AlixAlumni

ALUMNI PRIVACY POLICY

Effective Date:

2018-MAY-25

(Updated)

Owning Department:
Legal, Compliance, and Risk

PRIVACY POLICY

AlixPartners, LLP, its subsidiaries and it’s affiliates (collectively referred to as “AlixPartners”, “we”, “us” and “our”) are fully committed to respecting the privacy rights of individuals, and to compliance with data protection laws in all jurisdictions in which we operate. The purpose of this privacy policy is to explain how and why we collect, use, transfer (“Process”) and protect personal data relating to our alumni network and our alumni website alumni.alixpartners.com (“Alumni Site”). When we reference “Personal Data”, we mean any information which relates to an identified or identifiable individual.

For the purposes of the data protection laws which apply to our operations, the relevant AlixPartners group company (or companies) with which you are dealing will act as a “Data Controller” or “Business” in relation to your personal data. This means that AlixPartners determines both the purpose for which, and the means by which, personal data is processed. The Alumni Site is hosted by our unaffiliated service provider, PeoplePath, Inc. (“PeoplePath”), who is acting as a data processor on behalf of AlixPartners. PeoplePath built the website and manages it in consultation with AlixPartners.

AlixPartners and PeoplePath will only use and disclose your personal data as described in this Policy. As our business evolves we may make changes to the ways in which we process personal data, and we reserve the right to modify this policy from time to time. If we make material changes to our information practices and your privacy rights may be affected, we will bring these to your attention and give you the opportunity to provide or withdraw consent to further processing. In the event that AlixPartners’ contract with PeoplePath terminates, we will promptly notify you of this and provide you with information on how to continue to participate in our alumni network.

Should you have any questions regarding your privacy rights or anything else set out in this Policy, please contact privacy@alixpartners.com. California residents may also call our toll-free number (844) 441-9869 and entering the PIN 605300 when prompted . You may also appoint an agent to submit a request on your behalf.

The Alumni Site is a private site available only to current and former employees of AlixPartners.

Why do we collect Personal Data?

The primary reason for the processing of your Personal Data described in this policy is to cultivate and enhance an effective alumni network for the mutual benefit of AlixPartners, our current personnel and our former colleagues. We want to provide a valuable service that will allow those who leave our Firm to stay connected to us, creating potential opportunities to do business together in the future, to facilitate cross-referrals, to keep you informed about topics and events that may be of interest to you, request your insight or feedback in relation to research activities, and to make you aware of job opportunities that may appeal to you or your contacts. The table below provides further detail regarding our purposes for processing the Personal Data we collect, our legal basis for doing so, and any disclosures of such information to third parties in the last 12 months.

How your personal data is collected

Personal data you voluntarily provide to us

The Alumni Site collects personal data when you directly give it to us, for example when you register. During registration and profile setup, we require that you provide your name and email address. To the extent that AlixPartners has information relevant to the creation of your Alumni Site profile, that information may be automatically added to your profile at this Site. However, this information will not be shared with other members of the Alumni Site until you have accepted this privacy policy. When you do accept this privacy policy, your name and other personal information appears in the Directory and becomes visible to other members of the Alumni Site.

You have the option to expand your user profile to include a wide range of additional information, including photo, postal address, current occupation, industry, education, skills, and personal and business interests. By providing complete and accurate information in your profile, you enable us to customize your experience and help you get the most from the Alumni Site. However, please supply only information that is relevant for the purposes stated in this policy.

We also collect personal data in the following situations:

correspondence between you and the Alumni Site including the tracking of clicks, open rates and bounces;
information you post on the Alumni Site, such as, resumes, job applications, event RSVPs, comments on news articles; and
responses to online surveys or forms that we use for the Company feedback, research and product improvement.

Please keep in mind that whenever you voluntarily disclose personal information online – in the optional fields in your profile, through email, or in areas of the Alumni Site – that information could be accessible to the rest of the members of the [AlixPartners] Alumni Network and may be made public. Please do not post or add personal data to your profile or elsewhere on the Alumni Site that you would not want to be publicly available.

Information we collect automatically

When you use the Alumni Site, we collect information about your visit and usage of the Alumni Program services. We use this information to improve our services and the user experience as well as network management and security.

We may use various technologies to collect and store information when you use our Site, including cookies and similar tracking technologies, such as pixels and web beacons, to analyze trends, administer the website, and track users’ movements around the website. Users can control the use of cookies at the individual browser level. For more information about our use of cookies and other tracking technologies, as well as how to opt out of the use of cookies, please refer to our Cookies Policy here. Turning off cookies may result in a loss of functionality when using the Alumni Site or potentially the ability to use the Site at all.

Verification with personal data already held by AlixPartners

AlixPartners may verify that you are an AlixPartners alumnus/a or current employee by matching your registration information with data previously known about you by AlixPartners. This information may include, but is not limited to, your name, email address, last position, locations, expertise or skills, and university/college.

The Personal Data that we collect

Personal data relating to you that we process may include the following:

“Identity Data”: including first name, maiden name, last name, username or similar identifier, marital status, title, social media handle, date of birth, gender, photograph, likeness, image, your job function, your employer or department;

“Contact Data”: including email address, billing address, postal address, and telephone numbers including frequency of contact (these details may relate to your work or to you as an individual, depending on the nature of our relationship with you or the company you work for);

“Professional Data”: including your employer, job title, email address, phone number, addresses, and areas of specialism/expertise;

“Professional History Data”: including your professional experience, previous employers, positions, locations, and contacts within AlixPartners;

“Attendance Data”: details of your attendance at any of our premises or any events we host that you attend;

“Usage Data”: includes information about your use of our Website(s), as well as our local area networking facilities (including WiFi) and similar electronic services, such as, information collected when you visit the Alumni Site, including your referral website, pages you visit, actions you take, information on last viewed/visited site and details of the content viewed, including when and how many times the content was viewed, patterns of page visits, time details per visit (e.g. visit duration, number of visits, time spent on each page, frequency of visits), details about the path followed with special reference to the sequence of pages visited, interactions, functionalities and modules used, chat messages;

“Marketing and Communications Data”: including your marketing and communication preferences, such as alert and display preferences, content type and desired frequency of email alerts, content that interests you (including industry sectors, topics and jurisdictions), information about events to which you or your colleagues are invited, and your personal data and preferences to the extent that this information is relevant to organising and managing those events (this may include your dietary requirements but excludes any Special Category Data);

“Survey Data”: including responses you provide to requests or invitations to provide feedback on our products, services and content including the Alumni Site, and data relating to your participation in polls and surveys, should you choose to provide such data; and

“Technical Data”: including:

The Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit to our Website(s), such as the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), services viewed or searched for, page response times, download errors, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from a page, any phone number used to call our central switchboard number, and direct dials or social media handles used to connect with our consultants or other employees; and
Location data which we may collect through our Website(s) and which provides your real-time location in order to provide location services (where requested or agreed to by you), or deliver content or other services that depend on knowledge of your location. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the Website. Delivery of location services will involve reference to one or more of the following: (a) the coordinates (latitude/longitude) of your location; (b) look-up of your country of location by reference to your IP address against public sources; and/or (c) your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier. See our Cookies Policy for more information on the use of cookies and device identifiers on the Website(s).

Purpose/Activity	Types of Data	Lawful Basis for Processing	Source of Data
To provide an Alumni service for ex-colleagues and provide a networking platform	Identity Data Contact Data Professional Data Professional History Data Attendance Data Marketing and Communications Data	Consent Legitimate Interest (promoting our products and services and seeking to develop our business)	Directly from the individual Third party sources including searches of publicly available information such as online and social media
To provide our users with a customized experience on our Site, including personalization services, such as suggested contacts, news, events and interactive communications.	Identity Data Usage Data Marketing and Communications Data Technical Data	Legitimate Interest (seeking continuous improvement of our Alumni Site, products and services and seeking to develop our business) Consent	Directly from the individual Information already in AlixPartners’ possession
To enable other users to search for and locate you via the directory.	First name* Last name* Preferred Alumni office(s)* City Country Work status* Company/Organization* Function Industry Level Department Last Office Major Minor Last start date Last departure date Current status Company/Organization	Consent	Directly from the individual Information already in AlixPartners’ possession Third party sources including searches of publicly available information such as online and social media
To research and analyse our users’ demographics, interests and behaviour to better understand and serve our users and improve our Site and our AlixAlumni program offerings.	Identity Data Professional Data Professional History Data Attendance Data Usage Data Marketing and Communications Data Technical Data	Legitimate Interest (understanding how visitors interact with the Alumni Site, gaining insights into their user experience and seeking continuous improvement to develop our business)	Directly from the individual
To contact you periodically with communications about Company announcements, seminars, events, memoranda, publications or employment opportunities with the Company, affiliates or partners, which we feel might interest you, unless you ask not to be contacted. You will have an opportunity to opt out of receiving further messages.	Identity Data Contact Data Professional Data Professional History Data Attendance Data Marketing and Communications Data	Legitimate Interest (promoting our products and services and seeking to develop our business) Consent	Directly from the individual Information already in AlixPartners’ possession
To get your feedback and viewpoints through polls and surveys conducted by us and others. You are not obligated to respond to polls and surveys and can choose the information you provide.	Identity Data Contact Data Professional Data Survey Data	Consent	Directly from the individual
To share with other internal Company systems, including our CRM, our events software, and our email marketing system amongst others for a variety of reasons including to contact you with professionally relevant information.	Identity Data Contact Data Professional Data Professional History Data Attendance Data Usage Data Marketing and Communications Data	Legitimate Interest (promoting our products and services and seeking to develop our business)	Directly from the individual
To fulfil our legal obligations, including contractual, regulatory, and reporting obligations, and obligations in connection with potential or actual legal or regulatory proceedings or investigations.	Identity Data Contact Data Professional Data Attendance Data Usage Data Technical Data	Legal or regulatory obligation	Directly from the individual Information already in AlixPartners’ possession Third party sources including searches of publicly available information such as online and social media
To provide you and other members of the Site with resources for professional or career development and related support.	Identity Data Contact Data Professional Data Professional History Data Attendance Data Usage Data Marketing and Communications Data	Legitimate Interest (promoting our products and services and seeking to develop our business) Consent	Directly from the individual Information already in AlixPartners’ possession
To maintain and improve the Site, including auditing and monitoring its use in order to understand Site users’ demographics, interests, and content preferences.	Identity Data Usage Data Marketing and Communications Data Technical Data	Legitimate Interest (understanding how visitors interact with the Alumni Site, gaining insights into their user experience and seeking continuous improvement to develop our business)	Directly from the individual
To provide information requested by you, including in connection with opting in for our content including blogs, community groups, events, etc.	Identity Data Contact Data Marketing and Communications Data	Consent	Directly from the individual
To analyse whether event invitations and other emails sent by the Company have been successfully sent or have been opened.	Identity Data Contact Data Attendance Data Marketing and Communications Data Technical Data	Legitimate Interest (understanding the effectiveness of our marketing communications and seeking to develop our business)	Directly from the individual

We, may also produce, use, store and share aggregated information such as statistical or demographic data, either for us to use for our own internal purposes, or to share with third parties. Aggregated information may be derived from personal data but is no longer considered personal data under data protection laws once individual identifiers have been removed. We may, for instance, aggregate data regarding our users’ navigation of the Alumni Site to understand the proportion of visitors that access particular features or content. However, if we combine aggregate data with your personal data so that we can directly or indirectly identify you, we would treat this combined data as personal data and use it in accordance with this policy (or such other notice we may send to you which relates to such processing). PeoplePath may also occasionally collect and use aggregated data, for its own internal purposes.

Your choices and access to your Personal Data

You have control over, and direct access to, your personal data on the Alumni Site and can make changes to this information directly, as required, to ensure it remains accurate. AlixPartners is also able to update your profile data, such as your contact and employment details, where we are notified that these have changed, so that we can ensure the ongoing accuracy of your personal data on the Alumni Site.

When you register and set up your profile, your name and the other information you provide will be placed in the Member Directory. Unless you request otherwise through the opt-out mechanism provided on the Alumni Site, your name, profile picture, current and past professional data, degrees, and social media links will be accessible to other members of the Alumni Site. The rest of the information you provide for your profile will not be shared with other members of the Alumni Site until you provide consent for such sharing. You have control over this access through the privacy settings in your Profile. Click on the profile picture in the upper right corner of any page on the Site and select “Privacy”. Once you provide such consent, all the information in your profile will be visible in the Alumni Directory and will be accessible to other members of the Alumni Site.

International Transfers of personal data and disclosures to third parties

We may share your personal data between AlixPartners entities and to certain third parties on a confidential basis, where this is necessary for the legitimate purposes set out in this policy. This may involve transferring personal data to entities located outside of the UK, Switzerland, the EU or the EEA, including countries which do not provide the same level of protection for personal data. In such cases, we will put in place appropriate measures designed to ensure that such personal data is given adequate protection at its destination, in compliance with applicable laws. This may include the European Commission’s Standard Contractual Clauses, which can be found here.

A list of the countries in which AlixPartners entities are located and who may receive Personal Data is available on our Website.

AlixPartners does not sell, license or otherwise distribute your personal data; nor do we share your personal data with unaffiliated third parties for their independent use, except where:

you have provided your express consent or specific instructions for us to do so;
we are required to do so to comply with legal or regulatory obligations;
we are permitted to do so by law;
such disclosure is otherwise described in this Policy.

We may share your personal data with:

other users of the Alumni Site, through the Directory search function and an Alumnus’ profile;
our professional advisors and other trusted third party service providers, including information technology services and related infrastructure, email delivery, and other similar services;
advisers, services providers, potential transactional partners or other third parties if we consider, enter into negotiations or complete any transaction whereby we sell, transfer or merge parts of our business or assets. Alternatively, we may choose to acquire other businesses or merge with them. In the event of such a change to our business, the new owners or the combined organisation may use your personal data in the same way as set out in this privacy policy.

Where we do share your personal data in any of the ways set out above, we require the receiving entity or individual to respect its confidentiality, ensure it is kept securely and only be used in accordance with applicable laws. We permit such recipients to use the data we share only for limited, specified purposes and in accordance with our instructions.

Security

Having regard to the state of the art, the costs of implementation and the nature, scope, context and purpose of processing as well as the risk of varying likelihood and severity for the rights and freedoms of individuals, we implement and maintain appropriate technical, organisational and physical safeguards to ensure a level of security which is appropriate to the risk of processing. We take reasonable measures to restrict access to personal data so that only those AlixPartners personnel who require such access to your data in order to fulfil the purposes set out in this policy are granted such access. We ensure that individuals who have regular access to personal data are obliged to protect its confidentiality and receive appropriate training regarding their rights and obligations when processing personal data. Only relevant personnel of PeoplePath who require full access to operate the Alumni Site and provide the agreed services will be given access to the Alumni Site, including all personal data submitted to it.

However, no information system can be completely secure and we cannot guarantee the protection of any personal data you choose to transmit to our Websites.

Children’s Privacy

AlixPartners is committed to compliance with the Children’s Online Privacy Protection Act (“COPPA”). The AlixPartners Alumni Site is not intended for use by children under the age of 16. We do not knowingly collect any personal data from children under the age of 16 and request that such individuals do not submit any personal data to us via the Alumni Site. We recommend that schools and parents remind their children to handle their personal data securely and responsibly on the Internet, supervise their children’s online activities and consider the use of other means to provide a child-friendly online environment.

Linking to other websites

The Alumni Site contains links to other websites which are not operated by AlixPartners. These links are provided solely as a convenience to you. If you use these links, you will leave the Alumni Site and this policy will not apply to the site you navigate to. We have not reviewed these sites or their privacy policies, have no control over them, and assume no responsibility for the contents provided by third parties. If you decide to access any of these sites you should understand that you do so at your own risk, and we strongly suggest you review their privacy policies to ensure you are comfortable with their use of your personal data.

Retention of your Personal Data

We will only retain your personal data as reasonably necessary to achieves the purposes for which we collected it, including for the purposes of complying with any legal, regulatory, tax, accounting or reporting requirements. The duration will vary depending on the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We may retain your personal data for a longer period in the event that we receive a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

We will respond promptly and in accordance with our obligations to delete your data if we receive a valid request to do so. To exercise your data rights, see the “Your Data Rights” section below.

Your Data Rights

As an international firm AlixPartners operates in a number of jurisdictions which require differing levels of protection for personal data, and which confer various rights which individuals may exercise in relation to their data. Depending upon the applicable law, you may have the right:

to know the: (i) specific pieces of personal data collected; (ii) the categories of personal data; (iii) the categories of sources of personal data; (iv) the business or commercial purpose for collecting personal data; (v) the categories of personal data disclosed for a business purpose; (vi) the categories of third parties to whom the personal data is shared;
to request access to certain personal data relating to you that we process;
to have personal data corrected, for example if it is incomplete or inaccurate;
to opt-out of receiving marketing communications at any time;
to request that personal data is deleted, subject to exceptions that may apply under applicable laws;
to object to the processing of personal data;
to receive a copy of personal data which you have provided to us in a commonly used electronic format (commonly known as “data portability”). This right only applies if the processing is carried out by automated means and is either: (a) is based on your consent; or (b) necessary for the performance of a contract;
to withdraw your consent, where you have provided personal data voluntarily or otherwise consented to its use;
not to be discriminated against if you exercise any rights conferred on you by the California Consumer Privacy Act of 2018;
to bring a complaint to a Data Protection Authority. If you are in the European Union, this will be the Data Protection Authority in the country in which you are located. If you are in the United Kingdom, this will be the Information Commissioner’s Office. If you are in Switzerland, this will be the Federal Data Protection and Information Commissioner.

If you would like to find out which of these rights apply to you or wish to exercise any of these rights, please select the appropriate link below and complete the form:

If you are in the UK, Switzerland, or the European Economic Area (EEA), please click here.
If you are in Argentina, please click here.
If you are in California, please click here.
If you are in any other jurisdiction, please click here.

If you seek to exercise your rights, we may request that you prove your identity to us by providing us with a copy of a valid means of identification. This is a security measure designed to ensure that personal data is not disclosed to anyone who is not entitled to receive it. We may also request that you provide us with further information in order help us respond to your request efficiently.

You will not have to pay a fee in order to access your personal data. However, we may charge you a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. However it could take us longer to respond if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Should you have any questions regarding your privacy rights or anything else set out in this Policy, please contact privacy@alixpartners.com. California residents may also call our toll-free number (844) 441-9869 and entering the PIN 605300 when prompted. You may also appoint an agent to submit a request on your behalf.

If you are in Singapore you can also contact Ee Li Szie (eszie@alixpartners.com) or Wing Chung (kchung@alixpartners.com).

The Data Controller for this website is AlixPartners, LLP of 2000 Town Center, Suite 2400, Southfield, Michigan, 48075, United States of America. Our website server is based in the United States of America.