Policy last updated on December 20, 2019.
Cervello, an A.T. Kearney Company and its subsidiaries and affiliates (“Cervello”) respect your concerns about privacy. This Website Privacy Policy applies to personal information we collect on the Cervello websites and mobile applications (collectively, the “Sites”), how we use the information, with whom we share it, and the choices available to users of our Sites regarding our use of the information. We also describe the measures we take to protect the security of the information and how users can contact us about our privacy practices.

Contact information (such as name, company, position, postal address, telephone number, and email address)
Personal information, for Cervello job applicants, as contained in a résumé, C.V., application and/or our recruitment template, employment history, education history, references, transcripts, and, where legally permissible, ethnicity, race, gender, disability status, and veteran status.

Cervello will not consider information regarding an applicant’s ethnicity, race or gender, or an applicant’s choice to decline to provide it, in evaluating the applicant’s qualifications for employment with us. This information will be used only for Equal Employment Opportunity reporting and other legal compliance purposes.

When you visit our Sites, we may collect certain information by automated means, using technologies such as cookies, web server logs, web beacons, and JavaScript. Our Sites are not designed to respond to “do not track” signals from browsers. We do not knowingly allow other parties to collect personal information about our visitors’ online activities over time and across third-party web sites when visitors use our Sites.

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Sites may use cookies (such as HTTP and HTML5 cookies) and Flash cookies, as well as other types of local storage (such as browser-based or plugin-based local storage). Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies you may not be able to use all of the features of our Sites.

In conjunction with gathering information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses, and the country and time zone where your device is located. The web server logs also may record information such as the address of the web page that referred you to our Sites and the IP address of the device you use to connect to the Internet. They also may log information about your interaction with the Sites, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons,” which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Sites.

We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyze how users use the Sites. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn more about opting out of these activities, click here.

The providers of other third-party plug-ins on our Sites, such as social sharing tools, may use automated means to collect information regarding your use of the Sites and your interactions with the plug-ins. This information is subject to the privacy policies or notices of the plug-in providers and is not subject to this Website Privacy Policy. We are not responsible for these providers’ information practices.

• Provide our products and services.
• Communicate with you about, and administer your participation in, special events, programs, offers, surveys, and market research.
• Respond to your inquiries.
• Perform data analyses (including anonymization and aggregation of personal information).
• Operate, evaluate, and improve our business (including developing new products and services; enhancing and improving our products, services, websites and mobile apps; managing our communications; analyzing our products and services; and performing accounting, auditing and other internal functions).
• Protect against, identify, and prevent fraud and other unlawful activity, claims and other liabilities and enforce relevant industry standards, and our policies

execute any agreement we may have concluded with you; or
meet our legal obligations, such as to comply with and enforce applicable legal requirements.

Send you promotional materials or other communications;

Process employment applications, including by assessing qualifications, verifying information, conducting reference or other employment-related checks, and notifying you of future opportunities that might be of interest to you; or

Manage our Sites and other aspects of our business. For residents of the European Union or Switzerland: Information about our cookie practices in the European Union is available here.

We also may use the information in other ways for which we provide specific notice at the time of collection.

We do not sell or otherwise disclose personal information we collect about you, except as described in this Website Privacy Policy. We may share personal information with service providers in connection with the operation of this Website and our company, including website hosting, the provision of our services, and promotional material distribution;. We do not authorize these service providers to use or disclose the information except as necessary to perform services we asked them to perform or comply with legal requirements.

In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities, and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you to A.T. Kearney, and in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

We offer you certain choices in connection with the personal information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the “How to Contact Us” section of this Website Privacy Policy. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete, block, or move the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described in this here.

If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA. With respect to transfers of personal information to the U.S., Cervello, Inc. and A.T Kearney Inc. are certified under the EU/Swiss-U.S. Privacy Shield frameworks issued by the U.S. Department of Commerce regarding the transfer of personal information from the EEA and Switzerland to the U.S. Click here to view our EU/Swiss-U.S. Privacy Shield Privacy Policy.

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide on the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use.

Your information will be retained for as long as necessary for the purpose(s) for which it was collected and as required by applicable laws or regulations.

If you have any questions or comments about this Website Privacy Policy, you can contact us as indicated below. You also have a right to lodge a complaint with the supervisory authority for data protection in your country.

Our Sites may provide links to other websites or apps for your convenience and information. These websites may operate independently from us. Linked sites and apps may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for the websites’ or apps’ content, any use of the websites or apps, or the privacy practices of the websites or apps.

This Website Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our Sites to notify you of any significant changes to our Website Privacy Policy and indicate at the top of the notice when it was most recently updated.

If you would like us to update information we have about you or your preferences, please contact us by email at [email protected]. You also may write to:

Cervello, Inc.
Attention: Data Privacy Team
2 Seaport Lane, 11th Floor
Boston, MA 02210

If you are a resident of the EEA or Switzerland, please see below for contact information for the Cevello entity in your country.

For purposes of our Website Privacy Policy, below are country-specific contact details for Cervello entities in the EEA and Switzerland.

United Kingdom

Cervello, Inc.
Attention: Data Privacy Team
Acre House
11/15 William Road
London
NW1 3ER

California Residents

Information Collected by Cervello and How it is Used

The CCPA requires that we provide certain disclosures to you about how your personal information is collected and used. The Privacy Policy sections above provide the relevant information.

Cervello has not sold personal information of consumers in the preceding twelve months.

Your Rights and Choices

The CCPA provides 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 we 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, 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.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• The specific pieces of personal information we collected about you (also called a data portability request).
  • 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 we 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, 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 providers to:

• Complete the transaction for which we collected the personal information, provide a good or 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 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:

Calling us at +1(866)821-4389. [Note: please inform the operator that you are a California resident calling regarding Cervello’s use of their personal data, and would like to file a report.]

Email: [email protected]

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 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. 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