PRIVACY POLICY FOR CLIENTS AND POTENTIAL CLIENTS

PRIVACY POLICY FOR CLIENTS AND POTENTIAL CLIENTS

Latest Update: 12 de Junho de 2023

Welcome to Adecco Recursos Humanos Lda. and Adecco Prestação de Serviços Lda. We are committed to providing you with the best service and to protecting and respecting your privacy.

This privacy policy (“Privacy Notice”) (together with other documents referred to herein) describes the personal information we collect about you, how we collect, use and process it.

We know this is a long document, but we urge you to read it carefully.

Below is a table of contents so that you can select the option you want if you wish.

INDEX

1. Clarification of some terminology
2. What personal information do we collect and use?
3. Why do we use personal information and how long do we keep it?
4. What marketing communications do we send?
5. How we collect your personal information?
6. Do we use artificial intelligence?
7. Do we share your personal information with third parties?
8. Do we transfer your data outside the European Union?
9. What about data security when using Adecco systems?
10. What are your rights with respect to your personal information?
11. How do we make changes to this Privacy Policy?
12. How do you contact us?

1. Clarification of some terminology

First of all we need to clarify some expressions that will be used in this Policy.

Although it may seem obvious, we will refer to “You” in this document.

When we talk about “we” or the “Company”, we mean Adecco. We are headquartered at Av. D. João II, Lote 1.06.2.5 – 8º Andar, 1990-095 Lisboa. The Company is part of the Adecco Group, the largest provider of HR (Human Resources) services in the world. Through its various companies and business lines, the Adecco Group provides various HR (Human Resources) services such as temporary employment, payroll services, recruitment and selection, assessments, career transition, talent development, training, outplacement and international mobility (“our Activities”).

To conduct our Activities, the Company uses various computer systems. In some cases, the Company provides an Open Access Portal (“Portal”) to its clients. The Portal allows you to manage your relationship with the Company and its sister companies and to search for candidates that fit your needs.

Finally, this is a Policy about information relating to individuals. This type of information is usually referred to as “Personal Information”, “Personally Identifiable Information” or “PII”. In this Policy, we use the term “Personal Information” or “data”.

2. What personal information do we collect and use?

We collect and use information to provide you with the best possible opportunities, which we have grouped as follows:

1. a)Identity Data – means your first name, surname.
2. b)Professional Data- means your professional email address, professional telephone number, company name, company address and telephone number, job title, department, service, office location and other information that may be on your business card, and power of attorney.
3. c)Technical Data- means Internet protocol (IP) addresses from which you access our or other products and services, cookies (as set forth in our Cookie Policy ), your login data (such as time, date and duration), weblogs, the type and version of browser you use to access our and other websites, applications and products and services, [traffic data], your device time zone settings and your location, the browser plug-in types and versions you use, [other communication data], the features you access on our and other websites, applications and products and services, the operating system and platform of the device you use, and details of other technologies on the devices you use to access this website and/or system.
4. d)Contact Forms Data- means any information you provide to us when you use our contact forms (for example, using the “Contact Us”, “Send Us a Message” or “Keep in Touch” functions on our websites, applications, products or services), the record of that correspondence and other personal information or information you share with us when filling in our contact forms at your own discretion. (Please note that fields marked with an asterisk (*) are mandatory fields, as we need this information to fulfill or respond to your request).
5. e)Marketing Communications Data- means the information about the way you respond via email, sms, phone and other marketing campaigns.

We use the information you provide in order to provide you with our products and services, to send you information you have requested, or to contact you to provide additional information about our available products and services, as further detailed in section 2 below.

3. Why do we use personal information and how long do we keep it?

4. What marketing communications do we send?

Communications with companies

We process your data in the context of an existing business relationship with you or your company because:

• We have a contract with you (or are considering such a contract). In this case, the preponderance of the personal information that we collect and use for marketing purposes relates to individual employees of our customers and other companies with whom we have a business relationship; or

• It is in our legitimate interest to conduct our business activities (for example, to communicate with you in a “business to business” capacity in order to promote our products and services that we believe will be of interest to you or your company). In this regard, we may also obtain contact information from public sources, including content made public on websites and social media, to make an initial contact with a relevant individual at a customer or other company; or

• You have consented to receive marketing communications from us via email as an individual at our clients/companies. In this case, we will send you marketing communications in order to develop or maintain a business relationship in accordance with applicable legislation on electronic communications and marketing. These communications may include cookies and similar technologies that allow us to know whether you access, read or delete the message, and links you may click. We typically provide you with a verification box on the forms we use to collect your personal information. If you agree to receive communications, you must click the box.

How to cancel the subscription?

In any event, when we send you marketing communications by email, you may opt-out of receiving these communications by clicking on the ‘unsubscribe’ or ‘opt-out’ function in the email.

In addition, you may also exercise your right to opt-out at any time by contacting us via email:compliance.pt@adecco.com

5. How we collect your personal information?

The personal information we collect about you comes from the contact forms or other materials you submit to us, your interactions with us and with others as part of your business relationship.

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some of the information listed in Section 2 when you provide us with your business card, speak with us at a conference or other event, or if you are a customer or potential customer.

6. Do we use artificial intelligence?

Yes, sometimes the company makes decisions based on automated systems/processes – artificial intelligence (AI). However, we do not use your personal information in any automated decision making (a decision made solely by creating and applying technologies without any human intervention) or profiling (processing personal information with a range of technologies (processing personal information with a range of technologies that produces a legal effect or similar significant effect concerning you.

We use a range of technologies to analyze your data. In all cases, there is always human intervention in these processes, as we use these tools to support our experts in making human decisions.

We use automated systems/processes with the conditions described in the previous paragraph to help our employees manage the market to query it with the most reliable data.

We may use AI (e.g. machine learning, logic or knowledge-based approaches and statistics) to provide you and our candidates and associates with the services you request from us. Although we use AI systems, all decisions that may affect you are made by our trained recruiters. Therefore, these AI systems have no legal effect.

For example, we are looking for candidates for your open positions, we may use historical as well as actual market data to build a comparison of relevant market information using machine learning, logic or knowledge based approaches and statistics that use attributes such as salary data, location, working conditions, as well as actual market comparisons of candidates to compile a report on average conditions in your region, thus attracting more and better candidates.

7. Do we share your personal information with third parties?

As mentioned in section 8 below, we normally disclose your personal information to third parties. This is done to fulfill the purposes set out in section 3 above. We do this in the following circumstances:

To our suppliers. We may, for example, engage a vendor to perform administrative and operational work in support of the relationship we have with you. The vendor(s) will be subject to contractual and legal obligations to preserve the confidentiality of your data and respect your privacy, in addition, they will only have access to the data they need to perform their functions; as a rule, these suppliers are IT service providers (who host or service our IT systems, including information about you), facilities management companies (who look after the physical security in our buildings and therefore need to know information about you to allow you access to them), and back-office accounting and financial management suppliers (who need to handle your details to process accounts payable and receivable).

We also contract with vendors that provide computer technology services and solutions.

• To members of the Adecco group of companies in other countries. These are located inside or outside the European Union. A list of the countries in which we operate is available on our website at www.adeccogroup.com/worldwide-locations.Your information will be shared with them for different reasons:

o   information is shared with members of the Adecco group who perform IT functions for Adecco companies around the world; these IT functions are located in France, Prague and Amsterdam.

o   information is also shared with Adecco partners around the world, (including legal entities acquired after the information was collected) for the purposes described above or to provide you with offers tailored to your profile where you have expressed an interest in local or international opportunities in that market, or Adecco Group Members identify that you may have particular skills needed or useful in that market.

• With our clients/potential employers: we will share your personal information with our clients who have job offers in which you may be interested, or who are interested in your profile. Any of these entities fulfill contractual and confidentiality obligations regarding your data to us and to you;

• To government or law enforcement authorities: We will share your data with government, law enforcement, regulatory or regulatory authorities if, in our sole discretion, we believe that we are legally required or authorized to do so or if it is prudent to do so.
• With potential sellers or buyers and their advisors: As part of due diligence in connection with (or the implementation of) a merger, acquisition, or other business transaction, we may need to disclose your information to the prospective seller or buyer and their advisors

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8. Do we transfer your data outside the European Union?

Your data may be transferred to and processed in one or more countries within or outside the European Union or Switzerland. A complete list of the countries in which we are present is available under the “Choose a country” function on our website at www.adeccogroup.com/worldwide-locations

We will only transfer data to parties referred to in section 7 above that are outside the European Economic Area, the United Kingdom or Switzerland:

• to countries that the Commission believes offer you an adequate level of protection under Article 45 of the EU GDPR (a list of these countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en );

• or where the Adecco Group has implemented appropriate safeguards to seek to preserve the privacy of your information (namely standard data protection clauses approved by the European Commission, copies of which can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en . These are approved by the European Commission under Article 46 of the EU GDPR

You can request further information in this regard and obtain a copy of the relevant safeguard by contacting us using the details below.

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9. What about data security when using Adecco systems?

We understand the importance of protecting your personal information. As such, we have implemented appropriate operational procedures and technical and organizational security measures to prevent any unauthorized access, alteration, deletion or transmission of this personal information.

Although we will do our best to protect your personal information, you should be aware that the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your personal information transmitted to our website or to third parties; therefore, any transmission is at your own risk.

10. What are your rights with respect to your personal information?

Under applicable data protection laws, you have the following rights:

• Right to access and obtain a copy of your personal information

You have the right to request confirmation whether we process any of your personal information. If so, you may have access to your personal information and certain information about how it is processed. In some cases, you may ask us to provide you with an electronic copy of your information. In some limited circumstances, you also have the right to request that we transfer (“port”) your personal information directly to another provider.

Right to rectify your personal information

• Right to rectify your personal information

If you can demonstrate that the personal information we hold about you is not correct, you may request that it be updated or corrected.

• Right of deletion/right to be forgotten

In certain circumstances, you have the right to request that your personal information be deleted. You may request that your data be deleted at any time, and Adecco will subsequently determine its appropriateness, as the exercise of this right may be conditioned by other legal rights or obligations of the Company to retain data. In situations where no impediment to the execution of your request is determined, Adecco will delete your information without undue delay.

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• Right to restrict or object to the processing of your personal information

In certain circumstances, you have the right to obtain restrictions on the processing of your personal information, or to object to its processing for reasons relating to your particular situation.

• Right to Withdraw Consent

You have the right to withdraw your consent at any time when we rely on it to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we will warn you that we may not be able to provide you with certain products or services. If this is the case, we will let you know at the time you withdraw your consent.

If you wish to exercise any of your rights, please fill out the following form at https://privacyportal-eu.onetrust.com/webform/8940117c-e735-4010-9984-0b12ad7dc7fc/4f2eba0b-1185-44e2-9a58-b148136c348e or, alternatively, send us an e-mail to compliance.pt@adecco.com .

Finally, you have the right to lodge a complaint with the data protection authority where you live or work, or where you consider that a problem has arisen concerning the processing of your data.

11. How do we make changes to this Privacy Policy?

The terms of this Policy may be changed where appropriate. We will post any material changes to this Policy through appropriate alerts, on our website or by contacting you through other communication channels.

12. How do you contact us?

In the case of:

• there are any questions or concerns regarding this Privacy Policy,
• you want more information about how we protect your data (for example, when we transfer it outside of Europe), or
• If you wish to contact the Adecco Group’s Data Protection Officer (DPO) or your local Privacy Officer, please send an e-mail to adecco.globalprivacy@adecco.com or to the local privacy officer at dl_pt.dpopt@adecco.com

To exercise any of your rights related to your personal information, please fill out the following form at: https://privacyportal-eu.onetrust.com/webform/8940117c-e735-4010-9984-0b12ad7dc7fc/4f2eba0b-1185-44e2-9a58-b148136c348e or, alternatively, send us an e-mail to  compliance.pt@adecco.com