Privacy Policy

Introduction

Steele Executive Solutions is committed to maintaining your trust by protecting your personal data. This Privacy Notice explains how we collect, use, share and protect personal data. It also outlines the choices available to you regarding the use of your personal data. For the purposes of this Privacy Notice the terms "Steele Executive Solutions", "we", "us" and "our" shall refer to Steele Executive Solutions and its domestic and international subsidiaries.

Steele Executive Solutions is committed to ensuring that your privacy is protected, and to the extent possible by Steele Executive Solutions, that your personal data is secure. We shall process your personal data in a transparent and lawful way. Any personal data you provide when using our website located at steeleexecutivesolutions.com and any other website operated by us from which you are accessing this Privacy Notice. Please read this Privacy Notice carefully to understand our policies regarding your personal data. If you do not agree with this Privacy Notice, your choice is to not use our site and services. You are responsible for ensuring we have an up-to-date, active and deliverable e-mail address for you.

What is Personal Data?

For individuals covered by the General Data Protection Regulation (GDPR), personal data is any information relating to an identified or identifiable natural person. For individuals not covered by GDPR, Steele Executive Solutions defines personal data as data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the following foregoing data.

Information That We Collect

Steele Executive Solutions processes your personal data to ensure the efficiency and effectiveness of our services and products.

How We Collect Personal Data

Through the services we may collect personal data through the performance of the services. We may collect data from you offline, such as when you contact customer services or attend our events. We may receive personal data from other sources, such as public databases, joint marketing partners, social media platforms and from other third parties. We collect and use the personal data you provide directly to us. This data is collected in various online and physical forms and throughout our business relationship.

Other Ways You Provide Data to Us

If you provide feedback or contact us via e-mail, we will collect your name and e-mail address as well as any other content included in the e-mail, in order to send you a reply. When you participate in one of our surveys, we may collect additional profile information.

We do not process the following types of data:

• User generated data (photos, music, and text)
• Legal data
• Data on or about children

Data We Collect Automatically

We and our service providers automatically collect information about you when you access our site. Here are examples of the ways we collect information automatically.

Tracking Technologies

Cookies are small amounts of data that are stored in separate files within your computers internet Brower, cookies are accessed and recorded by the sites you visit, and by the companies that show advertisements on these website, so that they can recognise the same browser. For more information please see our cookies policy below.

Web beacons are small strings of code that provide a way for us to deliver a small graphic image on a web page or in an e-mail. Web beacons can recognise certain types of information on your computer such as cookies, the time and date a page is viewed and a description of the page where the web beacon is placed.

Google analytics is a web analysis service provided by Google Inc. Google utilizes the data collected to track and examine the use of this application, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Google AdWords conversion tracking is an analytics service provided by Google that connects data from the Google AdWords advertising network with actions performed on this site.

To make our site and services more useful to you, our servers which may be hosted by a third party service provider) collect information from you, including your Brower type, operating system, internet protocol address, domain name, and/or a date/time stamp for your visit.

Cookie Policy

Our site uses cookies to distinguish you from other users on our site. A cookie is a small file of letters and numbers that we will put on your computer if you agree. This helps us provide you with a good experience when you browse our site, and also allows us to improve our site and services.

We use cookies which are essential to make our site work and help us improve it by giving us some insight into how the site is being used. We may use both session cookies and persistent cookies to provide you with a more personal and interactive experience on our site. Persistent cookies can be removed by following internet browser help file directions.

If for any reason you think there is a problem, please let us know by either contacting your account manager or by e-mail to enquiries@steeleexec.com

Third Party Sharing

We may share information with third parties for purposes described in this policy. Information collected within the European Economic Area (EEA) may, for example, be transferred to countries outside the EEA for the purposes as described in this policy. We utilize standard contract clauses approved by the European Commission, adopt other mean under European Union law, and ensure there is a legal basis to process the personal data to legitimize data transfers from EEA to the United States and other countries.

Sub Processors

We transfer information to vendors, service providers, and other partners who globally support our business, such as providing technical infrastructure services, analysing how services are used, measuring the effectiveness of ads and services, providing customer service, facilitating payments, or conducting academic research and surveys. These partners must adhere to strict confidentiality obligations in a way that is consistent with his Privacy Notice and the agreements we enter into with them.

Access to Personal Data

If we receive a Data Subject Request from an individual whose data we process on behalf of another company, we will inform them of such request and work with both the third party and the individual to complete the request.

You have a right to withdraw you consent for any marketing or sales material. To do this, please send an email to enquiries@steeleexec.com

Security

We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate technical and organizational measure to safeguard and secure the personal data we process. No system is 100% secure and your personal data cannot be guaranteed. You must ensure you protect you username and password and do not share it with others. If, despite all our efforts, a data breach does occur, we shall do everything in our power to limit the damage. In case of a data breach which is likely to result in a high risk, and depending on the circumstances, we will inform you about remedial actions to prevent any further damage. We will always inform the relevant data controller, supervisory authority without undue delay.

Data Retention

We will not store your personal data longer than necessary for the purpose for which we have processed your personal data including our legal requirements to retain data after completion of the service. How long we retain your personal data depends on the type of data, the purpose for which we process it and the laws governing such data.

Complaints

If you have a complaint with how we handled a SAR please let us know and we will try to fix it. You can email the Data Protection Officer (DPO) at enquiries@steeleexec.com

If you are dissatisfied with Steele Executive Solutions handing of any privacy complaints, if you do not receive timely acknowledgement of your complaint, or your complaint is not satisfactorily addressed please contact the Information Commissioners office in England at https://ico.org.uk/concerns/

Controller:

Data Protection Officer
Marlos House
Nursery Gardens
Purley on Thames
Reading
Berkshire
RG8 8AS

Anti-Slavery and Human Trafficking Policy

Modern slavery is a crime and violation of fundamental human rights. All types of modern slavery have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with the integrity in all our business dealings and relationships and to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains.

We are also committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout our business relationships, consistent with our disclosure obligations under the Modern Slavery Act 2015. As part of this process, we have undertaken a review of our supply chain to identify and assess potential risk areas and maintain a register detailing the same.

We expect a high standard from all of our subcontractors, supplies and other business partners and have made this a contractual term in our agreements with significant supplies where possible.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of the employee's contract of employment and we may amend it at any time.

Responsibillity for the Policy

The management of the firm has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all of our people comply with it.

The legal department has primary and day-to-day responsibility for implementing this policy, but the procurement team provide assistance with reviewing the risk profile of our supply chain to ensure that any procedures implemented are effective and countering modern slavery.

Compliance with the Policy

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in a part of our business or supply chains is the responsibility of all those working for us or under our control, you are required to avoid any activity that, might lead to, or suggest, a breach of this policy.

Although you should report any concerns regarding modern slavery and/or human trafficking in any parts of our business or supply chains in accordance with our whistleblowing policy, you are also encouraged to discuss a specific matter (or our policy or relevant legislations) with any member of the legal department.

If you are in any doubt about whether a particular act or working conditions in any of our business relationships may contravene any aspect of this policy then err on the side of caution and report it in accordance with the whistleblowing policy, or speak to a member of the legal department.

We encourage openness and will support anyone who raises genuine concerns in good faith in accordance with the firm's whistleblowing policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their knowledge, or suspicion, that modern slavery is taking place in any part of our business or in any of our supply chains.

Communication and Awareness of this Policy

Our zero-tolerance approach to modern slavery is communicated to all significant supplies contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this Policy

Any employee who breaches this policy could face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they break this policy.