At Management & Technology Consulting Services Pte. Ltd. (‘MTCS’), we take the security of your Personal Data seriously and want you to be familiar with how we collect, use and disclose your Personal Data. This Privacy Policy (the ‘Privacy Policy’) describes our privacy practices regarding the collection, use and cross country transfer of Personal Data collected by MTCS. In this Privacy Policy, “Personal Data” refers to any data, whether true or otherwise, about an individual who can be identified (i) from that data; or (ii) from that data and other information to which the organisation has or is likely to have access.

By interacting with us, submitting information to us, enrolling or signing up for any products or services offered by us, you agree and consent to MTCS as well as their respective representatives and/or agents (‘Representatives’) collecting, using, disclosing and sharing amongst themselves your Personal Data and disclosing such Personal Data to MTCS’s authorised service providers and relevant third parties in the manner as set out in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consent you may have previously provided to MTCS in respect of your Personal Data and your consents herein are additional to any rights which any of MTCS may have at law to collect, use, and/or disclose your Personal Data.

This Privacy Policy may be updated from time to time to ensure consistency with MTCS’s future development, industry trend and/or any changes in legal and/or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on our website www.mtcsglobal.com. Please check regularly for updated information on our Privacy Policy.

MTCS collects your Personal Data (including but not limited to name, e-mail address and physical address) in the following manner:

• When you interact with us or provide information in respect of your interaction with us. For example, when you register to use our electronic system, submit or build a resume, respond to employment opportunities, answer online assessment questions, participate in online courseware, provide information about yourself to our representative or contact us via e-mail or postal mail.
• When you request that we contact you, be included in an e-mail or other mailing list, or when you respond to our request for additional Personal Data, our promotions and other initiatives.
• When you are contacted by and/or respond to our marketing representatives and agents
• When we seek or receive your Personal Data from third parties. For example, when a fellow assessment or coaching participant provides information about you, when co-branded organisations enter information to create an Executive Center, when a colleague recommends that we consider you for a position or from other sources such as public databases, joint marketing partners and social media platforms.
• When you submit your Personal Data to us for any other reasons.

We may use one or more third-party vendor(s) (‘Vendor’) to handle the sale of our books, assessments, other products and event registration. If you wish to purchase a product or register for an event, you may be directed to a webpage that is hosted by the Vendor (or its service providers) and not by MTCS (such page, the ‘Vendor Page’). Any personal information that you provide through the Vendor Page will be collected by the Vendor and not by MTCS, and will be subject to the Vendor’s privacy policy, rather than this Privacy Policy. MTCS has no control over, and shall not be responsible and/or liable for, the Vendor’s use of information collected through the Vendor Page. Please note that this Privacy Policy does not address the collection and use of Personal Data through the Vendor Page or the privacy or information practices of the Vendor.

If you submit any Personal Data relating to other people to us or to our service providers, you represent and warrant to us that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We use the information we collect in support of any products or services offered by us. The following paragraphs describe some of the ways in which we may use your Personal Data:

Fulfilling your requests

We may use your Personal Data to respond to your inquiries and fulfil your requests. If you contact us, we may keep a record of your contact information and correspondence, and we may use any information you provide in your message to respond to your inquiry.

Business purpose

We may use your Personal Data for our business purposes, such as audits, internal communication regarding candidates and clients, determining the effectiveness of our promotional activities, administering our products and services, maintaining and securing our infrastructure, and for procurement and financial transactions.

Informational communications

MTCS may from time to time send informational e-mails, articles, white papers, proposals, engagement letters, and other information regarding our products and/or services. Occasionally, and with your consent, we may use your Personal Data in press releases and direct marketing materials. We also may use your Personal Data such as e-mail or postal addresses to conduct surveys.

Administrative information

We may from time to time use your Personal Data to send you important information regarding our products and/or services, changes to our terms, conditions, and policies and/or other administrative information. We may also contact you from time to time to verify that your Personal Data that we have collected is accurate and current.

Other activities

In addition, we may use and disclose your Personal Data to enhance the provision of our products and/or services including but not limited to the following:

• Additional activities. In the course of providing our products and/or services, we use personal information that we have collected concerning candidates to identify professional opportunities that we think may be of interest. We may contact potential candidates from time to time regarding such opportunities. We also may contact individuals from time to time to solicit names of, or other personal information regarding, potential candidates in connection with a search that we are conducting and for purposes of market intelligence.

We also use personal information to confirm references and conduct education and background checks, as appropriate. We may further use personal information that we collect for purposes of aggregating and disclosing diversity statistics and other statistical information regarding our candidates and placement activities.

• Additional activities for our services. In the course of providing our services to our clients, we may use your Personal Data which we have collected through assessments that we have conducted on you.

Analytics

We may retain and use information about you, which may include, for example, your personal information, for research, publication, development, benchmarking and norms, validation, longitudinal studies, trend analysis and to improve and enhance our products and/or services or develop and market new products and/or services.  Any published end product may or may not refer only to larger aggregations of individuals and will not identify you personally or include any results attributable to you.

Key-coded data

We may key-code your personal information, meaning that such information is stripped of all information that may identify you (direct identifiers) and replaced by a key-code to minimise unwanted or unintended identification. Such key-coded information can be de-coded by the use of the key so that it identifies you again. We may use such information for the purposes described in the paragraph above entitled “Analytics” and as permitted by applicable law. Any published end product may or may not refer only to larger aggregations of individuals and will not identify you personally or include any results attributable to you.

De-identified data

Additionally, we may aggregate (anonymise) or de-identify personal information in such a manner that the end-product does not personally identify you or any other individual, for example, to generate norms by industry, geography, level, etc., enable us to conduct ongoing validation studies, compile reports, and publish journal articles to further the knowledge base of organisational and leadership science. Such aggregate or de-identified information is not considered personal information for purposes of this Privacy Policy and we may use it for any purpose.

Disclosure to clients

In the course of providing our products and/or services, we may disclose your Personal Data to clients who have acquired our products and/or engaged our services:

• In the course of providing our products and/or services, MTCS may disclose assessment and other information to the employer/client that has engaged MTCS and to designated client personnel. Assessment and other personal information collected by our consultants or provided by our client may be maintained in such database and/or platform which MTCS considers to be suitable in its sole discretion whereby our clients and/or certain personnel designated by our clients, will have access both during and after the conclusion of our engagement. If you take our assessments, we will not use your assessment reports in the provision of our products and/or services without your consent.
• In the course of providing our products and/or services, we may provide Personal Data regarding candidates, including the results of assessments to prospective employers that have engaged MTCS to fulfil search requests, or to reference sources.

Disclosure to MTCS companies

Subject to the provisions of any applicable law, your Personal Data may be provided to MTCS’s related corporation. Further, from time to time MTCS may also disclose your Personal Data to our network of independent consultants who provide Services on behalf of MTCS for the purposes stated above.

Disclosure to service providers

MTCS works with third parties, who provide services that may include, but are not necessarily limited to website hosting and IT support and consulting services; data analysis; resume verification; background checking; payroll services; public relations services; attorneys, accountants, and other administrative and back-up and security services. As part of providing those services, such third parties will be provided with access to your Personal Data. In addition, our software development partners may use your Personal Data for purposes of modifying, improving, refining and validating their technology and research and development.

Business transfers

MTCS reserves the right to disclose or transfer any and all personal information that we have collected from visitors, or that we otherwise collect in connection with our Services, to a third party, or in the event of a sale of our company or one of our affiliates, or a merger or consolidation involving our company or one of our affiliates, or a sale or transfer of assets or of any portion of our business or the business of one or more of our affiliates.

Other disclosures

MTCS may also use or disclose personal information in order to: (i) comply with applicable laws and regulations; (ii) respond to inquiries or requests from public or government authorities, including those outside of your country of residence; (iii) comply with valid legal process; (iv) protect the rights, privacy, safety or property of MTCS, users of the Online Systems or the public; (v) permit us to pursue available remedies or limit the damages that we may sustain; (vi) enforce our Legal Disclaimer; (vii) enforce our Terms and Conditions of Service; or (viii) respond to an emergency. We cannot and do not assume any responsibility for the actions or omissions of third parties, such as clients, including the manner in which they use personal information received either from MTCS or from other independent sources.

MTCS collects other information that does not reveal your specific identity (‘Other Information’), such as:

• Information collected through cookies, pixel tags and other technologies;
• App usage data;
• Demographic information and other information provided by you; and
• Aggregated information.

Since Other Information does not reveal your specific identity, we may use it for any purpose. If we combine any Other Information with your Personal Data (such as combining your name with your location), we will treat the combined information as your Personal Data.

We and our third-party service providers may collect Other Information in a variety of ways, including:

Using cookies

We use ‘cookies’ — that is, small text files placed on a visitor’s computer hard drive — and other technologies to help us determine information such as the type of content to which a visitor to our website links, and the length of time each visitor spends at any particular area of our website. MTCS cookies are only read by MTCS servers and are unable to execute any code or virus. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalise your experience while using our website, products and/or services, as well as for tracking purposes. We also gather statistical information about the usage of our website, products and/or services, in order to continually improve the design and functionality, understand how our website, products and/or services are used and to assist us with resolving questions regarding our website, products and/or services.

You can configure your browser settings to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. However, if you do not accept these cookies, you may experience some inconvenience in your use of our website, products and/or services. For example, we may not be able to recognise your computer and you may need to log in every time you visit our website, products and/or services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

Using pixel tags, web beacons, clear GIFs or other similar technologies

These may be used in connection with some of our web pages and HTML-formatted email messages to, among other things, track the actions of the users of our website and email recipients, measure the success of our communications and compile statistics about usage of our website and response rates.

Using Adobe Flash technology (including Flash Local Shared Objects (‘Flash LSOs’)) and other similar technologies

We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of our website, products and/or services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs, how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Online Systems.

Tracking data

MTCS monitors visitor traffic patterns throughout our website by logging ‘Tracking Data’, which is collected automatically from each visitor to our website. Tracking Data may include your ‘IP Address’ which is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP), as well as your browser type and operating system, the referring website, which page of our website that you have visited, the order in which they were visited and which hyperlinks were ‘clicked’.

MTCS uses Tracking Data in aggregate form to perform statistical analyses of the collective characteristics and behaviour of our visitors, and by measuring demographics and interests regarding specific areas of our website.

Physical location

We may collect the physical location of your device by, for example, using satellite, cellphone tower or Wi-Fi signals. We may use your device’s physical location to provide you with location-based services and content. In some instances, you may be able to allow or deny collection of your device’s location, but if you choose to deny such collection, we may not be able to provide you with the applicable location-based services and content.

From you

Information such as your preferred means of communication is collected when you voluntarily provide this information. Unless combined with your other Personal Data, this information does not personally identify you or any other user of our website, products and/or services.

By aggregating information

Aggregated personal information does not personally identify you or any other user of our website, products and/or services. For example, we may aggregate information to calculate the geographic distribution of participants in our website, products and/or services.

MTCS may from time to time sponsor special features or promotions on the website and additional privacy information may be posted. That privacy information, to the extent it conflicts with this Policy, will govern that particular feature or promotion.

Your provision of personal information to us is voluntary, although if you do not provide certain personal information you may not be able to participate in our website, products and/or services.

You may contact us at contact@mtcsglobal.com if you wish to receive certain information as to whether or not personal information relating to you is held by us and to obtain a copy of such information.

If you would like to: (i) ask questions about how we handle personal information; (ii) review, correct or update your personal information; or (iii) request that your personal information be removed from MTCS’s database, please contact us at contact@mtcsglobal.com. Please note that we are only able to provide you with a non-confidential summary of our final assessment report, since such report contains confidential client information that we are not allowed to disclose. You may request to be removed from MTCS’s database by putting ‘Remove User’ in the subject line of the e-mail, and including your full name and telephone number in the body of the e-mail message.

We will aim to comply with your request as soon as reasonably practical, and may need to contact you in order to be sure that we are deleting the appropriate information. Please note that we cannot be responsible for removing your information from our database if that information is part of our products and/or services commissioned by your company. In that case, your request may need to be directed to your company’s management. We will, however, forward your request to the appropriate person at your company.

We also may need to retain certain information about you, such as your e-mail address, in order to honor opt-out or similar requests. Please keep in mind that this residual information will remain within MTCS’s databases, access logs and other records, which may or may not contain personal information about you. The residual information will not be used for commercial purposes. However, MTCS reserves the right, from time to time, to contact former users of our website, products and/or services.