Overview:
Definitions, Scope and Applicable Regulatory Information

About this policy

This privacy policy (“Policy”) describes how Impex Resource Management, Inc. d/b/a Kander Consult. (hereinafter collectively referred to as the “Company,” “Kander Consult,” “we,” “us” or “our”) collect, use and share Personal Information of users of http://www.kanderconsult.com (the “Site”), Kander Consult’s corporate clients and Kander Consult employees, contractors and employment applicants. Kander Consult reserves the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on the Policy the date it was last updated. We encourage you to review this Policy whenever you visit our Site to make sure that you understand how any Personal Information you provide will be used.

What is Personal Information?

As used herein, the term “Personal Information” means information that directly or indirectly helps identify an individual (such as a name, address, telephone number, e-mail address, or other account number), and information about that individual’s activities, such as information about his or her use of the Site, or Kander Consult products or services, when directly linked to personally identifiable information. Personal Information also includes demographic information such as date of birth, gender, geographic area and preferences when such information is linked to other Personal Information that identifies you. Personal Information encompasses personal data as defined within the European Union’s General Data Protection Regulation (“GDPR” or “EU GDPR”).

Personal Information does not include “aggregate” information, which is data we collect about the use of the Site or about a group or category of products, services or users, from which individual identities, identifiable information or other Personal Information has been irreversibly removed. In other words, information about how you use a service may be collected, de-identified and then combined with information about how others use the same service. Aggregate data helps Kander Consult understand trends and users’ needs so that we can better consider new features or otherwise tailor our offerings. This Policy in no way restricts or limits our collection and use of aggregate information.

Compliance Frameworks

Standard Contractual Clauses

Transfers of Personal Information from the EEA and UK to Kander Consult are undertaken on the basis of applicable Standard Contractual Clauses, as per Kander Consult’s Data Processing Agreements. Due to the nature of the personal information that is provided to Kander Consult together with all data transfers to the US being encrypted, Kander Consult believes the risk of government surveillance to the privacy of customer data to be very low. Additionally, Kander Consult will only provide personal information to applicable law enforcement authorities when under strict legal compulsion.

California Privacy Rights

• Residents of California have the right to:

• Know what Personal Information we collect about you and from where we collect it

• Access a copy of the Personal Information we hold about you.

• Understand how we process your Personal Information and how it may be shared.

• Opt out of having your Personal Information shared with certain third parties.

• Request we delete your Personal Information.

• To make such a request, please send an email to privacy@Kanderconsult.com.

Federal Trade Commission

Kander Consult, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Use, Retention and Storage of Personal Information

The duration for which Kander Consult retains Personal Information depends on the purposes for which it is used. Kander Consult will maintain Personal Information for as long as Kander Consult has a legal basis and business purpose to do so and, thereafter, for no longer than is required or permitted by law, reasonably necessary for internal reporting and reconciliation purposes, or to provide users with feedback or information that is requested. The information Kander Consult collects will be stored and processed in servers in the United States.

Security of Personal Information

Kander Consult aims to protect the confidentiality, integrity and availability of data by taking reasonable steps given the context of the engagement in which data is provided to protect Personal Information from loss, misuse, interference, unauthorized access, disclosure, alteration, and destruction.

Use of Personal Information

Kander Consult may use your Personal Information to:

• operate, maintain, and improve our sites, products, and services;

• respond to comments and questions and provide customer service;

• send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;

• communicate promotions, upcoming events, and other news about products and services offered by us and our selected partners;

• link or combine user information with other Personal Information;

• protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and

• provide and deliver products and services requested by clients.

Sharing of Personal Information

Personal Information will only be shared with third parties in the following limited circumstances:

• Kander Consult may share Personal Information in order to provide website functionality, analytics, tracking, advertising and marketing through our legitimate interest or with user consent.

• Kander Consult may share Personal Information when we do a business deal, or negotiate a business deal, involving sale or transfer of all or a part of our business or assets. These deals may include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

• Kander Consult may share Personal Information for legal, protection, and safety purposes.

• Kander Consult may share Personal Information to comply with laws.

• Kander Consult may share Personal Information to respond to lawful requests and legal process, including to meet national security or law enforcement requirements.

• Kander Consult may share Personal Information to protect the rights and property of Kander Consult, our agents, customers, and others, this includes enforcing our agreements, policies, and terms of use.

• Kander Consult may share Personal Information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any other person.

• Kander Consult may also share aggregated and/or anonymized data with others for its own uses.

Children’s Privacy

Kander Consult’s products and services, and the Site, are not targeted to or intended for children below the age of 13. If it is believed that Kander Consult has received information from a person protected under child protection laws where necessary parental consent was not obtained, please notify Kander Consult immediately, and steps will be taken to securely remove that information. Kander Consult does not knowingly use Personal Information from children for any purpose except to deliver the products that are committed to Kander Consult clients. If you believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please notify us using the contact details below.

Deleting, Accessing and Updating Data

Users have the right, depending on jurisdiction to request the following actions related to Personal Information stored by Kander Consult:

• Review the data by requesting export and delivery of a machine-readable format

• Correct the data if the data is found to be in error

• Restrict the processing of data in any manner

• Decline inclusion in marketing activities

• Request deletion of Personal Information

Under the EU GDPR, persons in the EU have the right to report to your local Supervisory Authority if you believe your rights under data protection legislation have not been appropriately considered. However, before doing so, please contact us directly at privacy@Kanderconsult.com as we are committed to working with you to help resolve any concerns about your privacy.

How to Request Action on Personal Information

With respect to Personal Information gathered within any of the contexts included below, an individual who seeks access or who seeks to correct, amend, or delete inaccurate Personal Information, or limit the processing or sharing of their Personal Information, should contact privacy@Kanderconsult.com.

In such a request, please make clear: (i) what Personal Information is concerned; and (ii) which of the above rights (i.e. opt out, restrict, object, access, correct, or delete) you would like to enforce. For your protection, Kander Consult may only implement requests with respect to the Personal Information associated with the email address that was used to send the request, and Kander Consult may need to verify the identity of the user behind a request before taking action. Kander Consult will comply with privacy-related requests as soon as reasonably practicable and in any event, within 30 days of the request. Please note that Kander Consult may need to retain certain information for recordkeeping purposes and/or to complete any transactions that began prior to requesting such change or deletion.

Individuals submitting requests should refrain from providing additional Personal Information such as address, phone number, government identifiers, photos or any type of personal documentation. Any such data does not need to accompany the request for action.

With respect to Personal Information gathered through a third party, access and other similar rights will be managed by that third party and governed by such third party’s privacy policy.

Employee, Contractor and Applicant Data at Kander Consult, Inc.

Kander Consult is committed to protecting information collected from employees, contractors, temporary workers and employment candidates. This applies to Personal Information provided to Kander Consult by individuals applying for employment and employees, contractors and temporary employees during employment.

Data Collected

Kander Consult collects Personal Information based on individual employment responsibilities, citizenship and location of employment. Personal Information collected includes but is not limited to: name, address, government identification number (i.e., social security number, national identification number, tax payer identification number, driver’s license, etc.), date of birth, phone number, email address, gender, race, ethnicity, health and disability information, criminal history, resume information including but not limited to educational background, employment history, areas of expertise, job type preferences, and other related information.

How Data is Used

Kander Consult uses data collected on employees, contractors, temporary workers and employment candidates for the following purposes:

• Process employment applications and conduct background investigations.

• Administer compensation benefits and related human resources programs.

• Communicate with personnel.

• Comply with employment reporting regulations.

• Design, evaluate and implement education programs.

• Plan and manage budgets.

• Monitor and manage business related travel and expenses.

• Monitor and evaluate conduct and performance.

• The use of Personal Information includes storing, recording, transferring, summarizing, sharing and destroying Personal Information as necessary under the circumstances or as required by law. Kander Consult will not process Personal Information in a way that is inconsistent with the purposes for which it was collected.

Disclosure of Data

Kander Consult will not disclose or otherwise distribute Personal Information without an individual’s permission except under the following circumstances:

• Third Party Service Providers: Kander Consult discloses Personal Information to third parties such as suppliers, contractors and service agents providing services such as processing compensation, administering benefits, conducting background checks and performing legal and professional services.

• Legal Request and Investigations: Kander Consult may disclose Personal Information to third parties if disclosure is necessary to protect Kander Consult legal interests including but not limited to defending or prosecuting a lawsuit or administrative proceeding, to prevent fraud, to comply with an investigation of suspected or actual illegal activity, or to comply with any statute, law, rule or regulation.

• Protecting Kander Consult and its Partners: Kander Consult may disclose Personal Information to third parties to protect the rights, property, or safety of Kander Consult and its associates, in an emergency situation where the health or security of an associate or applicant may be endangered, and when Kander Consult believes disclosure is necessary or appropriate to prevent physical harm or financial loss.

• Business Transfers: As Kander Consult continues to grow, companies, subsidiaries or business units may be sold or purchased. Under such transactions, Personal Information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing privacy statement.

Accessing and Updating Data

Kander Consult will use reasonable efforts to correct any reported factual inaccuracies in Personal Information. Associates should notify HR immediately about changes to an individual’s legal name, address, dependents, beneficiaries under a benefits plan, and other such status changes. Personnel may request a copy of Personal Information stored by Kander Consult at any time.

Contact information

Kander Consult welcomes your comments or questions about this Policy. You may contact Kander Consult at the following email address: privacy@kanderconsult.com, or by mail at this address:

Impex Resource Management, Inc., d/b/a Kander Consult.
Attn: Privacy
8300 Boone Blvd
Suite 830
Vienna, VA 22182
United States

Changes to this Policy

Kander Consult may change this Policy at its discretion. Any updates will result in a change to the last updated date below.

This Policy was last updated on April 22, 2021.