Privacy Policy
Who we are
This privacy policy applies to The Succession Plan (“The Succession Plan Limited”,
“We”, “Us” or “Our”). This Privacy Policy (the “Policy”) explains how The Succession Plan
process personal information, including personal information associated to business
people and all other types of information through our services and website; how we use
and maintain, use, and share that information.
At The Succession Plan, we respect and protect the privacy of those who visit our company
website and of our clients who use SuccessionPlan.ai to for succession planning. We will
never share your personally identifiable information ("PII"), nor that of your group
members, with any third parties or send you unsolicited communications.
We are a global succession planning platform. Our approach to succession planning is changing the way business’s conduct succession plans and leadership risk mitigation.
You may contact us with the following: (1) 20 Wenlock Street, London, N1 7GU; (2) DataPrivacy@thesuccessionplan.com; (3) (Phone Number)
1. Introduction
The Succession Plan collects business information related to individuals through public
repositories and direct contact. We provide this information to our customers who are
business trying to reach business professionals for recruiting activities.
You can opt out of our database by contacting us using the details listed under “Contact
us” and at the end of the section “Who We Are”.
By remaining in our database, you may be contacted by us or our customers when they
are conducting recruiting activities. Communications you receive from our customers may
be relevant to your profession or employment role, but we cannot guarantee that you will
find such communications to be relevant or of interest to you.4
2. How we collect Data
A. Where does The Succession Plan get the business information for its talent insights?
The Succession Plan offers services around talent insights through the use of multiple data
points and direct contact. Once combined these are made available to users and our
customers through our platform “SuccessionPlan.ai”.
Business information that may be used include: Name, Title, Company Name, Department
Employment History, Location, phone numbers.
The Succession Plan obtains the data for its Talent Insights in several ways including:
1. Search Technology
2. License information from other companies
3. Research conducted by our in-house team
The Succession Plan only shares data with relevant customers though its platform.
B. Customer Information
Customer information Collect. The Succession Plan may collect the following information from
or regarding its customers: (1) personal contact information regarding users of the
Services (“Customer Details”); (2) information uploaded or otherwise provided to our
system by a user of the Services (“Uploaded Information”); (3) usage logs regarding the
use of the Site and Services, including logins and other actions taken, time stamps, IP
address, and other usage data (“Usage Logs”); and (4) any other information from or
relating to users of our Services (“Related Information”) (collectively, “Customer
Information”).
Use of Customer Information
Customer Information may be used for The Succession Plan’s legitimate business interests in
connection with a customer or its users’ use of the Site, including to respond to user
inquiries and fulfill user requests, complete transactions, provide customer service, send
administrative information, and to personalize user experience with the Site. We may use
Customer Information to contact customers or its users in the future about services,
promotions, opportunities, and other general information about The Succession Plan.
3. How we Use Information
In addition to the uses described in the above sections we may also use Business
Information for one or more of the following purposes:
• process an introduction/application for a role you have given us authorisation to
submit you for;
• contact you for future opportunities that may be interesting to you;
• to carry out our obligations arising from any contracts entered into by you and us;
• seek your views or comments on the services we provide;
• notify you of changes to our services;
• send you communications in order to update your details5
We review our data retention periods for personal information on a regular basis. We will
hold your personal information on our systems for as long as is necessary for the relevant
activity.
4. How we Share Information
Disclosures of Talent Insight. We may make any Business Information that we collect from
public web sources, we licenses from third parties available to users of our platform “SuccessionPlan.ai”, and to our customers. Information provided, including Business Information, in creating or updating a Professional Profile, will be included in SuccessionPlan.ai and thus can be viewed by third parties.
5. Cookies and Similar Technology
Most websites, including our Site, use a feature of browsers to set a small text file called a
“cookie” on a computer. The site placing the cookie on a computer can then recognize
the computer when the user of the computer revisits the site to allow auto login and track
how the user is using the site.
When individuals visit our Site, our servers and/or those of our service providers
automatically record certain information that the web browser sends, such as web
request, Internet Protocol address, browser type, referring/exit pages and URLs, page
loads and clicks, domain names, landing pages, pages viewed, time and date of use, and
other information. We may link this information to information that individuals submit
while on our Site, which does allow such individuals to be personally identified.
Individuals are free to decline cookies and can configure their browser to accept all
cookies, reject all cookies, erase cookies, or notify the user when a cookie is set. Electing
to reject or disable cookies may substantially limit an individual’s ability to use our Site.
The Succession Plan may also adopt other technologies that serve similar functions as
cookies.
Google Analytics
We use Google Analytics, a web analytics service provided by Google, Inc., on our Site.
Google Analytics uses cookies or other tracking technologies to help us analyze how
users interact with and use the Site, compile reports on the Site’s activity, and provide
other services related to Site activity and usage. The technologies used by Google may
collect information such as IP address, time of visit, whether a visitor is a return visitor, and
any referring website. The information generated by Google Analytics will be transmitted
to and stored by Google and will be subject to Google’s privacy policies. To learn more
about Google’s partner services and to learn how to opt out of tracking of analytics by
Google click here.6
6. Your Choices
How to change of delete Professional Information
Individuals can submit access requests, or opt of inclusion from our database through
contacting us using the details noted in “Who we Are”.
Request Access to Information The Succession Plan has collected
Individuals who want access to the information The Succession Plan has collected about them
can use the contact details provided. Once we have verified an individual’s identity we will
send a report with the information we have collected within 30 days (we may charge £10
for information requests to cover our costs in providing you with details of the information
we hold about you).
Remove The Succession Plan Profile Completely
If you wish to remove your profile completely please contact us on the details mentioned
in “Who we Are” and the information will be removed from any search result available.
How to Opt-Out of Certain Uses of Information
The Succession Plan gives individuals the opportunity to “opt out” of having their information
used for certain purposes. Please specify your preference by letting us know
at DataPrivacy@thesuccessionplan.com
7. How do we keep information Secure?
Information security is important to us. We follow generally accepted industry standards
to protect the information submitted to us, both during transmission and once we receive
it. However, no method of Internet transmission or electronic storage is 100% secure.
Therefore, while we strive to use commercially acceptable means to protect information,
we cannot guarantee its absolute security.
8. Data Retention
We will retain personal information for a period of time consistent with the original
purpose(s) for which we collected it, as described in this Privacy Policy, including, as
applicable, (i) for as long as we have an ongoing relationship with the individual to whom
the information pertains; (ii) as long as needed to provide users, our customers, or our
partners the Services; (iii) as necessary to comply with our legal obligation(s); (iv) as
necessary to resolve disputes or to protect ourselves from potential future disputes; or (v)
as necessary to enforce our agreements. Retention periods will be determined taking into
account the amount, nature, and sensitivity of the personal information and the purpose(s)
for which it was collected. After the retention period ends, we will delete the personal
information. Where we are unable to do so, we will ensure that appropriate measures are
put in place to prevent any further use of such information.7
9. Users in the European Economic Area (EEA), the UK, and
Switzerland
The following information applies to residents of the EEA, the UK, or Switzerland.
The Succession Plan endeavors to comply with the provisions of the General Data Protection
Regulation (“GDPR”) as to any information in its possession regarding EEA-, UK-, and
Switzerland-based persons (“data subjects”). As such, The Succession Plan only processes
personal information on data subjects where it has a lawful basis to do so, which may
include the consent of the person (especially in the case of website visitors who provide
their information), performance of a contract, compliance with a legal obligation, or the
legitimate interest of The Succession Plan or a third party. The Succession Plan provides notice to
all data subjects as required by GDPR Article 13 or 14, as appropriate, and honors the
rights of data subjects provided in Articles 12-23, including the right to be forgotten. For
any opt-out requests or other inquiries related to privacy, please
email DataPrivacy@thesuccessionplan.com
Purposes of processing and legal basis for processing: As explained above, we
process personal information in various ways depending upon data subjects’ use of our
Sites. We process personal information on the following legal bases:
1. consent;
2. as necessary to perform our agreement to provide Services or other applicable
agreements;
3. as necessary for compliance with a legal obligation to which we are subject; or
4. as necessary for the legitimate interests of The Succession Plan and The Succession Plan’s
customers and partners to engage in direct marketing, sales, and recruiting activities,
and The Succession Plan’s legitimate interests in organizing and making available
Professional and Business Profiles, given the limited impact that use of this Business
Information and similar information presents to an individual’s private life
The Succession Plan has put in place safeguards to protect personal privacy and individual
choice, including disclosures of its data processing activities, the use of consent or opt-
outs wherever possible, and the implementation of a privacy
center: DataPrivacy@thesuccessionplan.com
Right to lodge a complaint: Users that reside in the EEA, the UK, or Switzerland have the
right to lodge a complaint about our data collection and processing actions with the
supervisory authority concerned. Contact details for data protection authorities are
available here.
Transfers: Personal information we collect may be transferred to, and stored and
processed in, the United States or any other country in which we or our affiliates or
subcontractors maintain facilities. Per the applicable requirements of the GDPR, we will
ensure that transfers of personal information to a third country or an international
organization are subject to appropriate safeguards as described in Article 46 of the GDPR,
such as the UK or EU Standard Contractual Clauses, as applicable.
Individual Rights: Individuals who are a resident of the EEA, the UK, or Switzerland are
entitled to the following rights under the GDPR. Please note: In order to verify an
individual’s identity, we may require them to provide us with personal information prior to
accessing any records containing information about them.8
• The right to access, correction, and restriction of processing. Individuals have the
right to request access to, and a copy of, their personal information at no charge, as
well as certain information about our processing activities with respect to their data.
Individuals have the right to request correction or completion of their personal
information if it is inaccurate or incomplete. Individuals have the right to restrict our
processing if they contest the accuracy of the data we hold about them, for as long as
it takes to verify its accuracy.
• The right to data portability. Individuals have the right to ask for a copy of their data in
a machine-readable format. Individuals can also request that we transmit their data to
another entity where technically feasible.
• The right to request data erasure. Individuals have the right to have their data erased
from our Platform if the data is no longer necessary for the purpose for which it was
collected, they withdraw consent and no other legal basis for processing exists, or
their fundamental rights to data privacy and protection outweigh our legitimate
interest in continuing the processing.
• The right to object to our processing. Individuals have the right to object to our
processing if we are processing data based on legitimate interests or the performance
of a task in the public interest as an exercise of official authority (including profiling);
using data for direct marketing (including profiling); or processing data for purposes
of scientific or historical research and statistics.
When The Succession Plan is a Controller. The Succession Plan acts as a data controller when we collect and use information about data subjects who are visitors to our Site, as well as
when we collect and use information about data subjects for purposes of creating and
maintaining our Talent Profiles and providing the Services. The Succession Plan’s Data
Protection Officer can be contacted by email at DataPrivacy@thesuccessionplan.com
When The Succession Plan is a Processor. When our customers use our Services, they are
acting as the data controller and are responsible for ensuring that personal information
collected about data subjects is being processed lawfully. In those circumstances, we are
acting as the data processor, and receive personal information as agents of our customers
merely for processing as instructed by our customers. Our customers are solely
responsible for determining whether and how they wish to use our Services, and for
ensuring that all third-party individuals that are a visitor to or user of a website,
application, or service on which a customer uses our Services have been provided with
adequate notice regarding the processing of their personal information, have given
informed consent where such consent is necessary or advised, and that all legal
requirements applicable to the collection, use, or other processing of personal
information through our Services have been met by such customers. Our customers are
also responsible for handling data subject rights requests under applicable law, by their
users and other individuals whose data they process through the Services. The Succession Plan's obligations with respect to personal information for which we are solely a data
processor are defined in our agreements with our customers and are not covered by this
Policy. In certain circumstances, The Succession Plan may act as an independent controller of
personal information in connection with its provision of the Services to customers, such as
when customers agree to contribute data to our database.9
10. Changes to Policy
The Succession Plan can change this Privacy Notice. We may amend this Privacy Notice from
time to time by posting a revised version and updating the “Effective Date” above. The
revised version will be effective on the “Effective Date” listed. If you disagree with these
changes, you may stop using our Websites at any time. Your continued use of our
Websites constitutes your consent to any amendment of this Privacy Notice.
11. Dispute Resolution
If you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of
charge) at https://feedback-form.truste.com/watchdog/request.
12. Contact Us
For questions or concerns regarding this Privacy Policy, please contact us at:
The Succession Plan
Attn: Data Privacy
20 Wenlock Street,
London,
England,
N1 7GU
(020 8135 0747)
Email: info@thesuccessionplan.com