Privacy Policy

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WEBSITE PRIVACY POLICY (EU & UK)

Effective Date: 22 May 2018

Capstone Hill Search Limited ("Capstone UK") and its subsidiaries, Capstone Hill Search Inc. ("Capstone US") and Capstone Management Pty Ltd ("Capstone Australia"), and their respective employees (hereinafter referred to collectively as "Capstone Hill Search" or "we", "us" or the "Group") are a specialist executive search group serving the public relations, public affairs,corporate and digital communications industries.

Where you are a UK or EU based individual we handle your personal information ("personal data") in accordance with the legal requirements of the General Data Protection Regulation 2016 ("GDPR") which applies across the European Union ('EU'), including in the United Kingdom.

Capstone Hill Search Limited is a UK data controller in accordance with the GDPR and any replacement EU or UK legislation ("data protection law"). Where any member of our Group, including those outside of the European Economic Area, carries out processing of your personal data which is subject to data protection law, this policy shall apply.

We take your privacy very seriously and we pride ourselves on our discretion, confidentiality and integrity in protecting the personal data provided to us by our candidates and clients.

Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share (collectively known as "process/processing") your personal data through your use of our website, located at www.capstonehillsearch.com, including your use of our candidate services (collectively, the "website"). It also explains your rights in relation to your personal data and how to contact us in the event that you have a complaint.

To view our privacy policy on line, visit https://www.capstonehillsearch.com/privacypolicy.html. This policy should be read in conjunction with our cookies policy https://www.capstonehillsearch.com/cookiespolicy.html and our website terms of use https://www.capstonehillsearch.com/termsofuse.html

Clients and business visitors

Where we collect and use your personal data from a corporate perspective (i.e. where we are contracting with you as a sole trader, or contracting with the business you are employed/contracted by), this will be carried out in accordance with the relevant parts of this privacy policy.

Assignment services for companies seeking candidates are governed by the Capstone Hill Search Terms of Business.

DATA WE COLLECT ABOUT YOU

Data which you provide to us

Capstone Hill Search collects personal data through your use of the website and by other means, such as email or during telephonic or in-person meetings, as a client, a candidate for one of our roles, casual enquirer or a potential client or applicant.

All visitors to our website

We will collect your name and email address together with the relevant message when you communicate with us via the 'Contact Us' tab on our website.

Candidates

We may collect the following information when you submit an application through our website:

• name;
• contact information including address, phone and email;
• your CV or resume;
• your skills, experience, languages spoken and other qualifications;
• employment history and past roles and responsibilities, dates of promotions, reasons for leaving;
• salary, benefits package and earning history;
• professional association memberships;
• desired employment location and salary/benefits package;
• work or employment preferences;
• previous or current job applications within desired job market
• portfolio or examples of work;
• references and referrals;
• notice period;
• any existing employment contract information;
• information you provide through feedback or contacting us;
• other information as required for the purpose of finding a suitable placement for you.

Following receipt of your resume or during the course of an interview, we may request additional information including details of referees and references. When you attend our office for an interview or participate in a telephone interview with us, we may record the personal data you give to us either electronically or manually. If you do not supply the information required we may be limited in our ability to locate suitable employment for you.

Information which we obtain from other sources

We may receive information about you as a result of enquiries we make with former employers, work colleagues, other candidate referrals and professional associations or registration bodies.

We also obtain information about potential candidates by searching information which job seekers have (i) provided to our suppliers for recruitment purposes, which includes, (but is not limited to, and is subject to change from time to time) LinkedIn Recruitment Professional Services (RPS) and LinkedIn.com, PR Week, Gorkana, PRCA , ICCO, Holmes Report and PR Moment and (ii) made publicly available online on job board websites and online CV libraries for recruitment purposes.

We work closely with third parties including business partners, subcontractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional legal and recruitment, and ancillary support services.

Automatically Collected Data

• With regard to each of your visits to our website we may automatically collect the following information:
• • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, MAC addresses, traffic data, location data, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and cookies, which will be will be collected in accordance with our cookies policy.
• • details of your visits to our website and information about those visits, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), services you viewed or searched for, your conduct via the site and (where relevant) details of any information downloaded from the website or information which you have uploaded, and any other site activity, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us;

HOW WE USE YOUR INFORMATION

We use information held about you in the following ways:

Information you provide to us directly

We will use this information:

• to carry out our obligations arising from any agreements entered into between you and us and to provide you with the information and services that you request from us;
• to establish and maintain your relationship with Capstone Hill Search;
• to determine your suitability as a candidate for actual or potential roles;
• where you are a candidate, to introduce you to clients and potential employers who are seeking to identify candidates for a suitable contract or permanent role;
• to carry out appropriate and necessary investigations, including contacting referees to confirm the accuracy of your CV, and to discharge our legal and regulatory obligations and duties;
• to provide you with marketing information about events and information that we believe you may be interested in, such as our newsletter, invitations to seminars or business functions;
• to notify you about changes to our services;
• to build a profile of you and your preferences in order to personalise and enhance your experience with us and provide relevant and suitable roles for our candidates;
• to ensure that content from the site is presented in the most effective manner for you and for your computer.

Information we collect about you

We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to carry out appropriate and necessary investigations and discharge our legal and regulatory obligations and duties, and (where applicable) to safeguard our staff and other users in respect of unlawful, disruptive or objectionable behaviour on our website;
• to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
• as part of our efforts to keep our website safe and secure;
• to deliver effective and personalised marketing material and content, and where there is a legal basis for this, from other companies within our Group, and to assist us in the improvement and optimisation of advertising, marketing material and content, our services and the website;
• to measure, understand or monitor the effectiveness of advertising, promotions, marketing material and content and any joint initiatives with our affiliates, suppliers, partners, subcontractors and other selected third parties;
• build a profile of you, your preferences and your habits;

The website does not engage in the collection of personal data about your online activities over time and across third-party web sites or online services. No third parties collect personal data about your online activities over time and across different web sites through your use of the website.

WHO WE MAY SHARE YOUR PERSONAL DATA WITH

We share personal data with:

• candidates for the purposes of arranging interviews and engagements;
• any member of our Group located within or outside of the EEA;
• clients for the purpose of introducing candidates to them;
• clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you. This includes LinkedIn Recruiter Professional Services;
• subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
• analytics and search engine providers that assist us in the improvement of our website;
• credit reference agencies, our insurance broker, our compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a contractual requirement;
• third parties, if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of use or the Capstone Hill Search Terms of Business, services and other agreements; or to protect the rights, property, or safety of Capstone Hill Search, our clients, candidates or others. This includes exchanging information with other companies and law enforcement entities for the purposes of fraud prevention and credit risk reduction, other parties, such as potential buyers of some or all of our business or if Capstone Hill Search or substantially all of its assets are acquired by a third party, in which case personal data of clients and candidates will form part of the transferred assets. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
• LinkedIn.com, Bullhorn, Google, Intuit Quickbooks, our accountants, lawyers, legal advisors and other professional advisors.

THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

Our business is centred upon the introduction of candidates to our clients for the purpose of temporary or permanent engagement. This also extends to the provision of (i) support to candidates throughout their career and (ii) support to businesses in their resourcing requirements and strategies.

In accordance with data protection law, the legal bases for our processing will depend on the purposes for which the data was collected and is to be used by us.

Contract

Where we are negotiating, or have entered into an agreement with your business for (i) the placement of a candidate or (ii) the provision of any other goods or services which we provide to you or which you provide to us, the legal basis will be based upon the contract ground under para 1(b) of Article 6 of the GDPR.

Our legal obligations

Where we are required by UK law to process your data, for example, where we are legally obliged to share personal data with a third party e.g. for tax purposes, we will rely upon the legal obligation ground under para 1(c) of Article 6 of the GDPR.

Consent

In certain circumstances, we will ask you to provide your consent to our processing of your personal data e.g. where you are a candidate and you wish us to provide your details, such as your CV, to one of our clients. Where we need to contact third parties for references or to obtain other information on your behalf we will seek your prior consent to do so.

Where you are an individual from a business with whom we have no current or previous contractual relationship, or a current or potential candidate, we will seek your prior consent before we send you any information via electronic means (such as email and text message) in relation to our services, promotions, offers or events which we believe that you may be interested in receiving. You may easily unsubscribe from such communications at any time (see "Direct Marketing" below).

We will also seek your explicit consent to the processing of your personal data in the unlikely event that any special categories of data (previously called "sensitive personal data") are collected about you.

Where you provide your consent to the processing of your personal data you have the right to withdraw that consent at any time (please see 'Your Rights' below). Please note that if you wish to withdraw your consent to the provision of the core details which we require from you as a candidate in order to assist you in your placement, this may mean that we will be unable to continue to assist you.

Legitimate interests

To the extent that our processing of your personal data does not fall within the above legal grounds, our collection and use of your personal data will, in most cases, fall within para 1(f) of Article 6 of the GDPR. This legal basis allows us to process your personal data where this is necessary for the purposes of our legitimate interests or those of a third party with whom we share the data, except where these interests are overridden by your privacy rights. As a recruitment business, the exchange of candidates' personal data is an essential part of our business. In order to support our candidates' career aspirations and our clients' resourcing needs we require a database of candidate and client personal data containing relevant historical information as well as current resourcing requirements.

In addition, where you indicate that you wish to be considered for international appointments we may need to share your details outside of the EEA with overseas staff for the purposes of our legitimate business operation and in your interests in finding you such a placement. The sharing will be carried out on a proportionate, need to know, basis in compliance with data protection law.

To the extent that your personal data as a client is shared with our overseas offices, the legitimate interests or contract bases will usually apply.

Where we process your personal data as described under 'Automatically Collected Data' (see above) this is necessary for our legitimate business purposes in order to administer and improve our website and our services and keep our website safe and secure.

Where we carry out profiling as defined by the GDPR, we do not process special categories of data or personal data relating to criminal convictions. Whilst we may use computer systems to search and identify personal data in accordance with parameters set by a person, any decision making involving that data (e.g. in relation to a suitable placement for you) will always involve one of our staff. Such processing will be based upon our legitimate interests and those of the clients we serve in order to place candidates within the roles and organisations to which they are most suited.

Direct marketing communications

We may use your personal data to send you updates about our services, including exclusive offers, promotions or new services. We have a legitimate interest in processing your personal data for promotional purposes. This means that we do not always need your consent to send you direct marketing communications. However, where consent is needed, we will ask for this separately and clearly (see "Consent", above).

We will always treat your personal data with the utmost respect and we will never sell or share it with other organisations outside of Capstone Hill Search for marketing purposes.

You have the right to opt out of receiving any kind of direct marketing communications at any time by:

• contacting us at: [email protected] ; and
• using the 'unsubscribe' link in emails or 'STOP' number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of the business.

SECURITY, STORAGE AND INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

The security and confidentiality of personal data about you is our priority. We protect this information by maintaining physical, electronic, and procedural safeguards in order to prevent data from being accidentally or unlawfully destroyed, lost, altered or accessed or otherwise used in an unlawful manner We train our employees in the proper handling of personal data. When we use other companies to provide services for us, we require them to protect the confidentiality of personal data they receive. We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data, in accordance with data protection law. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

We store your data in secure cloud based applications as well as in hard copy and in local drives. We may transfer personal data about you to our clients or Capstone Hill Search affiliates outside of your home country. We share personal data between our offices and staff in the UK, the United States, Monaco and Australia for the purposes of job placement and for own quality assurance and audit purposes. We may also send your personal data, such as your CV to clients based in other countries outside of the EEA, including those in Africa, the Middle East and Canada, where this is appropriate to your application and where you ask us to do so.

Where your personal data is physically stored in computer servers within, or transferred to, a destination outside of the EEA, we will ensure that the data is protected in compliance with data protection law and other applicable law.

In order to ensure that the transfer or storage of personal data is secure and protected by data protection law, our standard practice is to use the standard data protection contract clauses which have been approved by the European Commission available at the ICO website www.ico.org.uk.

To obtain a copy of those clauses please contact us as indicated below.

Your rights

You have a number of rights under data protection law in relation to the way we process your personal data, although these are not absolute and in some instances we may be unable to accept your request, in which case we will respond to you to explain why. These are set out below. We will respond to any request received from you within one month from the date of the request.

Please address any questions, comments and requests regarding our data processing practices to us in this way in the first instance. You can exercise any of the rights below by contacting us as explained below.

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:

First Contact Team
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

LINKS TO OTHER WEBSITES

Please note that our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

DATA RETENTION AND USE LIMITATIONS

Capstone Hill Search uses personal data collected through your use of the website as indicated in this privacy policy. We retain the information we collect through your use of the website and from yourself directly or through other sources as long as necessary to provide services to our clients and candidates to respond to any questions, complaints or claims made by you or on your behalf, or as required by law and in accordance with data protection law.

The period of time for which any particular items of your personal data is processed (including storage) will depend on the nature of the personal data and the purpose for which we have indicated to you that it is to be processed by us. Personal data held for a direct marketing purpose is held for 2 years whereas personal data which you have provided for use in our client and candidate databases is retained for as long as is necessary in order to communicate with qualified candidates and clients regarding future opportunities, and in general terms, no longer than 6 years. If you would like your information removed, contact us at [email protected] and [email protected].

Please note: We may share, with candidates and potential candidates, information about our clients and employment opportunities. Any such information made available to you should be treated by you in the strictest confidence and used only in connection with the placement services provided by Capstone Hill Search.

We will not retain your personal data for longer than is necessary to the purposes set out in this privacy policy. Further details on data retention can be obtained by making contact with us as set out below.

COOKIES

We use "cookies" and similar technologies on the website. Cookies are data that a web server transfers to an individual's computer for recordkeeping purposes. We use cookies and other technologies to better serve you with more tailored information and facilitate your ongoing access to and use of our website. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. Our use of cookies is described in our Cookies Policy, located at https://www.capstonehillsearch.com/cookiespolicy.html.

To learn more about cookies, please visit http://www.allaboutcookies.org/.

CHANGES TO THIS POLICY

From time to time, we may change this privacy policy. Changes are effective as of the effective date listed above, and indicate the last time this privacy policy was revised or materially changed. Checking the effective date at the top of this privacy policy allows you to determine whether there have been changes since the last time you reviewed this policy.

CONTACT US

If you have any questions about how your information is stored or used by Capstone Hill Search, or to exercise any of your data protection rights please contact us at [email protected]. or by post to:

Capstone Hill Search Limited:

8th Floor 9 Appold Street,

London, EC2A 2AP

United Kingdom

+44 (0)207 017 3081

Capstone Hill Search Inc:
4th Floor,

325 Hudson Street,
New York, NY 10013,

USA
+1 646 480 9118

Capstone Management Pty Ltd:
35/209 Toorak Road,

South Yarra, Victoria 3141, Australia

+61 3 9827 7277

WEBSITE PRIVACY POLICY (US and Australia only )

Effective Date: 19 October, 2017

Last Materially Updated: 14 March, 2019

Capstone Hill Search Limited ("Capstone UK") and its subsidiaries, Capstone Hill Search Inc. ("Capstone US") and Capstone Management Pty Ltd ("Capstone Australia"), and their respective employees (hereinafter referred to collectively as "Capstone Hill" or "we" or "us" or “our”) prides itself on discretion, integrity, confidentiality and protecting the information provided to it by its candidates and clients (“you” or “your”).

This Privacy Policy describes how we collect, use, share and protect data through your use of our website, located at www.capstonehillsearch.com, including your use of candidate services provided by Capstone Hill (collectively, the "Website") and through your interactions with us, either online or offline. Assignment services for companies seeking candidates are governed by the Capstone Hill Terms of Business. To view our Privacy Policy on line, visit http://www.capstonehillsearch.com/privacy.

If you do not agree to the terms of this Privacy Policy, please do not use our Website. If you do not understand, or if you have questions about, this Privacy Policy, please contact us before using, or continuing to use, our Website.

Types of Information We Collect

Data You Provide

We collect two basic types of information when you use or interact with our Website and by other means, such as email or during telephonic or in-person interactions: personal and non-personal information.

Personal information includes all information that relates to you personally and either identifies, or may be used to identify, you personally (collectively, “personal information”). We collect personal information you may voluntarily provide to us for the purpose of placing you in a suitable contract or permanent role, including:

• Name;
• Contact information including address, phone and email;
• Your CV or resume;
• Your skills, experience, languages spoken and other qualifications;
• Employment history and past responsibilities;
• Salary and earning history;
• Professional association memberships;
• Desired location;
• Work or employment preferences;
• Portfolio or examples of work;
• Referee’s name and contact information;
• Information you provide through feedback or contacting us; and
• Other information as required for the purpose of finding a suitable placement for you.

Following receipt of your resume or during the course of an interview, we may request additional information including details of referees and references. We may receive information about you as a result of enquiries we make with former employers, work colleagues, professional associations or registration bodies.

We may conduct security checks or receive the results of any tests or examinations. We may also receive performance feedback, any complaint from or about you in the workplace, information about a workplace accident involving you, and information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or enquiry in which you are involved.

We also collect information from other sources or from our offline interactions with you, such as when you attend our office for an interview or participate in a telephone interview with us. We may record the information you give us either electronically or manually. Where practicable, the purpose for which we collect personal information and the consequences of not providing it will be made clear at the time of collection.

We may also collect non-personal information which includes information that does not personally identify you (collectively, “non-personal information”).

If you do not supply the information required we may be limited in our ability to locate suitable employment for you. Automatically Collected Data

We may automatically collect personal information through your use of the Website. This information includes:

• The IP address and session information of your computer or device.
We may also automatically collect non-personal information and aggregated, de-identified or anonymous information about your use of the Website, including:

• Dates and times when you access the Website;
• Non-personal information about navigation of the Website;
• Information and files that have been downloaded to the Website; and
• The type of browser or operating system you have.

How We Use Information

We may use your personal information to:

• introduce you to clients and potential employers seeking to identify candidates for a suitable contract or permanent role;
• provide you with our website, services and features;
• respond to your requests and communications;
• diagnose problems, analyze trends, and assess our performance;
• improve our operations, services and features;
• better understand the preferences of our customers;
• tailor our services to our customers;
• research and develop new services and features;
• evaluate generals trends and benchmarking in the market (including, for example, salary,
• vacancy rates);
• provide you with, and improve, relevant marketing or offers from us;
• inform you of events that we think may be of interest to you, this includes newsletters;
• invitations to seminars or business functions, and general information about us
• respond to legally binding requests from law enforcement, regulatory authorities or other
• third parties;
• defend, protect or enforce our rights or applicable terms of service;
• to prevent fraud or the recurrence of fraud;
• assist in the event of an emergency; and
• comply with applicable law.

We will not use your personal information for any other purpose without first seeking your consent, unless authorized or required by law.

We may use non-personal information for any legitimate business purpose.

Online Tracking

The Website does not engage in the collection of personal information about your online activities over time and across third-party web sites or online services. No third parties collect personal information about your online activities over time and across different web sites through your use of the Website.

How We Share Information

Except as disclosed in this Privacy Policy, we do not share your personal information with any companies other than Capstone Hill’s subsidiaries and affiliates. In no event will we sell or rent your personal information as part of a customer list or similar transaction.

We may transfer personal information about you to clients or Capstone Hill affiliates outside of your home country, including to the United States, for the sole purpose of job placement. When we do so we will ensure that personal information is protected and comply with applicable law. By using the Website, you expressly consent to this transfer.

Generally we disclose your personal information with third parties to:

• help us with the uses described in the section above;
• potential employers and clients who may wish to engage your services as an employee;
• organizations that conduct tests, referees, a worker’s compensation body;
• suppliers of services to us;
• establish and maintain your relationship with Capstone Hill;
• determine your suitability for actual or potential roles; and
• third parties (with your prior consent) who can assist in the process of placing you.

We may share website usage information, including searches, transaction and profile information (but not your name) with our partners for the purpose of marketing the online advertisements on our websites and other websites that display our advertisements more relevant. You may opt-out of receiving tailored online advertisements from us and our partners by adjusting your cookies settings. Please note that if you opt-out of tailored advertising, you will continue to receive general ads. To learn more about online advertising and your choices click here: http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices/.

We may share your personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of:

• responding to a subpoena, court order or other legal processes;
• defending, protecting or enforcing our rights;
• assisting in the event of an emergency; and
• complying with applicable law.

We may also transfer or assign your personal information to third parties as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose information about you that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.

We share non-personal information with our third-party service providers and partners as reasonably necessary to meet our business needs.

Your Rights

Subject to certain exceptions, you have the right to access, update, correct or delete your personal information collected through the Website. You can access and/or change information in connection with your account or application by logging on to your account online or by contacting us as described in the Contact Us section below.

Data Retention and Use Limitations

We may retain personal information as long as we have a business need to do so, including, for backup, archival, accounting, and/or audit purposes. We may retain non-personal information for as long as we have a business need to do so.

Client and candidate information provided to us is stored in our database for as long as is necessary in order to communicate with qualified candidates and clients regarding future opportunities. If you would like your information removed, contact us at [email protected].

We may provide candidates and potential candidates information about our clients and employment opportunities that is provided by our clients on a confidential basis. Any such information made available to you should be treated by you as confidential and used only in connection with the placement services provided by Capstone Hill.

Cookies

Like many websites, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We may also use cookies to monitor traffic, improve our website and make it easier and/or relevant for your use. To learn more about cookies, please visit http://www.allaboutcookies.org/. Our use of cookies is described in our Cookies Policy, located at http://www.capstonehillsearch.com/cookies.You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. If you delete your cookies or if you set your browser or device to decline these technologies, some services or features may not function properly. Our website does not currently change the way it operates upon detection of a Do Not Track or similar signal. As the internet and other e-commerce channels continue to develop, we may deploy and utilize different types of technologies to collect data regarding your visit or usage.

How We Protect Information

The security and confidentiality of personal information about you is our priority. We protect this information by maintaining physical, electronic, and procedural safeguards. We train our employees in the proper handling of personal information. When we use other companies to provide services for us, we require them to protect the confidentiality of personal information they receive.

While no data transmission over the Internet, wireless networks or data storage systems is guaranteed to be 100% secure, we continually evaluate and update our security measures. 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), please immediately notify us of the problem by contacting us as described in the Contact Us section below.

Cross-border transfer

There may be occasions in which we transfer Personal Data originating in the European Economic Area (“EEA”). Accordingly, Capstone Hill complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information transferred from the EEA to the US. Capstone Hill has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit (https://www.privacyshield.gov). The Federal Trade Commission (FTC) has jurisdiction over our compliance with the Privacy Shield Framework.

If you are a resident within the EEA, you have the right to access your Personal Data. You may do so to confirm the existence of the Personal Data, confirm its accuracy, edit it, or delete it. The Capstone Hill contact for initiating any of these actions is listed below.

If you are a resident within the EEA, you have the right to opt out whether your Personal Data is (i) to be disclosed to a third party who is not our agent, or (ii) to be used for a purpose that is materially different from the purpose for which it was originally collected and for which you authorized its use. The Capstone Hill contact for initiating any of these actions is listed below.

In compliance with the EU-US Privacy Shield Principles, we are committed to resolve complaints about your privacy and our collection and use of your personal information. Individuals within the EEA with questions or concerns about the use of their Personal Data should contact us at the contact information below. If your question or concern cannot be satisfied through this process we have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield to a Privacy Shield Panel convened by a EU Data Protection Authority (DPA). We will cooperate with the DPA in the investigation and resolution of any otherwise unresolved complaint, and we will comply with advice given by the DPA. Finally, as a last resort and in limited situations, an individual within the EEA may seek redress from a binding arbitration mechanism.

In accordance with the Privacy Shield Principles, except as otherwise provided herein, we disclose Personal Data only to third parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations. Further, we may provide Personal Data to third parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, we may store such Personal Data in the facilities operated by third parties. Such third parties must agree to use such Personal Data only for the purposes for which they have been engaged by us and they must either: (a) comply with the Privacy Shield Principles or another mechanism permitted by the applicable EU data protection law(s) for transfers and processing of Personal Data; or (b) agree to

provide adequate protections for the Personal Data that are no less protective than those set out in this Privacy Policy.

We also may disclose Personal Data for other purposes or to other third parties when you have consented to or requested such disclosure. Please be aware that we may be required to disclose an individual's Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We remain liable for appropriate onward transfers unless we prove we are not responsible for the event giving rise to the damage.

Changes to This Policy

We reserve the right, from time to time, to change this Privacy Policy. Changes to this Privacy Policy are effective as of the effective date listed above, and indicates the last time this Privacy Policy was revised or materially changed. Checking the effective date at the top of this Privacy Policy allows you to determine whether there have been changes since the last time you reviewed the Privacy Policy. We may also provide you with notice of changes by prominently posting on our website, via email or both, if we make any changes to this Privacy Policy that materially affect your rights.

Your continued use of the Website indicates your consent to the changes to this Privacy Policy. Please note that continued use of the Website may not be possible without consenting to the privacy practices disclosed in this Privacy Policy.

Use by Minors

Our Website is not for individuals under the age of 13. We do not knowingly collect personal information from children or minors. If you think we have received personal information from children under the age of 13, please contact us immediately.

Your California Privacy Rights

We do not share personal information with third parties for their own direct marketing purposes without your consent. To make any request pursuant to California privacy law, please contact us.

Third Party Websites and Apps

The Website may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

Contact Us

If you have any questions about how your information is stored or used by Capstone Hill, please contact us at [email protected], or by phone or mail at:

Capstone Hill Search Limited:

9 Appold Street, London, EC2A 2AP, United Kingdom +44 207 017 3088

Capstone Hill Search Inc:

4th floor, 325 Hudson Street, New York, NY 10013, USA +1 646 690 3706

Capstone Management Pty Ltd

35/209 Toorak Road, South Yarra, Victoria, Australia +61 3 9827 7277