Privacy Policy

Data Privacy Policy

  1. EFFECTIVE DATE.

This Data Protection Policy of August Leadership LLC having its registered office at 275 Madison Av, Suite 1500, New York, New York 10016 (the Company) is made and effective as of 01/01/2020. This policy is applicable to the Company’s subsidiaries as well as affiliates across the globe.

  1. PURPOSE.

The Company is committed to ensuring that all personal data as defined in Article 4 of GDPR is being processed and protected in compliance with the Regulations. However, the company takes reasonable technical, physical, and administrative measures to help secure and protect any personal data in our custody or control. Unfortunately, communications over the internet are not totally secure, and no storage system is impenetrable. The company does not guarantee that any communications, or any information that you submit or that we collect, in connection with the services or otherwise, will be totally secure. Our website is for informational purposes only and does not collect information. The company wants its employees and partners to feel free to report good faith concerns about any violations of data protection. All employees, including board members, staff, executives, and volunteers, should know that they will not face retaliation for violations reported according to this policy.

3. DEFINITIONS OF DATA.
 
The key elements of the policy focus on providing protection in the following areas:
  • Any personal data shall be processed lawfully, fairly and in a transparent manner. Lawful processes include “consent”, “contractual necessity” and “legitimate interest”;
  • Any personal data shall be collected for specified, explicit and legitimate purposes;
  • Any personal data shall be adequate, relevant and limited to what is necessary and kept for no longer than is necessary;
  • Any personal data shall be accurate and up to date;
  • Any personal data shall be processed in a manner that ensures appropriate security of the personal data;

4.  DATA PROTECTION MEASURES. 

To ensure data security and protection, the company uses UK based institutional grade Applicant Tracking System (ATS), Finance and Accounting tools, and Data Storage service providers. Our providers include:

  • Ezekia Applicant Tracking System: Ezekia is a GDPR compliance applicant tracking system which includes candidate management, collaboration tools, CRM, internal HR, interview management, resume parsing, resume search, job board posting, and interaction tracking capabilities. Ezekia can be contacted at [email protected]
  • Microsoft 365: The company utilizes Microsoft 365 licenses and its features for the ongoing daily work.
  • AppRiver: The company has engaged AppRiver, a US headquartered technology services firm, to enhance security and protection measures at the domain level. AppRiver is providing businesses of all sizes with office productivity, security, and endpoint protection technology and services.
  • Additional Measures:
    • Email Choices and Right to Erasure Request Process and Form. See Attached Form.
    • The website has the updated link to the Privacy Policy.
    • The email signatures contain links to Privacy Policy.

5. REPORTING VIOLATIONS. 

To report any suspected breaches of data protection policy, please write, email, or call one of the following resources:

(a) Compliance Officers. Compliance officers are individuals who are responsible for reviewing and investigating reported violations. The Company has appointed the following associates to serve as compliance officers. Suspected violations can be reported to one of the following compliance officers:

(b) Farah Haider, COO and General Counsel, [email protected]

(c) Alternative Reporting Options. If you feel uncomfortable reporting suspected violations to one of the compliance officers or feel that your report has not been addressed properly, contact the Chief Executive Officer at [email protected]

6. CONTENTS OF REPORT. 

In general, a report should contain as much information as possible, including the facts and dates that led you to suspect that a violation occurred. Although you are not required to give your name in your report, contact information will allow the compliance officer to follow up with you with further questions.

7. ANONYMITY AND CONFIDENTIALITY. 
 
Regardless of the method you use to report suspected violations, the Company will make every effort to keep your report confidential. However, the degree of anonymity possible will depend on the reporting method you choose. For example, if you report a suspected violation by telephone, the compliance officer may recognize your voice. Please select the reporting method that supports your desired level of anonymity.
 
8. INVESTIGATING AND RESOLVING REPORTS. 
 
(a) Documentation. When a report is received, the compliance officer will create a file for the suspected violation and will keep all documentation in that file.
 
(b) Timeframe. Investigation of violations shall begin within 5 days of receipt of the report. Every effort shall be made to investigate and resolve reports promptly.
 
9. COMPLIANCE OFFICERS’ DUTIES. 
Compliance officers shall use their best efforts to investigate thoroughly and with consideration for the reporter all reports of suspected violations. Compliance officers must report annually on the submission and resolution of these matters to the board.
 
10. OTHER LAW.  
 
Nothing in this policy may be construed in a way that conflicts with any reporting obligations or protections afforded by state or federal law.
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