Privacy Policy

Gladwin International Leadership Advisors (“Gladwin International”, “we”, “us”, or “our”) is committed to protecting your privacy and safeguarding the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, retain and protect information when you visit our website at gladwininternational.com, use our executive portal (“The Apex Council”), or engage with our executive search, leadership advisory and talent intelligence services.

By accessing our website or providing us with your personal information, you consent to the practices described in this policy. If you do not agree, please do not use our services or provide us with your data.

1. Information We Collect

1.1 Information You Provide Directly

• Contact information — name, email address, phone number, postal address, and professional title, provided when you fill out a contact form, request a consultation, or correspond with us.
• Professional and career information — curriculum vitae / résumé, employment history, educational qualifications, compensation details, board memberships, professional certifications and references, shared during an executive search engagement or candidate registration.
• Portal registration data — login credentials, preferences, and self-assessment responses submitted through The Apex Council executive portal.
• Billing and engagement data — company name, GST identification number, purchase order details, and invoicing information provided during a client engagement.
• Communication records — contents of emails, messages, call notes and meeting records generated during the course of our professional relationship.
• Executive website data — if you use The Leadership Narrative, the profile, career history, photographs, documents and requests you give us for your executive website, and your approval of each version we publish. See Section 5.
• “See yourself” preview details — the details, CV and photo you choose to give us to preview our website designs with your own name and portrait. See Section 5.

1.2 Information We Collect Automatically

• Device and browser data — IP address, browser type and version, operating system, device type, screen resolution, and language preferences.
• Usage data — pages visited, time spent on pages, referring URLs, click patterns, and navigation paths through our website.
• Cookies and similar technologies — we use cookies, local storage, and pixel tags to recognise returning visitors, remember preferences, and analyse site traffic. See Section 8 for details.

1.3 Information from Third Parties

• Professional networking platforms — publicly available information from LinkedIn and similar professional platforms used to identify and evaluate potential candidates.
• Reference checks — information provided by professional references you have authorised us to contact.
• Client-provided data — information about roles, organisational context, and candidate specifications shared by our client organisations during search engagements.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Executive search and placement — identifying, evaluating, and presenting candidates for leadership positions; conducting reference checks; facilitating interviews and offer negotiations.
• Leadership advisory services — providing succession planning, compensation benchmarking, board transformation, and talent intelligence engagements.
• Portal services — operating The Apex Council executive portal, including self-assessment modules, career studio, compensation benchmarking, and the Whisper silent search agent.
• Executive websites — building, publishing, hosting and maintaining The Leadership Narrative websites, and showing you previews of our designs with your own details.
• Communication — responding to enquiries, sending engagement-related correspondence, and sharing relevant research, insights, and leadership intelligence publications (with your consent).
• Website improvement — analysing usage patterns to improve site functionality, navigation, content relevance, and user experience.
• Legal compliance — fulfilling our obligations under applicable law, responding to legal process, and enforcing our contractual terms.

3. Legal Basis for Processing

We process personal data on the following legal bases:

• Consent — where you have given explicit consent to the processing, such as subscribing to our insights publications or registering on our portal.
• Contractual necessity — where processing is necessary for the performance of a search engagement or advisory contract.
• Legitimate interest — where processing is necessary for our legitimate business interests (such as identifying candidates for client engagements), provided these interests are not overridden by your data protection rights.
• Legal obligation — where processing is required to comply with applicable laws and regulations.

4. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your information in the following limited circumstances:

• With client organisations — candidate information (résumé, assessment summaries, reference feedback) is shared with client organisations during an active search engagement, only after the candidate has been informed and, where required, has consented.
• With service providers — we engage trusted third-party providers for hosting, email delivery, analytics, and payment processing. These providers are contractually bound to process data only on our instructions and in accordance with applicable data protection standards.
• With our AI service provider — when you ask us to read your CV for a “See yourself” preview, the text of your CV is sent to Anthropic, our AI service provider, solely to extract your profile details. See Section 5.1.
• With the public, when you choose to publish — the content of a Leadership Narrative website you approve for publication is visible to anyone. See Section 5.3.
• For legal reasons — we may disclose information when required by law, court order, or government regulation, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business transfers — in the event of a merger, acquisition, or sale of all or a portion of our business, personal data may be transferred as part of the transaction, subject to standard confidentiality agreements.

5. Executive Websites and “See Yourself” Previews

This section explains how we handle personal data for The Leadership Narrative, our executive website service.

5.1 Reading Your CV

On our design pages, “See yourself” lets you preview a design with your own details. You can type them in, or upload your CV for us to read. If you upload a CV, we extract its text on our own servers. We then send that text to Anthropic, our AI service provider, solely to extract your profile details (such as your name, roles, career history, qualifications and board positions). The text is processed under the provider’s commercial API terms. We do not keep the CV file itself; we keep only the details extracted from it, which you can review and edit.

5.2 Your Preview Details and Photo

We store your preview details, and any photo you add, only with your consent and only so that you can see them across our designs. Previews are private to you. When you add a photo, we re-encode it and remove its metadata (such as camera details and location). We keep your preview details and photo for:

• 30 days from your last save, if you are signed out.
• 180 days from your last save, if you are signed in as a member.

They are then deleted. You can delete them yourself at any time from the preview page.

5.3 Publishing Your Website

Your executive website is published only when you approve it. Once published, its content — which may include your name, photograph, career history, qualifications and contact details — is public. Anyone can see it, and search engines may index it. You choose what to publish.

You can withdraw at any time. Take your website offline yourself from your studio, ask for it to be deleted from the studio's request page, or write to us at the email address in Section 15. Once offline, it is no longer served by us. Copies already made by search engines or other third parties may take time to disappear and are outside our control.

5.4 Page Counts for Your Website

For each published website we count how many times each page is viewed, per day. We do this without cookies and without storing visitors’ IP addresses or any other identifier. The counts show you how your website is being read. They are kept while your website exists and are deleted with it.

5.5 Publication Approval Records

Each time you approve a version of your website for publication, we record the version approved, the account that approved it, the date and time, your confirmation that the content is accurate and that you hold the rights to it, and the IP address used. We keep this record as evidence of your approval, for the duration of your website service and for 7 years after it ends, the same period for which we keep client engagement records.

6. Data Retention

We retain personal information for as long as necessary to fulfil the purposes described in this policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Candidate data — retained for up to 5 years after the last active engagement to facilitate future opportunities. You may request earlier deletion at any time.
• Client engagement records — retained for 7 years in accordance with Indian tax and commercial law requirements.
• Website analytics data — aggregated and anonymised data is retained indefinitely. Individual-level data is retained for 26 months.
• Portal account data — retained for as long as your account is active and for 12 months after account closure.
• “See yourself” preview details and photo — 30 days from your last save if you are signed out, or 180 days if you are signed in as a member, then deleted. The CV file itself is not stored.
• Executive website content — retained while your website service is active. If hosting is not renewed, your website is taken offline from day 16 and permanently deleted on day 46, as set out in our Terms of Use, section 7.6. You can ask us to delete it sooner.
• Executive website page counts — daily totals with no visitor identifiers, kept while your website exists and deleted with it.
• Publication approval records (including IP address) — for the duration of your website service and for 7 years after it ends.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (TLS 1.2+) and at rest (AES-256).
• Role-based access controls limiting data access to authorised personnel only.
• Regular security assessments and vulnerability testing of our infrastructure.
• Secure hosting on AWS infrastructure with SOC 2 and ISO 27001 certifications.
• Employee confidentiality agreements and regular data protection training.

While we take reasonable precautions, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

8. Cookies and Tracking Technologies

Our website uses the following categories of cookies:

• Essential cookies — required for basic site functionality such as page navigation, session management, and security. These cannot be disabled.
• Analytics cookies — used to understand how visitors interact with our website, including pages visited, time on site, and traffic sources. We use Google Analytics with IP anonymisation enabled.
• Functional cookies — remember your preferences (such as language, region, or portal settings) to provide a personalised experience. If you use “See yourself” while signed out, a functional cookie holding a random identifier links you to your saved preview. It lasts 30 days and is removed when you delete your preview.

Page counts for published Leadership Narrative websites do not use cookies (see Section 5.4).

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

9. Your Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal data:

• Right of access — request a copy of the personal data we hold about you.
• Right to rectification — request correction of inaccurate or incomplete data.
• Right to erasure — request deletion of your personal data, subject to legal retention requirements.
• Right to restrict processing — request that we limit the processing of your data in certain circumstances.
• Right to data portability — receive your data in a structured, machine-readable format.
• Right to object — object to processing based on legitimate interests or direct marketing.
• Right to withdraw consent — withdraw previously given consent at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at hello@gladwininternational.com. We will respond within 30 days of receiving your request.

10. International Data Transfers

Our primary operations are in India. Where we transfer personal data outside India — for example, when presenting candidates to international client organisations, using cloud services hosted in other jurisdictions, or sending CV text to our AI service provider (Section 5.1) — we ensure appropriate safeguards are in place, including contractual data protection clauses and, where applicable, compliance with the Digital Personal Data Protection Act, 2023 (DPDP Act) and its subsequent rules.

11. Children’s Privacy

Our services are directed at business professionals and are not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected data from a person under 18, we will delete it promptly.

12. Third-Party Links

Our website may contain links to third-party websites, including LinkedIn, professional associations, and industry publications. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before sharing any personal information.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The revised policy will be posted on this page with an updated effective date. We encourage you to review this page periodically. Material changes will be communicated via email to registered portal users.

14. Compliance with Indian Law

This Privacy Policy is designed to comply with applicable Indian data protection legislation, including the Information Technology Act, 2000 and the IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, as well as the Digital Personal Data Protection Act, 2023, as and when its rules are notified and come into effect. In the event of any conflict between this policy and applicable law, the provisions of applicable law shall prevail.

15. Grievance Officer

In accordance with applicable Indian regulations, the designated Grievance Officer for data protection matters is: