Privacy policy

FOUNDERS KEEPERS LLP

PRIVACY NOTICE

1. INTRODUCTION

Background

Founders Keepers is a global executive search firm, helping the most ambitious companies in the world, at critical stages of their growth, hire their most impactful digital talent. We are uniquely positioned as part of the Founders Forum group, a global community of the world’s most successful tech entrepreneurs and investors. This means that we bring the combined experiences, knowledge and networks of our whole team, and the wider Founders Forum ecosystem to bear on each project which helps our clients to build pioneering, digitally led organisations.

We have offices in London and Berlin, and work globally across cities including London, Manchester, San Francisco, Paris, Berlin, Tel Aviv and New York.

Founders Keepers respects your privacy and is committed to protecting your personal information. We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information through your use of this website or in relation to services that we provide, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

What does this privacy notice cover?

Specifically, this privacy notice covers personal information we collect: (1) in connection with the executive search and other services we provide (“Services”), and (2) when you visit our website at https://founderskeepers.co (“Website”).

Our Website and Services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Who collects information about you?

Founders Keepers LLP (“Founders Keepers”) collects, uses and is responsible for certain personal information about you. When we do so we are responsible as ‘data controller’ of that personal information.

Our Head of Operations is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Head of Operations at privacy@founderskeepers.co.

Any references to the “Founders Forum Group” in this privacy notice shall include (i) Founders Forum LLP, (ii) subsidiaries of Founders Forum LLP (as defined in section 1159 of the UK Companies Act 2006), (iii) current and future portfolio companies of Founders Forum LLP (i.e. where they own less than 50% of the company), and (iv) associated companies of Founders Forum LLP, including firstminute Capital and Founders Factory.

Useful terms

We use various terms throughout this privacy notice and some of these are explained below to help you when you read it:

“Applicants” means any applicant or candidate who is considered, evaluated or assessed by Founders Keepers in connection with the Services we provide to our Clients.

“Clients” means any of our clients (including the individuals working for our clients) who are looking to expand and recruit for their teams via the Services we provide to them.

“Referee” means any individual who provides references (whether employment or personal) for a particular Applicant.

“Source” means any individual who helps us to identify potential Applicants.

“Supplier” means those external vendors and suppliers that provide services to Founders Keepers.

“Personal information” (or “personal data”) means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).

2. DATA COLLECTED THROUGH OUR SERVICES

This section applies to personal information we collect and process about you in connection with our Services.

What personal information do we collect?

A. Applicants

If you are an Applicant, we collect personal information about you which we need to help us assess your suitability for roles with our Clients in connection with the Services we provide. This information typically includes:

• Contact details, such as your name, work and personal email addresses, postal address and telephone number(s).
• CV information, such as contact details, work history, salary and benefits, educational history, professional qualifications and training, references, links to professional profiles (e.g. LinkedIn, Twitter, etc.), languages and any other skills and activities.
• Compliance and identity information, such as your right to work status, civil/marital status, date of birth, gender, nationality, national identifier (e.g. passport, driver’s license or equivalent form of national ID in your country).
• Profile information, such as details about your hobbies and interests, memberships, community involvement and social activities, and any assessment of your competencies at executive level or other observations relating to character and personality (which may be relevant to assessing your suitability for a role with our Clients).
• Other information, such as marketing preferences, our contact history with you and any other relevant information which you may choose to share with us. We may also receive feedback about you from Clients after they have reviewed your profile or interviewed you.

B. Clients

As a Client, we collect personal information about you, or individuals at your organisation, in the course of providing Services to you. This information typically includes:

• Contact details, such as your name, job title, telephone number and email address.
• Information about your engagement with Applicant profiles through our Client platform, including any feedback you may provide about Applicants.
• Other information, such as marketing preferences, our contact history with you and any relevant information which you or someone in your organisation chooses to share with us.

C. Suppliers

We need a small amount of personal information from our Suppliers to ensure that our contract runs smoothly. This information typically includes:

• Contact details of relevant individuals within your organisation, such as name, job title, telephone number and email address.
• Bank details, so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
• Any other information that someone in your organisation has chosen to tell us from time to time.

D. Sources

Where you refer or recommend an Applicant to us, we may process the following personal information about you:

• Contact details, such as your name, telephone number and email address.
• Professional details, such as job title, occupation, company, work history and professional qualifications.
• Information about your connection to the Applicant, such as your relationship to, opinions relating to, or experience with the relevant Applicant.

E. Referees

We typically process the following information about Referees:

• Contact details, such as your name, job title, telephone number and email address.
• Professional details, such as job title, occupation, company, work history and professional qualifications.
• Information about your connection to the Applicant, such as your relationship to, opinions relating to, or experience with the relevant Applicant.

How do we collect personal information about you?

A. Applicants

We may collect information about Applicants from the following sources:

Directly from you: This is information you provide while searching for a new opportunity. For example, by filling in an application form for an advertised role via LinkedIn or by corresponding with us in person, by phone, email or otherwise.

Publicly available third party sources: This will include information about you that is available through publicly available sources with professional relevance, such as professional networking sites (including LinkedIn), corporate websites, news reports and press releases.

Sources and Referees: For example, you may be recommended by a colleague, former employer, former colleague or someone in the Founders Forum Group network and we would receive information about you from these Sources. Referees may also disclose personal information about you.

Third party data providers: We may source personal information about you from third party data providers, e.g. BoardEx. When we obtain information about you from third party data providers, we take steps to ensure that these third parties are permitted to share this information with us.

B. Clients

We collect information about Clients from the following sources:

Directly from you: This is the information you or an individual at your organisation provide to us during the course of our engagement to provide the Services. It also includes any information you provide when you attend our events, interact with us at a conference or correspond with us in person, by phone, email or otherwise.

Third party sources: This will include information about you or your colleagues that is available through publicly available sources, such as professional networking sites (including LinkedIn) and general market research. We sometimes need to look outside our existing network of Clients to the wider Founders Forum Group and partner organisations for suggestions of, and introductions to, contacts who might benefit from our Services.

C. Suppliers

If you are a Supplier, we will collect your personal information directly from you, or from one of your colleagues, during the course of your engagement to provide services to us.

D. Sources

If you are a Source, we will collect your personal information directly from you and from publicly available sources, such as LinkedIn.

E. Referees

If you are a Referee, we will your personal information from Applicants as well as directly from you and from publicly available sources, such as LinkedIn.

How do we use your personal information?

A. Applicants

We use Applicants’ personal information for the following purposes:

• To perform the Services;
• To assess your suitability for roles with Clients;
• To contact you about executive search assignments;
• To send your information on to our Clients where you have been selected as a candidate;
• To verify any details that you have provided (including requesting references from Referees);
• To maintain and administer our business relationship with you;
• To store your details so that you may be considered for future roles with our Clients;
• For other business purposes, such as research and analysis, determining the effectiveness of our Services and to improve the Services.
• To comply with legal or regulatory requirements.

B. Clients

We use Clients’ personal information for the following purposes:

• To provide the Services to your organisation;
• To administer and manage our business relationship with you;
• For other business purposes, such as research and analysis, business development and planning, determining the effectiveness of our Services and to improve the Services;
• To send you information that we think you may find interesting (such as market research, reports, events and general information about relevant industry sectors), in accordance with your marketing preferences; and
• To comply with legal or regulatory requirements.

C. Suppliers

We use Suppliers’ personal information for the following purposes:

• To store (and update where necessary) your contact details on our database, so that we can contact you in relation to our agreements;
• To administer and manage our business relationship with you and to obtain services from you;
• To comply with legal and regulatory requirements; and
• To help us establish, exercise or defend legal claims.

D. Sources

We use Sources’ personal information for the following purposes:

• To identify and consider potential Applicants during the course of providing the Services to our Clients;
• To contact you in relation to our Services where we think they may be of interest to you as a potential Client or Applicant (in accordance with your marketing preferences).

E. Referees

We use Referees’ personal information for the following purposes:

• To contact you to obtain a reference for an Applicant during the course of providing the Services to our Clients;
• To contact you in relation to our Services where we think they may be of interest to you as a potential Client or Applicant (in accordance with your marketing preferences).

What is our legal basis for processing your personal information?

A. Applicants

Where we process Applicants’ personal information in connection with the Services, our processing is necessary for our legitimate interests and we consider that your interests and fundamental rights do not override those interests. As a recruitment business, we are engaged to find suitable candidates for fill roles with our Clients. As such, it is necessary to use the information we collect about Applicants (whether directly or indirectly) to assess their suitability for potential roles. We also need to share Applicants’ personal information with our Clients where they are being considered for a specific role and this sharing of data is a fundamental part of the process. In order to perform effectively as an executive search firm, to maintain and develop our Services and to meet our Clients’ resourcing needs, we also need to keep a database of historical and prospective Applicants.

We will always ask for your express consent (and keep a record of your response) before sharing your personal information with a Client in relation to a role for which you are being considered. As we work globally, some of our Clients will be located in countries outside the European Economic Area (“EEA”) so we will also ask for your explicit consent to transfer your personal information to non-EEA countries.

Where you have given us your consent to process personal information, you have the right to withdraw this at any time (as set out in Section 4 below).

B. Clients

Where we process your personal information in connection with providing Services to you, we consider that this processing is necessary to perform the contract we have entered into with you.

Where we process your information to administer and manage our business relationship with you, for other business purposes and for marketing purposes, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.

We will rely on legal obligation if we are legally required to hold your personal information to comply with legal or regulatory requirements, such as disclosure to regulators and for purposes of disputes or legal proceedings affecting us.

C. Suppliers

Where we process your personal information in connection with obtaining services from you, we consider that this processing is necessary to perform the contract we have entered into with you.

Where we process your information to administer and manage our business relationship with you, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.

We will rely on legal obligation if we are legally required to hold your personal information to comply with legal or regulatory requirements, such as disclosure to regulators and for purposes of disputes or legal proceedings affecting us.

D. Sources

Where we process your personal information to identify and consider potential Applicants or to contact you in relation to our Services where we think they may be of interest to you, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.

E. Referees

Where we process your personal information to contact you for a reference for an Applicant, or in relation to our Services where we think they may be of interest to you, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.

What happens if you fail to provide personal information?

If you do not provide us with certain requested personal information (e.g. where you apply for a role via LinkedIn), object to or withdraw your consent (where applicable) for the processing of your personal information, this may limit our ability to provide the Services or consider you, or other Applicants, in connection with the Services.

3. DATA COLLECTED VIA OUR WEBSITE

This section applies to personal information we collect and process about you when you use our Website.

What personal information do we collect?

We may collect the following personal information about you when you visit our Website or offline, when you attend one of our events or engage with us at a conference:

• Contact details, such as your name, company, job title, telephone number and email address.
• Technical data, such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
• Usage data, such as information about how your device has interacted with our Website, including pages and links clicked.
• Marketing and communications data, such as your preferences in receiving marketing or other communications from us.

How do we collect personal information about you?

We may collect your personal information as follows:

Directly from you: This is information you provide when you enquire about, or request a service directly from us. For example, where you contact us directly via email or telephone, or using the contact form on our Website. As noted above, we may also collect personal information from you offline, where you attend one of our events or engage with us at a conference.

Information we collect automatically: When you visit our Website, we collect certain technical and usage information automatically from your device. This information helps us to better understand how people use our Website and we collect it through our and our technology partners’ use of cookies and similar technologies.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Notice for further details.

How do we use your personal information?

We use your personal information for the following purposes:

• To respond to your enquiries, such as a request for information about our Services;
• To administer and protect our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
• To deliver relevant website content to you and to measure or understand the effectiveness of the content we serve to you; and
• To use data analytics to improve our Website, content, marketing and user experience.

What is our legal basis for processing your personal information?

Where we process your information for the purposes set out above, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.

What happens if you fail to provide personal information?

You can still visit our Website and learn more about Founders Keepers without giving us your personal information. However, where you have submitted an enquiry via the Website we will need your contact details to administer and respond to your queries. If you do not provide us with certain requested information, this may limit our ability to provide the Services or respond to your enquiries.

4. GENERAL INFORMATION

Marketing

As set out above, we may use your contact details to send you marketing communications (e.g. about our Services which we think you might be interested in) if you have requested information from us or provided us with your details and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal information with any company outside the Founders Forum Group for marketing purposes.

You can ask us to stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you or by contacting us at privacy@founderskeepers.co at any time. Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of other interactions via the Website or in connection with our Services.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who we share your personal information with

We may share your personal information with the following categories of third parties for the purposes described in this privacy notice:

• We use a number of service providers (our Suppliers) who perform functions on our behalf and/or help us in providing our Services, such as cloud-based software and hosting suppliers, CRM software providers and web analytics providers.
• In the case of Applicants, Sources and Referees, we may share your personal information with Clients who will need to process your personal information for the purposes set out in this privacy notice;
• In the case of Candidates, we may share your personal information with Sources and Referees where we need to correspond with them in connection with providing the Services for our Clients.
• We may share personal information with other companies in the Founders Forum Group where they host or curate events in partnership with us, for example.
• We may also share personal information with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.
• We may also be required to share some personal information as required to comply with the law.
• We may share your personal information with any other person with your consent.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Transfers of your personal information outside the EEA

The information that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA). For example, some of the services providers we use to help us in connection with the Services are based in the US and this would involve a transfer of your personal information to the US. Where your personal information is shared with Clients as set out above, this may also involve an international data transfer because we work globally and Clients may not be located in the country in which you are resident.

Whenever we transfer your information outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented. Please contact us if you want further information about the specific mechanism used by us when transferring your personal information outside the EEA.

Your rights

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”) and to certain other supplementary information that this privacy notice is already designed to address;
• Request correction of the personal information we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
• Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
• Object at any time to processing of personal information concerning you for direct marketing;
• Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• Object in certain other situations to our continued processing of your personal information;
• Request the restriction of processing of your personal information. This enables you to as us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
• Withdraw your consent to our processing of your personal information, where we have collected and processed your personal information with your consent. Please note, however, that where you withdraw your consent this may limit our ability to provide the Services.

If you would like to exercise any of those rights, please email our Head of Operations at privacy@founderskeepers.co and let us have enough information to identify you. We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information 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 have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How long do we use your personal information?

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

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Third-party links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

How to complain

We hope that we can resolve any query or concern you raise about our use of your personal information.

You also have the right to lodge a complaint with your supervisory authority in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner’s Office who may be contacted at https://ico.org.uk/concerns/.

Changes to this privacy notice

This version was last updated on 21 January 2019. We may change this privacy notice from time to time, when we do we will inform you by updating this section.

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 relationship with us.