PREAMBLE
Sodexo is committed to handling Personal Data in compliance with The Information Technology Act, 2000, The Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, The General Data Protection Regulation (GDPR), to the extent applicable and any other applicable law and aims to deal promptly and efficiently with any queries relating to the Sodexo entities’ processing of Personal Data.

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’s requests relating to compliance with the applicable legislation and the Data subject’s Personal Data.

DEFINITIONS

 
SCOPE
This policy applies to the global organization of Sodexo entities (hereinafter designated as “Sodexo”) for all dimensions and activities, in all geographies where we operate, where the Sodexo’s Binding Corporate Rules or the General Data Protection Regulation apply.

This policy applies to the Processing of Personal Data 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 Data” 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 global organization of Sodexo entities.

YOUR RIGHTS UNDER APPLICABLE LAW
Where Sodexo processes your Personal Data for its own purposes, please consult the Section “Your Rights” of our India Data Protection Policy.

Where Sodexo processes Personal Data 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 Local Data Protection Point of Contact.

If you have any queries with the Processing of your Personal Data, 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 acting as Controller 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 webform or complete the below Request Form and send it 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 Data.

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 Data Protection Point of Contact 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 thirty (30) 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 Local Data Protection Point of Contact in the country of your habitual residence, place of work or place of the alleged infringement, regardless of whether you have suffered damages or not.
You have also the right to lodge your complaint before the courts where the Sodexo entity has an establishment or where you have your habitual residence.

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