McChrystal Group Online Privacy Policy

This Online Privacy Policy (“Privacy Policy”) describes how McChrystal Group, LLC (“MG,” “us,” “we,” or “our”) collects, uses, and discloses personal information when you visit our website(s) at www.mcchrystalgroup.com (“Websites”) or any other online services that we operate that include a link to this Privacy Policy, and in relation to our workforce analytics services described below (collectively, the “Services”). As used in this Privacy Policy, “personal information” means information that identifies or that could be used to identify you.

Our workforce analytics services may at times involve the collection of personal information from publicly available websites to include in our workforce database. We use and disclose this information in the course of internal and external projects as well as broader workforce research efforts.

This Privacy Policy does not apply to information that we process as a service provider to our customers. If you have questions about the information practices of our customers, please review their privacy policy or contact them directly.

Information We Collect About You & How We Collect It

We may collect personal information about you when you use the Services or otherwise interact with Us. The information we collect generally falls into three categories: (a) information you provide Us directly; (b) information we collect automatically; and (c) information we receive about you from others.

Information You Provide to Us Directly

The personal information you provide depends on the nature and context of your interactions with us. When you use the Services or otherwise interact with us, you may be asked or otherwise choose to provide information to us directly. This information may include:

• Personal and contact details such as your name, email and postal addresses, telephone number.
• Demographic information such as your date of birth, age, and gender.
• Responses to surveys, if you participate in surveys that we commission or administer.
• Entry information, if you enter a contest or sweepstakes that we offer.
• Other information that you choose to provide to us when you use the Services, such as when you fill out contact forms on the Websites.

If you use the Services to apply for a job with us, we will collect information that you provide in pre-qualification questionnaires that you submit through our Websites, and information included in other materials that you submit as part of your application, including as may be included on your resume and application form. This information may include your personal and contact details and information about your professional qualifications, work history, and educational background.

Information We Collect Automatically

As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Services, including traffic data, location data, and other communication data and the resources that you access and use on the Services.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• Usage and clickstream information, which may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information about your use of the Services.
• Location information, such as your approximate geographic location based on your IP address.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services. The information we collect automatically may include personal information and we may maintain it or associate it with personal Information we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the Services according to your individual interests.
• Recognize you when you return to the Services.

The technologies we use for this automatic data collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on the hard drive of your computer or your mobile device. You may refuse to accept cookies by activating the appropriate setting on your browser or device. However, if you select this setting you may be unable to access certain parts of the Services.
• Flash Cookies. Certain features of our Websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of our Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that enable us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Information We Receive from Third Party Sources

We may receive personal information about you from other sources. For example, this may include receiving personal information from:

• Professional network or job posting sites.
• Our business partners and service providers, including data aggregation and analytics vendors.

Professional profiles, resumes, and CVs received from third party providers may include related personal information such as your name, education, professional qualifications, work history, work title, and work experience that is available on publicly accessible websites. We use this information for our workforce analytics services program described above.

How We Use Your Information

We use information that we collect about you or that you provide to us for the following purposes:

• To provide, maintain, administer, or expand the Services.
• To perform business analyses or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer.
• Recruitment and hiring purposes, including evaluating and processing your employment application.
• To perform obligations pursuant to contractual terms you have accepted, such as our terms and conditions.
• To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Services.
• To respond to your comments, questions, and requests, and provide customer service.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To protect the security and integrity of the Services, ourselves, or others.
• To investigate possible fraud or other violations of our contract terms or this Privacy Policy and/or attempts to harm our users.
• To evaluate or facilitate a business transfer, such as to a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets to be transferred.
• For any other purpose that is disclosed to you at the point of collection of the personal information, for any purpose for which you provide your prior consent.
• As otherwise requested or directed by you.

Except where prohibited by applicable law or regulation, we may combine information collected through one source with information obtained through other resources. We also may supplement the information we collect with information obtained from third parties. This may include information collected offline with information we collect through the Services.

We may also collect, or use personal information that we have collected to create, aggregated or de-identified data that does not identify and cannot reasonably be used to identify you or a device linked to you. We will maintain and use the such aggregated de-identified data without attempting to re-identify the data, and it may be used and disclosed for any lawful purpose.

How We Disclose Your Information

We may disclose the categories of personal information that we collect or you provide as described in the Information We Collect About You and How We Collect It section of this Privacy Policy to the following categories of third parties:

• To our vendors, consultants, contractors, and other service providers who access personal information to carry out work on our behalf and improve the products and services they provide to us (e.g., companies that assist us with data collection, web hosting, fraud prevention, analytics, marketing and advertising).
• To comply with applicable law, other legal requirements, and industry standards.
• To enforce our policies, terms of use, contracts, or other legal rights.
• To investigate or prevent unlawful activities or misuse of the Services.
• To protect against malicious, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements for such activity.
• To operate, evaluate, debug, identify and repair errors, and improve our Services and offerings.
• To an actual or potential buyer, successor, or other organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.
• To our current or future parents, affiliates, subsidiaries and other companies under common control and ownership.
• To such other parties as you may authorize.

We may also publish summaries of aggregate and de-identified information for our customers, created from information collected through the Services.

Data Retention

Our retention periods for personal information are based on business and legal requirements. We retain personal information as is necessary for the processing purpose(s) for which the personal information was collected and any other permissible, related purpose, and as permitted or required by the applicable laws. For example, if you register on our Services, we will store your information for as long as needed to maintain your account, provide you the Services or other functionality as you request it, enforce any applicable terms that govern your use of the Services, and maintain appropriate records to reflect our delivery of Services to you.

Your Choices and Rights

You may choose not to provide the personal information we request through the Services. However, not providing information we request may restrict your ability to use certain features of the Services.

Similarly, you may also be able to restrict the collection of personal information through the Services through your device’s operating system or by disabling cookies, but doing so may prevent you from using the functionality of the Services. Some Internet browsers have a “do-not-track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, the Services do not respond to browser “do-not-track” signals.

For information about interest-based advertising, and to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative (NAI) opt out tool (https://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (DAA) Self-Regulatory Program for Online Behavioral Advertising (https://youradchoices.com/), or, for users in Europe, the EDAA’s opt-out page (https://youronlinechoices.eu/). Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may continue to receive advertising, but that advertising may be less relevant to your interests.

You can opt-out of receiving certain promotional or marketing communications from us at any time by using the unsubscribe link in the emails communications we send. Please note that if you have an account with us and you opt out of receiving promotional and marketing related communications from us, we may continue to send you non-promotional communications, e.g., service-related emails.

Depending on where you reside, you may have the following privacy rights related to the personal information that we collect:

• Right to Know: Request that we disclose what personal information we have collected, used, disclosed, sold, or shared about you, and how it is used and disclosed;
• Right to Data Portability: Receive your personal information in a structured, commonly used, and machine-readable format, to transfer this information to another data controller;
• Right to Delete: Request that we delete the personal information we have collected from you (with some exceptions) and that our service providers do the same;
• Non-Discrimination: Not to receive discriminatory treatment for the exercise of your privacy rights under applicable law;
• Right to Correct: To request we correct the inaccurate personal information that we have about you;
• Right to Restrict Processing: To request that we restrict the processing of your personal information;
• Right to Object: To object to the processing of your personal information on certain grounds; and
• Right to opt-out of sale/sharing/targeted advertising: To opt-out of the “sale,” “share,” or use of your personal information for targeted advertising.

To exercise your options as described in this Privacy Policy, you may contact us by submitting this form or by emailing [email protected]. To protect personal information about you from unauthorized access or deletion, we may require you to verify your identity before we can process a privacy request related to your personal information. If we cannot verify your identity, we may be unable to comply with your request to provide, correct, or delete your personal information.

Third-Party Websites and Services

The Services may reference or provide links to websites and online services operated by unaffiliated third parties with which we do business. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, their security or privacy practices. You access these third-party services at your own risk. This Privacy Policy does not apply to any third-party services; please refer to the privacy notices or policies for such third-party services for information about how they collect, use, and process personal information.

Children

We do not knowingly collect personal information from children under 18. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

How We Protect Your Information

We maintain safeguards that are reasonably designed to protect the information collected through the Services. Please note, however, that we cannot and do not guarantee the security of your information, as no method of data storage or transmission is 100% secure.

Data Transfers

McChrystal Group is headquartered in the United States, and we process and store the information we collect from you, regardless of your location, in the U.S. If you are based outside the U.S., we transfer your personal information to, and process your personal information on, servers located in the U.S., a jurisdiction that may not provide equivalent levels of data protection as your home jurisdiction. By reference to the section headed “How We Disclose Your Information” above, your personal information may also be transferred to, stored, and processed in the U.S. or other jurisdictions where the third parties are located or from which the third parties provide us services. Such transfers and processing of your personal information are necessary to provide our Services. By submitting your personal information to us, you understand and consent to the transfer of such information as described above.

Changes to this Privacy Policy

We will make changes to this Privacy Policy from time to time and may not provide notice of material changes. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically reviewing this Privacy Policy to check for any changes.