Privacy Statement

Introduction

Keystone Partners (“we”, “our”, “us”) is committed to protecting the privacy rights of all persons with whom it deals on its website and services controlled by Keystone Partners where this Privacy Statement is provided (“Sites”). To demonstrate its commitment to your privacy, Keystone Partners has made its information and privacy practices available in this Privacy Statement.

Our Sites may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them. This Privacy Statement sets forth the online data collection and usage policies and practices that apply to the Sites including notification about:

  • Any personal information of yours or third-party personal identification that is collected from you through the Sites.
  • How your personal information is used.
  • With whom your personal information may be shared.
  • What choices and rights are available to you regarding collection, use and distribution of your personal information.
  • The kind of security procedures that are in place to protect the loss, misuse, or alteration of information under the control of Keystone Partners.
  • How you can correct any inaccuracies in the information.

If you have questions or concerns regarding the privacy of your personal information, please write to Keystone Partners’ Privacy Officer at dataprivacy@keystonepartners.com or call 617-720-7300.

Consent

By using the Keystone Partners’ Sites at https://www.keystonepartners.com, https://www.essexpartners.com, and https://kparchde.force.com you consent to the policies and practices described in this Privacy Statement. If you provide personal information in your capacity as an employee, you represent that you bind your employer to this Privacy Statement.

What is Personal Information?

Personal information is information relating to an identified or identifiable individual. (e.g., name, email address, mailing address, phone number, credit card number).  Personal information is considered information that is (1) recorded in any form; (2) is about, or pertains to, a specific individual; and (3) can be linked to that individual.

Personal information is collected by Keystone Partners when you use our Sites or choose to receive information or services from Keystone Partners or its affiliated partners. You will be informed that your personal information is being collected, the purpose for which it is being collected and that you have a right of access to the information.

We may also receive personal information from our business associates and other third parties provided that such third parties confirm to us that they have obtained your consent to the disclosure of your personal information.

Information We Collect

We collect personal information, such as your name, street address, email address, job title, employment information, employer, and phone number, and other information that would be related to the delivery of the services we are providing.

Keystone Partners uses the information we gather on the Sites, whether personal, demographic, collective or technical, for the purpose of operating and improving the Sites, fostering a positive user experience, and delivering the products and services available from Keystone Partners or its affiliated partners. Keystone Partners uses the information for:

  • Monitoring information to ensure compliance with Keystone Partners policies;
  • Editorial and feedback solicitation purposes;
  • Establishing and maintaining communication, including marketing, advertising, and other beneficial services; and,
  • Compliance with federal, state, provincial or municipal laws.

Sites are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18.

Demographic and profile data is collected at our site. We use this data to tailor our visitors’ experience at our Sites, showing them content that we think they might be interested in, and displaying the content according to their preferences.

Your personal information is required for:

Registration

When you register for services using any of the Sites, Keystone Partners will request personal information from you, including your name and email address. Some of the information requested from you during registration is optional and is clearly identified on the Sites.

Information collected by Keystone Partners as part of the login/registration is NOT made accessible to the public, other users of the site or anyone not employed by Keystone Partners directly. This information is held in strict confidence and can be removed at your request at any time.

Your personal information is used to communicate with you about your account and to provide you with information related to Keystone Partners services. We may use your contact information in order to send you email or other communications regarding updates to the Sites, such as new career opportunities which may be of interest to you. The nature and frequency of these messages will vary depending upon the information we have about you.

You have the option to elect to receive additional communications, and information including without limitation free informational newsletters from Keystone Partners relating to topics that may be of special interest to you. You always have the option, however, to tell us not to share your personal information with other Keystone Partners Companies or to exclude you from offers for other products or services.

My Account

Personal contact Information is collected (e.g., First Name, Last Name, Address, Home Phone, Work Phone, Email Address, Fax number, and other information that would be related to the delivery of the services we are providing). You can choose to make this information visible to public in your resume or you may choose for this information to remain private.

Email Messages / Feedback

When you send us messages via email, we will use your name and email address only to respond to the concerns you write to us with. Your email may be shared with appropriate people within the Keystone Partners organization to help us respond to your concerns and improve the services we provide.

We have an area where you can submit feedback. Any feedback you submit in this area becomes our property, and we can use such feedback (such as success stories) for marketing purposes, without attribution, or contact you for further information and release.

Online Forums

Please remember that any personal information that is disclosed in public areas of the Sites becomes public information. We recommend that you exercise caution when deciding to disclose any personal information, as it could be collected and used by others over whom Keystone Partners has no control. We are not responsible for the use made by third parties of information you post or otherwise make available in public areas of the Sites.

SMS Text Terms and Conditions

By providing your contact information or confirming the use of our services, you are opting into communications by email, text and/or phone.

Keystone Partners uses mobile phone numbers as a way to communicate to eligible participants of our services. Such communication may include program information, details of our services and the assignment of a consultant. We also utilize SMS/MMS messaging for appointment reminders. 

When opted-in, you will receive text messages (SMS/MMS) to your mobile number. These kinds of messages may include, but are not limited to, appointment reminders or other information related to Keystone Partners service offerings. You can opt-out of this service at any time by simply replying “STOP” to the message. After you text “STOP” to us, you will receive a final SMS reply to confirm that you have successfully unsubscribed, and you will no longer receive SMS messages from us. To reinstate text message communications, text “START”.

Carriers, such as Verizon or AT&T, are not liable for delayed or undelivered messages. Message and data rates may apply for any messages sent to you from us and to us from you. Message frequency will vary. If you have any questions about your text plan or data plan, please contact your wireless provider.

Information Supplied by Your Browser / Use of Cookies

We collect cookies on our websites and use Google Analytics for aggregate data. A cookie is a text file that is placed on your hard drive to collect information about your activities on a website. “Cookies” give us an idea of which parts of our site users are visiting. For example, if you personalize Keystone Partners pages, or register for services, a cookie helps you to recall your specific information (e.g., your username, password, and preferences). When you return to the Sites, the information you previously provided can be retrieved, so you can easily use the features that you customized. We use this information only as anonymous aggregate data to determine how many people visit our site, which features are used most frequently, and which browsers are primarily used. We do not use it to track or record information about individuals. This information assists us in diagnosing problems with our site and helps us deliver a better overall experience for you and other visitors.

Many consumers do not know that “cookies” are being placed on their computers when they visit websites. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer and can usually only be read by the web server that issued the cookie to you.

Most browsers are initially set up to accept cookies. If you want to know when this happens, or to prevent it from happening, you can set your browser to warn you when a website attempts to place a “cookie” on your computer. You can also delete cookies on our websites. Accepting cookies is voluntary; however, if you decline cookies, you may not be able to use some features of the Keystone Partners Websites.

For more information on our Cookie Policy, see here.

How We Respond to Do Not Track Signals

The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them.

How We Share Your Data

Keystone Partners may make aggregate information about our users available to third parties for the purposes of marketing, advertising, and other beneficial services. The information gathered on the Sites may be shared within Keystone Partners and its affiliated partners acting on our behalf, who are subject to confidentiality agreements.

If you choose to provide personal information to us, we will use and disclose it as described in this Privacy Statement.

Prior to disclosing Personal Information to a third party, Keystone Partners will notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure.

To enable us to more efficiently provide the services you have requested from us, Keystone Partners may share aggregated anonymous information about visitors to the Sites (for example, the number of visitors to the Sites) with its clients, agents and other third parties so that they may understand the kinds of visitors to the Sites.

We may disclose your personal information to other Keystone Partners companies, agents, contractors, service providers, and individuals we employ to perform functions on our behalf. Only the information necessary to perform a specified business function will be disclosed (e.g., to provide career assistance, host our web servers, or provide customer service). These companies and individuals will have access to your personal information only as necessary to perform their functions and are subject to strict terms of confidentiality.

In other circumstances we may be required or authorized by law to disclose the information you provide. Though we make every effort to preserve user privacy, we may need to disclose personal information if legally required to do so, if requested to do so by a governmental entity or if we believe in good faith that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect the rights or property of Keystone Partners or its affiliated partners; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.

Keystone Partners may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

How and Where We Store Your Data, Consent to Transfer

We only keep your personal information for as long as we need to provide the services you have requested and/or as long as permitted under applicable law.

If you are visiting our Sites from a location outside of the U.S., your connection may be through and to servers located in the U.S. Any information you provide during your visit will be processed and maintained on our server and other internal systems located within the U.S. You acknowledge you understand that by providing your personal information to us, your personal information (i) will be used for the uses identified above in accordance with this Privacy Statement, and (ii) may be transferred to the U.S. as indicated above, in accordance with applicable law. For example, where personal information is transferred from the European Economic Area or United Kingdom to areas which have not been determined to have an adequate level of protection, we take measures designed to transfer the information in accordance with lawful requirements, such as standard contractual clauses or the international data transfer agreement.

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Security

Keystone Partners will take reasonable steps to protect your information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. We have put in place physical, electronic, and managerial procedures to safeguard and secure the information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure due to the inherent risks of data transmission over the Internet. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you understand that any information that you transfer to us is done at your own risk. If we learn of a security system breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Sites or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Sites. We may post a notice via our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Your profile has a password so that only you can access it. We recommend that you do not provide your password to anyone. You are responsible for maintaining the secrecy of your account information and all activities that occur under your account. If you share a computer with someone else or are using a computer in a public location, remember to sign out and close your browser window when you have finished to ensure that others cannot access your personal information.

Data Integrity and Purpose Limitation

Keystone Partners will only process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

Lawful Bases

We collect and use personal information when we have a lawful basis to do so, as follows:

  • Consent. We may process personal information with the consent of the individual whose data is being processed and/or in reliance upon the consent of the administrator of the account, who must affirm that s/he has obtained appropriate consent from all participants.
  • Contract.  When we enter into a contract with you and/or an administrator for your account, we process personal information on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract. This is necessary for us to provide the Websites to you.
  • As required by law.  We may process personal information as required to comply with legal obligations to which we are subject for the for the purpose of compliance with EEA, UK, or Swiss public, governmental, judicial, or other regulatory authorities.
  • For legitimate business purposes. This includes but is not limited to legal compliance and the purposes described in this Privacy Statement.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If there is any change in the purposes for which we collect your personal information, we will inform you of such change. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purposes, please contact us through the contact methods provided at the end of this Privacy Policy.

Data Rights

Depending on your residence, the rights available to you may differ in some respects. We will respond to any rights request in accordance with local legal regulations. If you wish to make a request regarding any of the below rights, please contact our Privacy Officer at dataprivacy@keystonepartners.com or call 617-720-7300

Right of Access

You may have the right to get confirmation about whether your personal information is being processed. If so, you have the right to access the personal information and other information, such as the purposes, the categories of personal information, the recipients (or categories of recipients) to whom the personal information have been or will be disclosed – our list of service providers who may receive your personal information can be obtained by contacting the Privacy Officer at dataprivacy@keystonepartners.com or call 617-720-7300, for particular recipients in third countries or international organizations, where possible, the predicted period that the personal information will be stored, or, if not possible, the criteria used to determine that period, your rights, etc.

Where feasible and permitted by law, we will provide a copy of the personal information we are processing. For any further copies, we may charge a reasonable fee based on administrative costs. If you make the request by electronic means, and unless otherwise requested, the information shall be provided in electronic form.

Right to Rectification

You may have the right to rectify or complete your personal information if inaccurate or incomplete.

Right to Erasure (‘right to be forgotten’)

You may have the right to the erasure of your personal information in certain circumstances. For examples, see below:

  • Your personal information is no longer necessary for the purposes for which it was processed
  • You withdraw your consent on which the processing is based, and we have no other legal ground for the processing
  • You object to the processing and there are no overriding legitimate grounds for the processing
  • Your personal information has been unlawfully processed
  • Your personal information has to be erased for compliance with a legal obligation to which we are subject

This right shall not apply to the extent that processing is necessary for the below purposes.

  • For exercising the right of freedom of expression and information
  • For compliance with a legal obligation which requires processing by a law to which we are subject
  • For the performance of a task carried out in the public interest
  • For the establishment, exercise, or defense of our legal claims

Right to Restriction of Processing

You may have the right to restrict the processing for the below reasons:

  • You contest the accuracy of your personal information, for a period enabling us to verify the accuracy of the personal information
  • The processing is unlawful, and you oppose the erasure of the personal information and request the restriction of their use
  • We no longer need the personal information for the purposes of the processing, but they are required by you for the establishment, exercise, or defense of legal claims
  • You exercised your right to object to processing pending the verification whether our legitimate grounds override yours

Right to Data Portability

You may have the right to receive the personal information that you have given us, in a structured, commonly used, and machine-readable format. You have the right to send that personal information to another controller if the processing is based on consent pursuant or on a contract and is carried out by automated means.

Right to object

You may have the right to object, on grounds relating to your particular situation, to processing of your personal information which is based on our legitimate purposes. We will stop processing the personal information unless we have compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims. If personal information is processed for direct marketing purposes, including profiling, you may object at any time.

Automated Individual Decision-Making, including Profiling

You may have the right not to be subject to a decision based solely on automated processing, including profiling, except under certain exceptions under local law.

Right to Withdraw Consent

Where the processing of personal information is based on your consent, you may have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.

Right to Anonymity

You may also have a right to request anonymity. This means that your personal information would not be collected or processed. If you choose to exercise this right, we may not be able to provide you with your requested goods or services.

Right to lodge a complaint with a supervisory authority

We are committed to working with you in the event that you have a complaint of concern about privacy. If you need help lodging a complaint, you can contact us through the contact methods provided at the end of the Privacy Policy. You may also have the right to lodge a complaint with a supervisory authority.

Change in Business Ownership

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal information that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Statement, be permitted to use that data only for the same purposes for which it was originally collected by us.

Links to Other Sites

This Privacy Statement applies solely to the information we collect on the Sites and does not apply to information we collect in any other fashion.

Users should be aware that when you are on Keystone Partners sites, you could be directed to other sites that are beyond our control. Keystone Partners is not responsible for the privacy practices or the content of other websites that may be linked to this site.

There may be links to other sites from the Sites that take you outside our service. These other sites may send their own cookies to users, collect data, or solicit personal information. Personal which you choose to provide to another party or website will be subject to their privacy policy.

Changes to this Policy

Keystone Partners, LLC is the controller and legal entity which determines the purposes and means of processing the information gathered at the Sites. The Privacy Statement may be amended from time to time. If we plan to make significant changes to our Privacy Statement, we will post those changes to the Sites at least 30 days before they take effect. If you have any questions about this Privacy Statement, the practices of the Sites, or your dealings with this website, you can send e-mail to dataprivacy@keystonepartners.com or call 617-720-7300.

Questions or Concerns
If you have any questions or concerns about the information contained in this privacy statement, please contact our Office at: dataprivacy@keystonepartners.com or call 617-720-7300

If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you may contact your supervisory authority:

In Canada:
Office of the Privacy Commissioner at info@privcom.gc.ca
Website: https://www.priv.gc.ca/en/ 

In the European Union:
Website: http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm

Thank you for using keystonepartners.comessexpartners.com, and https://kparchde.force.com.

For more information on our Privacy Policy, see here

Keystone Partners Continues to Grow

Recently, we acquired ICC and CEC to expand and enhance our services. Today we are excited to welcome The Ayers Group to Keystone Partners. This latest acquisition unites The Ayers Group’s expertise in leadership development and organizational consulting with our growing suite of leadership transformation, executive coaching, and coaching certification offerings.

Join us as we continue to innovate and drive organizational resilience for businesses seeking a happier, more productive workforce.