ESG Privacy Notice
Effective date 4th October 2018
Elite Strategy Global, LLC (ESG) and its business subsidiaries and affiliates (“ESG”, “us” or “we”), understand that the protection of your privacy is important to you and of course paramount to us, as we seek to both establish and sustain a strong business partnership centered around integrity and trust. ESG subsidiaries and affiliates may process your personal data in their capacity as data controllers and managers, facilitating the processing of your personal information/data to provide you with the benefits derived from using our convenient (Electronic information)- “E-info” processing and exchange capabilities. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Data Privacy Notice (“PN”), describes how we handle and protect your personal data in connection with ESG’s client intake and business associate services processes and procedures.
This PN only applies to the personal data of perspective clients and current and/or future ESG business associates, who use our website to submit their personal information through our respective client intake and business associates’ applications services portals. It does not apply to any other personal data that ESG may collect for other purposes.
As referenced in this PN, “personal data” means information that identifies potential clients and current employees or candidates for employment with ESG, submitted through either our web-based client intake processing portal or respective employee centric services portals, where applicable.
We will process all personal data in accordance with this PN, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail.
By submitting your personal data to us, you acknowledge that:
- You have read and understood this PN and agree to the use of your personal data as outlined herein.
- Your personal data may be transferred and processed worldwide, including countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this PN.
- You are not required to provide any requested information to us, but failing to do so may result in not being able to conduct proper use or facilitation of ESG services on your behalf.
- All of your representations and information submitted are true and accurate to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature, if and where applicable. Providing any inaccurate information may delay or negatively impact the provision of ESG services on your behalf.
- This PN does not create or establish a legally binding contract of with ESG of any kind whatsoever.
Personal data we collect
The types of personal data that we request from you and the ways that we process it are determined by the requirements of the country in which you are physically located at the time of submission, and not the country in which you physically reside.
We typically collect personal data directly provided when you submit a request for potential services engagement with ESG, i.e., your name, email address and/or contact number. At this time, we don’t collect information from third parties about potential ESG clients, as currently data collections practices are limited in scope to personal information submitted via our client inquiry intake submission form provided on the site. Please refrain from providing ESG associates with highly sensitive personal data when filling out your contact submission request, as we will follow-up via a confidential phone call upon receipt of your initial submission inquiry to obtain any additional information we deemed necessary to better assist you.
Use of your personal data
We collect and use your personal data for legitimate business engagement reasons including:
- identifying and evaluating prospective client requests for engagement of our services;
- recordkeeping in relation to client intake metrics tracking and operational work-flow considerations;
We may also analyze your personal data or aggregated/pseudonymized data to improve our overall client services processes.
We process your personal data for the purposes described above: when we have your consent to do so; when necessary to enter into a business contract with you; when necessary for us to comply with a legal obligation; or when necessary for the purposes of our legitimate interests as a provider of consulting services.
We may desire to retain your personal data to consider you for future business engagement efforts. In such an event, we will seek your consent, prior to doing so, as such data retention practices are entirely OPTIONAL.
Data recipients and international data transfers
Your personal data may be accessed by highly trained and professional ESG business associates. Individuals performing administrative functions and IT personnel within ESG may also have a limited access to your personal data to perform their jobs. In some countries, you may have fewer rights under local law than you do in your country of residence, but we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by ESG subsidiaries and affiliates within the ESG global organization, including the transfer of your personal data to countries other than the one in which you reside.
If every applicable, ESG maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this PN and protects the confidentiality, availability, and integrity of your personal data. Where required by law, we put in place legal mechanisms designed to ensure adequate data protection of your personal data in a third country. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, please contact us at the address provided at the end of this PN.
In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
If you decide to enter into a legally binding business relationship with us, ESG shall only retain a minimum amount of your personal data to record your initial interaction with us. In doing so, ESG shall employ highly secure data protection practices to take every reasonable precaution to safeguard any personal information that may be associated with your client account.
We have implemented generally accepted standards of technical and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized personnel of ESG are provided access to personal data. Despite these precautions, we cannot provide a 100% guarantee that unauthorized persons will not obtain access to your personal data.
We take reasonable steps that are designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to ensure that our processing of your personal data complies with this PN and applicable law.
You may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may have the right to request a copy of the personal data we have collected about you and to have any inaccuracies about you corrected. You may also request that we cease processing your personal data (e.g., if you choose to withdraw from our client intake process), although note that we may need to retain certain personal data where required or permitted to under applicable law.
If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at privacy_information@EliteStrategyGlobal.com.
To help protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Depending upon the circumstances and the request, we may not be permitted to provide access to personal data or otherwise fully comply with your request; for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or to deny your requests where, in the Firm’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law.
In addition, and where granted by applicable law, you may have the right to lodge a complaint with a competent data protection authority.
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ESG Strategy Global
Office of Legal Affairs Division
1100 North Glebe Rd., STE #1010
Arlington, VA 22201
ESG reserves the right to modify this PN at any time and will post any changes to our PN on this page. Please check this page regularly for up-to-date PN changes, where applicable.