The information you provide to us will be shared within our global group of companies operating under the Kennard Associates brand. All references to “Kennard Associates” in this Privacy Notice and Cookies Policy therefore include Kennard Associates and its related group companies (the “Group”), unless stated to the contrary.

By providing us with your personal information you understand and accept that the personal information provided may be accessed from some of our offices based in countries not offering the same rights and protection to your personal data as your country of residence. Kennard Associates operates a framework of organizational and technical measures to ensure the personal information you provide is kept secure and that your access rights are respected regardless of the country in which it is processed.

• Information about your Internet Service Provider, your operating system, browser type and/or domain name;
• The Internet Protocol (IP) address of your computer (or other electronic Internet-enabled device);
• Your access time(s).

This information helps us to understand which parts of the site are popular or need changing. We do not retain this information in a manner that is attributable to you as an individual and this means it is not your “personal data” (as described below).

If you use our site search facility, queries and results are logged anonymously without any user-specific details being collected. Our collection of website use information may also involve the use of cookies and web beacons. Please see the Cookies section below for more information.

If you want to contact us or to use certain facilities we provide on this site, you will need to provide us with some additional personal information so that we can liaise with you and deal with your request, query or application. This information (either on its own or in combination with other information we hold about you) may allow us to identify you as an individual. This type of personal information is called “personal data”. If you do choose to provide us with your personal data, we will collect that information for the purposes described in this Notice.

Most of the information we process about you will have been collected directly from you. However, sometimes, where lawful to do so and where you have indicated that we (as a third party) may access this personal data, we also collect personal information from (and combine it with data from) public sources, third party service providers, government, tax or law enforcement agencies, and other third parties. If you have not provided personal data directly to us, we will notify you prior to processing it.

Below is a list of the personal data about you which we may process:

• Your full name;
• Your work and/or home contact details, e.g., company name, job title, address, postal code, country, fax number, telephone numbers and/or e-mail address;
• Other company information, e.g., number of employees and industry sector;
• The reason for your contact such as a query in respect of a job application or information about our services;
• Information about services that interest you;
• Information necessary for legal compliance; and/or
• Where you “like” us or make posts on our pages on social networking websites.

We only process personal data about you that is relevant for the purposes for which it is to be used.

If you apply for a role with Kennard Associates or with one of Kennard Associates’s clients, we will provide you with a separate notice (the “Recruitment Privacy Notice”) explaining the way we will use your personal information for the purpose of processing your job application.

The Recruitment Privacy Notice is displayed at the time you register your details on our careers site.

If we collect sensitive information from you during the recruitment process, we will inform you and, if legally required, seek your explicit consent to use it, disclose it to any third party or use it for a purpose other than those for which it was originally collected or subsequently authorized.

As part of its core business, Kennard Associates provides a range of outsourced services. These include recruitment and selection processes, digital marketing, recruitment advertising and candidate satisfaction surveys. As part of these business activities, the two principal scenarios for which your persona data is used are:

• We process Personal Data as instructed by our clients and under their brands (“We Become You”). You will not be approached directly from Kennard Associates and this reflects our clients outsourcing some of their operations to us.
• When we contact you as Kennard Associates, we are processing Personal Data under our brand to help you secure a new and exciting role with one of our global clients. For this purpose, you will be approached under the Kennard Associates Search Solutions or Kennard Associates’s Total Talent Solutions’ brands.

We will only process personal data where we have a lawful reason for doing so. The lawful basis for processing personal data by Kennard Associates will be one of the following:

• The processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
• The processing is necessary in order for us to comply with our legal obligations (such as compliance with anti-money laundering legislation);
• The processing is necessary for the pursuit of our legitimate business interests (including that of the delivery and the promotion of our services); and/or
• Processing is necessary for the establishment, exercise or defense of legal claims.

This means that we use information about you:

• To fulfill our contractual obligations to our clients for service provision. For example: sourcing and recruiting candidates for open or future roles, of pre-employment vetting, logistic management of payroll, implementation of technology solutions and employer brand services, including digital marketing;
• To match you against suitable job opportunities with our clients;
• To process and respond to your request or inquiry;
• To improve our services;
• Administration of the site;
• For internal record keeping when necessary;
• To contact you (directly, either by Kennard Associates or by the Group, or indirectly through a relevant partner or agent) by e-mail, post/mail or phone for the above reasons;
• Where necessary as part of any restructuring of Kennard Associates or sale of a relevant Group company’s business or assets;
• To perform management analysis, audit, forecasts, business planning and transactions, ensuring our compliance with applicable laws, regulatory requirements and Kennard Associates policies, and dealing with legal claims and related administrative activities and related records retention; and
• Kennard Associates also converts personal data into anonymous data and uses it (normally on an aggregated statistical basis) for research and analysis to improve Kennard Associates/Group performance. For more information, please see the Aggregated Data section below.

Aggregated personal information does not personally identify you or any other user of the site. It may be used for statistical analysis and administration, including analysis of trends, tailoring services, risk assessment and analysis of costs and charges in relation to our services.

Your personal data will be made available within the Kennard Associates Group of companies for the purposes listed in this notice (or as otherwise notified to you from time to time), on a “need-to-know” basis and only to responsible management, human resources, accounting, legal, audit, compliance, information technology and other corporate staff who properly need to know these details for their functions within the Kennard Associates Group of companies.

We may share personal data within the Group as needed for reasonable management, analysis, planning and decision-making, including in relation to making decisions regarding the expansion and promotion of a service offering, and for use by those companies for the other purposes described in this Notice.

Use of data processors: Data processors are third parties who provide elements of our services for us, including technology providers that we use for our recruitment and marketing activities and website hosting and management. We may share personal data with such third-party data processors as needed in connection with the services they provide to us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct.

If requested and as governed by applicable law, we may disclose specific information upon lawful request by government, law enforcement and regulatory authorities where required or permitted to do so by law and/or for tax or other purposes. Personal data may also be released to external parties in connection with legal processes, where required to comply with laws, to enforce our contracts, corporate policies and terms of use, and/or to protect the rights, property or safety of Kennard Associates, Kennard Associates employees, agents, customers and others, as well as to parties to whom you have authorized Kennard Associates to release your personal data.

In addition, we may disclose your personal data as necessary in the event that Kennard Associates or any part of the Group restructures, assigns, sells or otherwise disposes of all or any of its business or assets.

Kennard Associates may provide you with information about new services, promotions, industry updates, events and offers from Kennard Associates and the Group, which may be of interest to you, and may invite you to take part in market research or request feedback on Kennard Associates and/or Group services. This communication will occur by email, SMS or telephone. We will obtain your consent where we are required to do so in accordance with applicable law.

Kennard Associates will ensure that any direct marketing or market research that you receive or are contacted about by electronic means will provide a simple means for you to refuse further marketing. For example, in emails it may provide you with an ‘unsubscribe’ link, or an email address to which you can send an opt-out request. Kennard Associates will take steps to stop any direct marketing to you to which you object or in respect of which you withdraw your consent within a reasonable period, in order to allow sufficient time for the change to be administered.

In such cases Kennard Associates would not necessarily remove all your personal data from its database(s) but would note and respect your modified direct marketing preferences. If you would like for your data to be removed from Kennard Associates’s database, please convey this request in writing to privacy@kennardassociates.com

Kennard Associates does not sell Personal Information to third parties outside the scope of recruitment activities. According to §1798.45(2)A) of the Cal. Civ. Code, the provisions of the CCPA shall not apply where: “Personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business.”

Kennard Associates takes steps to seek to protect the confidentiality and security of your personal data and applies technical and organizational measures in accordance with applicable legislation. As for all website operations, we cannot guarantee the security of any transmission of personal data over the Internet and on a non-encrypted connection. Communications over the internet such as emails are not secure unless they have been encrypted. So, while we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us whilst in transit. Please do not submit personal data through the site unless you accept the security implications of doing so.

If you apply for roles at Kennard Associates, the JazzHR CRM and applicant tracking platform use encryption to transmit and store your personal data and the service providers listed above all comply under contract with international information security standards.

We take all required steps to ensure that the personal data we hold about you is accurate, complete and current so that it is reliable for its intended use. In certain circumstances under applicable laws, such as the EU GDPR, you have the following rights:

• To request access to or a copy of your personal data (“Subject Access Request”). Kennard Associates will work to resolve Subject Access Requests within one calendar month of the request being received. One copy of your data will be provided free of charge. For each additional copy requested and provided, a reasonable administrative fee will apply;
• To request for your personal data to be rectified;
• To request that we cease processing your personal data;
• To request that we permanently erase your personal data;
• If you have manually inputted your data in web form, you may also request a copy of your personal data in a portable machine-readable format.

If you would like to exercise any of your rights, please write to us at: privacy@kennardassociates.com 

Keeping you informed through the process: We will initially acknowledge your request and will then contact you to discuss it further and to address any specific queries you may have regarding the process. We will maintain a record of your personal data until we have finalized dealing with your request. We may also retain a record of some or all of your personal data afterwards, if this is required by applicable law.

We use “cookies” for certain areas of our site. Cookies are small data files stored on your hard drive by a website. Cookies help us monitor and improve the functionality and usage of our site and your experience. We use cookies to see which areas and features are popular and to count visits to our websites, to recognize you as a returning visitor and to tailor your experience of the site according to your preferences. We also use cookies for targeting or advertising purposes.

We also use “web beacons” on our site or in our emails. Web beacons are electronic images that may be used to deliver cookies, count visits, understand usage of the site and to tell if an email has been opened and acted upon.

To delete or block cookies by browser settings at any time and for more general information about cookies including the difference between session and persistent cookies, visit www.allaboutcookies.org.

The cookies used on our site are categorized as follows:

• Cookies which are “strictly necessary” for functionality of the site’s platforms. These cookies are essential in order to enable users to move around the site and use its features.
• “Functionality” cookies which allow the site to remember choices you make and your preferences, for example, where you register/sign-up for events and/or services.
• “Performance/Analytical” cookies which collect information about how users navigate the site, for example, which pages users access most frequently. They identify how users interact with our site, any errors that occur, which pages are not used often, which pages take a long time to load, which pages users tend to visit and in what order. These cookies do not collect any information which could identify you and are only used to help us improve how our site works and understand what interests our site’s users.
• “Targeting or advertising” cookies are used to deliver advertisements relevant to an identified machine or other device (not a named or otherwise identifiable person) and are tailored to interests associated with the website activity tied to that machine or device. 
• For example, if a cookie on a third party website recognizes that a particular product was purchased from a particular device, that cookie may “talk to” marketing cookies on the site to ensure advertisements about similar products displayed on the site are accessed from that device. These cookies are also used to limit the number of times a user sees an advertisement as well as to help measure the effectiveness of an advertising campaign. They may also remember that the site has been visited from a device and share that information with marketing organizations. The marketing cookies on our site are operated by third parties with our permission. Marketing cookies are used to monitor from which advertising source a user was directed towards our site so that we know whether it is worth us investing in that particular advertising source. If your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads, we will alert our partners to suspend use. As described more fully herein, we allow our advertising partners to collect personal information about your online activities when you leave our site.

Google Analytics: The Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses its own cookies to help us analyze how you and other users use the site. The information generated by the cookies about your use of the site (which may include your IP address, the internet browser and language you use, preferences, the date and hour of your access to the web page and the websites you access after visiting the site) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the site, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the site. By using the site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Your consent to our use of Cookies: below explain the cookies used on the site and if you visit the site, they will be placed on your machine.

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

This Privacy Notice and Cookies Policy applies to the website www.kennardassociates.com (referred to as the “site” throughout the document) which is owned by Kennard Associates, LLC. (“Kennard Associates”, “we”, “us”, “our”). 

Please direct any complaints or requests for dispute resolution under this Notice to: Privacy Officer, Kennard Associates at privacy@kennardassociates.com.

We change this Notice from time to time by updating this page in order to reflect changes in the law and our privacy practices. We will update the date at the top of the Notice accordingly. If you have opted in to receive information from Kennard Associates, we will contact you to inform you that our Notice has been updated.

By using the site, submitting your personal data to us and/or registering an account, you consent to the use of your personal data as described in this Notice (as amended from time to time).