1/ Privacy

Within Connectis and all of its affiliated companies (“Connectis”), we believe strongly in protecting the privacy of our customers and prospective customers (“you”). This Privacy Statement (“Privacy Statement”) describes the information we collect through the Connectis operations and through www.connectis-latam.com or those other websites owned by and maintained by Connectis (“Websites”), how we use it, and the ways it may be disclosed.

Connectis are committed to protecting the privacy of Personal Data (as defined below). Ensuring security is at the heart of everything Connectis does. In order to provide you with details of Connectis products and services, Connectis may need to collect information about you. This Privacy Statement explains how Connectis collect and use Personal Data. Third party websites accessed via our websites are not covered by this Privacy Statement and Connectis accepts no responsibility or liability in respect of third party websites.

Connectis review this Privacy Statement regularly. Occasionally Connectis may need to make changes or additions to this Privacy Statement that may affect how Connectis process your Personal Data. We will indicate on this page when the Privacy Statement has changed so please refer to our website for the latest version.

Connectis has appointed one Data Protection Officer for Connectis. The Connectis Data Protection Officer can be contacted via e-mail dpo@getronics.com or via telephone 0034 628 837 198. The Connectis Data Protection Officer is supported by other responsible Connectis employees in the local country Connectis offices in order to implement the local country data protection applications.

1.1 Personal Data

Connectis uses the following definition to describe Personal Data: any data relating to an identified or identifiable living natural person processed by Connectis or its subcontractors.

1.2 Your Information

This Privacy Statement tells you how Connectis, will collect and use your Personal Data to provide you with a positive experience on our Websites and in using our products and services.

Connectis use different methods to collect data from and about you including through:

• Direct interactions. You may give us your identity and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Further details on cookies and how to manage your cookie settings are set out below.

Third parties or publicly available sources. We may receive personal data about you from various third parties  as set out below.

Data from the following parties:

(a) website analytics providers;

(b) Identity and contact data from data brokers, credit reference agencies, or aggregators;

(c) professional social media sources such as LinkedIn;

(d)Identity and contact data from publicly available sources.

In order for Connectis to deliver information, products and services to you Connectis will need to collect Personal Data for the following purposes and your Personal Data will be processed by Connectis based on a legal ground, this includes but not limited to:

Recruitment

We collect personal data about applicants through the application and recruitment process, either directly from candidates or sometimes from an employment agency, a referrer, a referee, or background check provider for determining eligibility and suitability for initial employment, including the verification of references and qualifications and checking your are legally entitled to work in the territory where the position you are applying to is based, including for making a decision about your recruitment or appointment; determining the terms on which you work for us; checking you are legally entitled to work in the applicable region; preventing and detecting fraud; quality and diversity monitoring complying with legal or regulatory requirements, communicating with you about the recruitment process and keeping records relating to the recruitment process. This is because it is in our legitimate interests to decide whether to appoint you to a role since it would be beneficial to our business to do so. We may pass your personal data to our recruitment partners including AGS (for a list of all our recruitment partners please contact dpo@getronics.com) and our background check providers.

In any event, Connectis is committed to ensuring that the information Connectis collects and uses is appropriate for these purposes, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes Connectis would contact you for additional consent. When Connectis processing of your Personal Data is based upon your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

1.3 Information Security

Connectis employs physical, administrative, and technical safeguards and measures to protect the information Connectis processes from unauthorised access, improper use or disclosure, unauthorised modification, and unlawful destruction or accidental loss. Connectis employees and third parties to whom we employ with access to Personal Data are required to respect and observe the principles stated in this Privacy Statement. Connectis will limit access to only those persons with a legitimate need to access the Personal Data. Billing and payment information for online ordering is transferred using widely available security mechanisms. Connectis servers are maintained in secure facilities.

1.4 Information Sharing

Connectis will not sell, rent or otherwise disclose your Personal Data to any third party without your consent, except in the following circumstances:

• Connectis share non-personal, non-individually identifiable information in aggregate form with third parties for business purposes.
• Connectis will disclose your Personal Data to any appropriate third party or legal authority if we believe that you are involved in any illegal or harmful conduct; if Connectis are required to do so by law; or if Connectis believe that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend Connectis rights and property or that of Connectis customers; (3) prevent fraud; (4) protect against abuse, misuse or unauthorized use of Connectis Websites; or (5) protect the personal safety or property of Connectis customers, other persons, or the public (e.g. if you provide false or deceptive information about yourself or attempt to pose as someone else, Connectis will disclose such information about you as necessary to assist any type of investigation into your actions).
• Connectis may retain third parties to provide services to Connectis, such as technical, administrative, logistical, or professional services. These third parties may have access to the Personal Data needed to perform their functions, but not for any other purposes. Any such third party will be bound by contractual and confidentiality agreements not to disclose any Personal Data for any other purpose.

If your Personal Data is transferred across the Connectis group entities or to (sub-) contractors, suppliers and service providers (“Suppliers”) located outside the EEA in countries not offering adequate protection of Personal Data, Connectis shall put in place appropriate and suitable safeguards to protect your Personal Data, such as model clauses approved by the EU Commission. A copy of such safeguards can be obtained from Connectis’ Data Protection Officer.

1.5 How Connectis use the information

Connectis will process (collect, store and use) the Personal Data you provide in a manner compatible with the applicable data protection laws and regulations. Connectis will keep your Personal Data accurate and up to date, and not keep it for longer than is necessary for the purposes set out above in the section ‘Your Information’. Connectis is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Personal Data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal Data may be held in addition to these periods depending on individual business needs.

If you require details of the retention periods applied to the different aspects of your personal data please contact us for further details.

Connectis does not use any automated or profiling systems for processing your Personal Data.

1.6 Under what circumstances will Connectis contact me?

Connectis aim is not to be intrusive, and Connectis undertakes not to ask irrelevant or unnecessary questions. You may receive marketing material if you have consented, or we have a legitimate interest in sending this to you and you may opt out (by clicking the opt out link in the marketing material communication or by contacting the Connectis DPO directly) of receiving this material at any time.

1.7 Can I find out the Personal Data that the Connectis holds about me?

At your request, Connectis can confirm what Personal Data we hold about you and how it is processed.
At your request, Connectis can confirm what Personal Data we hold about you and how it is processed. As a data subject, you enjoy the following rights, which may be applicable in certain circumstances and may be subject to certain conditions, exemptions or exceptions as set out in applicable data protection legislation:

• Right of access. You have the right to obtain confirmation about whether or not your Personal Data is being processed and, if so, to obtain access to your Personal Data and information regarding the processing.
• Right to rectification. You have the right to correct incorrect Personal Data, complete your Personal Data and have recipients to whom Personal Data was provided informed of the rectification.
• Right to erasure. Subject to certain conditions, you have the right to have your Personal Data erased. If your Personal Data was made public, Connectis will take reasonable steps to inform the controllers who are processing the Personal Data of your request to erase it and to inform the recipients of Personal Data of your request to erase it.
• Right to restriction of processing. Subject to certain conditions, you have the right to obtain restriction of the processing of your Personal Data, and, in case of restriction, have the processing limited to mere storage.
• Right to data portability. Subject to certain conditions, you have the right to be provided with your Personal Data, which you can reuse as you wish. If you so request, Connectis has the obligation to transfer your Personal Data directly to another controller.
• Right to object. You have the right to object to the processing of your Personal Data based on certain grounds and the right at all times to object to the use of your Personal Data for direct marketing purposes.
• Right to withdraw consent. If you have given your consent to our processing of your Personal Data, you have the right to withdraw that consent at any time, without such withdrawal affecting the lawfulness of processing based on consent before its withdrawal.
• Automated individual decision-making, including profiling. In the case of automated individual decision-making, you have the right to obtain human intervention, give your point of view, receive an explanation for the automated decision, and challenge that decision.
• Right to lodge a complaint with the supervisory authority. You have the right to lodge a complaint with the relevant supervisory authority.

1.8 How to request information

In the first instance, please complete the contact form on www.connectis-latam.com outlining the request. The Connectis Data Protection Officer will respond back as required.

Connectis will require appropriate and valid proof of identity before any details of Personal Data is shared.

1.9 External Links

Connectis is not responsible for the privacy practices of other websites that may be accessed from our Websites. This Privacy Statement does not apply to the collection or use of Personal Data by other websites.

1.10 Cookies Usage

Cookie Policy

A cookie is a small text file which we transfer to your hard drive through your web browser when you visit our website. It enables our system to recognise you when you visit our website again and improve our service to you. Cookies may also be used to compile aggregate information about areas of our website that are visited most. This traffic information is used to improve the content of our website and make it easier to use. We use the following types of cookies:

• – Strictly necessary cookies: These are cookies that are required for the operation of a website. They include, for example, cookies that enable users to log into secure areas of a website, use a shopping cart or make use of e-billing service
• – Analytical/performance cookies: These types of cookies allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This assists us in improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• You can choose which cookies we activate in your cookie settings.

Cookie Settings

Blocking/Restricting Cookies

You may restrict cookies by choosing which cookies to accept in our cookie settings.

Cookie Settings

How we use cookies and similar technologies

When you visit our Websites we may send a ‘cookie’ to your computer. Cookies are files that store information on your hard drive or browser. They enable our Websites to identify your computer, and recognise that you have visited before. Cookies themselves do not contain any personal information. However, we may link the information we store in cookies to any personally identifiable information you submit while on our site.

Cookies help us understand which sections of our Websites are the most popular, as they help show which pages are being visited and how long for. This helps Connectis adapt our Websites to provide more relevant and accessible information. For example, cookies allow us to ensure that the information displayed on your next visit to our Websites will match up with your user preferences.

From time to time we may also use other technologies to log and collect data in order to analyse traffic to our Websites. These technologies will regularly only allow for an anonymous notice of your visit to be generated. However, in some instances they may allow us to obtain details about your IP address and to track visits to our Websites. In conjunction with cookies, this will enable us to identify what portions of our Websites are of interest to our visitors and to help us provide you with tailored information from our Websites.

1.11 Microsoft Teams Usage

Connectis provides employees and customers access to MS Teams.

When accessing MS Teams Connectis and in order to provide the service Connectis will have access to the following personal data:

• Content Your meetings and conversations chats, voicemail, shared files, recordings and transcriptions.
• Profile Data Data that is shared within Connectis or your company (if a customer) of you. Examples include your E-mail address, profile picture, and phone number.
• Call History A detailed history of the phone calls you make, which allows you to go back and review your own call records.
• Call Quality data Details of meetings and call data are available to our system administrators. This allows our administrators to diagnose issues related to poor call quality and service usage.
• Support/Feedback data Information related to troubleshooting tickets or feedback submission sent to Microsoft.

Connectis collects this personal data in order to provide the MS Team Service and for the legitimate interests of (a) providing the service (b) offering a communication platform to our internal and external users (c) allowing the platform to operate (d) diagnostic and service improvement.

We do pass personal data to Microsoft as part of operating this service and you can review their privacy policy at: Microsoft Teams Privacy – Microsoft Teams | Microsoft Docs

1.12 Privacy Statement Changes

Connectis may need to modify this Privacy Statement occasionally to reflect changes in our businesses or the ways in which we use information. If Connectis amends this Privacy Statement, Connectis will post those changes in a revised Privacy Statement accessible from our Websites. Unless otherwise stated, Connectis will use information in accordance with the Privacy Statement in effect when the information was collected. If Connectis materially changes the way Connectis uses or discloses Personal Data that was collected under a different Privacy Statement, Connectis will notify affected individuals via email and provide a reasonable opportunity to opt out of the revised use or disclosure (which may cause a person to be completely removed from Connectis databases).

1.13 Contact Information

If you have any requests, question, or comments concerning this Privacy Statement and or the Connectis Cookie Policy, you may contact Connectis at: dpo@getronics.com

Last updated: 1st February 2022

2/ Connectis Human Rights Statement

Connectis is a leading global IT professional services company, providing a broad range of services and solutions in strategy, consulting, digital, technology and in collaboration with the Global Workspace Alliance has operations in over 100 countries across the globe. Our stockholders, customers, suppliers, and employees represent virtually every race, national origin, religion, culture, political philosophy, and language. This diversity is the foundation of our business excellence and embodies Connectis respect for human rights and dignity of all people.

Connectis procures a variety of goods and services both for internal use and for that of our customers.

Procured goods include:

• ICT products and spares to meet both external and internal requirements
• ICT software
• Office Consumable and Equipment Supplies.

Procured Services include:

• Third Party Maintenance
• Logistics
• Financial, legal, insurance and other Professional services
• Recruitment
• Service Desks
• Fleet Services
• Training

The original manufacturer of goods procured by Connectis could be from locations across the globe. It would not be feasible for Connectis to audit the end to end supply chain. Connectis can and will however work to ensure the goods and services which Connectis procures are from manufacturers who have a strong anti-slavery policy and are taking action themselves to remove the risk of modern day slavery from their supply chain.

Connectis are committed to eradicating human exploitation from our supply chain. All Connectis suppliers must comply with the Connectis Supplier Code of Conduct

2.1 The Modern Slavery Act 2015

The Modern Slavery Act 2015 (the Act) requires companies operating in the United Kingdom (UK) to disclose information regarding the steps taken to eradicate slavery and human trafficking from their business and global supply chains. The statement below is released by the Connectis entities within the United Kingdom in response to the Act for fiscal year 2018. It describes the Connectis  business structure, relevant policies, and ongoing efforts to reduce the possibility that slavery and human trafficking occur in the Connectis business or global supply chains. Furthermore, Connectis intend to use this statement to provide stockholders, customers, and suppliers with the ability to make informed choices about the companies they support.

UK Slavery and Human Trafficking Statement

2.2 Human Rights

All Connectis Suppliers  will support and respect the protection of internationally proclaimed human rights and will operate in the spirit of the Universal Declaration of Human Rights. This includes, but is not limited to, the following subjects:

All Connectis Suppliers will recognise and respect:

• Fundamental human rights, social justice and human dignity
• Diversity of local cultures.

2.3 Labour

All Connectis Suppliers will support and respect the internationally proclaimed labour rights and will operate in the spirit of the core Conventions of the International Labour Organisation (ILO). This includes, but is not limited to, the following subjects:

2.4 All Connectis Suppliers will recognise and respect employee’s right to:

• Collective bargaining
• Freedom of association.

2.5 All Connectis Suppliers will not indulge in acts of:

• Discrimination
• Child labour
• Forced labour.

2.6 All Connectis Suppliers will:

• Compensate workers in accordance with all applicable wage laws
• Limit the working hours to the maximum as set by applicable laws
• Ensure a safe working environment.

Connectis have implemented and continue to update and strengthen its  processes to achieve the level of transparency and traceability necessary to ensure that Connectis procurement practices do not contribute to modern day slavery at any stage in the Connectis supply chain.

Steps to achieve this aim include:

• All new Connectis Suppliers will certify their compliance with the Connectis Supplier Code of Conduct
• All existing suppliers will upon the renewal of their agreement with Connectis will certify their compliance with Connectis Supplier Code of Conduct
• Connectis will map and assess the Connectis supply chain to identify potential areas of risk of forced labour and people trafficking within it
• Connectis ensuring workers in the Connectis supply chain are paid at least the minimum or living wage required by local law
• Connectis ensure that robust immigration checks are in place with Connectis  suppliers
• Connectis does where appropriate raise awareness of modern day slavery within the Connectis  business.

Below are some useful links in relation to Modern Day Slavery and Human Trafficking:

Modern Slavery Act 2015 – http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted

Walk Free Global Slavery Index – http://www.globalslaveryindex.org/

ILO Resources on Forced Labour, Human Trafficking and Slavery – http://www.ilo.org/global/topics/forced-labour/lang–en/index.htm

Verité eLearning on Supply Chain Accountability – http://www.verite.org/research/elearning

3/ Connectis Global Code of Business Conduct

The Connectis Board of Management has adopted the Connectis Global Code of Business Conduct (the “Code”) to ensure honest and ethical conduct; compliance with applicable laws and regulations; and fairness with Connectis customers, suppliers, competitors and employees. Connectis recognises and values good citizenship and do not take advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practices. The Code applies wherever Connectis does business, equally to all Connectis directors and employees, including officers, as well as employees of Connectis subsidiaries and affiliates. Connectis also expect all suppliers, contract employees, agents, consultants and others acting on Connectis behalf to abide by the principles in the Code.

Connectis is committed to the highest possible standard of corporate governance and responsibility. The Code  is not merely to comply with the letter of laws or regulations, but rather to instil and maintain a true culture of compliance wherever Connectis does business. In consequence, Connectis expects that all suppliers will embrace the letter and spirit of its commitment to integrity.

Connectis Global Code of Business Conduct