Personal Data Policy
Unity SC., with its registered office at 611 rue Aristide Bergès, Z.A. de Pré Millet 38330 Montbonnot-Saint-Martin, FRANCE, and its subsidiaries, are committed to ensuring the privacy and security of employee, customer, vendor, and visitor Personal Data. This Policy explains how we use the Personal Data we collect about you, with whom we share it, the rights you have in relation to the Personal Data we hold about you, and the procedures we have to safeguard your Personal Data.
The term “Personal Data” as used in this Policy means any information relating to you and by which you are identified or can be identified, such as your name, contact details, email address, log-in data, bank account details, etc.
1. How is Personal Data obtained and how is it used?
We collect and store Personal Data you give us. The Personal Data is collected from (a) employment relationships, (b) customers and vendors in the course of doing business, (c) visitors to our facilities, websites, and events, and (d) those who call our compliance hotline. The following sub-sections cover the specifics of each of the groups from which Personal Data is collected and explain how we use Personal Data. We will only use your Personal Data for the purposes for which we collected it.
In employment relationships, Personal Data can be processed if needed to initiate, carry out, and terminate the employment relationship. During the application process, you provide Personal Data that is used by us in making a hiring decision. Upon employment, additional Personal Data will be collected as part of your initial onboarding, in order to receive benefits for yourself and family, and in day-to-day interactions during the workday. This data is used in connection with many employment-related activities, including:
- staffing (e.g., headcount planning, recruitment, relocation, termination, succession planning);
- expatriate and secondment assignments;
- organizational planning and development and workforce management;
- budget planning and administration;
- compensation, payroll, and benefit planning and administration (e.g., salary, tax withholding, tax equalization, awards, insurance, pension, retirement accounts, wellness programs);
- workforce development, education, training, and certification;
- background checks;
- performance management;
- problem resolution (e.g., internal reviews, grievances), internal investigations, auditing, compliance, risk management;
- authorizing, granting, administering, monitoring and terminating access to or use of Unity SC systems, facilities, records, property and infrastructure;
- employee photos for identification badges, system profiles, and worldwide, regional and group organizational charts;
- business travel (e.g., rental cars, commercial flights, lodging);
- expense management (e.g., corporate card, expense and grant of authority administration, purchasing);
- project management;
- conflict of interest reporting;
- employee communications;
- flexible work arrangements;
- work-related injury and illness reporting;
- monitoring and surveillance for facility access and security;
- legal proceedings and government investigations, including preservation of confidential data;
- as required or expressly authorized by laws or regulations applicable to our business globally or by government agencies that oversee our business globally.
In certain circumstances, we may request that you provide specific consent (by appropriate and permitted means) for the collection, use and disclosure of Personal Data for some of these purposes.
b. Customers and Vendors
As a customer or vendor, you may provide Personal Data in the course of doing business with us. This Personal Data may be provided in person and through electronic communication. The Personal Data that you provide us is used to respond to your requests, notify you of product changes, orders, and deliveries, issue purchase orders, order acknowledgements, invoices, and payment, customize your interactions with us, provide materials or offers to you, and communicate with you.
Such Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in our products and services, and certain information about the company you are working for (company name and address), as well as Personal Data as to the type of relationship that exists between Unity SC and yourself. The Personal Data that you provide us is used to respond to your requests, notify you of products, customize your interactions with us, improve our offerings, provide materials or offers to you, and work with you.
If you visit an Unity SC facility, website, or event, additional information may be collected from you as a Visitor (see below).
In visiting a facility, your likeness and image may be captured by security cameras. You may also be required to disclose your identity, purpose, and contact information as part of the check-in process during your visit. If you are entering sensitive areas, you may also be required to sign a non-disclosure agreement or acknowledge in writing certain rules regarding your access.
As an event attendee, you may give us information such as your name, address, phone number, e-mail address, employment information, application information, ideas for new projects or applications, and your buying interests. The information that you provide us is used to respond to your requests, notify you of products, customize your interactions with us, improve our offerings, provide materials or offers to you, and communicate with you.
d. Hotline Callers
When calling our hotline to report an ethics or compliance issue, you may give us Personal Data such as your name, address, phone number, e-mail address, and employment information. The Personal Data that you provide us is used to investigate and respond to your report.
2. Lawful Basis
We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:
- if you have consented to us doing so; or
- if we need it to perform the contract we have entered into with you; or
- if we need it to comply with a legal obligation; or
- if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms.
3. Who does Unitysc share Personal Data with?
When using your Personal Data for the purposes and on the legal basis described above, we may have to share these with other Unitysc offices and Unitysc entities around the world as well as other vendors or services providers we work with. We may also have to share your Personal Data with regulators, public institutions, courts, or other third parties.
For the purposes described above, we may have to transfer your Personal Data from the European Economic Area (EEA) to an Unitysc office or a third party outside of the EEA and in a jurisdiction not being subject to an adequacy decision of the European Commission. We will always ensure that there is a legal basis for such data transfer so that your Personal Data is treated in a manner that is consistent with and respects the EU laws and other applicable laws and regulations on data protection. A relevant safeguard method may be having EU standard contractual clauses in place. If you require further information about this or would like to receive a copy of the safeguards in place, you can request it from firstname.lastname@example.org
4. How is my Personal Data protected?
We are committed to protecting your Personal Data from unauthorized access and unlawful processing or disclosure, as well as accidental loss, modification, or destruction. We make efforts to ensure it is kept up-to-date and collected fairly and for legitimate business and legal purposes only. Your Personal Data will not be communicated informally, stored in an unprotected manner, or kept for longer than needed to meet legal and business needs.
As a global company, Unitysc continues to determine that important business efficiencies can be achieved by consolidating information in centralized databases and systems located on third-party servers in facilities in France and Unitysc-owned servers at Unitysc facilities worldwide. All servers used by Unitysc are physically secured. Data at rest or in transit is encrypted whenever necessary, and data is backed up in an encrypted format. We have implemented network security measures to monitor and protect electronic data from cyberattacks and data breaches. Any paper documents containing Personal Data are physically protected and shredded at time of disposal.
5. How long will Unitysc retain my Personal Data?
We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements or other legitimate business purposes.
To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized 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.
In some circumstances we may anonymize your Personal Data so that it would no longer be associated with you, in which case it would no longer be Personal Data.
6. Your Rights in Relation to Your Personal Data
You can always choose not to give us your Personal Data. However, certain Personal Data is necessary for you to engage with us as a job applicant, employee, customer, vendor, visitor, or hotline caller, and we may not be able to provide all or some of our goods or services, to enter into a contract with you, or to send you requested (marketing) information.
You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data we hold. These rights are to:
- request access to your Personal Data (commonly known as a “data subject access request”), and request certain information in relation to its processing;
- request rectification of your Personal Data;
- request the erasure of your Personal Data;
- request the restriction of processing of your Personal Data;
- object to the processing of your Personal Data;
- request the transfer of your Personal Data to another party.
If you want to exercise any of these rights, please contact our Data Protection Officer at email@example.com
In addition, you may exercise your right to lodge a complaint with a supervisory authority of an EU member state.
7. Right to Withdraw Consent
In case you have provided your consent to the collection, processing, and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. To withdraw your consent, please contact our Data Protection Officer at firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims. In case we processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such marketing purposes.
You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Policy. However, we may charge a reasonable fee if your exercising of individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
9. No Automated Decision-Making
We do not apply automated decision-making or profiling techniques.
11. Changes to Our Policy
Our Policy may change from time to time. Check our website frequently to see recent changes. Unless we expressly state otherwise, our current Policy applies to all information we have about you.
12. Contact Us
If you have any further questions regarding data we collect, or how we use it, then please contact us by email at email@example.com.