Effective: 24 May 2023

Who are we?

This privacy policy applies to Wilbury Stratton (“Wilbury Stratton Consulting Limited”, “We”, “Us” or “Our”). This Privacy Policy (the “Policy”) explains how Wilbury Stratton process personal information, including personal information associated to business people and all other types of information through our services and website; how we use and maintain, use, and share that information.

At Wilbury Stratton, we respect and protect the privacy of those who visit our company website and of our clients who use Wilbury on Demand to for talent research. We will never share your personally identifiable information (“PII”), nor that of your group members, with any third parties or send you unsolicited communications.

We are a global intelligence platform. Our approach to research is changing the way business decisions are made. We connect leaders with the best thinking in their field and introduce them to the people who can help bring these ideas to life. Our aim is to empower leaders by sharing our knowledge of how the best work gets done. That’s why over a third of the FTSE 100 rely on our insights, strategic advice, and talent intelligence services to make their most important decisions. We use a proprietary research process which prioritises direct engagement with market sources.

You may contact us with the following: (1) 3rd Floor South Suite, 1 Jubilee Street, Brighton, England, BN1 1GE; (2)  DataPrivacy@wscl.com; (3) +44 (0) 203 376 4444

Introduction

Wilbury Stratton collects business information related to individuals through public repositories and direct contact. We provide this information to our customers who are business trying to reach business professionals for recruiting activities.

You can opt out of our database by contacting us using the details listed under “Contact us” and at the end of the section “Who We Are”.

By remaining in our database, you may be contacted by us or our customers when they are conducting recruiting activities. Communications you receive from our customers may be relevant to your profession or employment role, but we cannot guarantee that you will find such communications to be relevant or of interest to you.

How we collect Data

A. Where does Wilbury Stratton get the business information for its talent insights?

Wilbury Stratton offers services around talent insights through the use of multiple data points and direct contact. Once combined these are made available to users and our customers through our platform “Wilbury on Demand”.

Business information that may be used include: Name, Title, Company Name, Department Employment History, Location, phone numbers.

Wilbury Stratton obtains the data for its Talent Insights in several ways including:

1. Search Technology
2. License information from other companies
3. Outreach and research conducted by our in-house team

Wilbury Stratton only shares data with relevant customers though its platform.

B. Customer Information

Customer information Collect. Wilbury Stratton may collect the following information from or regarding its customers: (1) personal contact information regarding users of the Services (“Customer Details”); (2) information uploaded or otherwise provided to our system by a user of the Services (“Uploaded Information”); (3) usage logs regarding the use of the Site and Services, including logins and other actions taken, time stamps, IP address, and other usage data (“Usage Logs”); and (4) any other information from or relating to users of our Services (“Related Information”) (collectively, “Customer Information”).

Use of Customer Information

Customer Information may be used for Wilbury Stratton’s legitimate business interests in connection with a customer or its users’ use of the Site, including to respond to user inquiries and fulfill user requests, complete transactions, provide customer service, send administrative information, and to personalize user experience with the Site. We may use Customer Information to contact customers or its users in the future about services, promotions, opportunities, and other general information about Wilbury Stratton.

How we Use Information

In addition to the uses described in the above sections we may also use Business Information for one or more of the following purposes:

• process an introduction/application for a role you have given us authorisation to submit you for;
• contact you for future opportunities that may be interesting to you;
• to carry out our obligations arising from any contracts entered into by you and us;
• seek your views or comments on the services we provide;
• notify you of changes to our services;
• send you communications in order to update your details

We review our data retention periods for personal information on a regular basis. We will hold your personal information on our systems for as long as is necessary for the relevant activity.

How we Share Information

Disclosures of Talent Insight. We may make any Business Information that we collect from public web sources, phone interviews conducted by our Research team, we licenses from third parties available to users of our platform “Wilbury on Demand”, and to our customers. Information provided, including Business Information, in creating or updating a Professional Profile, will be included in Wilbury on Demand and thus can be viewed by third parties.

Cookies and Similar Technology

Most websites, including our Site, use a feature of browsers to set a small text file called a “cookie” on a computer. The site placing the cookie on a computer can then recognize the computer when the user of the computer revisits the site to allow auto login and track how the user is using the site.

When individuals visit our Site, our servers and/or those of our service providers automatically record certain information that the web browser sends, such as web request, Internet Protocol address, browser type, referring/exit pages and URLs, page loads and clicks, domain names, landing pages, pages viewed, time and date of use, and other information. We may link this information to information that individuals submit while on our Site, which does allow such individuals to be personally identified.

Individuals are free to decline cookies and can configure their browser to accept all cookies, reject all cookies, erase cookies, or notify the user when a cookie is set. Electing to reject or disable cookies may substantially limit an individual’s ability to use our Site.

Wilbury Stratton may also adopt other technologies that serve similar functions as cookies.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc., on our Site. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Site, compile reports on the Site’s activity, and provide other services related to Site activity and usage. The technologies used by Google may collect information such as IP address, time of visit, whether a visitor is a return visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google click here.

Your Choices

How to change of delete Professional Information

Individuals can submit access requests, or opt of inclusion from our database through contacting us using the details noted in “Who we Are”.

Request Access to Information Wilbury Stratton has collected

Individuals who want access to the information Wilbury Stratton has collected about them can use the contact details provided. Once we have verified an individual’s identity we will send a report with the information we have collected within 30 days (we may charge £10 for information requests to cover our costs in providing you with details of the information we hold about you).

Remove Wilbury Stratton Profile Completely

If you wish to remove your profile completely please contact us on the details mentioned in “Who we Are” and the information will be removed from any search result available.

How to Opt-Out of Certain Uses of Information

Wilbury Stratton gives individuals the opportunity to “opt out” of having their information used for certain purposes. Please specify your preference by letting us know at  DataPrivacy@wscl.com

How do we keep information Secure?

Information security is important to us. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. However, no method of Internet transmission or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect information, we cannot guarantee its absolute security.

Data Rentention

We will retain personal information for a period of time consistent with the original purpose(s) for which we collected it, as described in this Privacy Policy, including, as applicable, (i) for as long as we have an ongoing relationship with the individual to whom the information pertains; (ii) as long as needed to provide users, our customers, or our partners the Services; (iii) as necessary to comply with our legal obligation(s); (iv) as necessary to resolve disputes or to protect ourselves from potential future disputes; or (v) as necessary to enforce our agreements. Retention periods will be determined taking into account the amount, nature, and sensitivity of the personal information and the purpose(s) for which it was collected. After the retention period ends, we will delete the personal information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of such information.

Users in the European Economic Area (EEA), the UK, and Switzerland

The following information applies to residents of the EEA, the UK, or Switzerland.

Wilbury Stratton endeavors to comply with the provisions of the General Data Protection Regulation (“GDPR”) as to any information in its possession regarding EEA-, UK-, and Switzerland-based persons (“data subjects”). As such, Wilbury Stratton only processes personal information on data subjects where it has a lawful basis to do so, which may include the consent of the person (especially in the case of website visitors who provide their information), performance of a contract, compliance with a legal obligation, or the legitimate interest of Wilbury Stratton or a third party. Wilbury Stratton provides notice to all data subjects as required by GDPR Article 13 or 14, as appropriate, and honors the rights of data subjects provided in Articles 12-23, including the right to be forgotten. For any opt-out requests or other inquiries related to privacy, please email  DataPrivacy@wscl.com

Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon data subjects’ use of our Sites. We process personal information on the following legal bases:

1. consent;
2. as necessary to perform our agreement to provide Services or other applicable agreements;
3. as necessary for compliance with a legal obligation to which we are subject; or
4. as necessary for the legitimate interests of Wilbury Stratton and Wilbury Stratton’s customers and partners to engage in direct marketing, sales, and recruiting activities, and Wilbury Stratton’s legitimate interests in organizing and making available Professional and Business Profiles, given the limited impact that use of this Business Information and similar information presents to an individual’s private life

Wilbury Stratton has put in place safeguards to protect personal privacy and individual choice, including disclosures of its data processing activities, the use of consent or opt-outs wherever possible, and the implementation of a privacy center:  DataPrivacy@wscl.com

Right to lodge a complaint: Users that reside in the EEA, the UK, or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Per the applicable requirements of the GDPR, we will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR, such as the UK or EU Standard Contractual Clauses, as applicable.

Individual Rights: Individuals who are a resident of the EEA, the UK, or Switzerland are entitled to the following rights under the GDPR. Please note: In order to verify an individual’s identity, we may require them to provide us with personal information prior to accessing any records containing information about them.

• The right to access, correction, and restriction of processing. Individuals have the right to request access to, and a copy of, their personal information at no charge, as well as certain information about our processing activities with respect to their data. Individuals have the right to request correction or completion of their personal information if it is inaccurate or incomplete. Individuals have the right to restrict our processing if they contest the accuracy of the data we hold about them, for as long as it takes to verify its accuracy.
• The right to data portability. Individuals have the right to ask for a copy of their data in a machine-readable format. Individuals can also request that we transmit their data to another entity where technically feasible.
• The right to request data erasure. Individuals have the right to have their data erased from our Platform if the data is no longer necessary for the purpose for which it was collected, they withdraw consent and no other legal basis for processing exists, or their fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
• The right to object to our processing. Individuals have the right to object to our processing if we are processing data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using data for direct marketing (including profiling); or processing data for purposes of scientific or historical research and statistics.

When Wilbury Stratton is a Controller. Wilbury Stratton acts as a data controller when we collect and use information about data subjects who are visitors to our Site, as well as when we collect and use information about data subjects for purposes of creating and maintaining our Talent Profiles and providing the Services. Wilbury Stratton’s Data Protection Officer can be contacted by email at  DataPrivacy@wscl.com

When Wilbury Stratton is a Processor. When our customers use our Services, they are acting as the data controller and are responsible for ensuring that personal information collected about data subjects is being processed lawfully. In those circumstances, we are acting as the data processor, and receive personal information as agents of our customers merely for processing as instructed by our customers. Our customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all third-party individuals that are a visitor to or user of a website, application, or service on which a customer uses our Services have been provided with adequate notice regarding the processing of their personal information, have given informed consent where such consent is necessary or advised, and that all legal requirements applicable to the collection, use, or other processing of personal information through our Services have been met by such customers. Our customers are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose data they process through the Services. Wilbury Stratton’s obligations with respect to personal information for which we are solely a data processor are defined in our agreements with our customers and are not covered by this Policy. In certain circumstances, Wilbury Stratton may act as an independent controller of personal information in connection with its provision of the Services to customers, such as when customers agree to contribute data to our database.

Changes to Policy

Wilbury Stratton can change this Privacy Notice. We may amend this Privacy Notice from time to time by posting a revised version and updating the “Effective Date” above. The revised version will be effective on the “Effective Date” listed. If you disagree with these changes, you may stop using our Websites at any time. Your continued use of our Websites constitutes your consent to any amendment of this Privacy Notice.

Dispute Resolution

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Contact Us

For questions or concerns regarding this Privacy Policy, please contact us at:

Wilbury Stratton
Attn: Data Privacy
3rd Floor South Suite,
1 Jubilee Street,

Brighton,

England,

BN1 1GE
+44 (0) 203 376 4444
Email: DataPrivacy@wscl.com