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DATA PROTECTION REQUESTS POLICY

Last update: February 17, 2020

Preamble

Sodexo Group is committed to handling Personal Information in compliance with the Cyber Security Law of the PRC and any other applicable law and aims to deal promptly and efficiently with any queries relating to the Sodexo entities’ processing of Personal Information.

In some cases, Sodexo entities may act as a Processor on behalf of a Client. In this instance the Client is responsible for handling Data subject Requests relating to compliance with relevant laws and regulations and the Data subject’s Personal Information.

Definitions

Scope

This policy applies to all Sodexo entities in Mainland China (hereinafter designated as “Sodexo”).

This policy applies to the Processing of Personal Information collected by Sodexo, directly or indirectly, from all individuals including, but not limited to Sodexo’s current, past or prospective job applicants, employees, clients, consumers, children, suppliers/vendors, contractors/subcontractors, shareholders or any third parties, with “Personal Information” being defined as any data that relates to an identified or identifiable individual or a person who may be identified by means reasonably likely to be used.

In this policy, “you” and “your” means any covered individual. “We”, “us”, “our” and “Sodexo” means the Sodexo entities.

Your rights under relevant laws

Where Sodexo processes your Personal Information for its own purposes, please consult the Section “Your Rights” of our Sodexo China Data Protection Policy.

Where Sodexo processes Personal Information on behalf of a Client, Sodexo will notify the Client of any Data subject’s Request received. Sodexo will cooperate and provide the Client with assistance in relation to the Request, to the extent legally permitted.

What our teams will do if they receive a Request?

Our approach is to engage positively and resolve your Request in a satisfactory manner without you having to file a complaint to the local Court or the relevant Data Protection Supervisory Authority.

If you have any queries with the Processing of your Personal Information, you should not hesitate to raise your query to Sodexo. To help us to deal with your Request, please provide a full written explanation of your query by completing the Request Form below.

Sodexo shall inform its Client of any Request made by a Data subject as soon as possible. The Client will be in charge of handling such Request and Sodexo will assist the Client in responding to Data subject Requests. Sodexo will directly handle Requests only when it is agreed with the Client or if the Client disappeared or cease to exist in law or became insolvent. In all other cases, Sodexo will assist the Client in responding to Data subject Requests.

Handling Requests

At the time of drafting your Request and to allow Sodexo to deal promptly with your Request in the most efficient manner, you are invited to follow these steps:

STEP 1: Complete and submit the Request Form by email to the generic email address as indicated in the information notices and/or the privacy policies provided to you at the time of the collection of your Personal Information and/or to the Local Data Protection Point of Contact at the following email address: dpo.china @sodexo.com.

STEP 2: Your Request will be treated confidentially and fully investigated where necessary. During this process, you may receive additional communication from the relevant Sodexo’s Local Single Data Protection Point of Contact and/or Sodexo’s Global Data Protection Office to investigate your concern. If you have not provided sufficient information in your Request, we will let you know what further information is needed to process your Request.

STEP 3: Once the information related to your Request is complete, we will contact you within fifteen (15) working days to provide you with an answer. This deadline may be extended in certain circumstances, depending on the nature of the Request.

STEP 4: Please note that you can choose to lodge a complaint with the Data Protection Supervisory Authority in the country of your habitual residence, place of work or place of the alleged infringement, regardless of whether you have suffered damages. Personal Information

Download the Request Form

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