CONFIDENTIALITY DECLARATION

AXEPTA SA’S PRIVACY PRINCIPLES

Axepta has long recognized the importance of maintaining the confidentiality of sensitive information about employees, candidates, customers, suppliers and partners. The nature of our profession requires that we collect and deal with sensitive information and we have a responsibility to protect that information for as long as it is in our possession.

Axepta respects Swiss and European laws relating to data protection to the extent that they are applicable. This privacy statement provides the information necessary to understand how we collect, use and manage the personal data of the natural persons concerned.

You are reading the French version of our privacy statement: in case of doubt, this version is valid, the versions in other languages ​​being translations of the French version.

RESPONSIBLE FOR PROCESSING

Your data is processed by Axepta SA (“we”, “Axepta”), registered in the Geneva commercial register, and which is the data controller. However, we use subcontractors to delegate part of the processing, and this document describes the measures taken to guarantee the security of your personal data also in these cases.

This privacy statement applies to the personal data of any natural person using our services (“you”):

• The users of our website;
• The people we seek to place (our candidates, consultants and temporary workers);
• Contacts with our customers, suppliers and business partners;

In addition, this privacy statement describes;

• The types of personal data that we collect and process,
• How we treat and protect this information, how long we keep it,
• With whom we share them,
• And what are your rights in relation to your personal data, and how you can exercise them.

WHAT DATA DO WE COLLECT?

It depends on the nature of our relationship.

Most of the time, we store your contact information, such as name, mailing address, email address, and phone numbers.

As a user of our website, we record information about your use (IP address, date and time, service requested, etc.), and we also store cookies. You can consult our Cookies Policy.

If you ask us to provide you with services such as a placement with our clients, we also record the necessary information, and usually contained in a CV, such as:

• Your date of birth, gender, nationality, work and settlement permit
• Your professional qualifications; your educational and professional backgrounds; your language,
  computer or other skills; your career interests; or any other information that may qualify you for a job
• If you provide them to us, your photo, extracts from the criminal record and the prosecution offices

If, in addition, we hire you as a temporary worker or consultant to one of our clients, we record administrative or financial information, such as:

• Your bank details, your AVS (social security) number, and the information on an identity document;
• Contractual, salary, tax or other information necessary for processing your contract and allowing us to fulfill our obligations as your employer
  If you provide them to us, the contact details of the people to contact in case of emergency.

Please note that your application documents may also contain sensitive data within the meaning of Art. 3 let. c of the Federal Data Protection Act (nLPD) or special categories of personal data within the meaning of Art. 9 of the EU General Data Protection Regulation. This may include, for example, data on political opinions, religious beliefs, physical or mental health or a photo showing ethnicity. If you provide such information in your application materials, you acknowledge that we may store, process and transmit this information.

HOW DO WE USE THIS INFORMATION?

We carry out all our processing on a legal basis, corresponding to (at least) one of the following categories:

• Your oral or written consent
• Compliance with a legal, regulatory or contractual requirement (such as guaranteeing the treatment of your wages or social contributions)
• Our legitimate interests, described in the next section

WE USE YOUR PERSONAL DATA IN ORDER TO:

• Create and manage your accounts on our site
• Manage our contracts with you, including the processing and payment of salaries
• Manage our client-supplier relationships
• According to the conditions of use of our website, for example sending you promotional material, newsletters, or alerts about open positions
• Perform direct marketing actions, such as promotions, offers, surveys, contests, newsletters, market research, or special events
• Respond to your requests and complaints
• Operate, evaluate and improve our business (including the analysis, optimization and development of our services; the management of our communications; the analysis of data; and the performance of internal functions such as accounting, etc. )
• Protect us against fraud and other illegal activities, by seeking to identify and prevent them, as well as in the event of legal proceedings or other claims; and
• Comply with applicable legal requirements, customary industry standards, our contractual obligations and internal policies.

In addition to the activities mentioned above, if you are a candidate, consultant or temporary worker, and you have an account on our site or have applied with us, we also use your personal data to:

• Assess your suitability and qualifications as a candidate for a position
• Offer you employment and work opportunities
• Provide you with Human Resources services, including benefit programs, assignment, payroll, performance management and disciplinary action
• Provide you with additional services, such as training, career counseling and career transition services

Perform statistical data analyzes, such as analyzing our base of candidates, consultants and temporary workers; assessment of individual performance and abilities, including scoring of work-related skills; identifying skills shortages; bringing people together and potential employment opportunities, and analyzing recruitments.

We may also use your information for other purposes, as long as we specifically notify you, at the latest when recording this information, or with your oral or written consent.

WHAT ARE OUR LEGITIMATE INTERESTS?

As data controller, Axepta may process personal information for legitimate business purposes, including:

• The analysis, optimization, development or, in general, modification of our services;
• The identification and prevention of fraud;
• Improving the security of our network and our information systems;
• Better understanding of our visitors’ interactions with our website;
• Direct marketing purposes, as well as measuring the efficiency of promotional and advertising campaigns
• Sending postal communications which we deem to be of interest to you.

Whenever we process data for these purposes, we take great care to ensure that your rights are considered and respected. You have the right to object to such processing, and for information on how to exercise this right, please refer to the How to exercise your rights section below.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We keep personal data in our systems for as long as they are necessary for our processing or to fulfill our legal obligations or justified by our legitimate interests. We determine this time period by considering:

• The need to have the data to offer you the agreed services
• Our legitimate interests, as described in this document
• Compliance with our legal obligations, for example as the employer of our employees, consultants and temporary workers

WHAT INFORMATION DO WE SHARE?

We do not disclose the personal data we collect about you except as described in this privacy statement or in specific terms provided in connection with specific activities.

We may share your personal data with our suppliers, who perform services on our behalf and on the basis of our instructions. We have committed our suppliers to treat your data as confidential and we do not authorize these suppliers to use or disclose your personal data except to provide such services on our behalf or to comply with legal requirements.

In addition, we may disclose personal data about you (i) if the law or legal process requires us to do so; (ii) to law enforcement authorities or on the basis of a legal request for disclosure; and (iii) when we believe the disclosure is appropriate to prevent personal injury, damage or financial loss, or in connection with an investigation of suspected illegal or fraudulent activity.

We also reserve the right to transfer your personal data in the event of a total or partial sale of our business or our assets (including in the event of reorganization, dissolution or liquidation).

DO WE TRANSFER YOUR DATA ABROAD?

We may transfer your personal data outside of Switzerland, to countries in the European Union (subject to the EU General Data Protection Regulation) or to other countries. When we transfer your personal data to countries without a level of data protection equivalent to that of the EU or Switzerland, we make sure to obtain the necessary guarantees for the sufficient protection of your personal data. In particular, we apply the directives of the Federal Data Protection and Transparency Officer.

WHAT ARE YOUR RIGHTS ?

The legal framework may give you the following rights in relation to your personal data. You can exercise several of these rights, by contacting us at dpo@axepta.com.

• Right to information: you have the right to receive a range of information, whether your personal data has been collected from you or not.
• Right of access and right of rectification: you have the right to access your personal data in order to verify that it is processed in accordance with the law. You also have the right to have your personal data corrected or supplemented in order to ensure the accuracy of the processing.
• Right to erasure (“right to be forgotten”), and right to restriction of processing: You have the right to ask us to delete your personal data, or to stop processing them if we are unable to delete them.
• The responsible person’s notification obligation: any rectification, erasure or limitation of the processing of your personal data must be communicated to you, unless such communication proves impossible or requires disproportionate efforts.
• Right to data portability: you have the right to retrieve your personal data, in a structured, commonly used and machine-readable format and the right to transmit your personal data to another controller.
• Right to object: you have the right to object at any time to our processing of your personal data, for reasons set out in law, without having to justify your decision.
• Right to object to decisions taken by automated means: also concerns profiling, and typically regulates the use of cookies.
• Right to communication of a personal data breach: you have the right to have your personal data breaches communicated as soon as possible that may pose a high risk to your rights and freedoms.

When the processing is based on your consent, you have the right to withdraw your consent at any time with effect for the future.

To exercise your rights regarding the processing of your personal data, please refer to the “How to exercise your rights” section below.

UPDATES TO OUR PRIVACY STATEMENT

This privacy statement may be amended at any time to reflect changes in our privacy practices or the legal framework. In the event of a material change, we will do our best to notify you, including by posting a message on our website. In any case, we recommend that you check the version of this statement, the version of which published on our website is authoritative.

HOW TO EXERCISE YOUR RIGHTS

To exercise your rights, or to request the deletion of your data: you can send an e-mail to the address dpo@axepta.com

Please keep in mind that if you exercise your right of objection, it may affect our ability to perform and provide services to you for your benefit.

HOW TO CONTACT US

For any questions or comments about this privacy statement or our data processing, you can write to:

Axepta SA
Data Protection Officer
Quai du Seujet 12
1201 Genève, Suisse

E-mail: dpo@axepta.com