Notice of Privacy In accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter "THE LAW"), we would like to ask you to carefully read the Terms and Conditions contained in this document, since the simple contribution you make of your "Personal Data" (hereinafter your "PERSONAL DATA") constitutes acceptance of these Terms and Conditions 1. PREMIERDS DESTINATION SERVICES, SA DE CV and other subsidiaries (hereinafter PREMIERDS), will be responsible for your "PERSONAL DATA", in accordance with the provisions of section I of article 16 of "THE LAW", with address at Varsovia 36, 5th floor Private 503, Colonia Juárez, Cuauhtémoc Delegation, Mexico City, Postal Code 06600. 2. The terms "Personal Data" and "Sensitive Personal Data" will have the meaning attributed to them in sections V and VI of article 3 of "THE LAW". 3. The term "Treatment" (hereinafter the "TREATMENT") will have the meaning attributed to it in section XVIII of "THE LAW". 4. The "PERSONAL DATA" that you can provide to PREMIERDS will be your full name, address, telephone number, age, gender, occupation, email, and illness or disease. 5. The "SENSITIVE PERSONAL DATA" that you can provide to PREMIERDS will be your condition and will have the use described below: USE OF DATA AND ITS PURPOSE 6. The information that you could provide to PREMIERDS may be used by the latter in order to identify you, locate you, communicate, contact you, share scientific information about your conditions, and to give you the necessary use according to the legal relationship. or commercial that may exist between PREMIERDS and you. Send you merchandise, information about benefits, advertising campaigns, promotions, surveys, statistics, purposes that are accessory to those previously indicated. 7. Said information may be transmitted to third parties by any means allowed by "THE LAW", in accordance with what is established below. The use of your "PERSONAL DATA" will be directly related to the relationship you have as a consumer, client, supplier or visitor. The temporality of the management of your "PERSONAL DATA" will remain until the purpose for which it was requested is fulfilled, from the date you provide it to PREMIERDS, being able to oppose it at the time that you deem appropriate. Once your information has been used for the purposes for which it was used, the treatment of your "PERSONAL DATA" will be canceled in accordance with the provisions of article 37 of the Regulations of "THE LAW". LIMITATION TO THE USE OF THE DATA 8. Once you give PREMIERDS your "PERSONAL DATA", these will be kept in different types of support, in accordance with current technology, access to which will be limited only to the natural and/or legal persons with whom "PREMIERDS ” have some legal relationship. PREMIERDS will have the security measures it deems appropriate to protect the use of your "PERSONAL DATA" even by unauthorized third parties. In case of requirement of your "PERSONAL DATA" by any federal and/or state authority -within its sphere of competence-, they may be made available to them, within strict compliance with "THE LAW". TREATMENT 9. The "TREATMENT" of your "PERSONAL DATA", which have been made available to PREMIERDS under any form or circumstance, may be used by PREMIERDS in accordance with these Terms and Conditions, so from this At this time it is understood that you expressly authorize PREMIERDS for this purpose, until you express your opposition in writing, by telephone, electronically, or by any optical, sound, visual or other means that technology allows now or in the future. through any of the means indicated by "THE LAW". DATA 10. You will have access to your "PERSONAL DATA" at all times, whether to request access, rectification, cancellation or opposition in accordance with the provisions of "THE LAW", in writing, electronically or by telephone, directing your message generically to PREMIERDS DESTINATION SERVICES, SA DE CV, at the following address: Varsovia 36, 5th floor Private 503, Colonia Juárez, Cuauhtémoc Delegation, Mexico City, Postal Code 06600, or to the email address privacy@PREMIERDestinationServices.com, with attention to Sean Collazos, or by calling +1-954-659-8438, Monday through Friday from 9:00 a.m. to 5:00 p.m., on business days, as appropriate. For purposes of exercising this right, in accordance with article 29 of "THE LAW", you must notify PREMIERDS reliably and by any means, stating the purpose for which you provide your "PERSONAL DATA", as well as the name of the person to whom you gave them and in general comply with the requirements established in article 29 of "THE LAW". The response time to your request to exercise ARCO rights will be carried out in accordance with the deadlines established by article 32 of "THE LAW". 11. You may limit the use and disclosure of your personal data, other than the exercise of your ARCO rights, in accordance with the provisions of article 16 section III of "THE LAW", in written, electronic or telephone form as established in the previous paragraph. DATA TRANSFER 12. The "PERSONAL DATA" that you provide to PREMIERD may be transferred to our clients and only in some cases, in order to obtain the benefits that you will have as a client, supplier or visitor. In the case of your "Sensitive Personal Data", you will have the right to have PREMIERDS inform you about any "TRANSFER" that it may carry out of the same to any third party, and for this you will be notified of such action by any means, whether written , telephone, electronic, optical, sound, visual or any other that technology allows now or in the future. If this is the case, you will have the right to oppose it, and you must follow the process mentioned in the immediately preceding point. 13. In the event that PREMIERDS requires the use of your "PERSONAL DATA" for purposes other than those indicated in this Privacy Notice, it will notify you either in writing, by telephone, electronically, or by any optical, sound, visual or other that technology allows now or in the future, and will explain the new uses that you intend to give said information in order to obtain your authorization. 14. In the case of "Sensitive Personal Data", you must provide PREMIERDS with your express written consent for its "TREATMENT", through your handwritten signature, electronic signature, or any authentication mechanism established for that purpose and in accordance with what is established by "THE LAW". CHANGES TO THE PRIVACY NOTICE PREMIERDS can review "LA LEY" at any time, since any change will be communicated in a timely manner on this page. If you continue to use our site, such action indicates that you accept the use of the newly provided information in accordance with the modifications made by PREMIERDS. The terms of this notice comply with applicable law, available at PREMIERdestinationservices.com. Please review them carefully since, by providing your personal data, it constitutes your acceptance. PREMIER DESTINATION SERVICES, SA DE CV, will be the "Responsible Party" for your personal information, whose address is Varsovia 36, 5th floor Private 503, Colonia Juárez, Cuauhtémoc Delegation, Mexico City, Postal Code 06600. The use of your Personal Data will have directly related to your call and will serve to identify, communicate and/or contact you derived from your activity as a customer, supplier and/or visitor. In the same way, your personal data will be used to send you merchandise, information about benefits, advertising campaigns, promotions, surveys and statistics, purposes that are accessory to those mentioned above.
Data Protection Policy 1. INTRODUCTION As part of our responsibilities to be fully compliant with all rules and regulations where we operate and offer our services, PREMIERDS Destination Services Inc. or an affiliate of PREMIERDS Destination Services Inc. (together, “PREMIERDS” or “PREMIERDS Affiliates”), are committed to international compliance with data protection laws. Ensuring data protection is pivotal not only to our service offering and reputation, but most importantly for building and developing trustworthy partnerships with businesses and customers alike.Daniel Wing This policy (“Policy”) sets out our commitment to comply with all rules and regulations under all applicable data protection laws, including transparency. It provides the necessary framework conditions and ensures the proper level of data protection for cross-border data transmission among the PREMIERDS Affiliates (as defined below), staff, consultants and/or contractors. The Executive Committee and Compliance Committee (as defined below), responsible for ensuring that we comply with all legal obligations, have approved this policy. It sets out the rules and steps to take or actions to carry out whenever we obtain, store, use, delete and/or destroy Personal Data (as defined below). 2. POLICY SCOPE & APPLICATION We process Personal Data of Individuals (as defined below) such as staff, consultants and/or contractors, and customers only for specific purposes, including but not limited to pre-authorized services. This processing is regulated by data protection laws, rules and regulations where we operate and from May 2018 the European Union’s General Data Protection Regulation (“GDPR”). PREMIERDS is not registered as a Data Controller/Processor with any regulatory body and/or authority; however, we take data privacy and protection obligations extremely seriously- including the different data managing roles we may play- and are fully committed to be compliant with GDPR and other legislation where we operate. This Policy applies to all our staff, consultants and/or contractors/agents, and other third parties authorized by us who use or process any Personal Data pertaining or related to us and/or our service offering. In countries where the data of legal entities is protected to the same extent as Personal Data, this Policy will equally apply. PREMIERDS Affiliates are not entitled to adopt regulations that deviate from this Policy. Additional data protection policies can be created in agreement with the Data Protection Officer (as defined below) and Compliance Committee only if required by applicable national laws. Overall, the reason for enforcing this Policy is to make sure that all Personal Data handled by us and/or oue staff, consultants and/or contractors, is: Handled and processed in a lawful, fair and transparent manner; Handled and processed specifically, explicitly, legitimately and most important –exclusively- for the purposes of our service offering; Handled and processed not in a manner that is incompatible with those purposes; Handled and processed with proper care – including appropriate safeguards set out by us- accurate, up to date and limited scope to what is required; and Avoid keeping it longer than necessary other than for the purposes for which it is being processed. 3. POLICY DEFINITIONS Definition of the following terms used throughout this Policy include: Consent: means the Individual has been fully informed of the intended purpose of processing Personal Data, and agrees for PREMIERDS (including but not limited to PREMIERDS Network –as defined below-, staff, consultants and/or contractors) to do so without pressure being exerted upon them. There must be some active communication between the PREMIERDS, the Data Controller and/or the Individual such as consent is given as part of completion of an on-line form, physical signing a form or in email format and a record of the consent should be retained; Data Controller: includes any individual, business partner, government authority or other body who (or which) decides what Personal Data PREMIERDS will process and for what purpose, and the means and guidelines for its use. PREMIERDS’s Data Controller role is limited to the data which it processes directly – including staff, consultants and/or contractors personal information; Data Processor: means any individual, business partner, contractor or third party, which processes Personal Data on PREMIERDS’s behalf and/or on PREMIERDS’s instructions (i.e. those within PREMIERDS’s supply chain network that provide a specific service); Data Protection Officer (“DPO”): is the person accountable for ensuring that PREMIERDS follows this Policy and complies with all data protection laws, including GDPR; Individual: includes all data subjects who PREMIERDS holds or otherwise process Personal Data on behalf of. All Individuals have legal rights in relation to their Personal Data as prescribed by law and as described in this Policy; Personal Data: entails any personal information relating to a living individual who is either identified or identifiable. It must be an individual and cannot be a company or a public body. Legal representatives of companies or organizations would, however, be individuals; PREMIERDS Affiliates comprises a group of entities affiliated with or controlled by PREMIERDS for purposes of PREMIERDS’s service offering; Processing means any activity and/or operation carried out by a Data Processor that involves Personal Data; and Special Categories of Personal Data include information deemed sensible about an individual, such as racial or ethnic origin; political opinions; religious beliefs; disabilities; health and medical records; genetic and biometric data; criminal records and sexual orientation. PREMIERDS will process this Personal Data only if required by law and/or under strict conditions. 4. PREMIERDS ROLES & RESPONSIBILITIES For a full list of members for each group, please contact the DPO. PREMIERDS Executive Committee The Executive Group is responsible for review and approval of this Policy. PREMIERDS Compliance Committee The Compliance Committee is responsible for approval and execution of this Policy. Compliance Committee Members are selected by PREMIERDS’s Executive Group. PREMIERDS Business Unit Managers PREMIERDS has appointed Business Unit Managers (“BUM”) with local responsibility for data protection compliance for Personal Data processed in their area and within their teams. PREMIERDS Data Protection Officer PREMIERDS’s Data Protection Officer (“DPO”) is primarily responsible for advising on and assessing PREMIERDS’s compliance with data protection laws and GDPR and making recommendations to improve practice in this area. Further, the DPO acts as PREMIERDS’s primary point of contact for all data protection matters, including GDPR. PREMIERDS Staff All staff, including permanent staff, fixed term contractors and temporary workers must comply with the rules and policies made by PREMIERDS including this Policy, and from May 2018 GDPR whenever collecting and processing Personal Data held, as part of their role or activities carried out by or on behalf of PREMIERDS PREMIERDS Consultants and Contractors Third parties such as consultants, contractors or agents, undertaking work on behalf of PREMIERDS involving Personal Data, must adhere to PREMIERDS’s Policy, comply with data protection laws and from May 2018, the GDPR. Provisions will be included in contracts with external providers to ensure compliance with this Policy, data protection laws and GDPR. Responsibilities include: Adding, amend and updating Personal Data – PREMIERDS Staff; Deleting Personal Data – IT Administrator as instructed by DPO; Responding to requests for rectification, erasure, restriction data portability, objection, automated decision making processes and profiling and withdrawal of consent – IT Administrator as instructed by DPO; Reporting Personal Data breaches and/or dealing with complaints – PREMIERDS Compliance Committee. 5. PERSONAL DATA – COMPLIANCE WITH DATA PROTECTION LAWS, INCLUDING GDPR PREMIERDS will implement and monitor annual completion of, mandatory data protection reinforcement for all staff. The content of such reinforcement will be reviewed annually; however, it may also issue additional procedures, guidance or instructions from time to time. PREMIERDS reserves the right to correct any activities carried out by or on behalf of PREMIERDS that it deems not compliant with this Policy whenever necessary; PREMIERDS will protect the security of Personal Data by maintaining, and monitoring compliance with PREMIERDS’s Information Security Policy and Information Classification Scheme; PREMIERDS will maintain a Records Retention and Disposal Schedule setting the periods for which records containing Personal Data are to be retained; PREMIERDS will enter into legally binding agreements and/or addenda with external bodies where those bodies are engaged to process Personal Data on PREMIERDS’s behalf; PREMIERDS will implement adequacy arrangements where transferring any Personal Data coming from or going outside the European Union; PREMIERDS will only disclose Personal Data to third parties such as sub-sub processors and other bodies such as central governments, police and institutions where there is a lawful basis for doing so and appropriate arrangements are in place with those parties; and PREMIERDS will seek to ensure that Personal Data is shared across different PREMIERDS teams, business units and/or locations only if these have a legitimate business need for accessing that data. 6. PERSONAL DATA – COLLECTION, USAGE, TRANSFER & PROCESSING In the course of PREMIERDS’s service offering, Personal Data from many different Individuals may be collected and processed for destination and immigration services purposes only. The legal bases we rely upon to offer these services to you are consent, legitimate interest, legal obligation, contractual obligation. Collection also includes Personal Data received straight from the Individual, a Data Controller, etc. Personal Data may include, but is not limited to, name, gender, date of birth, address, email address, phone number, citizenship, passport information, educational background, employment history, etc. We also receive Personal Data from third parties with whom we conduct business with, such as distributors, and other companies or organizations with whom we enter into agreements to support our business and operations. PREMIERDS’s usage and processing of Personal Data will always be lawful and in addition to other provisions under this Policy, within one of the following legal conditions: Required for an agreement, application, request for, with or on behalf of the Individual; Mandatory in order for PREMIERDS to comply with a legal obligation; Deemed as a vital interest (protecting someone’s life); Essential for PREMIERDS to perform a task in the public interest, and the task has a clear basis in law; Required for legitimate interests pursued by PREMIERDS, PREMIERDS’s staff, consultants and/or contractors, unless these are overridden by the interests, rights and freedoms of the Individual; If none of the conditions above applies, the usage and/or processing will only be lawful if the Individual has given Consent. PREMIERDS processes Personal Data for PREMIERDS’s services offering only, in both electronic and paper form. Personal Data can include – without limitation- information such as names, contact details, education or employment details. Further, Special Categories of Personal Data may be requested, however this will only be for specific purposes explained to the Individual. In the event Children’s Personal Data is required for PREMIERDS’s service offering, PREMIERDS will seek Consent and require this from the children’s parents or legal guardian. 7. PERSONAL DATA – DISCLOSURE & CONSENT PREMIERDS may share data with third parties only where it pertains PREMIERDS’s service offering related to a specific Individual and where it has a legal basis to do so. All PREMIERDS forms (whether electronic or paper-based) that gather Personal Data on an Individual contain a statement explaining the purpose of using and disclosing such Personal Data. This may require Consent from the Individual if there is not a lawful basis to share the data, however PREMIERDS will request such Consent at all times, including through application forms, notifications and other relevant means and documentation. Personal Data should not be obtained, held, used or disclosed unless the individual has given consent. Only authorized and properly instructed PREMIERDS team members are allowed to disclose Personal Data. PREMIERDS will always keep records of Personal Data shared with a third party, which will include recording any exemptions which have been applied, and why they have been applied. Consent can however, be withdrawn at any time and if withdrawn, the processing will stop. Individuals will be promptly informed of their right to withdraw Consent. 8. PERSONAL DATA – PROTECTION RIGHTS, INCLUDING RIGHT TO BE FORGOTTEN PREMIERDS will comply with requests from an Individual to exercise their rights under data protection laws, and from 25 May 2018, GDPR. Individual’s rights in relation to their personal data include: The right to object to the processing of their Personal Data. The right to request that the processing of their Personal Data is restricted. The right to request their Personal Data is rectified if inaccurate. The right to request erasure of their Personal Data. The right of portability in relation to their Personal Data and The right to object to processing which involves automated decision making or profiling. All Individuals have the right to be informed what information PREMIERDS holds about them and to request copies of that information (also known as “Subject Access Request”). Any Individual wishing to submit a Subject Access Request should contact privacy@ PREMIERDSdestinationservices.com. Any PREMIERDS staff, consultant and/or contractor who receives a request from an Individual to exercise the above rights under data protection laws and GDPR must escalate such request to the DPO and Compliance Committee immediately via privacy@ PREMIERDSdestinationservices.com. PREMIERDS staff, consultants and/or contractors are responsible for cooperating with the DPO and the Compliance Committee to ensure that PREMIERDS can comply with an Individual’s request. PREMIERDS at all times will promptly inform the Data Processor who authorized PREMIERDS of such service (when applicable) about the Individual’s request and will be copied on all steps taken in order to comply with the Individual’s request. 9. PERSONAL DATA – PREMIERDS & STAFF All PREMIERDS staff, consultants and/or contractors are responsible for checking the information they provide to PREMIERDS in connection with or related to their employment, supplier’s role and/or agreement is accurate and up to date. Any changes to Personal Data provided (including, but not limited to change of address, etc.) must be promptly notified, in writing, to PREMIERDS via privacy@ PREMIERdestinationservices.com or the appropriate channel according to supply chain instructions. PREMIERDS will not be held responsible for errors unless staff, consultants and/or contractors have properly informed PREMIERDS about them. 10. PERSONAL DATA – SECURITY & BREACHES PREMIERDS will always use appropriate measures to keep Personal Data secure at all points of the processing. Keeping Personal Data secure includes protecting it from unauthorized or unlawful processing, or from accidental loss, destruction or damage. PREMIERDS has implemented security measures which provide a level of security which is appropriate to the risks involved in the processing. Measures include but are not limited to technical and organizational security procedures, encryption, cyber security and data minimization (i.e. not keeping Personal Data for longer than necessary). In assessing what measures are the most appropriate, PREMIERDS has taken into account the following: Security measures quality and effectiveness. Implementation Costs. Nature, scope, context and purpose of Personal Data Processing; and Risk assessment to the safeguards of Individuals’ Personal Data, including data breach. PREMIERDS’s security measures include, without limitation: Technical systems security features, including secure server and software programs, password protected files, encrypted information, double authentication, digital fingerprints, etc. Restrictions (both physically and digital) to minimize access to Personal Data. Restoration of systems and availability of Personal Data in the event of an incident and/or emergency. Physical security or information at PREMIERDS’s premises. Management and organizational guidelines, in the form of policies, procedures, training and/or audits. Continuous testing and evaluation of PREMIERDS’s security measures effectiveness. Personal Data breaches means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed. PREMIERDS will comply with requests from an Individual to exercise their rights under data protection laws, and from 25 May 2018, GDPR. Individual’s rights in relation to their personal data include: The right to object to the processing of their Personal Data. The right to request that the processing of their Personal Data is restricted. The right to request their Personal Data is rectified if inaccurate. The right to request erasure of their Personal Data. The right of portability in relation to their Personal Data; and The right to object to processing which involves automated decision making or profiling. All Individuals have the right to be informed what information PREMIERDS holds about them and to request copies of that information (also known as “Subject Access Request”). Any Individual wishing to submit a Subject Access Request should contact privacy@ PREMIERDSdestinationservices.com. Any PREMIERDS staff, consultant and/or contractor who receives a request from an Individual to exercise the above rights under data protection laws and GDPR must escalate such request to the DPO and Compliance Committee immediately via privacy@ PREMIERDSdestinationservices.com. PREMIERDS staff, consultants and/or contractors are responsible for cooperating with the DPO and the Compliance Committee to ensure that PREMIERDS can comply with an Individual’s request. PREMIERDS at all times will promptly inform the Data Processor who authorized PREMIERDS of such service (when applicable) about the Individual’s request and will be copied on all steps taken in order to comply with the Individual’s request. 11. PERSONAL DATA – CONFIDENTIALITY PREMIERDS’s use of Personal Data is subject to data secrecy. PREMIERDS treats this data as confidential on a personal level and secured with suitable organizational and technical measures to prevent unauthorized access, illegal processing or distribution, as well as accidental loss, modification or destruction. 12. PERSONAL DATA – DELETION & DESTRUCTION Personal Data that is no longer needed by PREMIERDS (including PREMIERDS staff, consultants and/or contractors) after the finalization of a service and/or expiration of legal or business process-related periods must be deleted and/or destroyed. From time to time, there will be instances in which such Personal Data is deemed significant for the continuance of PREMIERDS’s service offering pertaining certain Individuals. If so, such Personal Data must be kept on file until the interests that merit protection have been made clear, or PREMIERDS’s corporate archive has examined the Personal Data to determine whether it must be retained for historical purposes. 13. PERSONAL DATA – DIRECT MARKETING PREMIERDS will comply with the rules set out in data protection laws, including GDPR and other any laws, which may amend or replace the regulations around direct marketing. This includes, without limitation, when PREMIERDS makes contact with Individuals by post, email, text message, social media messaging, telephone (both live and recorded calls), fax, and any other means. PREMIERDS deems direct marketing as any kind of communication of any advertising or marketing material, which is directed or addressed to Individuals. This does not need to be for selling or advertising purposes. It includes contact made by organizations to individuals for the purposes of promoting the organization’s aims. Any direct marketing material that PREMIERDS sends will identify PREMIERDS as the sender and will describe how people can object to receiving similar communications in the future. If an Individual exercises their right to object to direct marketing PREMIERDS will immediately stop this. 14. COMPLIANCE Compliance with this Policy and any data protection laws –including from May 2018, GDPR- is responsibility of all PREMIERDS staff, consultants and/or contractors and all must comply with the rules and procedures set out in this Policy and any other set by PREMIERDS. It is a condition of being part of PREMIERDS staff, consultants and/or contractors that all PREMIERDS rules and regulations (including but not limited to, this Policy) are fully complied with. Any breach of this Policy by PREMIERDS’s staff, consultants and/or contractors may result in disciplinary action, including but not limited to, denied access to PREMIERDS’s system, immediate termination of their agreement with PREMIERDS and any other PREMIERDS deems necessary. Serious or deliberate breaches of data protection laws can result in a criminal prosecution. Any breach of GDPR by PREMIERDS (including PREMIERDS’s staff, consultants and/or contractors) may result in a substantial fine or actions imposed upon PREMIERDS by Data Processors. 15. OTHER This Policy applies regardless of where Personal Data is held and or the equipment used if the Processing is for purposes of PREMIERDS services offering. Further, this Policy applies to all Personal Data, Special Category Data held in any form whether manual paper records or electronic records. Questions about the interpretation or operation of this Policy should be taken up with the DPO via privacy @PREMIERDSdestinationservices.com. Any individual who considers that this Policy has not been followed in respect of Personal Data about themselves should also raise the matter with the DPO via privacy @PREMIERDSdestinationservices.com. This Policy can be amended and/or update at any time by the DPO and Compliance Committee. Any changes will be posted online and, where appropriate, we will notify changes by email. From time to time, PREMIERDS may carry out risk assessments pertaining Personal Data Processing. This include situations when PREMIERDS process Personal Data relating to vulnerable, high profile or politically exposed people, using new technology, and/or transferring data from outside the EU. Any decision on conducting a risk assessment will be recorded by the DPO and the Compliance Committee. Further information, including guidance for PREMIERDS’s staff, consultants and/or contractors about data protection laws, including GDPR can be found on PREMIERDS’s website.
Anti-Corruption, Anti-Bribery, Compliance Provisions 1. INTRODUCTION PREMIER Destination Services Inc., (“PREMIERDS”) is a global corporation comprising a network of entities affiliated with or controlled by PREMIERDS, a company registered in the State of Florida, United States of America. PREMIERDS has strict anti-bribery, anti-corruption, compliance, privacy and data protection policies (the “Policies”) that apply to all PREMIERDS services worldwide. For ease of reference, these Policies apply to PREMIERDS’s dealings with counterparties in both the public and commercial sectors. In addition, these Policies set out the basis on which any Personal Data (as defined below) PREMIERDS collects from you, or that you provide to PREMIERDS, will be processed. PREMIERDS expects business partners and others within the PREMIERDS supply chain (the “Suppliers”) to comply not only with PREMIERDS’s Policies, but also with applicable bribery, corruption, compliance and data protection laws (the “Laws”) from May 2018 the European Union’s General Data Protection Regulation (“GDPR”). All of the above information is in order to maintain the highest ethical standards of business conduct which apply to all dealings with, on behalf of, or involving PREMIERDS. 2. STATEMENT OF POLICIES PREMIERDS does not tolerate any form of bribery or corruption and it is a requirement that PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers comply with both the letter and the spirit of these Policies and all applicable Laws. PREMIERDS will not, directly or indirectly, engage in bribery and/or corruption in any form and has a zero tolerance approach to breach, whether it involves private individuals or public officials. PREMIERDS will never accept, solicit, agree to receive, promise, offer or give a bribe, facilitation payment, kickback or other improper payment. 3. BRIBERY For purposes of these Policies, “bribery” means receiving or offering a financial or other advantage, intended to induce someone (with either public or private responsibilities) to give improper assistance in breach of their duty, in bad faith and dishonesty. It also consists of improperly influencing someone with the underlying purpose of obtaining/retaining business, or an advantage in the course of business. 4. SCOPE OF POLICIES & PROHIBITIONS PREMIERDS’s Policies apply to PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers performing work for or on behalf of PREMIERDS. All the aforementioned shall refrain from and have strictly prohibited to: Engage in acts of corruption, offering or accepting bribes, including any financial payment or other form of benefit offered to any government official, for influencing any decision that it should take and that is contrary to any Laws. Participate in any transactions (including financial transactions) using privileged information owned by PREMIERDS or allow the improper use of such information for their benefit. This provision includes disclosing confidential or privileged information that may be used for illicit purposes. Take part in actions of corruption, both actively (offering and/or paying bribes) and/or passively (accepting the pressure resulting from extortion). Provide any gratification (including economic benefit of any kind), to any public official or in customs in any jurisdiction, in order for them to omit and/or refrain any of their official acts and thereby ensure or accelerate any operation that relates to the area in which they operate. Accept a gift or hospitality from a third party if they know or suspect that it is offered or provided with an expectation that a business advantage will be provided by PREMIERDS in return; Threaten or retaliate against another member of PREMIERDS, including but not limited to staff, consultants, contactors and/or agents, Suppliers and/or other who have refused to commit a bribery offence. Please take note the list above is not exhaustive and PREMIERDS will revise this as and when needed. 5. VIOLATION & FAILURE TO COMPLY WITH THESE POLICIES PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers who contravene these Policies and/or Laws may expose PREMIERDS practices and themselves to significant criminal and/or civil sanctions. A failure to act in accordance with the letter and spirit of any applicable Laws and PREMIERDS’s Policies may result in: Penalties and responsibilities, which may be exercised under the laws of one or more than one jurisdiction; Damage to PREMIERDS’s corporate image and reputation, including any comments or information that comes out in the media; Termination of agreements with immediate effect. Other penalties as deemed necessary by PREMIERDS or according to applicable Laws. 6. PROTECTION PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers should tell their PREMIERDS contact any time they become aware that a payment is being requested and/or demanded and that they suspect is forbidden by these Policies. This includes threats, bribes and/or blackmailing. If the aforementioned suspect a colleague of having made a payment, that is not permitted, they should report it directly to their PREMIERDS contact in the strictest confidence. PREMIERDS encourages openness and will support anyone who raises in good faith, genuine concerns under these Policies even if they turn out to be mistaken. PREMIERDS is committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith his/her suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. 7. RISK ASSESSMENT & PROCEDURES PREMIERDS regularly carries out a risk assessment identifying and prioritizing anti-corruption risks. This includes an evaluation of the jurisdictions in which PREMIERDS operates as well as for the entities and Suppliers have dealings with, third parties and the degree of interaction with public and/or government officials. 8. EDUCATION & REINFORCEMENT PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers are not expected to be experts in the Laws applicable to them. However, they should be aware of the circumstances when Bribery and corruption concerns may arise because of any of the Laws of their own and other jurisdictions and adjust their behavior accordingly. 9. PERSONAL DATA PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers collect, use, transfer and process personal information to facilitate the provision of our service offering, including but not limited to client services, billing and marketing (“Personal Data”). Personal Data may also include contact details (i.e. name, work address, telephone number and email address), work history (i.e. work function, education, training and details of former/current employment), identification information (i.e. passport details, visa and immigration status, date and place of birth) and billing information (i.e. account numbers and tax information). For further information, please review our Data Protection Policy. 10. USAGE PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers collect Personal Data through direct contact with clients, potential clients, their affiliates and affiliated individuals, and others within PREMIERDS’s supply chain through various means, including but not limited to, publicly available information on websites or from subscription services. This processing is regulated by data protection laws, rules and regulations where PREMIERDS operates and from May 2018 the European Union’s General Data Protection Regulation (“GDPR”). During the course of PREMIERDS’s business relationship with staff, consultants, contactors and/or agents, as well as Suppliers, Personal Data may be transferred to other offices within PREMIERDS affiliates or by Suppliers to facilitate and centralize the operation of services. PREMIERDS expects staff, consultants, contactors and/or agents, as well as Suppliers to handle Personal Data diligently and according to all applicable Laws, including GDPR. 11. CONSENT PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers agree not to use or disclose without consent, Personal Data for any purpose other than the purpose for which PREMIERDS provide services. It also agreed Suppliers would store all Personal Data, in a secure environment and to make all reasonable efforts to maintain the security of Personal Data and other confidential information. Please take note PREMIERDS may request from time to time, information regarding such care in order to comply with PREMIERDS’s legal obligations. For further information in relation to consent, including but not limited to, how PREMIERDS requests consent please see Primer’s Data Protection Policy. 12. INTEGRITY PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers will always handle Personal Data with absolute confidentiality, and will not alienate, disclose or appropriate Personal Data obtained in the course of our service offering, nor share with a third party unless otherwise authorized by PREMIERDS and in accordance to the Laws, including GDPR. Consistent with PREMIERDS legal obligations, PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers are expected to exercise the utmost discretion regarding the Personal Data PREMIERDS’s clients and others entrust to them. Personal Data is only collected and processed to the extent necessary for the purposes described above. Suppliers will update, correct and erase Personal Data on a regular basis. Suppliers must store and process Personal Data only for the term of their business relationship with PREMIERDS and for a period thereafter reasonably determined by business necessity and/or professional obligations, or as may be required by Laws. 13. SECURITY & PROTECTION PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers will take all commercially reasonable steps consistent with industry practice and all laws, including GDPR, to protect Personal Data by using established security standards and procedures. Please be assured that PREMIERDS adopted various procedural and technical safeguards to protect Personal Data within PREMIERDS’s global network, therefore Suppliers are expected to follow strict safeguards as well. To prevent the loss, misuse, unauthorized access, disclosure, alteration and destruction of Personal Data, all of such Personal Data in possession of Suppliers will be stored on a secure server. In addition, Personal Data provided through online forms and/or other electronic means, will be protected with absolute confidentiality by Suppliers. RESPONSIBILITIES & IMPLEMENTATION OF PREMIERDS POLICIES 14. MONITORING & REVIEW PREMIERDS must comply with the Laws in all of the countries where it operates and has offices. The exact nature of the Laws varies from country, however in order to make sure all of PREMIERDS activities (and those from others) are covered by these Policies, PREMIERDS will monitor and review them annually to measure its progress and judge its effectiveness. PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers should make sure to constantly review their compliance to these Policies. 15. ENFORCEMENT PREMIERDS staff, consultants, contractors and/or agents, as well as Suppliers who depart from these Policies are subject to strict measures, which may include termination of their agreement. Questions or concerns about the protection these Policies should be directed to the Supplier’s PREMIERDS contact. PREMIERDS and Suppliers will work in good faith to resolve any concerns related to these Policies. In addition, PREMIERDS and Suppliers will cooperate with the relevant data protection and privacy authorities in any jurisdiction in which PREMIERDS and Suppliers maintain an office and/or have operations. These Policies were issued in order to help PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers avoid risk areas, and enable them to recognize situations where they should consult PREMIERDS regarding Anti-Bribery, Anti-Corruption, Compliance and Privacy (including Data Protection) concerns. PREMIERDS will provide assistance to determine whether the behavior or project is within PREMIERDS’s guidelines and lawful and help to identify ways to achieve the same results without the risk of breaching any of applicable Laws. PREMIERDS reserves the right to change these Policies at any time without advance notice. If the changes are significant or substantive, PREMIERDS will advise them to PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers. Therefore, it is accepted all them must: Read, understand and comply with these Policies. Avoid any activity that might lead to or suggest a breach of these Policies. Notify PREMIERDS as soon as possible if believe a breach of these Policies has occurred. These Policies supersede all previous notices with respect to matters described herein. PREMIERDS appreciates confirmation by PREMIERDS staff, consultants, contactors and/or agents, as well as Suppliers of the acceptance of these Policies, a copy of which will be part of any existing file for all Suppliers.
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