over time and updated to remain aligned with legal and technological developments.

Kincentric will retain your personal data only for as long as the data is needed in connection with the purposes for which it is collected and used. After this, we will either delete the data or pseudonymize it, making sure that it is not directly attributable to you, and use it for data analytics, benchmarking and statistical purposes only. The following criteria will be used to guide us when retaining your information:

• We will retain personal data for as long as we maintain an active relationship with our client;
• Once our relationship with the client has ended, the data (in a pseudonymized or anonymized form) may still be relevant for our current or future legitimate business purposes.

You have the right to access, erase, correct, update or complete your personal data, or to request no further contact from Kincentric. Additionally, you have the right to request the transfer of your personal data to a third party, to object to the processing of your personal information, to ask us to restrict our processing of your personal information, or to withdraw your consent at any time. If you wish to exercise any of these rights, you may contact privacy@kincentric.com.

If you are a California resident, you have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”). Specifically, you may request the categories of personal data we have collected, the sources of such personal information, and the specific pieces of personal data we have collected about you. If applicable, you may also request the business or commercial purpose we have for collecting your personal data, the categories (outlined above) of your personal data we have shared or disclosed, and the categories of third parties to whom we have shared or disclosed such personal data. You also have the right to request the deletion of your personal data. To exercise any of your rights, you may contact the email address above (privacy@kincentric.com), or you may call us at 1 (844) 390-CCPA (1-844-390-2272). We will not discriminate against you for exercising any of your rights pertaining to your personal data.

If you are a China resident and you wish to exercise any of your rights under China Personal Information Protection Law or any under this privacy policy, you may contract chinaprivacy@kincentric.com.

Should you request that we remove your personal information from our database, please note that we may retain a minimal amount of personal information about you in order to record your wish for your data to be removed, and to keep a record of the information disclosed to our clients. If deletion (or anonymization if applicable) of your personal data is not possible (for example, because your personal information has been stored in backup archives) then we will securely store your personal information and isolate it from any further processing until deletion is possible.

If we have collected and processed your personal information on the basis of your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect any processing performed prior to your withdrawal nor will it affect processing on the basis of lawful processing grounds other than consent.

Finally, you have the right to bring a complaint to the relevant data protection authority in your jurisdiction about our collection and use of your personal information. For more information on how to lodge a complaint, please contact your local data protection authority.

Kincentric reserves the right to modify or amend the Privacy Policy at any time and for any reason. If there are material changes to the Privacy Policy, we will post those changes to our website and take appropriate measures to keep you informed. Please check this Privacy Policy from time to time to stay informed.

If you have any questions about your personal information, please e-mail us at privacy@kincentric.com.