Privacy Policy
Effective Date: January 3, 2020
Last Updated: March 1, 2021
Teneo is committed to protecting and respecting your privacy.
This Privacy Notice (this “Notice”) explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure.*
It applies to those who may view and communicate with us through our Website as well as people with whom we do business.
Teneo reserves the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Notice, the ways in which Teneo collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: +1 (212) 886-1600
E-mail: [email protected]
Postal Address:
Teneo Holdings LLC
Attn: General Counsel
280 Park Ave, 4th Floor,
New York, NY 10017
*This Notice complies with the California Consumer Privacy Act of 2018 (the “CCPA”). Supplemental provisions applicable to visitors, users and others who reside in California are described below in the section entitled CALIFORNIA RESIDENTS. For residents in the European Economic Area who may be entitled to rights under the General Data Protection Regulation issued by the European Union please see the section entitled EUROPEAN UNION.
ABOUT TENEO
Teneo, is a global advisory firm that provides comprehensive strategic advisory services across a wide range of key objectives and issues addressing complex business and reputational challenges. We support chief executives, their boards, and the communications, corporate affairs, investor relations, and marketing teams of the world's largest organisations.
Teneo’s global headquarters is located at 280 Park Ave, 4th Fl, New York, NY 10017.
COLLECTION AND USE OF PERSONAL INFORMATION
Personal information is data that can be used to identify or contact a single person.
Depending on where you live, and in accordance with applicable laws, we may collect various categories of information from you when you access or use our Website and when you provide information directly to us (e.g., when you register for our events, request our services, explore a business opportunity through our Careers portal, or access various content and features on our Website). Those categories include:
Identifiers, such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;
Personal Information such as your signature, social security number, physical characteristics or description, passport number, driver’s license or state identification card number, education (e.g., grades, transcripts), employment (e.g., current or past job history or performance evaluations), bank account number, or any other financial information, medical information, or health insurance information;
Internet or other similar network activity, such as browsing history, search history, or information on your interaction with our Website;
Location data, but not your precise geolocation. We may collect location information provided by a mobile or other device interacting with this Website, or associated with your IP address or other online or device identifier. We may collect this information through the lawful use and deployment of cookies and other tracking technologies, as set forth in our Cookie Policy.
You may choose not to provide personal information to Teneo by refraining from, among other things, submitting information directly to us. However, if you do not provide information when requested, we may not be able to provide you with information about our services and business opportunities.
We may store and use personal information to:
- track the usage of our Website and to help us improve our services and understanding of the interests and needs of those who contact us;
- carry out our obligations arising from any contracts between you or the company you work for and us;
- provide you with the information and services that you request from us;
- guide us in answering your questions or to explore career, professional or business opportunities with you;
- develop analysis and business intelligence that enable us to operate, grow, protect, make informed decisions and report on the performance of our business;
- pursue other legitimate interests of our own such as maintaining a database of contacts working with or in our industry for networking or business development purposes.
PROTECTING PERSONAL INFORMATION
We secure personal information against unauthorized or unlawful processing, and against accidental loss, destruction or damage by appropriate technical, physical and organizational measures.
We evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal information.
We also take measures to ensure confidentiality, meaning that only people who have a need to know and use the personal information can access it.
SHARING YOUR INFORMATION
We will never sell or rent your personal information to third parties.
We sometimes share personal data among the group of companies owned by Teneo. This may involve transferring your personal information to other countries (including the U.K., and other countries, inside and outside the European Economic Area) where Teneo companies or other third parties operate and process your personal information. We also share personal data with vendors or agents working on our behalf for the purposes described in this Notice.
To the extent that we do share your personal information, we would only do so if we have entered into a written agreement with that party and that party has agreed to comply with our privacy standards as described in this Notice.
We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets, where we are required to do so by law, support auditing, compliance and corporate governance functions, in connection with legal proceedings or where disclosure is necessary to protect the vital interests of a person.
DATA RETENTION
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
CHANGES TO YOUR INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
CALIFORNIA RESIDENTS
For purposes of the CCPA, personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Teneo may obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase;
- Indirectly from you. For example, from observing your actions on our Website;
- From third-party business partners such as social media sites (LinkedIn), ad networks, and analytics providers.
Please note that Teneo, in accordance with all applicable laws, will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Rights and Choices of California residents under the CCPA
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Teneo disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Teneo delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- contacting our General Counsel located at our headquarters in New York; or
- visiting https://www.teneo.com/
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you services.
- Charge you different prices or rates for the services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of services.
- Suggest that you may receive a different price or rate for services or a different level or quality of services.
EUROPEAN UNION RESIDENTS
Your rights in connection with personal information
If you are in the European Economic Area and are entitled to rights provided under the General Data Protection Regulation issued by the European Union you may:
- request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate,
- request erasure of your personal information where there is no good reason for us continuing to process it;
- object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground,
- object where we are processing your personal information for direct marketing purposes,
- request the restriction of processing of your personal information,
- request the transfer of your personal information to another party.
If you believe you may be entitled to rights provided under the GDPR and want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our General Counsel located at our headquarters in New York.
Effective Date: 26 August, 2025
Last Updated: 15 September 2025
1: Purpose and nature
Teneo Financial Advisory Australia Pty Ltd (ACN 687 059 070) and Teneo Strategy Australia Pty Ltd (ACN 159 824 138) (Teneo) recognise the importance of your privacy. This Privacy Policy explains how Teneo intends to collect, store, use, disclose, protect and otherwise handle your personal information having regard to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).
This Privacy Policy does not constitute a contractual representation, promise, guarantee or warranty by Teneo to you as to the manner in which Teneo will or may collect, store, use, disclose, protect or otherwise handle your personal information. Some matters are beyond the control of Teneo, such as third party malicious or criminal attacks.
Teneo may allow its related entities, including its subsidiaries, to use and process your personal information in the same way and to the same extent that Teneo is permitted to under this Privacy Policy. These related entities comply with the same obligations that Teneo has to protect your personal information under this Privacy Policy.
2: What is personal information?
Personal information is information or an opinion about you from which you can be reasonably identified. This includes your name, contact details, date of birth and financial details.
3: Why does Teneo collect personal information?
Teneo collects personal information for the primary purpose of providing professional services to our clients, including insolvency, restructuring and other financial advisory services, and to otherwise perform our business functions and activities. Teneo may also use your personal information for secondary purposes closely related to this primary purpose.
If Teneo does not collect your personal information, it may not be able to provide you with its services.
4: What personal information does Teneo collect?
The types of personal information collected by Teneo includes, but is not limited to, the forms of Personal Information listed below.
(a) names;
(b) contact details of our actual and prospective clients, suppliers and other business contacts (including address, email address, telephone number(s) and other contact details);
(c) dates of birth;
(d) gender;
(e) tax file numbers and tax related information, such as tax residency;
(f) passport numbers;
(g) drivers licence numbers;
(h) financial and investment information including but not limited to income, expenditures, details of owned vehicles, properties, shareholdings, personal guarantees, debts or debts owed, payroll records and banking details;
(i) superannuation and insurance information;
(j) educational background, occupation, directorship and employment details including past employment (in respect of job applicants for positions in respect of us or our clients);
(k) other personal information Teneo is required or permitted to collect by law, regulation, rule or professional standard; and
(l) other information you provide to us.
4.2: Additional personal information for insolvency appointments
In addition to the personal information that may be collected from you, as listed above, the following information may also be collected where a representative of Teneo has been appointed as an insolvency practitioner and requires such information in accordance with that appointment:
(a) details of financial benefits, vehicles, properties, bonuses and dividends a person received because of their function and occupation within a company which is subject to an insolvency or restructuring regime (the “Company”);
(b) details of personal guarantees or indemnities you may have given in respect of the Company’s liabilities;
(c) occupation and function within the Company and explanation you provide of the reasons for the Company’s insolvency (where appropriate);
(d) marital status, details of co-habitees/co-occupants and dependents;
(e) all other information reasonably required in accordance with an insolvency appointment; and
(f) CCTV footage that has been collected by our clients and provided to Teneo (for example, a company in respect of which a representative of Teneo has been appointed as an insolvency practitioner), where:
(i) the client is responsible for the initial collection of the CCTV footage and complying with its legal obligations when doing so;
(ii) the client provides the CCTV footage to Teneo for the limited purpose of enabling us to carry out our functions and activities, including the conduct of insolvency and restructuring services; and
(iii) we collect this CCTV footage only where it is reasonably necessary for, or directly related to, the performance of our functions and activities.
4.3: Sensitive Information
The personal information collected by Teneo may include sensitive information, which is defined in the Privacy Act as information or an opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information, or in some cases biometric data. Teneo will only use sensitive information:
(a) for the primary purpose for which it was obtained;
(b) for a secondary purpose that is directly related to the primary purpose;
(c) with your consent; or
(d) where required or authorised by law.
5: How does Teneo collect your personal information?
Teneo will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner. When you provide Teneo with personal information you consent to the use, disclosure and handling of your personal information in accordance with this Privacy Policy and any subsequent amendments (see clause 13).
5.1: Collecting information from you
If it is reasonable and practical to do so, Teneo will collect personal information directly from you.
Depending on how you choose to interact with Teneo, Teneo may collect your personal information when you contact, or are contacted by, Teneo or its service providers by telephone, by mail, by email, through Teneo’s website, apps, social media and other digital services or when you complete a form or document and provide it to Teneo.
5.2: Collecting information from third parties
Teneo may also collect information about you from other people (e.g., a third party administrator) or independent sources. For example, Teneo may collect personal information about you from its services providers and professional advisors, clients, related entities of a corporate group, other publicly available sources, commercial or subscription-based databases, regulatory or government bodies, or character referees in an employment context. However, Teneo will only do so where it is not reasonable and practicable to collect the information from you directly. Where Teneo has collected your information from a third party, such personal information will be held, used and disclosed by Teneo in accordance with this Privacy Policy.
5.3: Collecting information from visits to Teneo’s website
When you visit Teneo’s website, you are generally in control of the personal information you share with Teneo. Teneo may also collect information based on how you use its website, including through 'cookies', web beacons, analytics and other similar technologies. Teneo may capture limited personal data automatically via these tools.
Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable Teneo’s systems to recognise your browser and record non-personal information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).
Teneo uses cookies to provide you with a more consistent experience across our services. No attempt is made by Teneo to use Cookie Information to personally identify you. However, if Cookie Information is linked with personal information as set out above, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.
You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of Teneo’s website may not function fully for users that disable cookies. Please see the Teneo Cookies Policy (https://www.teneo.com/cookie-policy/) for more information on the data collected, how it is used, and how you can manage your preferences.
Teneo’s legal grounds for processing personal data in connection with the website are:
(a) Teneo’s legitimate interest in effectively delivering information and services to you and ensuring the effective and lawful operation of its business;
(b) Teneo’s legitimate interest in developing and improving the website; and
(c) your explicit consent as a visitor to the website.
The Teneo website may contain links to third-party sites not controlled by Teneo and which do not operate under Teneo’s privacy practices. When you link to third-party sites, Teneo’s privacy practices no longer apply and Teneo does not accept any responsibility for the information you provide on those sites or for their collection and use of your personal information. Teneo encourages you to review each third-party site’s privacy policy before disclosing any personally identifiable information.
Teneo uses social media platforms for a variety of purposes, such as recruitment and marketing, and to provide easy access to relevant information regarding matters such as opportunities and events. Although Teneo is responsible for the content published using its social media platforms, Teneo is not responsible for managing those platforms. Individuals engaging with Teneo via these channels are required to adhere to the legal and privacy terms imposed by the relevant social media platform provider.
The Teneo website is not intended for use by minors under the age of sixteen (16) years. It is Teneo’s policy not to knowingly collect or maintain personal data for anyone under the age of 16 except as part of an engagement to provide professional services.
5.4: Unsolicited information
If Teneo receives personal information that it has not requested and determines that the personal information received is not reasonably necessary to provide its services, Teneo will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.
6: How does Teneo hold your personal information?
The security of your personal information is important to Teneo. Accordingly, Teneo takes reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification or disclosure. These steps include the implementation of the following safeguards:
(a) data encryption and implementation of IT infrastructure security measures;
(b) physical controls such as swipe card access to buildings and locked filing units;
(c) digital data access controls; and
(d) protected databases, staff training, system firewalls and internal information security policies.
Teneo is required by law to retain data for compliance purposes for extended periods of time. When Teneo is no longer required to hold data for such compliance purposes (where such timeframes have been complied with), or where the data is no longer reasonably required, it will take reasonable steps to permanently de-identify or destroy personal information contained within the data.
6.1: Security breach procedures
Teneo’s data security practices have been adopted with a view to protecting the data held by Teneo. Notwithstanding this, individuals should be aware that there are inherent risks associated with the transmission of data over the internet and other mediums. Accordingly, Teneo cannot guarantee any transmission will be completely secure.
7: How does Teneo use your personal information?
Teneo may hold, use or disclose your personal information so that it can:
(a) provide professional services to you or other clients;
(b) comply with the terms of its client engagements;
(c) respond to an individual’s request;
(d) communicate, and maintain contact, with clients, including responding to client inquiries and feedback, keeping clients informed of news and events, and sending clients industry publications and other material;
(e) for general management and reporting purposes, such as invoicing and account management;
(f) for quality reviews, training and other quality enhancement initiatives;
(g) to develop methodologies, services, products and technology, and in research, benchmarking and studies;
(h) for recruitment purposes;
(i) for purposes related to the employment of our personnel, including the provision of benefits and providing internal products and services to our staff; and
(j) other purposes related to our business (for example, photographs or videos we take at seminars or events may be used for training and promotional purposes).
Teneo may also hold, use or disclose your personal information to:
(a) consider any concern or complaint that you raise against Teneo or to manage any legal action between you and Teneo;
(b) prevent or investigate any actual or suspected fraud, unlawful activity or misconduct; or
(c) comply with any relevant laws, regulations, codes of practice and court orders.
7.1: Direct Marketing
Teneo may also use your personal information to identify and promote products or services that may be of interest to you.
You may opt out of receiving direct marketing communications from Teneo. To do so, please click the unsubscribe or opt out link in the communication or contact the email address at clause 12. Unless and until you opt out, your consent to receive direct marketing communications from Teneo and to the handling of your personal information for this purpose will continue.
7.2: Data analytics
We may use de-identified or aggregated information for research, analytics, service improvement, artificial intelligence or machine learning purposes. We may use commercially available artificial intelligence products to support our business operations. Wherever practicable, data will be de-identified before analysis to prevent re-identification of individuals. Personal information will not be used to train artificial intelligence tools or otherwise improve the underlying models.
8: How is personal information disclosed to others?
Teneo does not sell, rent or trade personal information to, or with third parties.
Teneo may disclose your personal information to third parties in limited circumstances, including government agencies, independent contractors and consultants, insurers, travel service providers, mail houses, off-site security storage providers, information technology providers, event managers, credit managers, debt collecting agencies and each of Teneo’s affiliates.
Teneo’s website may contain certain links to other websites. Teneo does not share your personal information with those websites, and it is not responsible for the privacy practices applying in respect of those websites. For more information, please refer to Teneo’s Terms of Use (https://www.teneo.com/terms/).
8.1: Cross-border disclosure
Teneo may transfer your personal information to its affiliates located outside Australia. Global office locations include, but are not limited to the United Kingdom and United States of America. Teneo may transfer your personal information to other entities outside Australia to assist Teneo in providing its services, or to provide certain products and services to Teneo (including cloud storage providers). We will take reasonable steps to ensure overseas recipients handle your information in compliance with Australian privacy laws, or otherwise obtain your consent where appropriate.
9: Change of control
If Teneo sells, assigns or otherwise transfers part or the whole of its business (including through a business sale, divestment, merger or other similar transaction), your personal information may be among the items transferred or sold to the extent that it is relevant to Teneo’s business and the transaction undertaken.
10: How you may access or correct your personal information
You may contact Teneo to request access to the personal information it holds about you at any time. You may also ask Teneo to correct information about you that you may believe is inaccurate, incomplete or out of date.
Please contact Teneo using the contact details set out in clause 12. Teneo will need to verify your identity before giving you access to, or correcting, your personal information. Teneo will respond to the request within a reasonable period after the request is made. There is no charge to make a request, however Teneo may charge a reasonable fee to cover the administrative costs of retrieving your personal information.
In certain circumstances, Teneo may refuse, or be unable, to correct or provide you with access to your personal information. In these circumstances, Teneo will write to you to explain the reasons why this is the case.
11: How you may complain if you have concerns about how Teneo has managed your personal information
If you have a complaint related to how Teneo has managed your personal information, please contact Teneo using the contact details set out in clause 12. Teneo may ask you to place your concerns in writing so that its compliance staff can fully understand and investigate your complaint.
Teneo will provide you with an estimated response timeframe in relation to your complaint. In any event, Teneo will endeavour to respond to your complaint within 30 days.
If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined.
12: How to contact us
If you have any questions about this Privacy Policy or Teneo’s management of your personal information, please contact Teneo on:
Email: [email protected]
13: Changes to Teneo’s privacy policy and information handling practices
This Privacy Policy is subject to change at any time so we encourage you to review this Privacy Policy at regular intervals. If Teneo changes this Privacy Policy an updated version will be posted on Teneo’s website to notify you of this change. By continuing to use Teneo’s services after that time you will be deemed to have accepted any changes to its Privacy Policy.
Effective Date: January 5, 2022
Introduction
Teneo is committed to protecting and respecting your privacy.
This privacy notice (“Notice”) explains what personal information Teneo gathers about you, what we use it for and who we share it with.
It applies to those who may view and communicate with us through our website as well as people with whom we do business.
We may change this Notice from time-to-time so please check this page occasionally to ensure that you’re happy with any changes. When we make changes to this Notice, we will post the updated Notice on the website and update the Notice’s effective date.
If you have any questions or comments about this Notice, the ways in which Teneo collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:
Email: [email protected]
Post: Privacy Office, Nerine Chambers, PO Box 905, Road Town, Tortola, British Virgin Islands
About Teneo
Teneo is a global advisory firm that provides comprehensive strategic advisory services across a wide range of key objectives and issues addressing complex business and reputational challenges. We support chief executives, their boards and the communications, corporate affairs, investor relations and marketing teams of the world's largest organisations.
This Notice is issued on behalf of Teneo (British Virgin Islands) Limited. When we mention “Teneo,” “our,” “we” or “us" in this Notice, we are referring to the relevant company in the Teneo Group responsible for processing your data. Teneo Holdings LLC is the company responsible for Teneo.com.
Collection and Use of Personal Information
In this Notice, “personal data” (sometimes referred to as "personal information", "personally identifiable information" or "PII") means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier.
We may collect personal data directly (for example, when we perform professional services through a contract, you attend an event or subscribe to a newsletter) or indirectly (for example through public sources or from our clients).
The categories of personal data we may collect include:
Identifiers such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;
Personal Information such as your signature, physical characteristics or description, passport number, driver’s license, educational background, employment history, bank account number, any other financial information, or CCTV footage;
Internet or other similar network activity such as browsing history, search history or information on your interaction with our website;
Location data, but not your precise geolocation. We may collect location information provided by a mobile or other device interacting with this website or associated with your IP address or other online or device identifier. We may collect this information through the lawful use and deployment of cookies and other tracking technologies, as set out in our Cookie Policy.
We typically do not collect sensitive or special categories of data about individuals other than employees; however, in some circumstances it may be necessary for us to process sensitive personal data, for example:
- Personal identification documents which may reveal race, religion, ethnic origin or in some cases biometric data;
- Information that is provided to us by our clients in the course of providing our professional services;
- Health data where this is necessary, for example to provide a safe environment for our staff, clients and suppliers.
If you choose not to provide, or object to us processing, the information we collect (see the "Your rights" section below), we may not be able to process your instructions or continue to provide some or all of our services to you or our client.
When our client or another third party gives us personal data about you, we take reasonable steps to make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing and has obtained any necessary permission for us to process that information as described in this privacy statement.
If any information you give us relates to a third party by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.
How we use your personal data
We process information about you and/or your business to enable us and other members of the Teneo Group to provide our services to you or our clients, and to meet our legal or regulatory obligations. Some of your personal data may be used for other business purposes.
Please select the relevant purpose below for further detail as to how we process your personal data.
Clients
Collecting your personal data
When Teneo provides professional services, we process information about you and/or your business to enable us to provide our services to you or our clients and to meet our legal or regulatory obligations when we have a valid business reason to do so. We only ask our clients to share personal data with us where it is necessary in order to provide our services or other agreed purposes.
We also process personal data of individuals who are not directly our clients (for example, employees, customers or suppliers of our clients). See the section “Individuals whose personal data we obtain in connection with providing services to our clients” for additional information.
Because we provide a wide range of services to our clients or other third parties, we process many categories of personal data. The majority of the personal data we collect and use is supplied voluntarily by our clients (or collected from third-party sources at the request of our clients). As a result, if you are a client of Teneo, it will generally be obvious to you what personal data we collect and use. This information generally includes (as appropriate for the services we are providing):
- Basic information, such as your name, the organisation you work for and your job title;
- Contact information, such as your address, email, and mobile phone number;
- Financial and tax-related information, such as your income, investments and tax residency; and
- Any other information relating to you (or other third parties) which you provide to us for the purpose of receiving our services.
For certain services or activities, and when permitted by law or with an individual’s consent, we may also process special categories of personal data. Examples of these activities include performing “know your client” checks (which require us to process government identification documents that may contain biometric data or data revealing racial or ethnic origin) and providing you with lunch during a meeting. It is important you provide us with all necessary information and documents as this affects our ability to provide services to you.
Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.
Use of your personal data
We use this information for the following reasons:
- Providing professional services to you, including corresponding with you, other third parties, our service providers or competent authorities;
- Client account opening and other administrative tasks;
- Financial accounting, invoicing and tax purposes;
- Relationship management with clients and prospective clients, which may involve:
- Sending you thought leadership or details of our products and services;
- Contacting you for feedback on services;
- Sending you event invitations; and
- Other marketing or research purposes;
- Recruitment and business development, which may involve:
- The use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
- The use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
- Administering, managing and developing our business and services, which may involve:
- Developing our businesses and services (such as identifying client needs and improvements in service delivery);
- Maintaining and using our IT systems; and
- Administering and managing our website, systems and applications;
- Services we receive from our professional advisors, such as lawyers, accountants and consultants;
- Security, quality and risk management activities;
- Complying with our legal and regulatory obligations and any requirements of a professional body of which we are a member; and
- Protecting our rights and those of our clients.
Our legal grounds for processing your personal data are:
- Compliance with a legal or regulatory obligation;
- Explicit consent to processing your information for a specific reason;
- Performance of the contract we have with you (or taking steps to enter into a contract with you); and
- A legitimate interest pursued by us or a third party, including to:
- Provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
- Prevent fraud;
- Protect our business interests;
- Ensure that complaints are investigated;
- Evaluate, develop or improve our services or products; or
- Keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- You have given us your explicit consent to process that data;
- We are required by law to process that data in order to ensure we meet our “know your client” and “anti-money laundering” obligations (or other legal obligations imposed on us);
- The processing is necessary to carry out our obligations under employment, social security or social protection law;
- The processing is necessary for the establishment, exercise or defense of legal claims; or
- You have made the data manifestly public.
Please note that in certain circumstances it may still be lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Individuals whose personal data we obtain in connection with providing services to our clients
Collecting your personal data
As part of the professional services Teneo provides to clients, we process personal data of individuals with whom we do not have a direct (contractual or other) relationship. For example, if Teneo undertakes a review on behalf of a client, we obtain personal data concerning the target’s employees, management and customers.
We seek confirmation from our clients that any personal data they provide has been processed in compliance with relevant privacy laws and regulations and that they have authority to provide personal data to us in connection with the performance of our services.
Because we provide a wide range of services, we process many categories of personal data. This information generally includes (as appropriate for the services we are providing):
- Personal details, such as your name, age/date of birth, gender, marital status and country of residence;
- Contact information, such as your address, email and mobile phone number;
- Financial and tax-related information, such as your income, investments and tax residency; and
- Employment details, such as your role, rank, experience, performance data and employment numbers.
For certain services or activities and when permitted by law or with an individual’s consent, we may also process special categories of personal data.
Use of your personal data
We use this information for the following reasons:
- Providing professional services;
- Administering, managing and developing our businesses and services;
- Security, quality and risk management activities;
- Complying with any requirement of law, regulation or a professional body of which we are a member; and
- Where agreed with our clients, we may use non-personal, anonymised and aggregated information that we receive in the course of providing professional services for other lawful purposes, including data analytics, research, submissions, thought leadership and promotional activity.
Our legal grounds for processing your personal data:
- Compliance with a legal or regulatory obligation; and
- A legitimate interest pursued by us or a third party, including to provide our services to our clients and other third parties and ensure that our client engagements are well-managed.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- You have given us your explicit consent to process that data;
- We are required by law to process that data in order to ensure we meet our legal obligations;
- The processing is necessary to carry out our obligations under employment, social security or social protection law;
- The processing is necessary for the establishment, exercise or defence of legal claims; or
- You have made the data manifestly public.
Please note that in certain circumstances it may still be lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Individuals who get in touch with us another way
Individuals who contact us by email, phone and voicemail
We collect personal data when an individual contacts us with a question, complaint, comment or feedback (such as your name, contact details and contents of the communication). In these cases, you are in control of the personal data shared with us and we will only use the data for the purpose of responding to your communication.
Individuals who contact us through our social media sites
We use social media platforms for a variety of reasons, including recruitment, marketing and providing easy access to relevant information regarding opportunities and events. Although Teneo is responsible for the content published using our social media platforms, we are not responsible for managing those platforms. You are therefore obliged to adhere to the legal and privacy terms imposed by the relevant social media platform provider.
Insolvency and restructuring
See separate insolvency notice.
Journalists
Collecting your personal data
We engage with journalists and other individuals who work in the media on behalf of our clients as part of the professional services we provide and may process your personal contact information and areas of interest.
Use of your personal data
We use this information for the following reasons:
- Facilitating contacts and arranging interviews with individuals employed by our clients
- Sharing insights with you on areas that we think are relevant
- Responding to any questions relating to our clients or more generally
- Sending invitations to relevant events or meetings.
Our legal grounds for processing your personal data are:
- Our legitimate interest in undertaking any of the above actions
- Your explicit consent.
Participants in events and meetings
Collecting your personal data
We will collect personal data in connection with your attendance at Teneo meetings, conferences, events and learning sessions, which will be provided directly by you. This may include the following (to the extent required for a particular event):
- Name, age or date of birth;
- Email address;
- Company;
- Job title;
- Telephone number;
- Dietary / accessibility requirements;
- Guest details; and
- Other specific event-related data such as: arrival time/departure time, hotel check-in/check-out time, flight information (airline, arrival and departure dates).
We do not intentionally collect sensitive category data, unless you provide us with such data (for example, special dietary requirements which reveal your religious affiliation or any food allergies or other data relating to your health necessary to provide support to participants, if needed, for example, if a wheelchair will be required).
Use of your personal data
We will use your personal data to manage our events and to ensure that any special requirements you request are communicated to any relevant third parties. For example, we will share any dietary requirements that you provide to us with venues and/or caterers.
Our legal grounds for processing your personal data are:
- Your explicit consent as a participant;
- Our legitimate interest in organising events and managing the registration process for such events;
- Our legitimate interest in protecting our people, assets and information, and to prevent unauthorised people gaining access to off-site events; and
- Our legitimate interest in providing information about Teneo, our services and events we organise.
Suppliers
Collecting your personal data
We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship and contract with our suppliers, to receive services from our suppliers and, where relevant, to provide professional services to our clients.
The personal data we process is usually limited to contact information (name, name of employer, phone, email and other contact details) and financial information (payment-related information).
Use of your personal data
We use this personal data for the following reasons:
- Receiving services from our suppliers;
- Providing professional services to our clients;
- Administering, managing and developing our business and services;
- Security, quality and risk management activities;
- Providing information about us and our range of services; and
- Complying with our legal and regulatory obligations.
Our legal grounds for processing your personal data are:
- Performance of a contract;
- Compliance with a legal or regulatory obligation;
- Our legitimate interest in managing payments, fees and charges;
- Our legitimate interest in safeguarding Teneo against inadvertently dealing with the proceeds of criminal activities or assisting in any other unlawful or fraudulent activities; and
- Our legitimate interest in carrying out any of the above actions.
Visitors to our office
Collecting your personal data
The personal data which we collect from visitors to our office, provided directly by you, is generally limited to your name, email address, mobile number (where relevant) and the time you enter and leave our office. Our sign-in processes vary between offices and more information will be provided on arrival. If you have any queries in advance of visiting an office please email [email protected]
WIFI
We monitor traffic on our WIFI networks. This allows us to see limited information about a user’s network behaviour, including (at least) the source and destination addresses the user is connecting from and to.
CCTV
We use CCTV monitoring where permitted by law. CCTV images are securely stored and are only accessed on a need-to-know basis (for example, to look into an incident). We may disclose CCTV images to law enforcement bodies as requested and permitted by law. We will also share CCTV images with our insurers for the purpose of processing an insurance claim as a result of an incident. CCTV recordings are typically deleted or automatically overwritten after a short period of time, unless an issue is identified that requires further investigation.
Use of your personal data
We use this personal data for the following reasons:
- Communicating with visitors in relation to their attendance and conduct at our office;
- Providing visitors with facilities including access to our office, conference rooms or WIFI;
- Controlling access to our office; and
- Protecting our office, personnel, goods and confidential information.
Our legal grounds for processing your personal data are:
- Our legitimate interest in protecting our offices, personnel, goods and confidential information; and
- Our legitimate interest in preventing and detecting crime, and establishing, exercising and defending legal claims.
Visitors to our website
Collecting your personal data
When you visit our website, you are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies and analytics tools on our website. Please see our Cookies policy for more information on the data that is collected and how it is used.
Our legal grounds for processing your personal data are:
- Our legitimate interest in effectively delivering information and services to you and the effective and lawful operation of our business;
- Our legitimate interest in developing and improving our site; and
- Your explicit consent as a visitor to the website.
Third party links
Our website may link to third party sites not controlled by Teneo and which do not operate under our privacy practices. When you link to third party sites, Teneo’s privacy practices no longer apply and we do not accept any responsibility for the information you provide on those sites or their collection and use of your personal information. We encourage you to review each third-party site’s privacy policy before disclosing any personally identifiable information.
Minors
Our website is not intended for use by minors under the age of sixteen (16) years. It is Teneo’s policy to not knowingly collect or maintain the personal data for anyone under the age of 16 except as part of an engagement to provide professional services.
Protecting personal information
Teneo takes the security of all the data we hold very seriously. We have in place reasonable commercial standards of technology and operational security to protect your personal information from loss, misuse and unauthorised access, disclosure, alteration or destruction. Only authorised personnel, with appropriate awareness of privacy obligations, are provided access to your personal information. We regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
All our staff and third-party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.
Sharing your information
We will only share your personal data when we are legally permitted to do so, in connection with any of the purposes outlined in the “How we process your personal data” section above. This may involve disclosing your data to:
- Other members of the Teneo Group or third parties that provide services or online platforms to us and/or the Teneo Group;
- Competent authorities (including courts and authorities regulating us and other members of the Teneo Group);
- Our clients;
- Your employer and/or its advisers, or your advisers;
- Our auditors, insurers and professional advisers;
- Any other person or organisation after a restructure, sale or acquisition of any member of the Teneo Group, as long as they use your information for the same purposes we did;
- Credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
- Other third parties that reasonably require access to personal data relating to you.
As a result of sharing your personal data with the above parties, information we hold about you may be transferred to and stored in other countries. This may include countries outside of the European Economic Area (“EEA”) and countries with laws that have not necessarily been determined to provide an adequate level of protection for the processing of personal data under the laws of the EU or other jurisdictions.
When we, or our permitted third parties, transfer your personal data outside the EEA we will take reasonable steps to ensure that your information is treated securely and the means of transfer provide adequate safeguards.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means and the applicable legal requirements.
We seek to ensure that we only keep your personal data for the longest of:
- The period necessary for the relevant activity or services;
- Any retention period that is required by law; or
- The period in which litigation or investigations might arise in respect of the services.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If you would like to know more about the retention periods we apply to your personal data, please contact us at [email protected].
Your rights
You have various rights in relation to your personal data. In particular, you have a right to:
- Request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate;
- Request erasure of your personal information where there is no good reason for us continuing to process it;
- Object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
- Object where we are processing your personal information for direct marketing purposes;
- In some circumstances, request the restriction of processing of your personal information;
- In some circumstances, request the transfer of your personal information to another party.
If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:
- writing to the Privacy Office, Teneo (BVI) Limited Nerine Chambers, PO Box 905, Road Town, Tortola, British Virgin Islands ; or
- sending an email to [email protected].
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not, in general, have to pay a fee to exercise any of your individual rights set out in this Notice. However, we may refuse to provide access or charge a few for access if the relevant data protection legislation allows us to do so, in which case we will provide reasons for our decision as required by the law.
We hope that we will be able to resolve any query or concern you raise. However, if you feel that we have not handled your query or complaint to your satisfaction, you can contact the Information Commissioner, which regulates and supervises the use of personal data in the BVI. If you are not based in the BVI, you have a right to complain to the relevant supervisory authority in your jurisdiction.
Effective Date: May 28, 2021
Teneo is committed to protecting and respecting your privacy.
This Privacy Notice (this “Notice”) explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
It applies to those who may view and communicate with us through our Website as well as people with whom we do business.
By choosing to access and use this Website, you accept and agree to abide by Teneo’s Notice and its practices regarding the handling of and measures for protecting your personal information or data. Therefore, please read this Notice closely in order to be aware of your rights and obligations, being sure to consult the most up-to-date version in so far as you also accept and acknowledge that Teneo reserves the right, at any time, to modify, change or update this Notice without notice. By choosing to access and use this Website, you agree to such things as Teneo collecting and using your personal information or data in keeping with this Notice, on the understanding that Teneo complies with applicable Canadian laws and regulations.
If you have any questions, comments, or concerns about this Notice, the ways in which Teneo collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights under Canadian laws, please do not hesitate to contact us at:
Phone: +1 (212) 886-1600
E-mail: [email protected]
Postal Address:
Teneo Holdings LLC
Attn: General Counsel
280 Park Ave, 4th Floor,
New York, NY 10017
About Teneo
Teneo, is a global advisory firm that provides comprehensive strategic advisory services across a wide range of key objectives and issues addressing complex business and reputational challenges. We support chief executives, their boards, and the communications, corporate affairs, investor relations, and marketing teams of the world's largest organisations.
Teneo’s global headquarters is located at 280 Park Ave, 4th Fl, New York, NY 10017.
Collection & Use of Personal Information
Personal information is data that can be used to identify or contact a single person, but under Canadian privacy laws it does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card.
Depending on where you live, and in accordance with applicable laws, we may collect various categories of information from you when you access or use our Website and when you provide information directly to us (e.g., when you register for our events, request our services, explore a business opportunity through our Careers portal, or access various content and features on our Website). Those categories include:
Identifiers, such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;
Personal Information such as your signature, social security number, physical characteristics or description, passport number, driver’s license or state identification card number, education (e.g., grades, transcripts), employment (e.g., current or past job history or performance evaluations), bank account number, or any other financial information, medical information, or health insurance information;
Internet or other similar network activity, such as browsing history, search history, or information on your interaction with our Website;
Location data, but not your precise geolocation. We may collect location information provided by a mobile or other device interacting with this Website, or associated with your IP address or other online or device identifier. We may collect this information through the lawful use and deployment of cookies and other tracking technologies, as set forth in our Cookie Policy.
You may choose not to provide personal information to Teneo by refraining from, among other things, submitting information directly to us. However, if you do not provide information when requested, we may not be able to provide you with information about our services and business opportunities.
We may store and use personal information to:
- track the usage of our Website and to help us improve our services and understanding of the interests and needs of those who contact us;
- carry out our obligations arising from any contracts between you or the company you work for and us;
- provide you with the information and services that you request from us;
- guide us in answering your questions or to explore career, professional or business opportunities with you;
- develop analysis and business intelligence that enable us to operate, grow, protect, make informed decisions and report on the performance of our business;
- pursue other legitimate interests of our own such as maintaining a database of contacts working with or in our industry for networking or business development purposes.
Protecting Personal Information
We secure personal information against unauthorized or unlawful processing, and against accidental loss, destruction or damage by appropriate technical, physical and organizational measures.
We evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal information.
We also take measures to ensure confidentiality, meaning that only people who have a need to know and use the personal information can access it.
Sharing Your Information
We will never sell or rent your personal information to third parties.
We sometimes share personal data among the group of companies owned by Teneo. This may involve transferring your personal information to other countries (including the U.S, U.K., and other countries, inside and outside the European Economic Area) where Teneo companies or other third parties operate and process your personal information. We also share personal data with vendors or agents working on our behalf for the purposes described in this Notice.
To the extent that we do share your personal information, we would only do so if we have entered into a written agreement with that party and that party has agreed to comply with our privacy standards as described in this Notice.
We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets, where we are required to do so by law, support auditing, compliance and corporate governance functions, in connection with legal proceedings or where disclosure is necessary to protect the vital interests of a person.
Data Retention
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Changes & Access To Your Information
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. You have a right to challenge the accuracy and completeness of your personal information and to have it amended, as appropriate. You also have a right to request access to your personal information and receive an accounting of how that information has been used and disclosed, subject to certain exceptions prescribed by law. To request access or to amend your personal information, please contact us at the address stated above.
Third Parties Websites & Social Media
Links to websites not under our control are provided for the convenience of our visitors. We are not responsible for the accuracy or reliability of the content. We do not offer any guarantee and are not responsible for the information found through these links. We also do not endorse these sites or their content. With respect to privacy, visitors should research the privacy policies of these websites before providing personal information.
Our use of social media serves as an extension of our Website. Social media accounts are public and are not hosted on our servers. Visitors who choose to interact with us via social media should read the terms of service and privacy policies of these third-party service providers and those of any applications you use to access them. We use Twitter, LinkedIn, You Tube and other social media platforms.
Comments left by individuals on social media can be read by anyone. Therefore, we strongly advise you not to post any personal information – whether it is yours or not.
Effective Date: January 5, 2022
Introduction
Teneo is committed to protecting and respecting your privacy.
This privacy notice (“Notice”) explains what personal information Teneo gathers about you, what we use it for and who we share it with.
It applies to those who may view and communicate with us through our website as well as people with whom we do business.
We may change this Notice from time-to-time so please check this page occasionally to ensure that you’re happy with any changes. When we make changes to this Notice, we will post the updated Notice on the website and update the Notice’s effective date.
If you have any questions or comments about this Notice, the ways in which Teneo collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:
Email: [email protected]
Post: Privacy Office, Teneo (Cayman) Limited, 109M Elgin Avenue, George Town, Grand Cayman, KY1-9008, Cayman Islands
About Teneo
Teneo is a global advisory firm that provides comprehensive strategic advisory services across a wide range of key objectives and issues addressing complex business and reputational challenges. We support chief executives, their boards and the communications, corporate affairs, investor relations and marketing teams of the world's largest organisations.
This Notice is issued on behalf of Teneo (Cayman) Limited. When we mention “Teneo,” “our,” “we” or “us" in this Notice, we are referring to the relevant company in the Teneo Group responsible for processing your data. Teneo Holdings LLC is the company responsible for Teneo.com.
Collection and Use of Personal Information
In this Notice, “personal data” (sometimes referred to as "personal information", "personally identifiable information" or "PII") means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier.
We may collect personal data directly (for example, when we perform professional services through a contract, you attend an event or subscribe to a newsletter) or indirectly (for example through public sources or from our clients).
The categories of personal data we may collect include:
Identifiers such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;
Personal Information such as your signature, physical characteristics or description, passport number, driver’s license, educational background, employment history, bank account number, any other financial information, or CCTV footage;
Internet or other similar network activity such as browsing history, search history or information on your interaction with our website;
Location data, but not your precise geolocation. We may collect location information provided by a mobile or other device interacting with this website or associated with your IP address or other online or device identifier. We may collect this information through the lawful use and deployment of cookies and other tracking technologies, as set out in our Cookie Policy.
We typically do not collect sensitive or special categories of data about individuals other than employees; however, in some circumstances it may be necessary for us to process sensitive personal data, for example:
- Personal identification documents which may reveal race, religion, ethnic origin or in some cases biometric data;
- Information that is provided to us by our clients in the course of providing our professional services;
- Health data where this is necessary, for example to provide a safe environment for our staff, clients and suppliers.
If you choose not to provide, or object to us processing, the information we collect (see the "Your rights" section below), we may not be able to process your instructions or continue to provide some or all of our services to you or our client.
When our client or another third party gives us personal data about you, we take reasonable steps to make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing and has obtained any necessary permission for us to process that information as described in this privacy statement.
If any information you give us relates to a third party by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.
How we use your personal data
We process information about you and/or your business to enable us and other members of the Teneo Group to provide our services to you or our clients, and to meet our legal or regulatory obligations. Some of your personal data may be used for other business purposes.
Please select the relevant purpose below for further detail as to how we process your personal data.
Clients
Collecting your personal data
When Teneo provides professional services, we process information about you and/or your business to enable us to provide our services to you or our clients and to meet our legal or regulatory obligations when we have a valid business reason to do so. We only ask our clients to share personal data with us where it is necessary in order to provide our services or other agreed purposes.
We also process personal data of individuals who are not directly our clients (for example, employees, customers or suppliers of our clients). See the section “Individuals whose personal data we obtain in connection with providing services to our clients” for additional information.
Because we provide a wide range of services to our clients or other third parties, we process many categories of personal data. The majority of the personal data we collect and use is supplied voluntarily by our clients (or collected from third-party sources at the request of our clients). As a result, if you are a client of Teneo, it will generally be obvious to you what personal data we collect and use. This information generally includes (as appropriate for the services we are providing):
- Basic information, such as your name, the organisation you work for and your job title;
- Contact information, such as your address, email, and mobile phone number;
- Financial and tax-related information, such as your income, investments and tax residency; and
- Any other information relating to you (or other third parties) which you provide to us for the purpose of receiving our services.
For certain services or activities, and when permitted by law or with an individual’s consent, we may also process special categories of personal data. Examples of these activities include performing “know your client” checks (which require us to process government identification documents that may contain biometric data or data revealing racial or ethnic origin) and providing you with lunch during a meeting. It is important you provide us with all necessary information and documents as this affects our ability to provide services to you.
Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.
Use of your personal data
We use this information for the following reasons:
- Providing professional services to you, including corresponding with you, other third parties, our service providers or competent authorities;
- Client account opening and other administrative tasks;
- Financial accounting, invoicing and tax purposes;
- Relationship management with clients and prospective clients, which may involve:
- Sending you thought leadership or details of our products and services;
- Contacting you for feedback on services;
- Sending you event invitations; and
- Other marketing or research purposes;
- Recruitment and business development, which may involve:
- The use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
- The use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
- Administering, managing and developing our business and services, which may involve:
- Developing our businesses and services (such as identifying client needs and improvements in service delivery);
- Maintaining and using our IT systems; and
- Administering and managing our website, systems and applications;
- Services we receive from our professional advisors, such as lawyers, accountants and consultants;
- Security, quality and risk management activities;
- Complying with our legal and regulatory obligations and any requirements of a professional body of which we are a member; and
- Protecting our rights and those of our clients.
Our legal grounds for processing your personal data are:
- Compliance with a legal or regulatory obligation;
- Explicit consent to processing your information for a specific reason;
- Performance of the contract we have with you (or taking steps to enter into a contract with you); and
- A legitimate interest pursued by us or a third party, including to:
- Provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
- Prevent fraud;
- Protect our business interests;
- Ensure that complaints are investigated;
- Evaluate, develop or improve our services or products; or
- Keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- You have given us your explicit consent to process that data;
- We are required by law to process that data in order to ensure we meet our “know your client” and “anti-money laundering” obligations (or other legal obligations imposed on us);
- The processing is necessary to carry out our obligations under employment, social security or social protection law;
- The processing is necessary for the establishment, exercise or defense of legal claims; or
- You have made the data manifestly public.
Please note that in certain circumstances it may still be lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Individuals whose personal data we obtain in connection with providing services to our clients
Collecting your personal data
As part of the professional services Teneo provides to clients, we process personal data of individuals with whom we do not have a direct (contractual or other) relationship. For example, if Teneo undertakes a review on behalf of a client, we obtain personal data concerning the target’s employees, management and customers.
We seek confirmation from our clients that any personal data they provide has been processed in compliance with relevant privacy laws and regulations and that they have authority to provide personal data to us in connection with the performance of our services.
Because we provide a wide range of services, we process many categories of personal data. This information generally includes (as appropriate for the services we are providing):
- Personal details, such as your name, age/date of birth, gender, marital status and country of residence;
- Contact information, such as your address, email and mobile phone number;
- Financial and tax-related information, such as your income, investments and tax residency; and
- Employment details, such as your role, rank, experience, performance data and employment numbers.
For certain services or activities and when permitted by law or with an individual’s consent, we may also process special categories of personal data.
Use of your personal data
We use this information for the following reasons:
- Providing professional services;
- Administering, managing and developing our businesses and services;
- Security, quality and risk management activities;
- Complying with any requirement of law, regulation or a professional body of which we are a member; and
- Where agreed with our clients, we may use non-personal, anonymised and aggregated information that we receive in the course of providing professional services for other lawful purposes, including data analytics, research, submissions, thought leadership and promotional activity.
Our legal grounds for processing your personal data:
- Compliance with a legal or regulatory obligation; and
- A legitimate interest pursued by us or a third party, including to provide our services to our clients and other third parties and ensure that our client engagements are well-managed.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- You have given us your explicit consent to process that data;
- We are required by law to process that data in order to ensure we meet our legal obligations;
- The processing is necessary to carry out our obligations under employment, social security or social protection law;
- The processing is necessary for the establishment, exercise or defence of legal claims; or
- You have made the data manifestly public.
Please note that in certain circumstances it may still be lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Individuals who get in touch with us another way
Individuals who contact us by email, phone and voicemail
We collect personal data when an individual contacts us with a question, complaint, comment or feedback (such as your name, contact details and contents of the communication). In these cases, you are in control of the personal data shared with us and we will only use the data for the purpose of responding to your communication.
Individuals who contact us through our social media sites
We use social media platforms for a variety of reasons, including recruitment, marketing and providing easy access to relevant information regarding opportunities and events. Although Teneo is responsible for the content published using our social media platforms, we are not responsible for managing those platforms. You are therefore obliged to adhere to the legal and privacy terms imposed by the relevant social media platform provider.
Insolvency and restructuring
See separate insolvency notice.
Journalists
Collecting your personal data
We engage with journalists and other individuals who work in the media on behalf of our clients as part of the professional services we provide and may process your personal contact information and areas of interest.
Use of your personal data
We use this information for the following reasons:
- Facilitating contacts and arranging interviews with individuals employed by our clients
- Sharing insights with you on areas that we think are relevant
- Responding to any questions relating to our clients or more generally
- Sending invitations to relevant events or meetings.
Our legal grounds for processing your personal data are:
- Our legitimate interest in undertaking any of the above actions
- Your explicit consent.
Participants in events and meetings
Collecting your personal data
We will collect personal data in connection with your attendance at Teneo meetings, conferences, events and learning sessions, which will be provided directly by you. This may include the following (to the extent required for a particular event):
- Name, age or date of birth;
- Email address;
- Company;
- Job title;
- Telephone number;
- Dietary / accessibility requirements;
- Guest details; and
- Other specific event-related data such as: arrival time/departure time, hotel check-in/check-out time, flight information (airline, arrival and departure dates).
We do not intentionally collect sensitive category data, unless you provide us with such data (for example, special dietary requirements which reveal your religious affiliation or any food allergies or other data relating to your health necessary to provide support to participants, if needed, for example, if a wheelchair will be required).
Use of your personal data
We will use your personal data to manage our events and to ensure that any special requirements you request are communicated to any relevant third parties. For example, we will share any dietary requirements that you provide to us with venues and/or caterers.
Our legal grounds for processing your personal data are:
- Your explicit consent as a participant;
- Our legitimate interest in organising events and managing the registration process for such events;
- Our legitimate interest in protecting our people, assets and information, and to prevent unauthorised people gaining access to off-site events; and
- Our legitimate interest in providing information about Teneo, our services and events we organise.
Suppliers
Collecting your personal data
We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship and contract with our suppliers, to receive services from our suppliers and, where relevant, to provide professional services to our clients.
The personal data we process is usually limited to contact information (name, name of employer, phone, email and other contact details) and financial information (payment-related information).
Use of your personal data
We use this personal data for the following reasons:
- Receiving services from our suppliers;
- Providing professional services to our clients;
- Administering, managing and developing our business and services;
- Security, quality and risk management activities;
- Providing information about us and our range of services; and
- Complying with our legal and regulatory obligations.
Our legal grounds for processing your personal data are:
- Performance of a contract;
- Compliance with a legal or regulatory obligation;
- Our legitimate interest in managing payments, fees and charges;
- Our legitimate interest in safeguarding Teneo against inadvertently dealing with the proceeds of criminal activities or assisting in any other unlawful or fraudulent activities; and
- Our legitimate interest in carrying out any of the above actions.
Visitors to our office
Collecting your personal data
The personal data which we collect from visitors to our office, provided directly by you, is generally limited to your name, email address, mobile number (where relevant) and the time you enter and leave our office. Our sign-in processes vary between offices and more information will be provided on arrival. If you have any queries in advance of visiting an office please email [email protected]
WIFI
We monitor traffic on our WIFI networks. This allows us to see limited information about a user’s network behaviour, including (at least) the source and destination addresses the user is connecting from and to.
CCTV
We use CCTV monitoring where permitted by law. CCTV images are securely stored and are only accessed on a need-to-know basis (for example, to look into an incident). We may disclose CCTV images to law enforcement bodies as requested and permitted by law. We will also share CCTV images with our insurers for the purpose of processing an insurance claim as a result of an incident. CCTV recordings are typically deleted or automatically overwritten after a short period of time, unless an issue is identified that requires further investigation.
Use of your personal data
We use this personal data for the following reasons:
- Communicating with visitors in relation to their attendance and conduct at our office;
- Providing visitors with facilities including access to our office, conference rooms or WIFI;
- Controlling access to our office; and
- Protecting our office, personnel, goods and confidential information.
Our legal grounds for processing your personal data are:
- Our legitimate interest in protecting our offices, personnel, goods and confidential information; and
- Our legitimate interest in preventing and detecting crime, and establishing, exercising and defending legal claims.
Visitors to our website
Collecting your personal data
When you visit our website, you are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies and analytics tools on our website. Please see our Cookies policy for more information on the data that is collected and how it is used.
Our legal grounds for processing your personal data are:
- Our legitimate interest in effectively delivering information and services to you and the effective and lawful operation of our business;
- Our legitimate interest in developing and improving our site; and
- Your explicit consent as a visitor to the website.
Third party links
Our website may link to third party sites not controlled by Teneo and which do not operate under our privacy practices. When you link to third party sites, Teneo’s privacy practices no longer apply and we do not accept any responsibility for the information you provide on those sites or their collection and use of your personal information. We encourage you to review each third-party site’s privacy policy before disclosing any personally identifiable information.
Minors
Our website is not intended for use by minors under the age of sixteen (16) years. It is Teneo’s policy to not knowingly collect or maintain the personal data for anyone under the age of 16 except as part of an engagement to provide professional services.
Protecting personal information
Teneo takes the security of all the data we hold very seriously. We have in place reasonable commercial standards of technology and operational security to protect your personal information from loss, misuse and unauthorised access, disclosure, alteration or destruction. Only authorised personnel, with appropriate awareness of privacy obligations, are provided access to your personal information. We regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
All our staff and third-party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.
Sharing your information
We will only share your personal data when we are legally permitted to do so, in connection with any of the purposes outlined in the “How we process your personal data” section above. This may involve disclosing your data to:
- Other members of the Teneo Group or third parties that provide services or online platforms to us and/or the Teneo Group;
- Competent authorities (including courts and authorities regulating us and other members of the Teneo Group);
- Our clients;
- Your employer and/or its advisers, or your advisers;
- Our auditors, insurers and professional advisers;
- Any other person or organisation after a restructure, sale or acquisition of any member of the Teneo Group, as long as they use your information for the same purposes we did;
- Credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
- Other third parties that reasonably require access to personal data relating to you.
As a result of sharing your personal data with the above parties, information we hold about you may be transferred to and stored in other countries. This may include countries outside of the European Economic Area (“EEA”) and countries with laws that have not necessarily been determined to provide an adequate level of protection for the processing of personal data under the laws of the EU or other jurisdictions.
When we, or our permitted third parties, transfer your personal data outside the EEA we will take reasonable steps to ensure that your information is treated securely and the means of transfer provide adequate safeguards.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means and the applicable legal requirements.
We seek to ensure that we only keep your personal data for the longest of:
- The period necessary for the relevant activity or services;
- Any retention period that is required by law; or
- The period in which litigation or investigations might arise in respect of the services.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If you would like to know more about the retention periods we apply to your personal data, please contact us at [email protected].
Your rights
You have various rights in relation to your personal data. In particular, you have a right to:
- Request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate;
- Request erasure of your personal information where there is no good reason for us continuing to process it;
- Object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
- Object where we are processing your personal information for direct marketing purposes;
- In some circumstances, request the restriction of processing of your personal information;
- In some circumstances, request the transfer of your personal information to another party.
If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:
- Writing to the Privacy Office, Teneo (Cayman) Limited, 109M Elgin Avenue, George Town, Grand Cayman, KY1-9008, Cayman Islands; or
- Sending an email to [email protected].
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not, in general, have to pay a fee to exercise any of your individual rights set out in this Notice. However, we may refuse to provide access or charge a fee for access if the relevant data protection legislation allows us to do so, in which case we will provide reasons for our decision as required by the law.
We hope that we will be able to resolve any query or concern you raise. However, if you feel that we have not handled your query or complaint to your satisfaction, you can contact the Ombudsman, which regulates and supervises the use of personal data in the Cayman Islands. Further information on how to contact them is available at https://ombudsman.ky/data-protection. If you are not based in the Cayman Islands, you have a right to complain to the relevant supervisory authority in your jurisdiction.
Effective Date: January 3, 2020
Last Updated: July 11, 2025
Teneo is committed to protecting and respecting your privacy.
This privacy notice (“Notice”) explains what personal information Teneo gather about you, what we use it for and who we share it with.
It applies to those who may view and communicate with us through our website as well as people with whom we do business.
We may change this Notice from time to time so please check this page occasionally to ensure that you’re happy with any changes. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s effective date.
If you have any questions or comments about this Notice, the ways in which Teneo collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:
Email: [email protected]
About Teneo
Teneo, is a global advisory firm that provides comprehensive strategic advisory services across a wide range of key objectives and issues addressing complex business and reputational challenges. We support chief executives, their boards, and the communications, corporate affairs, investor relations, and marketing teams of the world's largest organisations.
This Notice is issued on behalf of the Teneo Group entities in the EU, namely, Teneo Strategy Ireland Limited, Teneo Restructuring (Ireland) Limited, Teneo Paris, Teneo Brussels SRL, Teneo Financial Advisory Germany GmbH, Teneo Germany GmbH, Herter & Co GmbH, Teneo FA (Spain) S.L.U. and Teneo Netherlands B.V. When we mention “Teneo,” “our”, “we” or “us in this Notice we are referring to the relevant company in the Teneo Group responsible for processing your data. Teneo Holdings LLC is the company responsible for Teneo.com.
Collection & Use of Personal Information
In this Notice, “personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier.
We may collect personal data directly (for example, when we perform professional services through a contract, you attend an event or subscribe to a newsletter) or indirectly (for example through public sources or from our clients)
The categories of personal data we may collect include:
Identifiers, such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;
Personal Information such as your signature, physical characteristics or description, passport number, driver’s license, educational background employment history, bank account number, any other financial information, or CCTV footage
Internet or other similar network activity, such as browsing history, search history, or information on your interaction with our Website;
Location data, but not your precise geolocation. We may collect location information provided by a mobile or other device interacting with this Website or associated with your IP address or other online or device identifier. We may collect this information through the lawful use and deployment of cookies and other tracking technologies, as set out in our Cookie Policy.
We typically do not collect sensitive or special categories of data about individuals other than employees, However, in some circumstances it may be necessary for us to process sensitive personal data, for example:
- personal identification documents which may reveal race, religion or ethnic origin or in some cases biometric data
- information that is provided to us by our clients in the course of providing our professional services
- health data where this is necessary, for example to provide a safe environment for our staff, clients and suppliers.
If you choose not to provide, or object to us processing, the information we collect (see the "Your rights" section below), we may not be able to process your instructions or continue to provide some or all of our services to you or our client.
When our client or another third party gives us personal data about you, we take reasonable steps to make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing and has obtained any necessary permission for us to process that information as described in this privacy statement.
If any information you give us relates to a third party by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.
How we use your personal data
We process information about you and/or your business to enable us and other members of the Teneo Group to provide our services to you or our clients, and to meet our legal or regulatory obligations. Some of your personal data may be used for other business purposes.
Please select the relevant purpose below for further detail as to how we process your personal data.
Clients
Collecting your personal data
When Teneo provides professional services, we process information about you and/or your business to enable us to provide our services to you or our clients and to meet our legal or regulatory obligations, when we have a valid business reason to do so. We only ask our clients to share personal data with us where it is necessary in order to provide our services or other agreed purposes.
We also process personal data of individuals who are not directly our clients (for example, employees, customers or suppliers of our clients). See the section “Individuals whose personal data we obtain in connection with providing services to our clients” for additional information.
Because we provide a wide range of services to our clients or other third parties, we process many categories of personal data. The majority of the personal data we collect and use is supplied voluntarily by our clients (or collected from third-party sources at the request of our clients). As a result, if you are a client of Teneo, it will generally be obvious to you what personal data we collect and use. This information generally includes (as appropriate for the services we are providing):
- basic information, such as your name, the organisation you work for and your job title;
- contact information, such as your address, email, and mobile phone number;
- financial and tax-related information, such as your income, investments and tax residency; and
- any other information relating to you (or other third parties) which you provide to us for the purpose of receiving our services.
For certain services or activities and when permitted by law or with an individual’s consent, we may also process special categories of personal data. Examples of these activities include performing know your client checks which require us to process government identification documents which may contain biometric data or data revealing racial or ethnic origin) and providing you with lunch during a meeting. It is important you provide us with all necessary information and documents as this affects our ability to provide services to you.
Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.
Use of your personal data
We use this information for the following reasons:
- providing professional services to you, including to correspond with you, other third parties, our service providers, or competent authorities;
- client account opening and other administrative tasks;
- financial accounting, invoicing and tax purposes;
- relationship management with clients and prospective clients, which may involve:
- sending you thought leadership or details of our products and services;
- contacting you for feedback on services;
- sending you event invitations; and
- other marketing or research purposes;
- recruitment and business development, which may involve:
- the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
- the use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
- administering, managing and developing our business and services, which may involve:
- developing our businesses and services (such as identifying client needs and improvements in service delivery);
- maintaining and using our IT systems; and
- administering and managing our website and systems and applications;
- services we receive from our professional advisors, such as lawyers, accountants and consultants;
- security, quality and risk management activities;
- complying with our legal and regulatory obligations and any requirements of a professional body of which we are a member; and
- protecting our rights and those of our clients.
Our legal grounds for processing your personal data are:
- compliance with a legal or regulatory obligation;
- explicit consent to processing your information for a specific reason;
- performance of the contract we have with you (or taking steps to enter into a contract with you); and
- a legitimate interest pursued by us or a third party, including to:
- provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
- prevent fraud;
- protect our business interests;
- ensure that complaints are investigated;
- evaluate, develop or improve our services or products; or
- keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- you have given us your explicit consent to process that data;
- we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- you have made the data manifestly public.
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Individuals whose personal data we obtain in connection with providing services to our clients
Collecting your personal data
As part of the professional services Teneo provides to clients, we process personal data of individuals with whom we do not have a direct (contractual or other) relationship. For example, if Teneo undertakes a review on behalf of a client, we obtain personal data concerning the target’s employees, management and customers.
We seek confirmation from our clients that any personal data they provide has been processed in compliance with relevant privacy laws and regulations and that they have authority to provide personal data to us in connection with the performance of our services.
Because we provide a wide range of services, we process many categories of personal data. This information generally includes (as appropriate for the services we are providing):
- personal details, such as your name, age/date of birth, gender, marital status and country of residence;
- contact information, such as your address, email and mobile phone number;
- financial and tax-related information, such as your income, investments and tax residency; and
- employment details, such as your role, rank, experience, performance data and employment numbers.
For certain services or activities and when permitted by law, or with an individual’s consent, we may also process special categories of personal data.
Use of your personal data
We use this information for the following reasons:
- providing professional services;
- administering, managing and developing our businesses and services;
- security, quality and risk management activities;
- complying with any requirement of law, regulation or a professional body of which we are a member; and
- where agreed with our clients, we may use non-personal, anonymised and aggregated information that we receive in the course of providing professional services for other lawful purposes, including data analytics, research, submissions, thought leadership and promotional activity.
Our legal grounds for processing your personal data:
- compliance with a legal or regulatory obligation; and
- a legitimate interest pursued by us or a third party, including to provide our services to our clients and other third parties and ensure that our client engagements are well-managed.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- you have given us your explicit consent to process that data;
- we are required by law to process that data in order to ensure we meet our legal obligations;
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- you have made the data manifestly public.
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Individuals who get in touch with us another way
Individuals who contact us by email, phone and voicemail
We collect personal data when an individual contacts us with a question, complaint, comment or feedback (such as your name, contact details and contents of the communication). In these cases, you are in control of the personal data shared with us and we will only use the data for the purpose of responding to your communication.
Individuals who contact us through our social media sites
We use social media platforms for a variety of matters, such as for recruitment and marketing, to provide easy access to relevant information regarding matters such as opportunities and events. Although Teneo is responsible for the content published using our social media platforms, we are not responsible for managing those platforms. You are therefore obliged to adhere to the legal and privacy terms imposed by the relevant social media platform provider.
Journalists
Collecting your personal data
We engage with journalists and other individuals who work in the media on behalf of our clients as part of the professional services we provide and may process your personal contact information and areas of interest.
Use of your personal data
We use this information for the following reasons:
- facilitating contacts and arranging interviews with individuals employed by our clients
- sharing insights with you on areas that we think are relevant
- responding to any questions relating to our clients or more generally
- sending invitations to relevant events or meetings
Our legal grounds for processing your personal data are:
- our legitimate interest in undertaking any of the above actions
- your explicit consent
Participants in events and meetings
Collecting your personal data
We will collect personal data in connection with your attendance at Teneo meetings, conferences, events and learning sessions, which will be provided directly by you. This may include the following (to the extent required for a particular event):
- name, age or date of birth;
- email address;
- company;
- job title;
- telephone number;
- dietary / accessibility requirements;
- guest details; and
- other specific event-related data such as: arrival time/departure time, hotel check-in/check-out time, flight information (airline, arrival and departure dates).
We do not intentionally collect sensitive category data, unless you provide us with such data (for example, special dietary requirements which reveal your religious affiliation or any food allergies or other data relating to your health necessary to provide support to participants, if needed, for example, if a wheelchair will be required).
Use of your personal data
We will use your personal data to manage our events and to ensure that any special requirements you request are communicated to any relevant third parties, for example we will share any dietary requirements that you provide to us with venues and/or caterers.
Our legal grounds for processing your personal data are:
- your explicit consent as a participant;
- our legitimate interest in organising events and managing the registration process for such events;
- our legitimate interest in protecting our people, assets and information, and to prevent unauthorised people gaining access to off-site events; and
- our legitimate interest in providing information about Teneo, our services and events we organise.
Suppliers
Collecting your personal data
We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship and contract with our suppliers, to receive services from our suppliers and, where relevant, to provide professional services to our clients.
The personal data we process is usually limited to contact information (name, name of employer, phone, email and other contact details) and financial information (payment-related information).
Use of your personal data
We use this personal data for the following reasons:
- receiving services from our suppliers;
- providing professional services to our clients;
- administering, managing and developing our business and services;
- security, quality and risk management activities;
- providing information about us and our range of services; and
- complying with our legal and regulatory obligations.
Our legal grounds for processing your personal data are:
- performance of a contract;
- compliance with a legal or regulatory obligation;
- our legitimate interest in managing payments, fees and charges;
- our legitimate interest in safeguarding Teneo against inadvertently dealing with the proceeds of criminal activities or assisting in any other unlawful or fraudulent activities; and
- our legitimate interest in carrying out any of the above actions.
Visitors to our office
Collecting your personal data
The personal data which we collect from visitors to our office, provided directly by you, is generally limited to your name, email address, mobile number (where relevant) and the time you enter and leave our office. Our sign-in processes vary between offices and more information will be provided on arrival. If you have any queries in advance of visiting an office please email [email protected]
WIFI
We monitor traffic on our WIFI networks. This allows us to see limited information about a user’s network behaviour, including (at least) the source and destination addresses the user is connecting from and to.
CCTV
We use CCTV monitoring where permitted by law. CCTV images are securely stored and are only accessed on a need-to-know basis (for example, to look into an incident). We may disclose CCTV images to law enforcement bodies as requested and permitted by law. We will also share CCTV images with our insurers for the purpose of processing an insurance claim as a result of an incident. CCTV recordings are typically deleted or automatically overwritten after a short period of time, unless an issue is identified that requires further investigation.
Use of your personal data
We use this personal data for the following reasons:
- communicating with visitors in relation to their attendance and conduct at our office;
- providing visitors with facilities including access to our office, conference rooms or WIFI;
- controlling access to our office; and
- protecting our office, personnel, goods and confidential information.
Our legal grounds for processing your personal data are:
- our legitimate interest in protecting our offices, personnel, goods and confidential information; and
- our legitimate interest in preventing and detecting crime, and establishing, exercising and defending legal claims.
Visitors to our website
Collecting your personal data
When you visit our Website, you are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies and analytics tools on our Website. Please see our Cookies policy for more information on the data that is collected, how it is used and
Our legal grounds for processing your personal data are:
- our legitimate interest in effectively delivering information and services to you and the effective and lawful operation of our business;
- our legitimate interest in developing and improving our site; and
- your explicit consent as a visitor to the Website.
Third party links
Our Website may link to third party sites not controlled by Teneo and which do not operate under our privacy practices. When you link to third party sites, Teneo’s privacy practices no longer apply and we do not accept any responsibility for the information you provide on those sites or their collection and use of your personal information. We encourage you to review each third party site’s privacy policy before disclosing any personally identifiable information.
Minors
Our Website is not intended for use by minors under the age of sixteen (16) years. It is Teneo’s policy to not knowingly collect or maintain the personal data for anyone under the age of 16 except as part of an engagement to provide professional services.
Protecting Personal Information
Teneo takes the security of all the data we hold very seriously. We have in place reasonable commercial standards of technology and operational security to protect your personal information from loss, misuse and unauthorised access, disclosure, alteration or destruction. Only authorised personnel, with appropriate awareness of privacy obligations, are provided access to your personal information. We regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
All our staff and third party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.
Sharing Your Information
We will only share your personal data when we are legally permitted to do so, in connection with any of the purposes outlined in the “How we process your personal data” section above. This may involve disclosing your data to:
- other members of the Teneo Group or third parties that provide services or online platforms to us and/or the Teneo Group;
- competent authorities (including courts and authorities regulating us and other members of the Teneo Group);
- our clients;
- your employer and/or its advisers, or your advisers;
- our auditors, insurers and professional advisers;
- any other person or organisation after a restructure, sale or acquisition of any member of the Teneo Group, as long as they use your information for the same purposes we did;
- credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
- other third parties that reasonably require access to personal data relating to you.
As a result of sharing your personal data with the above parties, information we hold about you may be transferred to other countries. This may include countries outside of the European Economic Area (“EEA”) and countries with laws that have not necessarily been determined to provide an adequate level of protection for the processing of personal data under the laws of the EU or other jurisdictions.
When we, or our permitted third parties, transfer your personal data outside the EEA , we will take reasonable steps to ensure that your information is treated securely and the means of transfer provide adequate safeguards.
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We seek to ensure that we only keep your personal data for the longest of:
- the period necessary for the relevant activity or services;
- any retention period that is required by law; or
- the period in which litigation or investigations might arise in respect of the services.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
If you would like to know more about the retention periods we apply to your personal data, please contact us at [email protected]
Your rights
You have various rights in relation to your personal data. In particular, you have a right to:
- request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate;
- request erasure of your personal information where there is no good reason for us continuing to process it;
- object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
- object where we are processing your personal information for direct marketing purposes;
- in some circumstances, request the restriction of processing of your personal information;
- in some circumstances, request the transfer of your personal information to another party.
If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by sending an email to [email protected].
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not, in general, have to pay a fee to exercise any of your individual rights set out in this Notice. However, we may refuse to provide access or charge a few for access if the relevant data protection legislation allows us to do so, in which case we will provide reasons for our decision as required by the law.
We hope that we will be able to resolve any query or concern you raise. However, if you feel that we have not handled your query or complaint to your satisfaction you may contact the relevant supervisory authority in your jurisdiction.
Effective Date: 7 June, 2022
Last Updated: 15 September, 2025
Teneo is committed to protecting and respecting your privacy.
This privacy notice (“Notice”) explains what personal information Teneo gather about you, what we use it for and who we share it with.
It applies to those who may view and communicate with us through our website as well as people with whom we do business.
We may change this Notice from time to time so please check this page occasionally to ensure that you’re happy with any changes. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s effective date.
If you have any questions or comments about this Notice, the ways in which Teneo collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:
Email: [email protected]
Post: Deputy General Counsel, Teneo, The Carter Building, 11 Pilgrim Street, London, EC4V 6RN
About Teneo
Teneo, is a global advisory firm that provides comprehensive strategic advisory services across a wide range of key objectives and issues addressing complex business and reputational challenges. We support chief executives, their boards, and the communications, corporate affairs, investor relations, and marketing teams of the world's largest organisations.
This Notice is issued on behalf of the Teneo Group entities in the UK, namely, Teneo Business Consulting Limited, Teneo Financial Advisory Limited, Teneo Asset Solutions Limited, Teneo Strategy Limited, Ridgeway Partners Limited t/a Teneo People Advisory, Teneo UK (Holdings) Limited, Teneo UK Bidco Limited, Blue Rubicon (Holdings) Limited, Tulchan Communications LLP, Tulchan Communications Group Limited, Ballintober Limited, Vox Media Limited. When we mention “Teneo,” “our”, “we” or “us in this Notice we are referring to the relevant company in the Teneo Group responsible for processing your data. Teneo Holdings LLC is the company responsible for Teneo.com.
Collection & Use of Personal Information
In this Notice, “personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier.
We may collect personal data directly (for example, when we perform professional services through a contract, you attend an event or subscribe to a newsletter) or indirectly (for example through public sources or from our clients)
The categories of personal data we may collect include:
Identifiers, such as your name, e-mail address, postal address, phone number, mobile number, IP address or other similar identifiers;
Personal Information such as your signature, physical characteristics or description, passport number, driver’s license, educational background employment history, bank account number, any other financial information, or CCTV footage
Internet or other similar network activity, such as browsing history, search history, or information on your interaction with our Website;
Location data, but not your precise geolocation. We may collect location information provided by a mobile or other device interacting with this Website or associated with your IP address or other online or device identifier. We may collect this information through the lawful use and deployment of cookies and other tracking technologies, as set out in our Cookie Policy.
We typically do not collect sensitive or special categories of data about individuals other than employees, However, in some circumstances it may be necessary for us to process sensitive personal data, for example:
- personal identification documents which may reveal race, religion or ethnic origin or in some cases biometric data
- information that is provided to us by our clients in the course of providing our professional services
- health data where this is necessary, for example to provide a safe environment for our staff, clients and suppliers.
If you choose not to provide, or object to us processing, the information we collect (see the "Your rights" section below), we may not be able to process your instructions or continue to provide some or all of our services to you or our client.
When our client or another third party gives us personal data about you, we take reasonable steps to make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing and has obtained any necessary permission for us to process that information as described in this privacy statement.
If any information you give us relates to a third party by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.
How we use your personal data
We process information about you and/or your business to enable us and other members of the Teneo Group to provide our services to you or our clients, and to meet our legal or regulatory obligations. Some of your personal data may be used for other business purposes.
Please select the relevant purpose below for further detail as to how we process your personal data.
Clients
Collecting your personal data
When Teneo provides professional services, we process information about you and/or your business to enable us to provide our services to you or our clients and to meet our legal or regulatory obligations, when we have a valid business reason to do so. We only ask our clients to share personal data with us where it is necessary in order to provide our services or other agreed purposes.
We also process personal data of individuals who are not directly our clients (for example, employees, customers or suppliers of our clients). See the section “Individuals whose personal data we obtain in connection with providing services to our clients” for additional information.
Because we provide a wide range of services to our clients or other third parties, we process many categories of personal data. The majority of the personal data we collect and use is supplied voluntarily by our clients (or collected from third-party sources at the request of our clients). As a result, if you are a client of Teneo, it will generally be obvious to you what personal data we collect and use. This information generally includes (as appropriate for the services we are providing):
- basic information, such as your name, the organisation you work for and your job title;
- contact information, such as your address, email, and mobile phone number;
- financial and tax-related information, such as your income, investments and tax residency; and
- any other information relating to you (or other third parties) which you provide to us for the purpose of receiving our services.
For certain services or activities and when permitted by law or with an individual’s consent, we may also process special categories of personal data. Examples of these activities include performing know your client checks which require us to process government identification documents which may contain biometric data or data revealing racial or ethnic origin) and providing you with lunch during a meeting. It is important you provide us with all necessary information and documents as this affects our ability to provide services to you.
Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.
Use of your personal data
We use this information for the following reasons:
- providing professional services to you, including to correspond with you, other third parties, our service providers, or competent authorities;
- client account opening and other administrative tasks;
- financial accounting, invoicing and tax purposes;
- relationship management with clients and prospective clients, which may involve:
- sending you thought leadership or details of our products and services;
- contacting you for feedback on services;
- sending you event invitations; and
- other marketing or research purposes;
- recruitment and business development, which may involve:
- the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
- the use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
- administering, managing and developing our business and services, which may involve:
- developing our businesses and services (such as identifying client needs and improvements in service delivery);
- maintaining and using our IT systems; and
- administering and managing our website and systems and applications;
- services we receive from our professional advisors, such as lawyers, accountants and consultants;
- security, quality and risk management activities;
- complying with our legal and regulatory obligations and any requirements of a professional body of which we are a member; and
- protecting our rights and those of our clients.
Our legal grounds for processing your personal data are:
- compliance with a legal or regulatory obligation;
- explicit consent to processing your information for a specific reason;
- performance of the contract we have with you (or taking steps to enter into a contract with you); and
- a legitimate interest pursued by us or a third party, including to:
- provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
- prevent fraud;
- protect our business interests;
- ensure that complaints are investigated;
- evaluate, develop or improve our services or products; or
- keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- you have given us your explicit consent to process that data;
- we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- you have made the data manifestly public.
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Individuals whose personal data we obtain in connection with providing services to our clients
Collecting your personal data
As part of the professional services Teneo provides to clients, we process personal data of individuals with whom we do not have a direct (contractual or other) relationship. For example, if Teneo undertakes a review on behalf of a client, we obtain personal data concerning the target’s employees, management and customers.
We seek confirmation from our clients that any personal data they provide has been processed in compliance with relevant privacy laws and regulations and that they have authority to provide personal data to us in connection with the performance of our services.
Because we provide a wide range of services, we process many categories of personal data. This information generally includes (as appropriate for the services we are providing):
- personal details, such as your name, age/date of birth, gender, marital status and country of residence;
- contact information, such as your address, email and mobile phone number;
- financial and tax-related information, such as your income, investments and tax residency; and
- employment details, such as your role, rank, experience, performance data and employment numbers.
For certain services or activities and when permitted by law, or with an individual’s consent, we may also process special categories of personal data.
Use of your personal data
We use this information for the following reasons:
- providing professional services;
- administering, managing and developing our businesses and services;
- security, quality and risk management activities;
- complying with any requirement of law, regulation or a professional body of which we are a member; and
- where agreed with our clients, we may use non-personal, anonymised and aggregated information that we receive in the course of providing professional services for other lawful purposes, including data analytics, research, submissions, thought leadership and promotional activity.
Our legal grounds for processing your personal data:
- compliance with a legal or regulatory obligation; and
- a legitimate interest pursued by us or a third party, including to provide our services to our clients and other third parties and ensure that our client engagements are well-managed.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- you have given us your explicit consent to process that data;
- we are required by law to process that data in order to ensure we meet our legal obligations;
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- you have made the data manifestly public.
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Individuals who get in touch with us another way
Individuals who contact us by email, phone and voicemail
We collect personal data when an individual contacts us with a question, complaint, comment or feedback (such as your name, contact details and contents of the communication). In these cases, you are in control of the personal data shared with us and we will only use the data for the purpose of responding to your communication.
Individuals who contact us through our social media sites
We use social media platforms for a variety of matters, such as for recruitment and marketing, to provide easy access to relevant information regarding matters such as opportunities and events. Although Teneo is responsible for the content published using our social media platforms, we are not responsible for managing those platforms. You are therefore obliged to adhere to the legal and privacy terms imposed by the relevant social media platform provider.
Insolvency and restructuring
Journalists
Collecting your personal data
We engage with journalists and other individuals who work in the media on behalf of our clients as part of the professional services we provide and may process your personal contact information and areas of interest.
Use of your personal data
We use this information for the following reasons:
- facilitating contacts and arranging interviews with individuals employed by our clients
- sharing insights with you on areas that we think are relevant
- responding to any questions relating to our clients or more generally
- sending invitations to relevant events or meetings
Our legal grounds for processing your personal data are:
- our legitimate interest in undertaking any of the above actions
- your explicit consent
Participants in events and meetings
Collecting your personal data
We will collect personal data in connection with your attendance at Teneo meetings, conferences, events and learning sessions, which will be provided directly by you. This may include the following (to the extent required for a particular event):
- name, age or date of birth;
- email address;
- company;
- job title;
- telephone number;
- dietary / accessibility requirements;
- guest details; and
- other specific event-related data such as: arrival time/departure time, hotel check-in/check-out time, flight information (airline, arrival and departure dates).
We do not intentionally collect sensitive category data, unless you provide us with such data (for example, special dietary requirements which reveal your religious affiliation or any food allergies or other data relating to your health necessary to provide support to participants, if needed, for example, if a wheelchair will be required).
Use of your personal data
We will use your personal data to manage our events and to ensure that any special requirements you request are communicated to any relevant third parties, for example we will share any dietary requirements that you provide to us with venues and/or caterers.
Our legal grounds for processing your personal data are:
- your explicit consent as a participant;
- our legitimate interest in organising events and managing the registration process for such events;
- our legitimate interest in protecting our people, assets and information, and to prevent unauthorised people gaining access to off-site events; and
- our legitimate interest in providing information about Teneo, our services and events we organise.
People Advisory Services
Candidates:
Collecting your personal data
We collect personal data from you during the recruitment, engagement, and onboarding stages. This may include your CV, identification documents, educational records, work history, references, correspondence and other personal data provided by you. In addition, we may also collect special category data, such as disability, race or health information where you have made this available to us.
We may also collect personal data from third parties such as an agent acting on your behalf, an interim manager, a third-party recommendation or referee or from publically available sources such as LinkedIn and company websites.
Use of your personal data
We use this information to determine your suitability as a candidate for the roles for which we are recruiting and to identify potential candidates for our clients.
Our legal grounds for processing your data are:
- a legitimate interest pursued by us or a third party including to provide our services to our clients
- compliance with a legal or regulatory obligation
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- you have given us your explicit consent to process that data;
- we are required by law to process that data in order to ensure we meet our legal obligations;
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- you have made the data manifestly public.
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Referees:
Collecting your personal data
We may collect your name and contact information (name, address, email address and phone number) from candidates during the provision of our talent advisory services.
Use of your personal data
We will use your personal data to contact and correspond with you in relation to the provision of a professional, character or other reference in relation to a candidate.
Our legal grounds for processing your personal data are:
- a legitimate interest pursued by us or a third party including to provide our services to our clients
- your explicit consent as a referee
Sub-processors
Teneo Financial Advisory Limited is required by Article 28 of the EU General Data Protection Regulation (GDPR) to disclose its sub-processors where Teneo Financial Advisory Limited is acting as a data processor. The information below includes a list of third-party sub-processors used across our products and services. Teneo Parties (meaning all entities including Teneo Financial Advisory Limited that are affiliates of Teneo Holdings LLC) may also be considered sub-processors where Teneo Financial Advisory Limited is acting as a data processor.
The applicable data protection legislation requires us to inform our clients about the sub-processors we engage where we act as a data processor. The information below contains the list of sub-processors used across Teneo Financial Advisory Limited products and services.
UK/EEA Vendors
| Vendor | Services | Address |
|---|---|---|
| Iron Mountain UK Plc | Records management storage | Cottons Centre 3rd Floor, Tooley Street, London, SE1 2TT |
| Virtual Cabinet, trading name of GetBusy UK Limited | Records management storage | Suite 8 The Works, Cambridge, CB22 3FT |
Third Country Vendors (Outside the UK/EEA)
| Vendor | Services | Address |
|---|---|---|
| Microsoft Corporation | IT Services | One Microsoft Way, Redmond, WA 98052, USA |
| Oracle America, Inc. | Technology | 1001 Sunset Blvd, Rocklin, CA 95765, USA |
Suppliers
Collecting your personal data
We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship and contract with our suppliers, to receive services from our suppliers and, where relevant, to provide professional services to our clients.
The personal data we process is usually limited to contact information (name, name of employer, phone, email and other contact details) and financial information (payment-related information).
Use of your personal data
We use this personal data for the following reasons:
- receiving services from our suppliers;
- providing professional services to our clients;
- administering, managing and developing our business and services;
- security, quality and risk management activities;
- providing information about us and our range of services; and
- complying with our legal and regulatory obligations.
Our legal grounds for processing your personal data are:
- performance of a contract;
- compliance with a legal or regulatory obligation;
- our legitimate interest in managing payments, fees and charges;
- our legitimate interest in safeguarding Teneo against inadvertently dealing with the proceeds of criminal activities or assisting in any other unlawful or fraudulent activities; and
- our legitimate interest in carrying out any of the above actions.
Visitors to our office
Collecting your personal data
The personal data which we collect from visitors to our office, provided directly by you, is generally limited to your name, email address, mobile number (where relevant) and the time you enter and leave our office. Our sign-in processes vary between offices and more information will be provided on arrival. If you have any queries in advance of visiting an office please email [email protected]
WIFI
We monitor traffic on our WIFI networks. This allows us to see limited information about a user’s network behaviour, including (at least) the source and destination addresses the user is connecting from and to.
CCTV
We use CCTV monitoring where permitted by law. CCTV images are securely stored and are only accessed on a need-to-know basis (for example, to look into an incident). We may disclose CCTV images to law enforcement bodies as requested and permitted by law. We will also share CCTV images with our insurers for the purpose of processing an insurance claim as a result of an incident. CCTV recordings are typically deleted or automatically overwritten after a short period of time, unless an issue is identified that requires further investigation.
Use of your personal data
We use this personal data for the following reasons:
- communicating with visitors in relation to their attendance and conduct at our office;
- providing visitors with facilities including access to our office, conference rooms or WIFI;
- controlling access to our office; and
- protecting our office, personnel, goods and confidential information.
Our legal grounds for processing your personal data are:
- our legitimate interest in protecting our offices, personnel, goods and confidential information; and
- our legitimate interest in preventing and detecting crime, and establishing, exercising and defending legal claims.
Visitors to our website
Collecting your personal data
When you visit our Website, you are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies and analytics tools on our Website. Please see our Cookies policy for more information on the data that is collected, how it is used and
Our legal grounds for processing your personal data are:
- our legitimate interest in effectively delivering information and services to you and the effective and lawful operation of our business;
- our legitimate interest in developing and improving our site; and
- your explicit consent as a visitor to the Website.
Third party links
Our Website may link to third party sites not controlled by Teneo and which do not operate under our privacy practices. When you link to third party sites, Teneo’s privacy practices no longer apply and we do not accept any responsibility for the information you provide on those sites or their collection and use of your personal information. We encourage you to review each third party site’s privacy policy before disclosing any personally identifiable information.
Minors
Our Website is not intended for use by minors under the age of sixteen (16) years. It is Teneo’s policy to not knowingly collect or maintain the personal data for anyone under the age of 16 except as part of an engagement to provide professional services.
Protecting Personal Information
Teneo takes the security of all the data we hold very seriously. We have in place reasonable commercial standards of technology and operational security to protect your personal information from loss, misuse and unauthorised access, disclosure, alteration or destruction. Only authorised personnel, with appropriate awareness of privacy obligations, are provided access to your personal information. We regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
All our staff and third party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.
Sharing Your Information
We will only share your personal data when we are legally permitted to do so, in connection with any of the purposes outlined in the “How we process your personal data” section above. This may involve disclosing your data to:
- other members of the Teneo Group or third parties that provide services or online platforms to us and/or the Teneo Group;
- competent authorities (including courts and authorities regulating us and other members of the Teneo Group);
- our clients;
- your employer and/or its advisers, or your advisers;
- our auditors, insurers and professional advisers;
- any other person or organisation after a restructure, sale or acquisition of any member of the Teneo Group, as long as they use your information for the same purposes we did;
- credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
- other third parties that reasonably require access to personal data relating to you.
As a result of sharing your personal data with the above parties, information we hold about you may be transferred to other countries. This may include countries outside the UK and the European Economic Area (“EEA”) and countries with laws that have not necessarily been determined to provide an adequate level of protection for the processing of personal data under the laws of the EU or other jurisdictions.
When we, or our permitted third parties, transfer your personal data outside the UK , we will take reasonable steps to ensure that your information is treated securely and the means of transfer provide adequate safeguards.
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We seek to ensure that we only keep your personal data for the longest of:
- the period necessary for the relevant activity or services;
- any retention period that is required by law; or
- the period in which litigation or investigations might arise in respect of the services.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Rights
You have various rights in relation to your personal data. In particular, you have a right to:
- request access to the personal information we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate;
- request erasure of your personal information where there is no good reason for us continuing to process it;
- object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
- object where we are processing your personal information for direct marketing purposes;
- in some circumstances, request the restriction of processing of your personal information;
- in some circumstances, request the transfer of your personal information to another party.
If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:
- writing to the Deputy General Counsel at The Carter Building, 11 Pilgrim Street, London, EC4V 6RN; or
- sending an email to [email protected].
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not, in general, have to pay a fee to exercise any of your individual rights set out in this Notice. However, we may refuse to provide access or charge a few for access if the relevant data protection legislation allows us to do so, in which case we will provide reasons for our decision as required by the law.
We hope that we will be able to resolve any query or concern you raise. However, if you feel that we have not handled your query or complaint to your satisfaction you can contact the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, on 0303 123 1113 or at ico.org.uk/concerns. . If you are not based in the UK, you have a right to complain to the relevant supervisory authority in your jurisdiction.