Privacy Policy & Cookie Policy for 360° Leadership Evaluation Website

Effective Date: 01.01.2025 | Last Updated: 01.01.25

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1. Privacy Policy

1.1 Introduction

We respect your privacy and are committed to protecting your personal data in accordance with the GDPR and the Swiss FADP. This Privacy Policy explains how we collect, use, store, and protect your personal information when using our 360° leadership evaluation platform.

1.2 Data Controller

Nexion Consulting Sàrl
Allée du Rionzi 29
1028 Préverenges, Switzerland
scela@nexion-consulting.com

For any data protection concerns, contact our DPO at scela@nexion-consulting.com.

1.3 Personal Data We Collect

1.3.1 Leaders

• First name, last name
• Gender
• Email address
• Language preference
• Self-evaluation and survey responses

1.3.2 Raters

• First name, last name
• Email address
• Gender
• Rater status (Supervisor, Peer, Direct Report, External)

We do not collect sensitive personal data such as race, political views, health information, or union membership.

1.4 How We Collect Data

• Leaders' data is provided by their company or the leader.
• Raters' data is provided by their company or nominated by leaders.
• Survey responses are collected when evaluations are completed.

1.5 How We Use Your Data

• To conduct leadership evaluations and generate reports.
• To notify leaders and raters about evaluation participation.
• To store evaluation responses for research and survey improvement.
• To comply with legal obligations.

1.6 Legal Basis for Processing

• Legitimate Interest (Art. 6(1)(f) GDPR): Leadership evaluations are essential for organizational processes.
• Consent (Art. 6(1)(a) GDPR): Leaders must accept Terms & Conditions before participation.
• Contractual Obligation (Art. 6(1)(b) GDPR): Necessary for fulfilling organizational agreements.

1.7 Data Retention & Deletion

• Personal data is stored for 6 months after evaluation completion.
• Evaluation responses are anonymized after 6 months for research purposes.
• Users can request data deletion by contacting us at support@nexion-consulting.com.

1.8 Who Has Access to Your Data?

• Only authorized company employees responsible for evaluations.
• Coaches only with explicit leader consent.
• We do not share personal data and evaluations with third parties.

1.9 Raters’ Privacy Rights

• Raters are informed via email about their nomination.
• Raters can opt out using the provided opt-out link.

1.10 Your Rights Under GDPR & FADP

• Access your data (Leaders can log in; raters can request access).
• Rectify incorrect data.
• Request deletion of personal data.
• Object to processing (Opt-out for raters).

To exercise your rights, contact us at scela@nexion-consulting.com.

2. Cookie Policy

2.1 What Are Cookies?

Cookies are small text files stored on your device to enhance user experience.

2.2 Types of Cookies We Use

2.2.1 Necessary Cookies (No Consent Required)

These cookies are essential for the website to function.

Cookie	Purpose	Retention
sessionid	Maintains user session for login	Session
csrftoken	Protects against CSRF attacks	Session
django_language	Stores language preference	12 months

2.2.2 Optional Cookies (Consent Required)

We do not use marketing or analytics cookies.

2.3 Managing Cookies

You can manage cookie preferences through your browser settings. To learn more, visit our Cookie Settings page.

2.4 Changes to This Policy

We may update this Privacy & Cookie Policy to reflect legal or operational changes.

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