Privacy Policy

Last Updated: June 8, 2018

FPL is a premier professional services firm dedicated to serving the human capital and organizational needs of the real estate and related industries around the globe. FPL and the other members of the global FPL family of companies (collectively, “FPL,” “we,” “our” or “us”) is serious about protecting your privacy, and we appreciate your trust that we will do so carefully and sensibly.

This Privacy Policy describes FPL’s practices in connection with personal data that we collect through our websites and our executive search services, compensation consulting services and surveys, leadership consulting services, and management consulting services (collectively, the “Services”) where we post or link to this Privacy Policy. For the purposes of this Privacy Policy, “personal data” means any information that, by itself, identifies you or can be combined with other information to identify you.

FPL participates in the EU-US Privacy Shield. Please see below for further details.

What Personal Data Do We Collect?

Information You Provide

We may collect personal data from you in connection with the Services, including over the phone, by email or on paper. For example, if you are a candidate for an executive search engagement, we may collect your name, street address, telephone number, email address, educational background, employment history and overall compensation.

Information from Other Sources

We may also collect personal data about you from other sources and combine that with information we obtain through the Services or directly from you. For example, if the company you work for has engaged FPL to provide certain services, your company may provide us with your name and information regarding your job responsibilities and reporting requirements, as well as information regarding your personal performance.

Information Automatically Collected

When you visit our websites, we may automatically collect certain information about your visit, such as your device’s operating system, application software, Internet Protocol (IP) address, access times, and specific pages that you visited before and after our website through essential and non-essential cookies, web beacons and other tracking technologies (collectively, “Cookies”). Cookies are small text files placed and stored on your computer hard drive, our websites or our emails, which we use to provide and improve our websites and your experience, such as to see which areas and features are popular by analyzing website traffic and usage patterns and/or tell if an email that we have sent to you has been opened and acted upon.

Your web browser may be set to accept cookies automatically, and only you can manage your browser settings. If you do not want information collected through the use of cookies, there is a simple procedure detailed in the “Help” section of the toolbar on most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. Please note that if you decline cookies, you may still use our websites, but some features may not function properly.

Do Not Track

Some internet browsers include the ability to transmit “Do Not Track” signals. Because uniform standards for “Do Not Track” have not been established, we do not process or respond to “Do Not Track” signals at this time.

How Do We Use Personal Data That We Collect?

We may use your personal data for legitimate business purposes, including:

  • To operate and improve our websites;
  • To communicate with you about potential opportunities;
  • To respond to your inquiries;
  • To provide the Services;
  • To conduct compensation studies and other research;
  • To provide you with information and updates about our Services, new offerings and events; and
  • For any other purposes described in this Privacy Policy and the Terms & Conditions or as otherwise disclosed to you in connection with our Services.

Legal Basis for Processing Personal Data

We rely on our legitimate interest in securing, improving and developing our websites and providing Services to you, the need to process your personal data to provide the Services required by contract, and as necessary to comply with legal obligations, as our legal bases (where required) for processing your personal data.

Data Retention

We will retain your personal data for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws.

Cross-Border Data Transfers

FPL is a US-headquartered organization and may store and process your personal data in the United States and other countries that may not have the same level of protection as the country in which you reside. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and applicable law, including with respect to transfers from the EU, relying on our Privacy Shield certification and/or the need to process your information in order to provide the requested services, as the bases for transferring your personal data. You may request details about the suitable safeguards we have in place by contacting us as detailed below.

With Whom Do We Share Personal Data?

We may share your personal data:

  • With any other members of our global family of companies for the purposes described in this Privacy Policy;
  • With our clients, to the extent you are engaged with us as a potential candidate in connection with an executive search or board assignment or otherwise in connection with our consulting services;
  • With our third-party service providers who provide services, such as website hosting, data analysis, information technology and other similar services;
  • In order to: (i) establish, exercise, or defend against legal claims; (ii) comply with laws or to respond to lawful requests and legal process; or (iii) investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person, to the extent permitted by applicable law; and
  • In connection with or during negotiation of any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.

EU-U.S. Privacy Shield

FPL participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework, and as part of this commitment, protects personal data received from the European Union (EU) in accordance with the Privacy Shield Framework’s applicable Principles. To learn more about the Privacy Shield Framework, and to view our self-certification, please visit the Privacy Shield List here.

FPL remains responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to third parties.  FPL complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

FPL commits to resolve complaints about our collection or use of personal data received or transferred pursuant to the Privacy Shield Framework and is subject to the investigatory and enforcement powers of the Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have questions or complaints regarding our participation in or certification to the Privacy Shield Framework, you should first contact FPL at privacy@fpl-global.com with the subject line “Privacy Shield Information.”  If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our third-party dispute resolution provider (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield. In addition, under certain conditions more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

What Choices Do You Have Regarding the Use and Sharing of Personal Data?

Email and Marketing Choices

You may elect at any time to opt-out of receiving any marketing emails and newsletters from us. You can exercise this option by: (i) following the opt-out instructions in promotional emails, or (ii) contacting optout@fpl-global.com with the subject line “Marketing Opt-Out.”

Exercising your Rights

Subject to applicable law in your jurisdiction (e.g., laws in the European Economic Area, United Kingdom, and Switzerland), you may have certain rights with respect to your personal data that we are processing. These rights may include the right to access your personal data, correct inaccurate personal data, object to the processing of your personal data based on FPL’s legitimate interests (e.g., direct marketing purposes), restrict or delete personal data that you have previously provided to us, or to receive an electronic copy of your personal data for purposes of transmitting it to another company. In cases where you provided consent to our processing of your personal data, you have the right to withdraw your consent at any time. If you would like to exercise any of these rights, please contact privacy@fpl-global.com with the subject line “Data Subject Rights Request.”

How Do We Protect Personal Data Collected About You?

FPL takes reasonable technical, physical, and administrative measures to help secure and protect your personal data in our custody or control. Unfortunately, communications over the internet are not totally secure, and no storage system is impenetrable. We cannot and do not guarantee that any communications sent through our websites, or any information that you submit or that we collect, in connection with the Services or otherwise, will be totally secure. Please immediately notify us of any breach of website security, or of this Privacy Policy or the Terms and Conditions, of which you become aware.

Linked Sites

Our websites may contain links to third-party websites. This Privacy Policy does not apply to, and FPL is not responsible for, the privacy practices of those third-party websites. To learn about privacy practices of a linked site, you should read that site’s privacy policies to understand how personal data that is collected about you is used and protected.

Changes to Privacy Policy

FPL may change this Privacy Policy from time to time. If we make any changes to this Privacy Policy, we will change the “Last Updated” date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we may also notify you by posting notice on our websites or by sending you an email.

Who Can You Contact For More Information?

If you have any questions regarding the use or disclosure of your personal data by FPL or our security measures, or if you have questions about this Privacy Policy, please send an email to privacy@fpl-global.com.

Alternatively, inquiries may be addressed to:

FPL Corporate Services LLC
Chief Administrative Officer
123 North Wacker Drive, Suite 1900
Chicago, Illinois 60606
USA

EU residents may also lodge a complaint with the data protection authority in the EU member state where they live, work or where an alleged infringement of applicable data protection law occurred.