Privacy Policy

Effective Date: January 3, 2020
Last Updated: March 1, 2021

Teneo is committed to protecting and respecting your privacy.

This Privacy Notice (this “Notice”) explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure.*

It applies to those who may view and communicate with us through our Website as well as people with whom we do business.

Teneo reserves the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

If you have any questions or comments about this Notice, the ways in which Teneo collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: +1 (212) 886-1600

E-mail: info@teneo.com

Postal Address:
Teneo Holdings LLC
Attn: General Counsel
280 Park Ave, 4th Floor,
New York, NY 10017

*This Notice complies with the California Consumer Privacy Act of 2018 (the “CCPA”). Supplemental provisions applicable to visitors, users and others who reside in California are described below in the section entitled CALIFORNIA RESIDENTS. For residents in the European Economic Area who may be entitled to rights under the General Data Protection Regulation issued by the European Union please see the section entitled EUROPEAN UNION.

ABOUT TENEO

Teneo, is a global advisory firm that provides comprehensive strategic advisory services across a wide range of key objectives and issues addressing complex business and reputational challenges. We support chief executives, their boards, and the communications, corporate affairs, investor relations, and marketing teams of the world's largest organisations.

Teneo’s global headquarters is located at 280 Park Ave, 4th Fl, New York, NY 10017.

COLLECTION AND USE OF PERSONAL INFORMATION

Personal information is data that can be used to identify or contact a single person.

Depending on where you live, and in accordance with applicable laws, we may collect various categories of information from you when you access or use our Website and when you provide information directly to us (e.g., when you register for our events, request our services, explore a business opportunity through our Careers portal, or access various content and features on our Website). Those categories include:

Identifiers, such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;

Personal Information such as your signature, social security number, physical characteristics or description, passport number, driver’s license or state identification card number, education (e.g., grades, transcripts), employment (e.g., current or past job history or performance evaluations), bank account number, or any other financial information, medical information, or health insurance information;

Internet or other similar network activity, such as browsing history, search history, or information on your interaction with our Website;

Location data, but not your precise geolocation. We may collect location information provided by a mobile or other device interacting with this Website, or associated with your IP address or other online or device identifier. We may collect this information through the lawful use and deployment of cookies and other tracking technologies, as set forth in our Cookie Policy.

You may choose not to provide personal information to Teneo by refraining from, among other things, submitting information directly to us. However, if you do not provide information when requested, we may not be able to provide you with information about our services and business opportunities.

We may store and use personal information to:

track the usage of our Website and to help us improve our services and understanding of the interests and needs of those who contact us;
carry out our obligations arising from any contracts between you or the company you work for and us;
provide you with the information and services that you request from us;
guide us in answering your questions or to explore career, professional or business opportunities with you;
develop analysis and business intelligence that enable us to operate, grow, protect, make informed decisions and report on the performance of our business;
pursue other legitimate interests of our own such as maintaining a database of contacts working with or in our industry for networking or business development purposes.

PROTECTING PERSONAL INFORMATION

We secure personal information against unauthorized or unlawful processing, and against accidental loss, destruction or damage by appropriate technical, physical and organizational measures.

We evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal information.

We also take measures to ensure confidentiality, meaning that only people who have a need to know and use the personal information can access it.

SHARING YOUR INFORMATION

We will never sell or rent your personal information to third parties.

We sometimes share personal data among the group of companies owned by Teneo. This may involve transferring your personal information to other countries (including the U.K., and other countries, inside and outside the European Economic Area) where Teneo companies or other third parties operate and process your personal information. We also share personal data with vendors or agents working on our behalf for the purposes described in this Notice.

To the extent that we do share your personal information, we would only do so if we have entered into a written agreement with that party and that party has agreed to comply with our privacy standards as described in this Notice.

We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets, where we are required to do so by law, support auditing, compliance and corporate governance functions, in connection with legal proceedings or where disclosure is necessary to protect the vital interests of a person.

DATA RETENTION

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

CHANGES TO YOUR INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

CALIFORNIA RESIDENTS

For purposes of the CCPA, personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Teneo may obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase;
Indirectly from you. For example, from observing your actions on our Website;
From third-party business partners such as social media sites (LinkedIn), ad networks, and analytics providers.

Please note that Teneo, in accordance with all applicable laws, will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Rights and Choices of California residents under the CCPA

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Teneo disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Teneo delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

contacting our General Counsel located at our headquarters in New York; or
visiting https://www.teneo.com/

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you services.
Charge you different prices or rates for the services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of services.
Suggest that you may receive a different price or rate for services or a different level or quality of services.

EUROPEAN UNION RESIDENTS

Your rights in connection with personal information

If you are in the European Economic Area and are entitled to rights provided under the General Data Protection Regulation issued by the European Union you may:

request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate,
request erasure of your personal information where there is no good reason for us continuing to process it;
object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground,
object where we are processing your personal information for direct marketing purposes,
request the restriction of processing of your personal information,
request the transfer of your personal information to another party.

If you believe you may be entitled to rights provided under the GDPR and want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our General Counsel located at our headquarters in New York.

Effective Date: January 3, 2020
Last Updated: November 1, 2023

Teneo is committed to protecting and respecting your privacy.

This privacy notice (“Notice”) explains what personal information Teneo gather about you, what we use it for and who we share it with.

It applies to those who may view and communicate with us through our website as well as people with whom we do business.

We may change this Notice from time to time so please check this page occasionally to ensure that you’re happy with any changes. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s effective date.

Email: GDPR@teneo.com

About Teneo

This Notice is issued on behalf of the Teneo Group entities in the EU, namely, Teneo Strategy Ireland Limited, Teneo Restructuring (Ireland) Limited, Teneo Strategy France SAS, Teneo Paris, Teneo Brussels SRL, Teneo Germany GmbH, Herter & Co GmbH and Teneo Netherlands B.V. When we mention “Teneo,” “our”, “we” or “us in this Notice we are referring to the relevant company in the Teneo Group responsible for processing your data. Teneo Holdings LLC is the company responsible for Teneo.com.

Collection & Use of Personal Information

In this Notice, “personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier.

We may collect personal data directly (for example, when we perform professional services through a contract, you attend an event or subscribe to a newsletter) or indirectly (for example through public sources or from our clients)

The categories of personal data we may collect include:

Identifiers, such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;

Personal Information such as your signature, physical characteristics or description, passport number, driver’s license, educational background employment history, bank account number, any other financial information, or CCTV footage

Internet or other similar network activity, such as browsing history, search history, or information on your interaction with our Website;

Location data, but not your precise geolocation. We may collect location information provided by a mobile or other device interacting with this Website or associated with your IP address or other online or device identifier. We may collect this information through the lawful use and deployment of cookies and other tracking technologies, as set out in our Cookie Policy.

We typically do not collect sensitive or special categories of data about individuals other than employees, However, in some circumstances it may be necessary for us to process sensitive personal data, for example:

personal identification documents which may reveal race, religion or ethnic origin or in some cases biometric data
information that is provided to us by our clients in the course of providing our professional services
health data where this is necessary, for example to provide a safe environment for our staff, clients and suppliers.

If you choose not to provide, or object to us processing, the information we collect (see the "Your rights" section below), we may not be able to process your instructions or continue to provide some or all of our services to you or our client.

When our client or another third party gives us personal data about you, we take reasonable steps to make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing and has obtained any necessary permission for us to process that information as described in this privacy statement.

If any information you give us relates to a third party by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.

How we use your personal data

We process information about you and/or your business to enable us and other members of the Teneo Group to provide our services to you or our clients, and to meet our legal or regulatory obligations. Some of your personal data may be used for other business purposes.

Please select the relevant purpose below for further detail as to how we process your personal data.

Clients

Collecting your personal data

When Teneo provides professional services, we process information about you and/or your business to enable us to provide our services to you or our clients and to meet our legal or regulatory obligations, when we have a valid business reason to do so. We only ask our clients to share personal data with us where it is necessary in order to provide our services or other agreed purposes.

We also process personal data of individuals who are not directly our clients (for example, employees, customers or suppliers of our clients). See the section “Individuals whose personal data we obtain in connection with providing services to our clients” for additional information.

Because we provide a wide range of services to our clients or other third parties, we process many categories of personal data. The majority of the personal data we collect and use is supplied voluntarily by our clients (or collected from third-party sources at the request of our clients). As a result, if you are a client of Teneo, it will generally be obvious to you what personal data we collect and use. This information generally includes (as appropriate for the services we are providing):

basic information, such as your name, the organisation you work for and your job title;
contact information, such as your address, email, and mobile phone number;
financial and tax-related information, such as your income, investments and tax residency; and
any other information relating to you (or other third parties) which you provide to us for the purpose of receiving our services.

For certain services or activities and when permitted by law or with an individual’s consent, we may also process special categories of personal data. Examples of these activities include performing know your client checks which require us to process government identification documents which may contain biometric data or data revealing racial or ethnic origin) and providing you with lunch during a meeting. It is important you provide us with all necessary information and documents as this affects our ability to provide services to you.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.

Use of your personal data

We use this information for the following reasons:

providing professional services to you, including to correspond with you, other third parties, our service providers, or competent authorities;
client account opening and other administrative tasks;
financial accounting, invoicing and tax purposes;
relationship management with clients and prospective clients, which may involve:
- sending you thought leadership or details of our products and services;
- contacting you for feedback on services;
- sending you event invitations; and
- other marketing or research purposes;
recruitment and business development, which may involve:
- the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
- the use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
administering, managing and developing our business and services, which may involve:
- developing our businesses and services (such as identifying client needs and improvements in service delivery);
- maintaining and using our IT systems; and
- administering and managing our website and systems and applications;
services we receive from our professional advisors, such as lawyers, accountants and consultants;
security, quality and risk management activities;
complying with our legal and regulatory obligations and any requirements of a professional body of which we are a member; and
protecting our rights and those of our clients.

Our legal grounds for processing your personal data are:

compliance with a legal or regulatory obligation;
explicit consent to processing your information for a specific reason;
performance of the contract we have with you (or taking steps to enter into a contract with you); and
a legitimate interest pursued by us or a third party, including to:
- provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
- prevent fraud;
- protect our business interests;
- ensure that complaints are investigated;
- evaluate, develop or improve our services or products; or
- keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

you have given us your explicit consent to process that data;
we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
the processing is necessary to carry out our obligations under employment, social security or social protection law;
the processing is necessary for the establishment, exercise or defence of legal claims; or
you have made the data manifestly public.

Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

Individuals whose personal data we obtain in connection with providing services to our clients

Collecting your personal data

As part of the professional services Teneo provides to clients, we process personal data of individuals with whom we do not have a direct (contractual or other) relationship. For example, if Teneo undertakes a review on behalf of a client, we obtain personal data concerning the target’s employees, management and customers.

We seek confirmation from our clients that any personal data they provide has been processed in compliance with relevant privacy laws and regulations and that they have authority to provide personal data to us in connection with the performance of our services.

Because we provide a wide range of services, we process many categories of personal data. This information generally includes (as appropriate for the services we are providing):

personal details, such as your name, age/date of birth, gender, marital status and country of residence;
contact information, such as your address, email and mobile phone number;
financial and tax-related information, such as your income, investments and tax residency; and
employment details, such as your role, rank, experience, performance data and employment numbers.

For certain services or activities and when permitted by law, or with an individual’s consent, we may also process special categories of personal data.

Use of your personal data

We use this information for the following reasons:

providing professional services;
administering, managing and developing our businesses and services;
security, quality and risk management activities;
complying with any requirement of law, regulation or a professional body of which we are a member; and
where agreed with our clients, we may use non-personal, anonymised and aggregated information that we receive in the course of providing professional services for other lawful purposes, including data analytics, research, submissions, thought leadership and promotional activity.

Our legal grounds for processing your personal data:

compliance with a legal or regulatory obligation; and
a legitimate interest pursued by us or a third party, including to provide our services to our clients and other third parties and ensure that our client engagements are well-managed.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

you have given us your explicit consent to process that data;
we are required by law to process that data in order to ensure we meet our legal obligations;
the processing is necessary to carry out our obligations under employment, social security or social protection law;
the processing is necessary for the establishment, exercise or defence of legal claims; or
you have made the data manifestly public.

Individuals who get in touch with us another way

Individuals who contact us by email, phone and voicemail

We collect personal data when an individual contacts us with a question, complaint, comment or feedback (such as your name, contact details and contents of the communication). In these cases, you are in control of the personal data shared with us and we will only use the data for the purpose of responding to your communication.

Individuals who contact us through our social media sites

We use social media platforms for a variety of matters, such as for recruitment and marketing, to provide easy access to relevant information regarding matters such as opportunities and events. Although Teneo is responsible for the content published using our social media platforms, we are not responsible for managing those platforms. You are therefore obliged to adhere to the legal and privacy terms imposed by the relevant social media platform provider.

Journalists

Collecting your personal data

We engage with journalists and other individuals who work in the media on behalf of our clients as part of the professional services we provide and may process your personal contact information and areas of interest.

Use of your personal data

We use this information for the following reasons:

facilitating contacts and arranging interviews with individuals employed by our clients
sharing insights with you on areas that we think are relevant
responding to any questions relating to our clients or more generally
sending invitations to relevant events or meetings

Our legal grounds for processing your personal data are:

our legitimate interest in undertaking any of the above actions
your explicit consent

Participants in events and meetings

Collecting your personal data

We will collect personal data in connection with your attendance at Teneo meetings, conferences, events and learning sessions, which will be provided directly by you. This may include the following (to the extent required for a particular event):

name, age or date of birth;
email address;
company;
job title;
telephone number;
dietary / accessibility requirements;
guest details; and
other specific event-related data such as: arrival time/departure time, hotel check-in/check-out time, flight information (airline, arrival and departure dates).

We do not intentionally collect sensitive category data, unless you provide us with such data (for example, special dietary requirements which reveal your religious affiliation or any food allergies or other data relating to your health necessary to provide support to participants, if needed, for example, if a wheelchair will be required).

Use of your personal data

We will use your personal data to manage our events and to ensure that any special requirements you request are communicated to any relevant third parties, for example we will share any dietary requirements that you provide to us with venues and/or caterers.

Our legal grounds for processing your personal data are:

your explicit consent as a participant;
our legitimate interest in organising events and managing the registration process for such events;
our legitimate interest in protecting our people, assets and information, and to prevent unauthorised people gaining access to off-site events; and
our legitimate interest in providing information about Teneo, our services and events we organise.

Suppliers

Collecting your personal data

We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship and contract with our suppliers, to receive services from our suppliers and, where relevant, to provide professional services to our clients.

The personal data we process is usually limited to contact information (name, name of employer, phone, email and other contact details) and financial information (payment-related information).

Use of your personal data

We use this personal data for the following reasons:

receiving services from our suppliers;
providing professional services to our clients;
administering, managing and developing our business and services;
security, quality and risk management activities;
providing information about us and our range of services; and
complying with our legal and regulatory obligations.

Our legal grounds for processing your personal data are:

performance of a contract;
compliance with a legal or regulatory obligation;
our legitimate interest in managing payments, fees and charges;
our legitimate interest in safeguarding Teneo against inadvertently dealing with the proceeds of criminal activities or assisting in any other unlawful or fraudulent activities; and
our legitimate interest in carrying out any of the above actions.

Visitors to our office

Collecting your personal data

The personal data which we collect from visitors to our office, provided directly by you, is generally limited to your name, email address, mobile number (where relevant) and the time you enter and leave our office. Our sign-in processes vary between offices and more information will be provided on arrival. If you have any queries in advance of visiting an office please email GDPR@teneo.com

WIFI

We monitor traffic on our WIFI networks. This allows us to see limited information about a user’s network behaviour, including (at least) the source and destination addresses the user is connecting from and to.

CCTV

We use CCTV monitoring where permitted by law. CCTV images are securely stored and are only accessed on a need-to-know basis (for example, to look into an incident). We may disclose CCTV images to law enforcement bodies as requested and permitted by law. We will also share CCTV images with our insurers for the purpose of processing an insurance claim as a result of an incident. CCTV recordings are typically deleted or automatically overwritten after a short period of time, unless an issue is identified that requires further investigation.

Use of your personal data

We use this personal data for the following reasons:

communicating with visitors in relation to their attendance and conduct at our office;
providing visitors with facilities including access to our office, conference rooms or WIFI;
controlling access to our office; and
protecting our office, personnel, goods and confidential information.

Our legal grounds for processing your personal data are:

our legitimate interest in protecting our offices, personnel, goods and confidential information; and
our legitimate interest in preventing and detecting crime, and establishing, exercising and defending legal claims.

Visitors to our website

Collecting your personal data

When you visit our Website, you are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies and analytics tools on our Website. Please see our Cookies policy for more information on the data that is collected, how it is used and

Our legal grounds for processing your personal data are:

our legitimate interest in effectively delivering information and services to you and the effective and lawful operation of our business;
our legitimate interest in developing and improving our site; and
your explicit consent as a visitor to the Website.

Third party links

Our Website may link to third party sites not controlled by Teneo and which do not operate under our privacy practices. When you link to third party sites, Teneo’s privacy practices no longer apply and we do not accept any responsibility for the information you provide on those sites or their collection and use of your personal information. We encourage you to review each third party site’s privacy policy before disclosing any personally identifiable information.

Minors

Our Website is not intended for use by minors under the age of sixteen (16) years. It is Teneo’s policy to not knowingly collect or maintain the personal data for anyone under the age of 16 except as part of an engagement to provide professional services.

Protecting Personal Information

Teneo takes the security of all the data we hold very seriously. We have in place reasonable commercial standards of technology and operational security to protect your personal information from loss, misuse and unauthorised access, disclosure, alteration or destruction. Only authorised personnel, with appropriate awareness of privacy obligations, are provided access to your personal information. We regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

All our staff and third party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.

Sharing Your Information

We will only share your personal data when we are legally permitted to do so, in connection with any of the purposes outlined in the “How we process your personal data” section above. This may involve disclosing your data to:

other members of the Teneo Group or third parties that provide services or online platforms to us and/or the Teneo Group;
competent authorities (including courts and authorities regulating us and other members of the Teneo Group);
our clients;
your employer and/or its advisers, or your advisers;
our auditors, insurers and professional advisers;
any other person or organisation after a restructure, sale or acquisition of any member of the Teneo Group, as long as they use your information for the same purposes we did;
credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
other third parties that reasonably require access to personal data relating to you.

As a result of sharing your personal data with the above parties, information we hold about you may be transferred to other countries. This may include countries outside of the European Economic Area (“EEA”) and countries with laws that have not necessarily been determined to provide an adequate level of protection for the processing of personal data under the laws of the EU or other jurisdictions.

When we, or our permitted third parties, transfer your personal data outside the EEA , we will take reasonable steps to ensure that your information is treated securely and the means of transfer provide adequate safeguards.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

To determine the appropriate retention period for personal data, we consider 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 requirements.

We seek to ensure that we only keep your personal data for the longest of:

the period necessary for the relevant activity or services;
any retention period that is required by law; or
the period in which litigation or investigations might arise in respect of the services.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you would like to know more about the retention periods we apply to your personal data, please contact us at GDPR@teneo.com

Your rights

You have various rights in relation to your personal data. In particular, you have a right to:

request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate;
request erasure of your personal information where there is no good reason for us continuing to process it;
object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
object where we are processing your personal information for direct marketing purposes;
in some circumstances, request the restriction of processing of your personal information;
in some circumstances, request the transfer of your personal information to another party.

If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by sending an email to GDPR@teneo.com.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not, in general, have to pay a fee to exercise any of your individual rights set out in this Notice. However, we may refuse to provide access or charge a few for access if the relevant data protection legislation allows us to do so, in which case we will provide reasons for our decision as required by the law.

We hope that we will be able to resolve any query or concern you raise. However, if you feel that we have not handled your query or complaint to your satisfaction you may contact the relevant supervisory authority in your jurisdiction.

Effective Date: 7 June, 2022

Last Updated: 1 November, 2023

Teneo is committed to protecting and respecting your privacy.

This privacy notice (“Notice”) explains what personal information Teneo gather about you, what we use it for and who we share it with.

It applies to those who may view and communicate with us through our website as well as people with whom we do business.

Email: GDPR@teneo.com
Post: Deputy General Counsel, Teneo, The Carter Building, 11 Pilgrim Street, London, EC4V 6RN

About Teneo

This Notice is issued on behalf of the Teneo Group entities in the UK, namely, Teneo Business Consulting Limited, Teneo Financial Advisory Limited, Teneo Strategy Limited, Ridgeway Partners Limited t/a Teneo People Advisory, Teneo UK (Holdings) Limited, Teneo UK Bidco Limited, Blue Rubicon (Holdings) Limited, Tulchan Communications LLP, Ballintober Limited, Vox Media Limited, Tulchan Analytics Limited, Tulchan Communications Group Limited, Tulchan Partners Limited and Tulchan Limited. When we mention “Teneo,” “our”, “we” or “us in this Notice we are referring to the relevant company in the Teneo Group responsible for processing your data. Teneo Holdings LLC is the company responsible for Teneo.com

Collection & Use of Personal Information

The categories of personal data we may collect include:

Identifiers, such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;

Internet or other similar network activity, such as browsing history, search history, or information on your interaction with our Website;

personal identification documents which may reveal race, religion or ethnic origin or in some cases biometric data
information that is provided to us by our clients in the course of providing our professional services
health data where this is necessary, for example to provide a safe environment for our staff, clients and suppliers.

How we use your personal data

Please select the relevant purpose below for further detail as to how we process your personal data.

Clients

Collecting your personal data

basic information, such as your name, the organisation you work for and your job title;
contact information, such as your address, email, and mobile phone number;
financial and tax-related information, such as your income, investments and tax residency; and
any other information relating to you (or other third parties) which you provide to us for the purpose of receiving our services.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.

Use of your personal data

We use this information for the following reasons:

providing professional services to you, including to correspond with you, other third parties, our service providers, or competent authorities;
client account opening and other administrative tasks;
financial accounting, invoicing and tax purposes;
relationship management with clients and prospective clients, which may involve:
- sending you thought leadership or details of our products and services;
- contacting you for feedback on services;
- sending you event invitations; and
- other marketing or research purposes;
recruitment and business development, which may involve:
- the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
- the use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
administering, managing and developing our business and services, which may involve:
- developing our businesses and services (such as identifying client needs and improvements in service delivery);
- maintaining and using our IT systems; and
- administering and managing our website and systems and applications;
services we receive from our professional advisors, such as lawyers, accountants and consultants;
security, quality and risk management activities;
complying with our legal and regulatory obligations and any requirements of a professional body of which we are a member; and
protecting our rights and those of our clients.

Our legal grounds for processing your personal data are:

compliance with a legal or regulatory obligation;
explicit consent to processing your information for a specific reason;
performance of the contract we have with you (or taking steps to enter into a contract with you); and
a legitimate interest pursued by us or a third party, including to:
- provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
- prevent fraud;
- protect our business interests;
- ensure that complaints are investigated;
- evaluate, develop or improve our services or products; or
- keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

you have given us your explicit consent to process that data;
we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
the processing is necessary to carry out our obligations under employment, social security or social protection law;
the processing is necessary for the establishment, exercise or defence of legal claims; or
you have made the data manifestly public.

Individuals whose personal data we obtain in connection with providing services to our clients

Collecting your personal data

Because we provide a wide range of services, we process many categories of personal data. This information generally includes (as appropriate for the services we are providing):

personal details, such as your name, age/date of birth, gender, marital status and country of residence;
contact information, such as your address, email and mobile phone number;
financial and tax-related information, such as your income, investments and tax residency; and
employment details, such as your role, rank, experience, performance data and employment numbers.

For certain services or activities and when permitted by law, or with an individual’s consent, we may also process special categories of personal data.

Use of your personal data

We use this information for the following reasons:

providing professional services;
administering, managing and developing our businesses and services;
security, quality and risk management activities;
complying with any requirement of law, regulation or a professional body of which we are a member; and
where agreed with our clients, we may use non-personal, anonymised and aggregated information that we receive in the course of providing professional services for other lawful purposes, including data analytics, research, submissions, thought leadership and promotional activity.

Our legal grounds for processing your personal data:

compliance with a legal or regulatory obligation; and
a legitimate interest pursued by us or a third party, including to provide our services to our clients and other third parties and ensure that our client engagements are well-managed.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

you have given us your explicit consent to process that data;
we are required by law to process that data in order to ensure we meet our legal obligations;
the processing is necessary to carry out our obligations under employment, social security or social protection law;
the processing is necessary for the establishment, exercise or defence of legal claims; or
you have made the data manifestly public.

Individuals who get in touch with us another way

Individuals who contact us by email, phone and voicemail

Individuals who contact us through our social media sites

Insolvency and restructuring

Insolvency and Restructuring notice

Journalists

Collecting your personal data

Use of your personal data

We use this information for the following reasons:

facilitating contacts and arranging interviews with individuals employed by our clients
sharing insights with you on areas that we think are relevant
responding to any questions relating to our clients or more generally
sending invitations to relevant events or meetings

Our legal grounds for processing your personal data are:

our legitimate interest in undertaking any of the above actions
your explicit consent

Participants in events and meetings

Collecting your personal data

name, age or date of birth;
email address;
company;
job title;
telephone number;
dietary / accessibility requirements;
guest details; and
other specific event-related data such as: arrival time/departure time, hotel check-in/check-out time, flight information (airline, arrival and departure dates).

Use of your personal data

Our legal grounds for processing your personal data are:

your explicit consent as a participant;
our legitimate interest in organising events and managing the registration process for such events;
our legitimate interest in protecting our people, assets and information, and to prevent unauthorised people gaining access to off-site events; and
our legitimate interest in providing information about Teneo, our services and events we organise.

People Advisory Services

Candidates:

Collecting your personal data

We collect personal data from you during the recruitment, engagement, and onboarding stages. This may include your CV, identification documents, educational records, work history, references, correspondence and other personal data provided by you. In addition, we may also collect special category data, such as disability, race or health information where you have made this available to us.

We may also collect personal data from third parties such as an agent acting on your behalf, an interim manager, a third-party recommendation or referee or from publically available sources such as LinkedIn and company websites.

Use of your personal data

We use this information to determine your suitability as a candidate for the roles for which we are recruiting and to identify potential candidates for our clients.

Our legal grounds for processing your data are:

a legitimate interest pursued by us or a third party including to provide our services to our clients
compliance with a legal or regulatory obligation

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

you have given us your explicit consent to process that data;
we are required by law to process that data in order to ensure we meet our legal obligations;
the processing is necessary to carry out our obligations under employment, social security or social protection law;
the processing is necessary for the establishment, exercise or defence of legal claims; or
you have made the data manifestly public.

Referees:

Collecting your personal data

We may collect your name and contact information (name, address, email address and phone number) from candidates during the provision of our talent advisory services.

Use of your personal data

We will use your personal data to contact and correspond with you in relation to the provision of a professional, character or other reference in relation to a candidate.

Our legal grounds for processing your personal data are:

a legitimate interest pursued by us or a third party including to provide our services to our clients
your explicit consent as a referee

Sub-processors

Teneo Financial Advisory Limited is required by Article 28 of the EU General Data Protection Regulation (GDPR) to disclose its sub-processors where Teneo Financial Advisory Limited is acting as a data processor. The information below includes a list of third-party sub-processors used across our products and services. Teneo Parties (meaning all entities including Teneo Financial Advisory Limited that are affiliates of Teneo Holdings LLC) may also be considered sub-processors where Teneo Financial Advisory Limited is acting as a data processor.

The applicable data protection legislation requires us to inform our clients about the sub-processors we engage where we act as a data processor. The information below contains the list of sub-processors used across Teneo Financial Advisory Limited products and services.

UK/EEA Vendors

Vendor	Services	Address
Iron Mountain UK Plc	Records management storage	Cottons Centre 3rd Floor, Tooley Street, London, SE1 2TT
Virtual Cabinet, trading name of GetBusy UK Limited	Records management storage	Suite 8 The Works, Cambridge, CB22 3FT

Third Country Vendors (Outside the UK/EEA)

Vendor	Services	Address
Microsoft Corporation	IT Services	One Microsoft Way, Redmond, WA 98052, USA
Oracle America, Inc.	Technology	1001 Sunset Blvd, Rocklin, CA 95765, USA

Suppliers

Collecting your personal data

The personal data we process is usually limited to contact information (name, name of employer, phone, email and other contact details) and financial information (payment-related information).

Use of your personal data

We use this personal data for the following reasons:

receiving services from our suppliers;
providing professional services to our clients;
administering, managing and developing our business and services;
security, quality and risk management activities;
providing information about us and our range of services; and
complying with our legal and regulatory obligations.

Our legal grounds for processing your personal data are:

performance of a contract;
compliance with a legal or regulatory obligation;
our legitimate interest in managing payments, fees and charges;
our legitimate interest in safeguarding Teneo against inadvertently dealing with the proceeds of criminal activities or assisting in any other unlawful or fraudulent activities; and
our legitimate interest in carrying out any of the above actions.

Visitors to our office

Collecting your personal data

WIFI

CCTV

Use of your personal data

We use this personal data for the following reasons:

communicating with visitors in relation to their attendance and conduct at our office;
providing visitors with facilities including access to our office, conference rooms or WIFI;
controlling access to our office; and
protecting our office, personnel, goods and confidential information.

Our legal grounds for processing your personal data are:

our legitimate interest in protecting our offices, personnel, goods and confidential information; and
our legitimate interest in preventing and detecting crime, and establishing, exercising and defending legal claims.

Visitors to our website

Collecting your personal data

Our legal grounds for processing your personal data are:

our legitimate interest in effectively delivering information and services to you and the effective and lawful operation of our business;
our legitimate interest in developing and improving our site; and
your explicit consent as a visitor to the Website.

Third party links

Minors

Protecting Personal Information

All our staff and third party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.

Sharing Your Information

other members of the Teneo Group or third parties that provide services or online platforms to us and/or the Teneo Group;
competent authorities (including courts and authorities regulating us and other members of the Teneo Group);
our clients;
your employer and/or its advisers, or your advisers;
our auditors, insurers and professional advisers;
any other person or organisation after a restructure, sale or acquisition of any member of the Teneo Group, as long as they use your information for the same purposes we did;
credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
other third parties that reasonably require access to personal data relating to you.

As a result of sharing your personal data with the above parties, information we hold about you may be transferred to other countries. This may include countries outside the UK and the European Economic Area (“EEA”) and countries with laws that have not necessarily been determined to provide an adequate level of protection for the processing of personal data under the laws of the EU or other jurisdictions.

When we, or our permitted third parties, transfer your personal data outside the UK , we will take reasonable steps to ensure that your information is treated securely and the means of transfer provide adequate safeguards.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

We seek to ensure that we only keep your personal data for the longest of:

the period necessary for the relevant activity or services;
any retention period that is required by law; or
the period in which litigation or investigations might arise in respect of the services.

Your Rights

You have various rights in relation to your personal data. In particular, you have a right to:

request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate;
request erasure of your personal information where there is no good reason for us continuing to process it;
object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
object where we are processing your personal information for direct marketing purposes;
in some circumstances, request the restriction of processing of your personal information;
in some circumstances, request the transfer of your personal information to another party.

writing to the Deputy General Counsel at The Carter Building, 11 Pilgrim Street, London, EC4V 6RN; or
sending an email to GDPR@teneo.com.

We hope that we will be able to resolve any query or concern you raise. However, if you feel that we have not handled your query or complaint to your satisfaction you can contact the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, on 0303 123 1113 or at ico.org.uk/concerns. . If you are not based in the UK, you have a right to complain to the relevant supervisory authority in your jurisdiction.

Effective Date: May 28, 2021

Teneo is committed to protecting and respecting your privacy.

This Privacy Notice (this “Notice”) explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

It applies to those who may view and communicate with us through our Website as well as people with whom we do business.

By choosing to access and use this Website, you accept and agree to abide by Teneo’s Notice and its practices regarding the handling of and measures for protecting your personal information or data. Therefore, please read this Notice closely in order to be aware of your rights and obligations, being sure to consult the most up-to-date version in so far as you also accept and acknowledge that Teneo reserves the right, at any time, to modify, change or update this Notice without notice. By choosing to access and use this Website, you agree to such things as Teneo collecting and using your personal information or data in keeping with this Notice, on the understanding that Teneo complies with applicable Canadian laws and regulations.

If you have any questions, comments, or concerns about this Notice, the ways in which Teneo collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights under Canadian laws, please do not hesitate to contact us at:

Phone: +1 (212) 886-1600
E-mail: info@teneo.com
Postal Address:
Teneo Holdings LLC
Attn: General Counsel
280 Park Ave, 4th Floor,
New York, NY 10017

About Teneo

Teneo’s global headquarters is located at 280 Park Ave, 4th Fl, New York, NY 10017.

Collection & Use of Personal Information

Personal information is data that can be used to identify or contact a single person, but under Canadian privacy laws it does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card.

Identifiers, such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;

Internet or other similar network activity, such as browsing history, search history, or information on your interaction with our Website;

We may store and use personal information to:

track the usage of our Website and to help us improve our services and understanding of the interests and needs of those who contact us;
carry out our obligations arising from any contracts between you or the company you work for and us;
provide you with the information and services that you request from us;
guide us in answering your questions or to explore career, professional or business opportunities with you;
develop analysis and business intelligence that enable us to operate, grow, protect, make informed decisions and report on the performance of our business;
pursue other legitimate interests of our own such as maintaining a database of contacts working with or in our industry for networking or business development purposes.

Protecting Personal Information

We secure personal information against unauthorized or unlawful processing, and against accidental loss, destruction or damage by appropriate technical, physical and organizational measures.

We evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal information.

We also take measures to ensure confidentiality, meaning that only people who have a need to know and use the personal information can access it.

Sharing Your Information

We will never sell or rent your personal information to third parties.

We sometimes share personal data among the group of companies owned by Teneo. This may involve transferring your personal information to other countries (including the U.S, U.K., and other countries, inside and outside the European Economic Area) where Teneo companies or other third parties operate and process your personal information. We also share personal data with vendors or agents working on our behalf for the purposes described in this Notice.

Data Retention

How long will you use my information for?

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Changes & Access To Your Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. You have a right to challenge the accuracy and completeness of your personal information and to have it amended, as appropriate. You also have a right to request access to your personal information and receive an accounting of how that information has been used and disclosed, subject to certain exceptions prescribed by law. To request access or to amend your personal information, please contact us at the address stated above.

Third Parties Websites & Social Media

Links to websites not under our control are provided for the convenience of our visitors. We are not responsible for the accuracy or reliability of the content. We do not offer any guarantee and are not responsible for the information found through these links. We also do not endorse these sites or their content. With respect to privacy, visitors should research the privacy policies of these websites before providing personal information.

Our use of social media serves as an extension of our Website. Social media accounts are public and are not hosted on our servers. Visitors who choose to interact with us via social media should read the terms of service and privacy policies of these third-party service providers and those of any applications you use to access them. We use Twitter, LinkedIn, You Tube and other social media platforms.

Comments left by individuals on social media can be read by anyone. Therefore, we strongly advise you not to post any personal information – whether it is yours or not.

Effective Date: January 5, 2022

Introduction

Teneo is committed to protecting and respecting your privacy.

This privacy notice (“Notice”) explains what personal information Teneo gathers about you, what we use it for and who we share it with.

It applies to those who may view and communicate with us through our website as well as people with whom we do business.

We may change this Notice from time-to-time so please check this page occasionally to ensure that you’re happy with any changes. When we make changes to this Notice, we will post the updated Notice on the website and update the Notice’s effective date.

Email: privacy@teneo.com
Post: Privacy Office, Teneo (Cayman) Limited, 109M Elgin Avenue, George Town, Grand Cayman, KY1-9008, Cayman Islands

About Teneo

Teneo is a global advisory firm that provides comprehensive strategic advisory services across a wide range of key objectives and issues addressing complex business and reputational challenges. We support chief executives, their boards and the communications, corporate affairs, investor relations and marketing teams of the world's largest organisations.

This Notice is issued on behalf of Teneo (Cayman) Limited. When we mention “Teneo,” “our,” “we” or “us" in this Notice, we are referring to the relevant company in the Teneo Group responsible for processing your data. Teneo Holdings LLC is the company responsible for Teneo.com.

Collection and Use of Personal Information

In this Notice, “personal data” (sometimes referred to as "personal information", "personally identifiable information" or "PII") means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier.

The categories of personal data we may collect include:

Identifiers such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;

Personal Information such as your signature, physical characteristics or description, passport number, driver’s license, educational background, employment history, bank account number, any other financial information, or CCTV footage;

Internet or other similar network activity such as browsing history, search history or information on your interaction with our website;

Location data, but not your precise geolocation. We may collect location information provided by a mobile or other device interacting with this website or associated with your IP address or other online or device identifier. We may collect this information through the lawful use and deployment of cookies and other tracking technologies, as set out in our Cookie Policy.

We typically do not collect sensitive or special categories of data about individuals other than employees; however, in some circumstances it may be necessary for us to process sensitive personal data, for example:

Personal identification documents which may reveal race, religion, ethnic origin or in some cases biometric data;
Information that is provided to us by our clients in the course of providing our professional services;
Health data where this is necessary, for example to provide a safe environment for our staff, clients and suppliers.

How we use your personal data

Please select the relevant purpose below for further detail as to how we process your personal data.

Clients

Collecting your personal data

When Teneo provides professional services, we process information about you and/or your business to enable us to provide our services to you or our clients and to meet our legal or regulatory obligations when we have a valid business reason to do so. We only ask our clients to share personal data with us where it is necessary in order to provide our services or other agreed purposes.

Basic information, such as your name, the organisation you work for and your job title;
Contact information, such as your address, email, and mobile phone number;
Financial and tax-related information, such as your income, investments and tax residency; and
Any other information relating to you (or other third parties) which you provide to us for the purpose of receiving our services.

For certain services or activities, and when permitted by law or with an individual’s consent, we may also process special categories of personal data. Examples of these activities include performing “know your client” checks (which require us to process government identification documents that may contain biometric data or data revealing racial or ethnic origin) and providing you with lunch during a meeting. It is important you provide us with all necessary information and documents as this affects our ability to provide services to you.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.

Use of your personal data

We use this information for the following reasons:

Providing professional services to you, including corresponding with you, other third parties, our service providers or competent authorities;
Client account opening and other administrative tasks;
Financial accounting, invoicing and tax purposes;
Relationship management with clients and prospective clients, which may involve:
- Sending you thought leadership or details of our products and services;
- Contacting you for feedback on services;
- Sending you event invitations; and
- Other marketing or research purposes;
Recruitment and business development, which may involve:
- The use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
- The use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
Administering, managing and developing our business and services, which may involve:
- Developing our businesses and services (such as identifying client needs and improvements in service delivery);
- Maintaining and using our IT systems; and
- Administering and managing our website, systems and applications;
Services we receive from our professional advisors, such as lawyers, accountants and consultants;
Security, quality and risk management activities;
Complying with our legal and regulatory obligations and any requirements of a professional body of which we are a member; and
Protecting our rights and those of our clients.

Our legal grounds for processing your personal data are:

Compliance with a legal or regulatory obligation;
Explicit consent to processing your information for a specific reason;
Performance of the contract we have with you (or taking steps to enter into a contract with you); and
A legitimate interest pursued by us or a third party, including to:
- Provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
- Prevent fraud;
- Protect our business interests;
- Ensure that complaints are investigated;
- Evaluate, develop or improve our services or products; or
- Keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

You have given us your explicit consent to process that data;
We are required by law to process that data in order to ensure we meet our “know your client” and “anti-money laundering” obligations (or other legal obligations imposed on us);
The processing is necessary to carry out our obligations under employment, social security or social protection law;
The processing is necessary for the establishment, exercise or defense of legal claims; or
You have made the data manifestly public.

Please note that in certain circumstances it may still be lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

Individuals whose personal data we obtain in connection with providing services to our clients

Collecting your personal data

Because we provide a wide range of services, we process many categories of personal data. This information generally includes (as appropriate for the services we are providing):

Personal details, such as your name, age/date of birth, gender, marital status and country of residence;
Contact information, such as your address, email and mobile phone number;
Financial and tax-related information, such as your income, investments and tax residency; and
Employment details, such as your role, rank, experience, performance data and employment numbers.

For certain services or activities and when permitted by law or with an individual’s consent, we may also process special categories of personal data.

Use of your personal data

We use this information for the following reasons:

Providing professional services;
Administering, managing and developing our businesses and services;
Security, quality and risk management activities;
Complying with any requirement of law, regulation or a professional body of which we are a member; and
Where agreed with our clients, we may use non-personal, anonymised and aggregated information that we receive in the course of providing professional services for other lawful purposes, including data analytics, research, submissions, thought leadership and promotional activity.

Our legal grounds for processing your personal data:

Compliance with a legal or regulatory obligation; and
A legitimate interest pursued by us or a third party, including to provide our services to our clients and other third parties and ensure that our client engagements are well-managed.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

You have given us your explicit consent to process that data;
We are required by law to process that data in order to ensure we meet our legal obligations;
The processing is necessary to carry out our obligations under employment, social security or social protection law;
The processing is necessary for the establishment, exercise or defence of legal claims; or
You have made the data manifestly public.

Individuals who get in touch with us another way

Individuals who contact us by email, phone and voicemail

Individuals who contact us through our social media sites

We use social media platforms for a variety of reasons, including recruitment, marketing and providing easy access to relevant information regarding opportunities and events. Although Teneo is responsible for the content published using our social media platforms, we are not responsible for managing those platforms. You are therefore obliged to adhere to the legal and privacy terms imposed by the relevant social media platform provider.

Insolvency and restructuring

See separate insolvency notice.

Journalists

Collecting your personal data

Use of your personal data

We use this information for the following reasons:

Facilitating contacts and arranging interviews with individuals employed by our clients
Sharing insights with you on areas that we think are relevant
Responding to any questions relating to our clients or more generally
Sending invitations to relevant events or meetings.

Our legal grounds for processing your personal data are:

Our legitimate interest in undertaking any of the above actions
Your explicit consent.

Participants in events and meetings

Collecting your personal data

Name, age or date of birth;
Email address;
Company;
Job title;
Telephone number;
Dietary / accessibility requirements;
Guest details; and
Other specific event-related data such as: arrival time/departure time, hotel check-in/check-out time, flight information (airline, arrival and departure dates).

Use of your personal data

We will use your personal data to manage our events and to ensure that any special requirements you request are communicated to any relevant third parties. For example, we will share any dietary requirements that you provide to us with venues and/or caterers.

Our legal grounds for processing your personal data are:

Your explicit consent as a participant;
Our legitimate interest in organising events and managing the registration process for such events;
Our legitimate interest in protecting our people, assets and information, and to prevent unauthorised people gaining access to off-site events; and
Our legitimate interest in providing information about Teneo, our services and events we organise.

Suppliers

Collecting your personal data

The personal data we process is usually limited to contact information (name, name of employer, phone, email and other contact details) and financial information (payment-related information).

Use of your personal data

We use this personal data for the following reasons:

Receiving services from our suppliers;
Providing professional services to our clients;
Administering, managing and developing our business and services;
Security, quality and risk management activities;
Providing information about us and our range of services; and
Complying with our legal and regulatory obligations.

Our legal grounds for processing your personal data are:

Performance of a contract;
Compliance with a legal or regulatory obligation;
Our legitimate interest in managing payments, fees and charges;
Our legitimate interest in safeguarding Teneo against inadvertently dealing with the proceeds of criminal activities or assisting in any other unlawful or fraudulent activities; and
Our legitimate interest in carrying out any of the above actions.

Visitors to our office

Collecting your personal data

WIFI

CCTV

Use of your personal data

We use this personal data for the following reasons:

Communicating with visitors in relation to their attendance and conduct at our office;
Providing visitors with facilities including access to our office, conference rooms or WIFI;
Controlling access to our office; and
Protecting our office, personnel, goods and confidential information.

Our legal grounds for processing your personal data are:

Our legitimate interest in protecting our offices, personnel, goods and confidential information; and
Our legitimate interest in preventing and detecting crime, and establishing, exercising and defending legal claims.

Visitors to our website

Collecting your personal data

When you visit our website, you are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies and analytics tools on our website. Please see our Cookies policy for more information on the data that is collected and how it is used.

Our legal grounds for processing your personal data are:

Our legitimate interest in effectively delivering information and services to you and the effective and lawful operation of our business;
Our legitimate interest in developing and improving our site; and
Your explicit consent as a visitor to the website.

Third party links

Our website may link to third party sites not controlled by Teneo and which do not operate under our privacy practices. When you link to third party sites, Teneo’s privacy practices no longer apply and we do not accept any responsibility for the information you provide on those sites or their collection and use of your personal information. We encourage you to review each third-party site’s privacy policy before disclosing any personally identifiable information.

Minors

Our website is not intended for use by minors under the age of sixteen (16) years. It is Teneo’s policy to not knowingly collect or maintain the personal data for anyone under the age of 16 except as part of an engagement to provide professional services.

Protecting personal information

All our staff and third-party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.

Sharing your information

Other members of the Teneo Group or third parties that provide services or online platforms to us and/or the Teneo Group;
Competent authorities (including courts and authorities regulating us and other members of the Teneo Group);
Our clients;
Your employer and/or its advisers, or your advisers;
Our auditors, insurers and professional advisers;
Any other person or organisation after a restructure, sale or acquisition of any member of the Teneo Group, as long as they use your information for the same purposes we did;
Credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
Other third parties that reasonably require access to personal data relating to you.

As a result of sharing your personal data with the above parties, information we hold about you may be transferred to and stored in other countries. This may include countries outside of the European Economic Area (“EEA”) and countries with laws that have not necessarily been determined to provide an adequate level of protection for the processing of personal data under the laws of the EU or other jurisdictions.

When we, or our permitted third parties, transfer your personal data outside the EEA we will take reasonable steps to ensure that your information is treated securely and the means of transfer provide adequate safeguards.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

To determine the appropriate retention period for personal data, we consider 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, whether we can achieve those purposes through other means and the applicable legal requirements.

We seek to ensure that we only keep your personal data for the longest of:

The period necessary for the relevant activity or services;
Any retention period that is required by law; or
The period in which litigation or investigations might arise in respect of the services.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you would like to know more about the retention periods we apply to your personal data, please contact us at privacy@teneo.com.

Your rights

You have various rights in relation to your personal data. In particular, you have a right to:

Request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate;
Request erasure of your personal information where there is no good reason for us continuing to process it;
Object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
Object where we are processing your personal information for direct marketing purposes;
In some circumstances, request the restriction of processing of your personal information;
In some circumstances, request the transfer of your personal information to another party.

Writing to the Privacy Office, Teneo (Cayman) Limited, 109M Elgin Avenue, George Town, Grand Cayman, KY1-9008, Cayman Islands; or
Sending an email to privacy@teneo.com.

You will not, in general, have to pay a fee to exercise any of your individual rights set out in this Notice. However, we may refuse to provide access or charge a fee for access if the relevant data protection legislation allows us to do so, in which case we will provide reasons for our decision as required by the law.

We hope that we will be able to resolve any query or concern you raise. However, if you feel that we have not handled your query or complaint to your satisfaction, you can contact the Ombudsman, which regulates and supervises the use of personal data in the Cayman Islands. Further information on how to contact them is available at https://ombudsman.ky/data-protection. If you are not based in the Cayman Islands, you have a right to complain to the relevant supervisory authority in your jurisdiction.

Effective Date: January 5, 2022

Introduction

Teneo is committed to protecting and respecting your privacy.

This privacy notice (“Notice”) explains what personal information Teneo gathers about you, what we use it for and who we share it with.

It applies to those who may view and communicate with us through our website as well as people with whom we do business.

Email: privacy@teneo.com
Post: Privacy Office, Nerine Chambers, PO Box 905, Road Town, Tortola, British Virgin Islands

About Teneo

This Notice is issued on behalf of Teneo (British Virgin Islands) Limited. When we mention “Teneo,” “our,” “we” or “us" in this Notice, we are referring to the relevant company in the Teneo Group responsible for processing your data. Teneo Holdings LLC is the company responsible for Teneo.com.

Collection and Use of Personal Information

The categories of personal data we may collect include:

Identifiers such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;

Internet or other similar network activity such as browsing history, search history or information on your interaction with our website;

Personal identification documents which may reveal race, religion, ethnic origin or in some cases biometric data;
Information that is provided to us by our clients in the course of providing our professional services;
Health data where this is necessary, for example to provide a safe environment for our staff, clients and suppliers.

How we use your personal data

Please select the relevant purpose below for further detail as to how we process your personal data.

Clients

Collecting your personal data

When Teneo provides professional services, we process information about you and/or your business to enable us to provide our services to you or our clients and to meet our legal or regulatory obligations when we have a valid business reason to do so. We only ask our clients to share personal data with us where it is necessary in order to provide our services or other agreed purposes.

Basic information, such as your name, the organisation you work for and your job title;
Contact information, such as your address, email, and mobile phone number;
Financial and tax-related information, such as your income, investments and tax residency; and
Any other information relating to you (or other third parties) which you provide to us for the purpose of receiving our services.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.

Use of your personal data

We use this information for the following reasons:

Providing professional services to you, including corresponding with you, other third parties, our service providers or competent authorities;
Client account opening and other administrative tasks;
Financial accounting, invoicing and tax purposes;
Relationship management with clients and prospective clients, which may involve:
- Sending you thought leadership or details of our products and services;
- Contacting you for feedback on services;
- Sending you event invitations; and
- Other marketing or research purposes;
Recruitment and business development, which may involve:
- The use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
- The use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
Administering, managing and developing our business and services, which may involve:
- Developing our businesses and services (such as identifying client needs and improvements in service delivery);
- Maintaining and using our IT systems; and
- Administering and managing our website, systems and applications;
Services we receive from our professional advisors, such as lawyers, accountants and consultants;
Security, quality and risk management activities;
Complying with our legal and regulatory obligations and any requirements of a professional body of which we are a member; and
Protecting our rights and those of our clients.

Our legal grounds for processing your personal data are:

Compliance with a legal or regulatory obligation;
Explicit consent to processing your information for a specific reason;
Performance of the contract we have with you (or taking steps to enter into a contract with you); and
A legitimate interest pursued by us or a third party, including to:
- Provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
- Prevent fraud;
- Protect our business interests;
- Ensure that complaints are investigated;
- Evaluate, develop or improve our services or products; or
- Keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

You have given us your explicit consent to process that data;
We are required by law to process that data in order to ensure we meet our “know your client” and “anti-money laundering” obligations (or other legal obligations imposed on us);
The processing is necessary to carry out our obligations under employment, social security or social protection law;
The processing is necessary for the establishment, exercise or defense of legal claims; or
You have made the data manifestly public.

Individuals whose personal data we obtain in connection with providing services to our clients

Collecting your personal data

Because we provide a wide range of services, we process many categories of personal data. This information generally includes (as appropriate for the services we are providing):

Personal details, such as your name, age/date of birth, gender, marital status and country of residence;
Contact information, such as your address, email and mobile phone number;
Financial and tax-related information, such as your income, investments and tax residency; and
Employment details, such as your role, rank, experience, performance data and employment numbers.

For certain services or activities and when permitted by law or with an individual’s consent, we may also process special categories of personal data.

Use of your personal data

We use this information for the following reasons:

Providing professional services;
Administering, managing and developing our businesses and services;
Security, quality and risk management activities;
Complying with any requirement of law, regulation or a professional body of which we are a member; and
Where agreed with our clients, we may use non-personal, anonymised and aggregated information that we receive in the course of providing professional services for other lawful purposes, including data analytics, research, submissions, thought leadership and promotional activity.

Our legal grounds for processing your personal data:

Compliance with a legal or regulatory obligation; and
A legitimate interest pursued by us or a third party, including to provide our services to our clients and other third parties and ensure that our client engagements are well-managed.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:

You have given us your explicit consent to process that data;
We are required by law to process that data in order to ensure we meet our legal obligations;
The processing is necessary to carry out our obligations under employment, social security or social protection law;
The processing is necessary for the establishment, exercise or defence of legal claims; or
You have made the data manifestly public.

Individuals who get in touch with us another way

Individuals who contact us by email, phone and voicemail

Individuals who contact us through our social media sites

Insolvency and restructuring

See separate insolvency notice.

Journalists

Collecting your personal data

Use of your personal data

We use this information for the following reasons:

Facilitating contacts and arranging interviews with individuals employed by our clients
Sharing insights with you on areas that we think are relevant
Responding to any questions relating to our clients or more generally
Sending invitations to relevant events or meetings.

Our legal grounds for processing your personal data are:

Our legitimate interest in undertaking any of the above actions
Your explicit consent.

Participants in events and meetings

Collecting your personal data

Name, age or date of birth;
Email address;
Company;
Job title;
Telephone number;
Dietary / accessibility requirements;
Guest details; and
Other specific event-related data such as: arrival time/departure time, hotel check-in/check-out time, flight information (airline, arrival and departure dates).

Use of your personal data

Our legal grounds for processing your personal data are:

Your explicit consent as a participant;
Our legitimate interest in organising events and managing the registration process for such events;
Our legitimate interest in protecting our people, assets and information, and to prevent unauthorised people gaining access to off-site events; and
Our legitimate interest in providing information about Teneo, our services and events we organise.

Suppliers

Collecting your personal data

The personal data we process is usually limited to contact information (name, name of employer, phone, email and other contact details) and financial information (payment-related information).

Use of your personal data

We use this personal data for the following reasons:

Receiving services from our suppliers;
Providing professional services to our clients;
Administering, managing and developing our business and services;
Security, quality and risk management activities;
Providing information about us and our range of services; and
Complying with our legal and regulatory obligations.

Our legal grounds for processing your personal data are:

Performance of a contract;
Compliance with a legal or regulatory obligation;
Our legitimate interest in managing payments, fees and charges;
Our legitimate interest in safeguarding Teneo against inadvertently dealing with the proceeds of criminal activities or assisting in any other unlawful or fraudulent activities; and
Our legitimate interest in carrying out any of the above actions.

Visitors to our office

Collecting your personal data

WIFI

CCTV

Use of your personal data

We use this personal data for the following reasons:

Communicating with visitors in relation to their attendance and conduct at our office;
Providing visitors with facilities including access to our office, conference rooms or WIFI;
Controlling access to our office; and
Protecting our office, personnel, goods and confidential information.

Our legal grounds for processing your personal data are:

Our legitimate interest in protecting our offices, personnel, goods and confidential information; and
Our legitimate interest in preventing and detecting crime, and establishing, exercising and defending legal claims.

Visitors to our website

Collecting your personal data

Our legal grounds for processing your personal data are:

Our legitimate interest in effectively delivering information and services to you and the effective and lawful operation of our business;
Our legitimate interest in developing and improving our site; and
Your explicit consent as a visitor to the website.

Third party links

Minors

Protecting personal information

All our staff and third-party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.

Sharing your information

Other members of the Teneo Group or third parties that provide services or online platforms to us and/or the Teneo Group;
Competent authorities (including courts and authorities regulating us and other members of the Teneo Group);
Our clients;
Your employer and/or its advisers, or your advisers;
Our auditors, insurers and professional advisers;
Any other person or organisation after a restructure, sale or acquisition of any member of the Teneo Group, as long as they use your information for the same purposes we did;
Credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
Other third parties that reasonably require access to personal data relating to you.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

To determine the appropriate retention period for personal data, we consider 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, whether we can achieve those purposes through other means and the applicable legal requirements.

We seek to ensure that we only keep your personal data for the longest of:

The period necessary for the relevant activity or services;
Any retention period that is required by law; or
The period in which litigation or investigations might arise in respect of the services.

If you would like to know more about the retention periods we apply to your personal data, please contact us at privacy@teneo.com.

Your rights

You have various rights in relation to your personal data. In particular, you have a right to:

Request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate;
Request erasure of your personal information where there is no good reason for us continuing to process it;
Object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
Object where we are processing your personal information for direct marketing purposes;
In some circumstances, request the restriction of processing of your personal information;
In some circumstances, request the transfer of your personal information to another party.

writing to the Privacy Office, Teneo (BVI) Limited Nerine Chambers, PO Box 905, Road Town, Tortola, British Virgin Islands ; or
sending an email to privacy@teneo.com.

We hope that we will be able to resolve any query or concern you raise. However, if you feel that we have not handled your query or complaint to your satisfaction, you can contact the Information Commissioner, which regulates and supervises the use of personal data in the BVI. If you are not based in the BVI, you have a right to complain to the relevant supervisory authority in your jurisdiction.

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Privacy Policy

About Teneo

Collection & Use of Personal Information

How we use your personal data

Clients

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data are:

Individuals whose personal data we obtain in connection with providing services to our clients

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data:

Individuals who get in touch with us another way

Journalists

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data are:

Participants in events and meetings

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data are:

Suppliers

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data are:

Visitors to our office

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data are:

Visitors to our website

Collecting your personal data

Our legal grounds for processing your personal data are:

Third party links

Minors

Protecting Personal Information

Sharing Your Information

Data Retention

Your rights

About Teneo

Collection & Use of Personal Information

How we use your personal data

Clients

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data are:

Individuals whose personal data we obtain in connection with providing services to our clients

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data:

Individuals who get in touch with us another way

Insolvency and restructuring

Journalists

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data are:

Participants in events and meetings

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data are:

People Advisory Services

Candidates:

Collecting your personal data

Use of your personal data

Our legal grounds for processing your data are:

Referees:

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data are:

Sub-processors

Suppliers

Collecting your personal data

Use of your personal data

Our legal grounds for processing your personal data are:

Visitors to our office

Collecting your personal data

Use of your personal data