# GENERAL PRIVACY STATEMENT

#### 1. Introduction

LHH Recruitment Solutions, Inc. (“LHH,” “we,” “us,” “our”)  is committed to protecting the privacy of individuals using our website in the United States. This Privacy Statement outlines how we collect, use, disclose, and protect personal information when you interact with our website. We comply with applicable privacy laws and regulations in the United States, including the California Consumer Privacy Act (CCPA) and other relevant state and federal privacy regulations.

This Privacy Statement does not address the handling of personal information in any other relationship you may have with LHH. For details on how personal information is processed in those contexts, please refer to the applicable privacy policy which supplements this Privacy Statement.

#### 2. What Personal Information We Collect

We may collect:

- **Basic Identifiers**  
  (name, email, phone, address)

- **Employment & Career Data**  
  (resume, work history, skills, references)

- **Assessment & Coaching Data**

- **Usage Data:**  
  (IP address, device info, browser type, cookies)

- **AI-Based Recommendations**  
  (processed with human oversight)

We do not collect sensitive information unless required by law or with explicit consent.

#### 3. How We Collect Personal Information

We collect personal information:

- **Directly from you:**  
  When you apply for jobs, submit your resume, or use our coaching services.

- **Automatically via cookies:**  
  To enhance your website experience (see the Cookies section below)

- **From third parties:**  
  Such as recruiters, job boards, reference providers, and employer partners.

#### 4. How We Use Your Information

We process personal information in compliance with applicable privacy laws and regulations for:

- To provide and improve our services
- To personalize your experience
- For analytics and marketing (with your consent)
- To comply with legal obligations

#### 5. Data Sharing & International Transfers

We only share data when necessary and with appropriate safeguards in place.

**Who We Share Data With:**

- **Employers & Recruiters:**  
  For job matching and career coaching opportunities when the services you request require it

- **Members of The Adecco Group:**  
  For IT functions and to propose offers adapted to your profile

- **Regulatory Authorities:**  
  When required by law

- **Prospective Sellers or Buyers:**  
  When required as part of due diligence

- **Third-Party Providers:**  
  For website support and functionality.

**Overseas Data Transfers:**  
If your personal data is transferred outside the United States, we will ensure that the recipient provides a standard of protection that is at least comparable to the requirements under applicable privacy laws, including through contractual agreements or other legally permissible mechanisms.

#### 6. Data Retention

We retain personal information only as long as necessary under GDPR:

- **CT/LD/Ezra Candidate record:**  
  Up to 3 years unless otherwise required.

- **Job applications & resumes:**  
  12-24 months unless otherwise required.

- **Leadership assessments & coaching records:**  
  Up to 5 years.

- **Website logs & analytics:**  
  Retained for site security and improvement for up to 12 months.

- **Contact Forms and surveys:**  
  Retained for up to 2 years after the last contact.

#### 7. Your Rights

Under GDPR, you have the right to:

- **Access your personal information:**  
  Receive a copy of the data we hold.

- **Request correction:**  
  Update or correct your information if it is inaccurate or outdated.

- **Opt out of marketing communications:**  
  At any time.

- **Request deletion of your personal information:**  
  Subject to legal and business requirements.

- **Right to Restrict or Object:**  
  Obtain restriction or object to certain processing.

- **Right to Withdraw Consent:**  
  Withdraw consent at any time, affecting future processing.

#### 8. Cookies & Tracking Technologies

We use cookies and similar technologies for website functionality, analytics, and marketing.

- **Essential Cookies:**  
  Necessary for website security and functionality.

- **Analytics Cookies:**  
  Help us improve site performance (opt-out available).

- **Marketing Cookies:**  
  Used for targeted job recommendations (optional, requires consent).

#### 9. Security Measures

We implement reasonable security measures to protect your personal information, including:

- **Encryption:**  
  For secure data transmission

- **Access Controls:**  
  To restrict unauthorized access

- **Regular Audits:**  
  To ensure AI systems do not introduce bias and to maintain compliance with applicable privacy laws

#### 10. Automated Decision-Making Transparency

Transparency in Automated Decision-Making We are committed to transparency in our use of automated decision-making processes. While we leverage AI technologies to enhance our services, all AI-generated recommendations are reviewed by a human before any decisions are made.

#### 11. AI Fairness Statement

We are dedicated to ensuring fairness, accountability, and transparency in our AI-driven processes. Our AI systems are designed to minimize bias and are regularly audited to ensure they operate within ethical guidelines.

**Use of Artificial Intelligence to Support Our Business:**  
We use AI to enhance our services while maintaining high standards of privacy, ethics, and transparency.

- **Use of AI in our business:**  
  - **Automated Customer Service:** AI-driven chatbots provide immediate responses to FAQs, guide users to resources, and hand over to human support when needed.
  - **Automated Task Nudging:** AI systems send automated reminders to help users complete tasks, enhancing productivity and engagement.
  - **Data Analysis and Reporting:** AI analyzes large data volumes to generate insights for business strategies and decision-making.
  - **Identification of Emerging High-Demand Roles:** AI identifies high-demand roles that match job seekers' interests and experience by analyzing market trends and user data.
  - **Document Management:** AI improves document management by organizing, categorizing, and retrieving documents efficiently.
  - **Meeting Transcription and Summarization:** AI tools transcribe and summarize meetings accurately.
  - **Document Drafting:** AI supports document drafting and revision, enhancing speed and accuracy.
  - **Content Creation:** AI generates content that aligns with executives' styles and voices, ensuring consistency and authenticity.

#### 12. Changes to this Privacy Notice

The terms of this Privacy Notice may change from time to time. We shall publish any material changes to this Privacy Notice through appropriate notices either on this Website or by contacting you using other communication channels.
