Privacy

GLOBAL PRIVACY POLICY (the "Policy")

This Policy describes how Korn Ferry and its affiliates and subsidiaries (collectively “Korn Ferry,” “we,” “our,” or “us”) collect, use, transfer, and disclose your information. A list of our affiliates and subsidiaries is available from our Privacy Office as described below, or at https://cdn.kornferry.com/privacy/subsidiariesalliances.pdf.

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  This Policy describes our practices of processing Personal Information that we collect and use in connection with:

• Websites operated by us from which you are accessing this Policy (the “Site”);
• Software platforms and applications we make available for use on or through computers or mobile devices (the “Applications”);
• Our social media pages from which you are accessing this Policy (collectively, our “Social Media Pages”);
• HTML-formatted email messages we send to you that link to this Policy;
• Communications, including via emails, SMS and/or text messages we send to you manually and from software that may qualify as autodialers (“Texts”); and
• Offline business interactions you have with us, including in person discussions, telephone conversations, and non-electronic communications.

Collectively, we refer to the services provided through the Site, Applications, Social Media Pages, email messages, and offline business interactions as the “Services.” Note, references in this Policy to “include” or "including" mean "including without limitation."

WHO WE ARE & WHAT WE DO

Korn Ferry is a global organizational consulting firm. We help companies design their organization – the structure, the roles and responsibilities, as well as how they compensate, develop and motivate their people. We also help organizations select and hire the talent they need to execute their strategy.

Korn Ferry provides a wide range of organizational consulting services to help companies structure their organization, and some of these Services involve the collection and use of your Personal Information. For certain Services, Korn Ferry, including its subsidiaries as listed here: https://cdn.kornferry.com/privacy/ControllerEntities.pdf, is the company responsible (or the ‘controller’) for the collection and use of your Personal Information. These Services are described in this Policy. For other services, Korn Ferry collects and uses your Personal Information as a service provider (or ‘processor’) on behalf of and under instructions from our clients. If you have any questions about the collection and use of your Personal Information in the context of those services, please contact the company that is responsible for the collection and use of your Personal Information (e.g., the company where you applied for a position).

The Services for which Korn Ferry collects and uses your Personal Information as a controller (and which are covered by this Policy) are:

• Search Services. We maintain a talent pool to help clients find talent at the board-level, chief executive, and other senior executive positions. We also offer search Services for clients to find talent for middle to upper-level management or temporary staff.
• Compensation and Benefit Analysis Products. We provide software products and consulting Services that our clients can use to conduct compensation and benefit analysis; job architecture and organizational structuring; and mapping to Korn Ferry’s proprietary job profiles.
• Credential Network. We participate in a Credential Network: a distributed ledger network that enables trusted, private, and secured exchange of career credentials between individuals and organizations. We may issue you credentials, verify your credentials exchanged on the Credential Network, or receive credentials you disclose to us.
• Learning Services and Development Products. We provide a business-to-consumer version of a software product, called KF Advance, that users can use for coaching and job-hunting preparation. In addition, we may offer e-learning and training services for individuals from time-to-time.
• Our Site. We disclose research, whitepapers, and service information on the Site; provide access to KF Store to purchase books and products; and share issues of the Briefings Magazine.

For additional controller activities, see the Processing of Personal Information section below.

The services for which Korn Ferry collects and uses your Personal Information as a processor are:

• Recruitment Process Outsourcing (RPO) Services. We provide recruitment process outsourcing and/or project recruitment services to help our clients attract top people. This involves Korn Ferry recruiting individuals on the client’s behalf.
• Consulting Services. We help our clients implement their business strategy by consulting with them on strategy execution and organization design, talent strategy and work design, rewards and benefits, assessment and succession, leadership development, and other talent needs.
• Assessment and Survey Services. We help clients in their roles as the data controllers, conduct employee and candidate assessments and surveys.
• Software Products (other than Compensation and Benefit Analysis Products). In addition to the Compensation and Benefit Analysis products mentioned above, we provide other software products that our clients can use, for example, to conduct assessments, surveys, or career coaching. When we collect and use your Personal Information in relation to these software products other than the Compensation and Benefit Analysis products, we do so as a processor for our clients.

COLLECTION AND PROCESSING OF PERSONAL INFORMATION

HOW WE COLLECT PERSONAL INFORMATION

We collect Personal Information in a variety of ways, including through our Services and from other sources, as set out in the grid below. If you do not provide the information requested, we may not be able to provide the Services. We will note which Personal Information is required to provide the Services at the time of its collection.

If you disclose any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.

PROCESSING OF PERSONAL INFORMATION

Korn Ferry collects Personal Information to provide Services to you, our clients, and to operate our business. The type of Personal Information we collect about you depends on the situation at hand. Please do not provide us with any Personal Information if you do not agree with this Policy.

We use your Personal Information for legitimate business purposes as described in the overview below.

Providing our products and Services

Events and visitors

Marketing and engagement

Personalization and improving our products and/or Services

Security and legal reasons

*For more information on our legal obligations, please see ‘Other Disclosures’ section below.
** For more information on disclosure of Personal Information in connection with a sale or business transaction, please see ‘Other Disclosures’ section below.

PERSONAL INFORMATION

We collect the following categories of Personal Information:

A. Personal Information we receive from you and examples of that Personal Information:

B. Personal Information we collect through your use of our Services or from other sources and examples of that Personal Information:

Disclosure Of Personal Information

As a global organization, we have affiliates and subsidiaries around the world. To the extent permitted by law, we may share Personal Information with our affiliates and subsidiaries (see https://cdn.kornferry.com/privacy/subsidiariesalliances.pdf) to provide seamless Services to you and our clients.

From time to time, we also disclose Personal Information to our strategic alliance partners and to our network of independent consultants who provide Services on Korn Ferry’s behalf.

• You can obtain a list of our strategic alliance partners by contacting our Privacy Office as described below.

Korn Ferry discloses Personal Information to third-party service providers who provide support for our Services or business operation.

• Korn Ferry works with third-party service providers who provide services that may include assessment services, including assessment validation services, website hosting and IT consulting services, data analysis, resume verification, background checking, payroll services, public relations services, marketing services, attorneys, accountants, and other administrative and back-up and security services.
• As part of providing services, these third-parties will be provided with access to Personal Information. In addition, our software development partners may use Personal Information, like usage metrics or bug issues, to modify, improve, refine, and validate their technology, research and development.

Korn Ferry may disclose certain Personal Information regarding candidates, including the results of candidate assessments and related data to your current (if applying for an internal position) or prospective employer who has engaged Korn Ferry to fulfill recruitment requests, or to reference sources.

Korn Ferry may disclose or transfer all or part of your Personal Information in the event of a sale of our company or one or more of our affiliates. We may also disclose or transfer all or part of your Personal Information in the event of a merger, joint venture, assignment, or consolidation involving our company or one or more of our affiliates. This may also occur if there is a sale or transfer or other disposition of assets or of any portion of our business or the business of one or more of our affiliates (including in connection with bankruptcy or similar proceedings). You will be notified of any such business transaction and of possible changes to the processing of your Personal Information in accordance with applicable law and the ‘Updates To This Policy’ section.

There may be other times that we disclose your Personal Information.

• Korn Ferry may also use or disclose Personal Information (to comply with a legal obligation or because we have legitimate interest to do so) to: (i) comply with applicable laws, (ii) respond to inquiries, requests or orders from public or government authorities, including those outside of your country of residence, or (iii) protect the rights, privacy, safety or property, of Korn Ferry and our affiliates, you or others.
• We cannot and do not assume any responsibility for the actions or omissions of third parties, such as clients, including the way they use Personal Information received either from Korn Ferry or from other independent sources.

Other Disclosures

We also disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so, as set out in further detail below.

OTHER INFORMATION WE COLLECT

Korn Ferry collects other information that does not reveal your specific identity (“Other Information”), such as:

• Information collected through cookies, pixel tags, and other technologies, App usage data,
• Demographic information and other information provided by you, and
• Aggregated information.

Because Other Information does not reveal your specific identity, we may use and disclose it for any purpose. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information for as long as it is combined. Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose your Personal Information as detailed in this Policy.

We and our third-party service providers may collect Other Information in a variety of ways.

We use “cookies” (small text files placed on a visitor’s computer hard drive) and other similar technologies to help us collect information like the type of content a visitor to the Site consumes, pages visited, mouse clicks, keystrokes, the length of time each visitor spends at any area of the Site, and other traffic data. Cookies and similar technologies enhance your experience on the Site and help us debug, identify, and fix errors that impair the intended functionality and quality of the Site. We do not currently respond to browser do-not-track signals. Please see Korn Ferry’s cookie policy for more information about our use of cookies. You can access our cookie tool here: https://www.kornferry.com/privacy.

If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies, or be given the choice of declining or accepting a particular cookie(s) from a particular site. Please refer to http://www.allaboutcookies.org/manage-cookies for information on how to manage cookies stored on your computer. If you disable cookies and similar technologies, your experience on the Site may be diminished and some features may not work as intended.

ADDITIONAL GUIDELINES

Korn Ferry may from time to time sponsor special features or promotions related to the Services and additional privacy information may be posted. Depending on the nature of the Service being utilized, your location, or our contract with our client that may have asked you to participate in a Service, you may be asked to consent to the collection, use, transfer, and disclosure of your Personal Information. You may also be shown a privacy notice before participating in a Service. That privacy notice, to the extent it conflicts with this Policy, will govern that particular Service, feature, or promotion.

Where your phone number is used for Texts, please note that message frequency varies. Message and/or data rates may apply; consult your carrier for details. Consent to receive Texts is not required and is neither a condition of purchasing a of Korn Ferry Service nor a condition to receive Services.  

CHOICES AND INDIVIDUALS’ RIGHTS

Click here https://cdn.kornferry.com/privacy/DSR.pdf for information on how to make a privacy rights request related to your Personal Information.

Your provision of Personal Information to us is voluntary, although if you do not provide certain Personal Information, you may not be able to participate in our Services.  We will note which Personal Information is required for us to provide the Services at the time of its collection. Contact us at privacy@kornferry.com if you would like to:

• ask questions about how we handle your Personal Information, or if we are processing your personal information,
• withdraw your consent (which will not affect the lawfulness of processing prior to the withdrawal) to our use of your Personal Information, including information about the possibility of denying consent and the consequences of such denial,
• object to our use of your Personal Information for our legitimate business interests,
• not be subject to a decision based solely on automated processing which produces legal effects or review such decisions made solely based on automated processing of Personal Information,
• request a copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law),
• request to access, correct, update, suppress or restrict the use of your Personal Information,
  • For requests to access, correct, update, suppress or restrict the use of your Personal Information, please include all relevant  email addresses, as well as the names of any Korn Ferry or Korn Ferry-related Sites, products, or Services you may have accessed in your communication to privacy@kornferry.com.
  • Although we strive to maintain accurate Personal Information, if it is determined the Personal Information is not accurate, we will work to correct it.
• request that your Personal Information be deleted
  • When requesting that we delete your Personal Information, please include all relevant email addresses as well as the names of any Korn Ferry or Korn Ferry-related Sites, products, or Services you may have accessed in your communication to privacy@kornferry.com.
  • Korn Ferry will make reasonable attempts to delete Personal Information upon your request.
  • Please note that to maintain consistency in our Services and operations, we retain backup systems. When you ask that your information be removed from Korn Ferry’s databases, we may not be able to delete residual copies from our systems or from our backup systems, but they will continue to be protected as required under this Policy.

If you would like to opt-out of receiving marketing communications from us, please contact us at privacy@kornferry.com.

• If you request to opt-out of receiving marketing communications from us through an email request, please include “Remove User” in the subject line of the email, and include your full name, User ID, and telephone number in the body of the email message.
• You may also forward a copy of the email or marketing communications from which you want to opt-out.
• You may unsubscribe from Texts at any time by replying “Stop” or by contacting us as set out below.
• Please note that if you opt out of receiving marketing-related communications from us, we may still send you important administrative messages from which you cannot opt out.

We will respond to your request(s) consistent with applicable law. We may decline to process requests that in our reasonable opinion may jeopardize the privacy and safety of others or put our intellectual property at risk.

• Please note that when we perform Services at the specific request of our client, your request may need to be directed to that client. We may only be able to provide you with a redacted summary of our final assessment report because these reports contain confidential client personal information that we are not allowed to disclose.
• For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will comply with your request as soon as reasonably practical and may need to contact you to be sure that we understand your request.
• We also may need to retain certain Personal Information about you such as your email address to honor opt-out or similar requests.
• Specific additional rights may apply if required by applicable law. For example, please view our additional disclosures directed to residents of the Mexico, California, and the People’s Republic of China (Excluding for the purposes of this statement Hong Kong,  Macau,  and Taiwan) (“PRC”) in this Policy.

When the processing of your personal information is subject to privacy laws of the European Economic Area (EEA), you may also lodge a complaint or report an alleged infringement of applicable data protection law with a data protection authority for your country or region where you have your habitual residence or place of work, or where an alleged infringement of applicable data protection law has occurred.  A list of data protection authorities in the European Economic Area (EEA) is available at https://ec.europa.eu/newsroom/article29/items/612080. If the processing of your personal information is subject to the privacy laws of the United Kingdom (UK), you may lodge a complaint with the UK Information Commissioner’s Office (ICO). If you are not certain whether the processing of your personal information is subject to EEA or UK privacy laws, please contact us in accordance with the “Contact Us” section below.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed where we have facilities (see https://cdn.kornferry.com/privacy/subsidiariesalliances.pdf) or where we engage service providers (see https://cdn.kornferry.com/privacy/subprocessor.pdf), and by using the Services you understand that your Personal Information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. We can provide a list of destination countries upon written request.

Where our Services will involve transferring your Personal Information outside the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Adequacy Decisions: Some of the non-EEA countries are recognized under the UK GDPR and by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here https://ec.europa.eu/info/law/law-topic/data-protection/data- transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).
• Standard Contractual Clauses: For transfers from the UK and/or EEA to third countries, which are not considered adequate under the UK GDPR and/or by the European Commission, we have put in place controller-to-controller and controller-to-processor standard contractual clauses, adopted under the UK GDPR and/or by the European Commission, to protect your Personal Information. You may obtain a copy of these measures and a list of third countries by contacting the Privacy Office at privacy@kornferry.com or viewing the relevant standard contractual clauses with our clients at https://www.kornferry.com/privacy/security/scc.  “UK GDPR” has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the UK Data Protection Act 2018.

SECURITY

Korn Ferry seeks to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

• If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised or your user credentials are no longer secure), please immediately notify us of the problem by contacting us as described in the “Contacting Us” section  below.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law, for example, for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

• The criteria used to determine our retention periods include:
  • The length of time we have an ongoing relationship with you or our client and provide the Services to you (for example, for as long as you have an account with us or keep using the Services),
  • A period beyond the time of the ongoing relationship if we have a legitimate internal operations need, such as a need to retain the information for analysis, record-keeping, and compliance with data retention schedules,
  • If there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them), or
  • If retention is advisable considering our legal position (such as regarding applicable statutes of limitations, litigation or regulatory investigations).

Where a legal obligation arises or retention is advisable in light of our legal position, in some circumstances, we will retain certain Personal Information, even after your account has been deleted and/or we no longer provide the Services to you, for example:

• To cooperate with law enforcement or public, regulatory and government authorities: If we receive a preservation order or search warrant related to your Services account, we will preserve Personal Information subject to such order or warrant after you delete your Services account.
• To comply with legal provisions on tax and accounting: We may retain your Personal Information, such as Billing Information, Relationship History, Transaction Information, Customer Invoices as permitted by applicable laws and Korn Ferry policies after you delete your Services account, as required by tax law and to comply with bookkeeping requirements.
• To pursue or defend a legal action: We may retain relevant Personal Information in the event of a legal claim or complaint, including regulatory investigations or legal proceedings about a claim related to your Personal Information, or if we reasonably believe there is a prospect of litigation (whether in respect of our relationship with you or otherwise) as permitted by applicable laws and Korn Ferry policies after the dispute has been settled or decided by a court or tribunal from which there is no further right of appeal.
• To document security or fraud incidents: We may keep and archive records of incidents for internal purposes and as documentation of steps taken.

In some circumstances and subject to applicable law, we de-identify, aggregate, pseudonymize, and/or use other technical and operational controls to anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

THIRD PARTY SERVICES

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any other third parties, including any third party operating any website or service to which the Services link.

• You may have the opportunity to follow a link from or to other websites maintained by Korn Ferry affiliates, or other third parties. The inclusion of a link to a third party site or service from our Services does not imply our endorsement of the linked site or service by us or by our affiliates. Because these other websites may not be hosted or controlled by Korn Ferry, this Policy does not address the privacy practices of those websites. We encourage you to review the privacy policies of each of those websites.
• Please note that we are not responsible for the information collection, use, disclosure, or security policies or practices (including the data security practices) of other organizations, such as LinkedIn, Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) through the Services or otherwise to us.

UPDATES TO THIS POLICY

Korn Ferry reviews its privacy practices regularly, and those practices are subject to change. You can determine when this Policy was last revised by checking the “Last Updated” legend at the bottom of the Policy. Any changes to the Policy will become effective upon posting of the revised Policy on the Internet.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16. We request that these individuals do not provide their Personal Information through the Services.

SUMMARIES OF POLICY

This Policy is the sole authorized statement of Korn Ferry’s practices with respect to the collection of Personal Information through the Services and the usage of Personal Information. Any summaries of this Policy generated by third party software or otherwise (for example, in connection with the “Platform for Privacy Preferences” or “P3P”) have no legal effect, are in no way binding upon Korn Ferry, cannot be relied upon in substitute for this Policy, and neither supersede nor modify this Policy.

CONTACTING US

Korn Ferry (including its subsidiaries as listed here: https://cdn.kornferry.com/privacy/ControllerEntities.pdf), located at 1900 Avenue of the Stars, Suite 1500, Los Angeles, CA 90067, is the company responsible for collection, use, and disclosure of your Personal Information under this Policy.

To submit questions regarding this Policy or to contact our Data Protection Officer (DPO), use the following contact information: via email to Korn Ferry at privacy@kornferry.com or, if by postal mail to Korn Ferry, 1900 Avenue of the Stars, Suite 1500, Los Angeles, CA 90067, Attn: Privacy Office.

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

For any inquiries regarding our compliance with EEA privacy laws and the content of this Privacy Policy, Please contact us at PrivacyEEA@kornferry.com.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively the “CCPA”), Korn Ferry is providing the following additional details regarding the categories of Personal Information that we collect, use and disclose about California residents and California residents’ rights. This section supplements the above disclosures in this Policy.

Notice at Collection

The following chart details which categories of Personal Information about California residents we collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.  The chart also details the categories of Personal Information that we “sell” (the term “sale” is broadly defined under the CCPA to include an exchange of Personal Information for valuable consideration of any kind, not simply for monetary compensation), including within the preceding 12 months.

For information on the sources of these categories of Personal Information, please refer to the “How we Collect Personal Information” section in this Policy, above. For information on retention periods for Personal Information and Sensitive Personal Information, please refer to the “Retention Period” section in this Policy, above.

For details on how we use your Personal Information, please refer to the chart under the “Processing of Personal Information” section at the start of this Policy. In addition, we collect, process, and disclose Sensitive Personal Information for purposes of: providing goods or services as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual.  We do not use Sensitive Personal Information beyond these purposes.

You have the right to opt out of the “sale” of your Personal Information. For more information on this right and to exercise your right to opt-out of sale, please go to Korn Ferry’s California: Do Not Sell My Personal Information page located here: https://www.kornferry.com/ccpa.

We do not “share” Personal Information, including Sensitive Personal Information, for purposes of cross-context behavioral advertising, as defined under the CCPA, and we have not engaged in “sharing” in the 12 months preceding the date this Policy was updated.  Without limiting the foregoing, we do not knowingly “sell” or “share” Personal Information, including Sensitive Personal Information, of minors under 16 years of age. 

If you are a California resident, you may request that we:

• Disclose to you the following information:
  • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  • The specific pieces of Personal Information we collected about you;
  • The categories of Personal Information about you that we sold and the categories of third parties to whom we sold such Personal Information;
  • The business or commercial purpose for collecting or selling Personal Information about you; and
  • The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties with whom we disclosed or to whom we disclosed such Personal Information (if applicable).
• Delete Personal Information we collected from you.
• Access Personal Information about yourself.
• Correct inaccurate Personal Information about yourself.
• Opt-out of the future sale of your Personal Information.  For more information on this right and to exercise your right to opt-out of sale, please go to Korn Ferry’s California: Do Not Sell My Personal Information page located here: https://www.kornferry.com/ccpa.

To make a request for disclosures, deletion, access or correction, as described above, or to opt-out of the future sale of your Personal Information, please submit this form (https://cdn.kornferry.com/privacy/DSR.pdf) to Privacy@KornFerry.com or call us at our toll-free number at 1-888-508-CCPA (1-888-508-2272).

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. In most cases, Korn Ferry will verify your identity by confirming that: (1) you control the email address associated with your Personal Information; and (2) your description of your interactions with Korn Ferry matches our records. If necessary, we may require additional information to verify your request.

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted above.  As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent.  In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

ADDITIONAL INFORMATION REGARDING MEXICO

Korn Ferry México, Sociedad Civil (“Korn Ferry Mexico”), located at Prado Sur 274, Floor 3, Col. Lomas de Chapultepec, Zip Code. 11000, Miguel Hidalgo, Mexico City, Mexico, is responsible for the processing of Personal Information that is subject to the Federal Law on Protection of Personal Data Held by Private Parties and its Regulations (collectively, the “Law”). This Mexico addendum supplements this Policy, except that the information in this section replaces the information in the “Choices and Access” section of the Policy. Questions regarding this addendum should be directed to the Korn Ferry Mexico Privacy Office avisoprivacidad@kornferry.com or, if by postal mail, at the Mexico City address above.

Korn Ferry Mexico uses your Personal Information for the purposes outlined above in the “How We Use The Personal Information We Collect” section. All these purposes, except for marketing, are necessary for maintaining your relationship with Korn Ferry Mexico. If you would like to opt-out of receiving marketing communications from us, please email avisoprivacidad@kornferry.com to have your contact information removed from our marketing databases. 

Korn Ferry Mexico transfers Personal Information to third parties inside and outside Mexico, as described in the “Who has Access to your Personal Information” section of the Policy.  Such transfers do not require your consent, with the exception of a transfer of Personal Information in the case of a merger, consolidation, or sale of assets of Korn Ferry Mexico or of an affiliate. Korn Ferry will transfer your Personal Information in the event of a merger, consolidation, or sale of assets. Your use of the Services means you accept this transfer. If you disagree, please email avisoprivacidad@kornferry.com and inform us of your preference. 

ARCO Rights: You may exercise your ARCO Rights by contacting the Korn Ferry Mexico Privacy Office by email at avisoprivacidad@kornferry.com or by telephone at 5096 0000. Your ARCO Rights are:

• Right of Access:  You have the right to request to know what Personal Information Korn Ferry Mexico holds about you and the purposes for which it is processed. 
• Right of Rectification:  You have the right to request the correction of your Personal Information if it is outdated, inaccurate, incorrect, or incomplete. 
• Right of Cancellation:  You have the right to request the removal of your Personal Information from Korn Ferry’s systems if you believe that it is not being used under the principles, duties and obligations set forth in the Law. If your cancellation request is granted, your ability to use the Services may be limited. Please note that to maintain consistency in our Services and operations, we retain backup systems. When you ask that your information be removed from Korn Ferry’s databases, we may not be able to delete residual copies from our systems or from our backup systems, but they will continue to be protected as required under this notice. We may also need to retain certain Personal Information about you such as your e-mail address to honor opt-out or similar requests.
• Right of Objection:  You have the right to object to Korn Ferry’s use of your Personal Information for specific purposes. If your objection request is granted, your ability to use the Services may be limited.

To exercise your ARCO rights, you may:

• send your request via email to avisoprivacidad@kornferry.com with the subject “Exercise of ARCO Rights”; or
• submit a printed request, with your handwritten signature, at the address indicated in this section.

Please specify what right(s) you would like to exercise and include sufficient detail to validate your identity and locate your information in our systems. To that end, please provide in your request:

• your name and a photocopy of your official ID;
• the email address you used to register for Korn Ferry Services; 
• your user ID for Korn Ferry Services and products, if applicable; 
• your interactions with Korn Ferry, including what Korn Ferry Services you used, and whether you took an assessment or survey, as well as a link to the assessment or surveys, if applicable;
• the names of Korn Ferry consultants or other personnel with whom you worked or corresponded; and
• a clear description of the Personal Information to which your request pertains. 

If we require additional information to validate your identity or understand what information you would like to access, rectify, cancel, or object to, Korn Ferry Mexico may ask you to provide it within 5 days after receiving your request. You will have 10 days to respond to our request, starting from the day following the day you receive it. If you do not respond within that period, your request will be deemed not received. We will respond by email within 20 days of receiving your request or the additional information, as applicable. If applicable, we will fulfill your request within 15 days after our response. 

Right to Revoke Consent to Processing: You may also revoke your consent where Korn Ferry Mexico’s processing of your Personal Information is based on consent. To do so, send your request via email providing the same information as for ARCO Rights requests, to avisoprivacidad@kornferry.com  with the subject “Revocation of Consent,” or submit a printed request, with your handwritten signature, to the address indicated at the beginning of this section, stating your request succinctly and clearly. If you revoke consent, your ability to use the Services may be limited.

We will respond to your request(s) consistent with applicable law. We may decline to process requests that in our reasonable opinion may jeopardize the privacy of others or put our intellectual property at risk. Please also note that when we perform Services at the specific request of a Korn Ferry Mexico client, your request may need to be directed to that client. For example, we may only be able to provide you with a non-confidential summary of our final assessment report because these reports contain confidential client personal information that we are not allowed to disclose. 

ADDITIONAL INFORMATION REGARDING CHINA

If there is any inconsistency between the below and the above Policy, the following will prevail in respect of the PRC.

Legal Basis for Processing; Consent

Notwithstanding anything contained in the above Policy to the contrary, we collect and process Personal Information about you in accordance with the legal bases provided for under the applicable laws. We will obtain your consent (where applicable, separate consent) to collect, use, share, overseas transfer, disclose or otherwise process your Personal Information if and to the extent required by the applicable laws. If we collect and process Personal Information based on your consent (where applicable, separate consent), you may withdraw your consent (where applicable, separate consent) at any time by contacting us at privacy@kornferry.com.

Sensitive Personal Information

We generally do not request sensitive Personal Information about you except in limited cases (such as when you voluntarily answer our demographic survey questions). Sensitive Personal Information means Personal Information the leakage or illegal use of which might lead to the infringement of your personal dignity or harm to personal or property safety. We may collect and process the following sensitive Personal Information as defined in the PRC laws:

• racial or ethnic origin, gender identity, religious or other beliefs, political opinions;
• facial photos, to the extent that the photos could reveal your biometric features; and/or
• undisclosed criminal records.

The processing of sensitive Personal Information is necessary to achieve the purposes described in the Policy and will be conducted in a way that would have the least impact on personal rights and interests.

International Data Transfers

For the purposes described in the above Policy and for the provision of the Services worldwide, we may, with your separate consent (if required by applicable laws), transfer your Personal Information to Korn Ferry affiliated entities (the latest list of which is available at https://cdn.kornferry.com/privacy/subsidiariesalliances.pdf) and third party vendors outside of mainland China, who will process your Personal Information for the purposes and in the manner as described in this Policy. Korn Ferry will take appropriate measures to ensure that cross-border data transfer and the processing of your Personal Information complies with the requirements of applicable laws and that such mechanisms are aimed at ensuring an adequate level of protection as regards your Personal Information under the applicable laws. If you wish to exercise your rights with respect to your Personal Information, please refer to the “Choice and Access” section of this Policy.

TRANSLATED PRIVACY POLICIES

• Chinese Simple Privacy Policy
• French Privacy Policy
• German Privacy Policy
• Japanese Privacy Policy
• Portuguese Brazil Privacy Policy
• Spanish Latin America Privacy Policy

Last Updated: English version updated on November 22, 2023.