Privacy Policy

1. Introduction

Chaloner Associates, Inc. (“Chaloner,” “we,” “us,” or “our”) is committed to protecting the privacy of candidates and prospective candidates (“you” and “your”) whose personal information we collect in connection with our recruiting and placement services. This privacy policy (the “Policy”), in addition to our Terms of Use, describes how we collect, use, disclose, and protect your personal information.

By providing us with your personal information, you acknowledge and consent to the collection, use, and disclosure of your personal information as described in this Policy and the Terms of Use.

2. Scope

This Policy applies when you use or access the website, www.chaloner.com, and its subdomains or portals (collectively, the “Website”) or otherwise provide Personal Information or interact with us online or in-person. For the purpose of this Policy, “Personal Information” (also known as “Personal Data”) means any personal information relating to an identified or identifiable individual that is protected by applicable privacy laws. We are boutique employee search firm partnering exclusively with certain organizations for placement of well qualified candidates (“Services”). By using the Services, you agree to our Terms of Use and this Policy. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that Personal Information is necessary to provide you with the Services or if we are legally required to collect it.

3. Categories of Personal Information We Collect

We may collect the following categories of Personal Information:

• Name, email, phone number, social media, address, birth date, and basic demographic data.
• Job titles, professional experience, work history, qualifications, compensation, licenses, certifications, and application materials.
• Institutions attended, degrees, certifications, and transcripts.
• Identity verification documents, reference or background check results.
• Veteran or disability status.
• Interview recordings, photos, and assessment notes.
• IP address, device identifiers, and browsing activity.

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4. Sources of Personal Information

We collect information in a variety of ways:

• We collect contact information, identifiers, financial information, commercial information, and professional or employment information that you provide directly to us.
• When you visit our offices or facilities, we also collect contact information and audio/visual data.
• When you access our Website, we collect identifiers, geolocation data, and internet or electronic usage data using tools like browser cookies.
• We may collect contact information, identifiers, financial information, commercial information, and professional or employment information from third-parties including our vendors, clients, recruiters, and service providers.
• We may collect contact information, identifiers, financial information, personal characteristics or traits, non-public education information, health information, medical information, sensitive Personal Information, and professional or employment information from our current or former applicants or consultants.
• Depending on the information you choose to share and your privacy settings, we may collect contact information, identifiers, audio/visual data, personal characteristics or traits, geolocation data, commercial information, professional or employment information, internet or electronic usage data, and inferences.

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5. How We Use Personal Information

We use your personal information for the following purposes:

• To (i) provide you or our clients with the services that we offer; (ii) communicate with you; (iii) provide you with assistance; and (iv) administer contracts with our vendors, clients, and service providers.
• To make informed decisions on recruitment and assess your suitability for the role, communicate with you about your application and respond to your inquiries and schedule interviews. We may also use your information to provide qualifications and credentialing information to our clients so that they may assess your suitability for a role, onboard you, and credential you into their systems.
• When permitted by law and with your consent, we may require our applicants to complete a background check to verify your identity, check for criminal history, and confirm the validity of your application. We may use your identifiers, personal characteristics or traits, professional or employment information, non-public education information, and sensitive Personal Information to enable the completion of the background check form.
• We may use contact information, identifiers, personal characteristics or traits, financial information, audio/visual data, professional or employment information, education information, sensitive Personal Information, and inferences for our day-to-day business operations including billing and collections, procurement, tax-related activities, maintaining records, planning, budgeting, calibration, headcount, database administration, metrics, surveys, evaluations, reports, compliance, regulatory, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.
• We may use identifiers, internet or electronic usage data, geolocation data, commercial information, and inferences to analyze preferences, trends and statistics.
• We may combine contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information we obtain from different sources with publicly available information, including to create reasonable inferences about you.
• We may use contact information, identifiers, financial information, professional or employment information, internet or electronic usage data, geolocation data, and inferences to improve our marketing efforts, conduct market research, prospect for new clients, client relationship management, client engagement, administering promotions, and to provide you with information about us, including personalized marketing communications.
• We may use identifiers, geolocation data, internet or electronic usage data to improve our Website and systems, provide and maintain functionality on our Website and systems, and help us diagnose technical and service problems and administer our Website and systems.
• We may use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to help us develop new products and/or services and to improve and analyze our existing products and service offerings.
• We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to: (i) protect our Website, premises, assets, systems, products, services and intellectual property; (ii) protect us, our affiliated companies, our employees, our carriers and others from fraud, theft and other misconduct; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
• We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.

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6. How We Share Personal Information

We share personal information in the following circumstances or as otherwise described in this Policy:

• We may share personal information with vendors and service providers who support the operation of our services, website, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, payment processing, email delivery, marketing, insurance, operating systems and platforms, and customer support services). In some cases, such as payment processors, the vendor or service provider may directly collect the information from you on our behalf.
• We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns.
• We share your personal information with our clients and companies we represent so that they may assess your suitability for employment or work as a consultant, onboard you into their systems, and credential you.
• We may share personal information with third party marketing, analytics or advertising partners, including social media platforms and networks, for commercial purposes such as sending you marketing emails.
• We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us.
• As required by law, we share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforce or protect our contracts, legal rights or the rights of others, including by responding to claims asserted against us.
• We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.
• We may share information with third parties whenever you consent to or direct such sharing.

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7. International Data Transfers

Your personal information will be processed and stored in the United States. By submitting your data, you consent to this transfer and acknowledge that data protection laws in the U.S. may differ from those in your country.

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8. Data Retention

Please refer to the Terms of Use for more detailed information regarding our data retention practices.

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9. Security

Please refer to the Terms of Use for more detailed information regarding our security implementation.

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10. Cookies and Tracking

We use cookies and similar technologies for analytics and Website functionality. You may change browser settings to limit cookies.

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11. Text Messages

By providing your phone number, you consent to receive job-related text messages. No mobile information will be shared for marketing purposes. You may opt out at any time by replying “STOP” or email us at info@chaloner.com

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Information, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

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12. Children’s Privacy

We do not knowingly collect information from anyone under the age of 18. If we become aware of such data, we delete it promptly.

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13. Your Privacy Rights

General Rights

• Obtain a copy of your personal data.
• Request correction of inaccuracies.
• Unsubscribe from marketing or contact at any time.

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California Residents (CCPA/CPRA)

Please refer to the Terms of Use for more detailed information regarding California Residents’ rights.

Other U.S. States

Residents of other states may hold similar rights to access, correct, delete, and opt out of targeted advertising or sale of data. Please refer to your respective state regulations to determine your rights.

EEA and UK (GDPR)

Your rights include access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. You may lodge a complaint with your local supervisory authority. Please refer to the Terms of Use for more detailed information regarding your rights under GDPR.

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14. Data Processing

Please be aware that information we obtain about you will be processed in the United States by us, our affiliates, our clients, our marketing/analytics/advertising partners, or our service providers. By using the Website or our services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own as described in the Terms of Use and this Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other jurisdictions may be different from the laws in your country of residence. The United States may not afford the same level of protection as laws in your own country.

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15. Exercising Your Rights

Please submit a request to the following contact:

Email: privacy@chaloner.com
Phone: 212-365-6645
Mail: 1750 Tysons Blvd Ste 1500 McLean, VA 22102

You may designate an authorized agent to act for you by providing written authorization.

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16. Updates to This Policy

We may update this Policy periodically. A revised version will be posted with a new “Last Updated” date. Material changes will be announced on our Website or via email.