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First Orion HR Privacy Notice - Global

First Orion Corp.(“First Orion,” “we,” “us,” or “our”) is committed to protecting the privacy and security of Personal Data of its employees, contractors, and job applicants (“you,” “your,” or “employee(s)”). This HR Privacy Notice (the “Notice”) outline show we collect, use, disclose, retain, and protect personal information in the course of managing HR activities.  

First Orion is the data controller for the processing of your Personal Data as described in thisNotice.

If  you have any questions regarding this Notice, please contact the HR  department or the Data Protection Officer in your country at privacy@firstorion.com.

1.             What is covered by this Notice

This Notice applies to the Processing of yourPersonal Data in the context of your recruitment and/or employment with FirstOrion. “Personal Data” is any information relating to you as an identified oridentifiable individual and “Processing” is any operation (or set thereof)which is performed on that Personal Data.

Within the category ofPersonal Data, are “special categories of personal data”, which require agreater degree of protection whilst Processing. This includes data on physicaland mental health, racial or ethnic origin, political opinions, trade union membership,religious beliefs, sexual life and genetic and biometric data.

2.             Personal Data that First OrionProcesses about Employees

First Orion may collect the followingcategories of Personal Data, either directly from Employees, or from othersources including benefits providers, background check agencies, and thirdparties such as past employers:

a.             Identification data: name, dateof birth, social security number, national insurance number, passport number,driver’s license number, employee ID, or other national ID as permitted by law

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b.             Contact information: physicaladdress, phone number(s), email, and emergency contact information.

c.             Demographic information: placeof birth, nationality, gender, marital/ civil status, language, andcitizenship/visa information.

d.             Recruitment information: yourapplication form, CV, references, educational and professional qualifications,previous employers, rehiring information, promotion information, interviewnotes, and position changes.

e.             Information about an employee’s roles,responsibilities and job performance, including your employmentcontract (and all modifications); information about previous and current dutiesand responsibilities; hire date; employee identification number; attendance;department; supervisor; employing entity; performance evaluation and assessments;and history of professional development (including any certifications,professional licenses and specialized training).

f.              Information about an employee’s compensation,reimbursement, and taxes, including salary, bonuses and additional allowances,benefits, details of bank account and pay slips, information on business traveland expenses, vacation claims and paid time off, full-time and part-timearrangements; marital status; information about parental leave (if applicable),promotions, and tax number and code.

g.             Information on the use of the company equipmentand IT systems, including CCTV footage, security access control systemsinformation, information on use of IT systems, and biometric information forverification purposes.  

h.             If there is a change in your information (e.g.,contact details, family details, identity information, bank account informationor tax number and code), it is important that you let the HR department in yourcountry know as soon as possible so our records can be updated.

3.             How long we store your Personal Data

We keep your data as long as necessary tofulfil the purposes described in this Notice, including for the purposes ofsatisfying any legal, accounting, or reporting requirements or in the terms ofany agreement between you and First Orion (including your employment contract,if any), or for so long as we are required to do so by law or in order tocomply with a legal obligation.  

4.             Purpose and Legal Basis for the Data Processing

First Orion Processes Personal Data for thefollowing purposes:

a.             recruitment;

b.             staff administration and HR management,including to plan and administer personnel matters, salary payments and theadministration and granting of benefits, complying with health & safetyregulations, for social security and tax administration and all otherprocessing related to the management of the employee contract;

c.             ensuring the safety and security of ourpremises, operations and systems, including managing admission control,ensuring the security of First Orion’s facilities and networks, managingadmission control, monitoring IT use in accordance with the Employee Handbook,where allowed by applicable law, prevention of fraud and other crime to ensurethe security of premises and information, business continuity and disasterrecovery;

d.             performance review and workforce planning,management of absences, training and professional development, conductdisciplinary and grievance proceedings;

e.             legal and compliance purposes, includingdefending our position in case of a legal dispute, to comply with employmentlaws and preventing illegal working, ensuring compliance with company policiesand requirements imposed by regulatory authorities, and conductinginvestigations into security and compliance concerns in cases of  misconduct;

f.              management of our business, includingundertaking business analytics and workplace planning (administrative andorganizational), invoicing customers, various reporting purposes, internalcommunications, including the intranet, business records, address book, andinternal newsletters, and communication with business partners, vendors andsuppliers, performing due diligence activities as well as the administrationand care of business and contact data; and

g.             staying in touch with you with news abouthappenings at First Orion.    

We Process Personal Data on the basis ofseveral legal justifications:

·     For Contractual Purposes: We haveobligations towards our Employees under the terms of their employment contractsand need to ensure we meet those obligations.

·     For our Legitimate Interests: First Orionhas a legitimate interest in conducting its business and ensuring businesscontinuity, defending its legal position and enforcing its policies.

·     To Fulfill a Legal Obligation: Certainlaws and regulations may require First Orion to Process the Personal Data ofEmployees in order to comply with our legal or regulatory obligations.

First Orion may also Process“special categories of personal data” but only where that Processing isrequired by law (such as trade union membership), where it is in the publicinterest (such as data on race or ethnicity for equal opportunity measures) orwhere you have made that data manifestly available to First Orion. In limitedcircumstances, First Orion may seek your explicit consent to process such data.It is not, however, a condition of your contract that you agree to any suchrequest by us.

Personal Data you provide to us about yourfamily members will be Processed by us for a variety of reasons, including asan emergency contact, the administration of pension and/or retirement plans,insurance programs and schemes, or otherwise as part of your benefits package.It is your responsibility to inform your family about the processing of theirPersonal Data for these purposes and to confirm that they have given theirpermission.

5.             How we share your Personal Data

For the purposes set out in Section 4 above,First Orion may share your Personal Data with other parties, including with ouraffiliates and other entities within our group that are located outside yourcountry of residence.

Other recipients of yourPersonal Data include our service providers who perform services on our behalfsuch as payroll providers, HR service providers, IT companies or serviceproviders, cloud processors, security companies, e-learning platforms, and otherservice providers appointed by First Orion from time to time. Also, we shareyour Personal Data with government entities, always associated with the laborrelation.  

We may also share yourPersonal Data with other parties who provide products or services to us, suchas our pension provider, benefits provider, insurance brokers and banks.  These third parties will also be data controllersof your Personal Data, which will be Processed in accordance with the thirdparty’s privacy policy.

We may also disclose yourPersonal Data to third parties where it is in our legitimate interest to do so,including to a potential buyer or seller of any business or assets, and togovernment/ state related agencies where we are under a duty to disclose orshare your Personal Data in order to comply with a legal obligation.

Your Personal Data may betransferred outside your country of residence, to countries that may not offeran equivalent level of protection. Regardless of where your Personal Data istransferred, we shall ensure that relevant safeguards are in place to affordyour information adequate protection in accordance with applicable legalrequirements. Where data is transferred between First Orion entities, it is onthe basis of the EU Standard Contractual Clauses. Further details regarding therelevant safeguards can be obtained from us on request.

6.             Employees’ Personal Data Rights

Depending on your country of residence, you mayhave the right to:

·     Request access to and receive information aboutthe Personal Data we maintain about you, to update and correct inaccuracies inyour Personal Data, to restrict or to object to the processing of your PersonalData, to have the information anonymized or deleted, as appropriate, or toexercise your right to data portability to easily transfer your Personal Datato another company. In addition, you may also have the right to lodge acomplaint with a supervisory authority, including in your country of residence,place of work or where an incident took place.

·     Withdraw any consent you previously provided tous regarding the processing of your Personal Data, at any time and free ofcharge. We will apply your preferences going forward and this will not affectthe lawfulness of the processing before your consent withdrawal, unless thereis any legal basis that obliges the maintenance of the consent and PersonalData.

Those rights may be limited in some circumstances by local lawrequirements.

You may exercise these rights at any time by contacting us asdescribed at the top of this policy.

·     Other privacy notices addressing specific staterequirements in the US can be found at https://firstorion.com/supplemental-hr-privacy-notice/.

7.             Security

We maintain administrative, technical andphysical safeguards designed to protect the Personal Data you provide or wecollect against accidental, unlawful or unauthorized destruction, loss,alteration, access, disclosure or use.

Highlights of First Orion’s Information Security Policy areavailable at https://firstorion.com/first-orion-security-overview/.  

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