UPDATED AUGUST 2018

Unity Portals Privacy Policy

In order to live up to its commitment to protect the online privacy of the users of its Unity Portals (“Portals”), as well as of any individuals whose information may be displayed via the Portals, SafeGuard World International Ltd., trading as Safeguard Global (“Safeguard Global”) has drafted this Privacy Policy, to clarify how personal information is handled in connection with the Portals and the provision of Safeguard Global’s services (“Services”).

Safeguard Global will process all personal data it receives from its customers in a lawful, fair and transparent manner, considering internationally recognised principles on the protection of personal data – including the principles of purpose limitation, storage limitation, data minimisation, data quality and confidentiality.

1. Data controller and Data Protection Officer

In providing services to its customers, Safeguard Global typically acts as a data processor, on behalf of its customers. Safeguard Global’s customers will always act as data controllers in this case, and so it is recommended for Portals users to ask the Safeguard Global customer they are affiliated to for more information on how their personal information may be processed in connection with the Services.

To get in touch with Safeguard Global’s Data Protection Officer, please contact: dpo@safeguardworld.com.

2. Personal Data processed

In order to gain access to and use the Portals, you will be required to provide information regarding yourself (as an individual user) which allows you to be identified, either directly or in connection with other information held on you.

Additionally, the Portals themselves will display information regarding you and/or other individuals affiliated to you (i.e., employees / workers on your payroll), processed by Safeguard Global in the context of the Services provided. Note that access to the Portals is restricted to (i) Safeguard Global employees / contractors, (ii) Safeguard Global customers and (iii) employees / workers of Safeguard Global customers.

This information may be classified as “Personal Data”. The categories of Personal Data which may be processed via the Portals are as follows:

a. Information requested by the Portals

In order to register an account on the Portals, you will be asked to submit information about yourself as a user, such as your professional e-mail address and date of birth. You will also be required to choose / submit your credentials (username, password, user ID and/or client ID, as applicable) in order to gain access to the Portals.

b. Information displayed in the Portals

The Portals will display Personal Data on you, or on individuals affiliated to you (i.e., your employees / workers), processed by Safeguard Global in connection with the Services provided to a given customer. This will include the following categories of information:

  • Personal identifiers (e.g., name, date of birth, contact details, marital status, nationality, identification document number);
  • Professional identifiers (e.g., employee number, date on which employment began, region, country, organisation unit, job code);
  • Payslip information (e.g., base salary, payments, contributions, deductions).

c. Special Categories of Personal Data

Depending on the local legal requirements of the country or region where a given employee is stationed, Safeguard Global may be required to process information related to that employee’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, or otherwise to process genetic data or biometric data (for the purpose of unique identification) on that employee, in order to provide the Services to Safeguard Global’s customers. This information is considered as “Special Categories of Personal Data”.

Safeguard Global does not collect any Special Categories of Personal Data via the Portals. Safeguard Global will display the Special Categories of Personal Data processed in connection with the Services provided to a given customer within the Portals, under restricted conditions of access (as is the case with all Personal Data displayed on the Portals).

d. Browsing data

The Personal Data includes several parameters including your IP address addresses of resources you request on the Portals, the time of requests made and so on. These data are used to compile statistical information on the use of the Portals, as well as to ensure its correct operation and identify any faults and/or abuse of the Portals.

e. Cookies

– Definitions, characteristics, and application of standards

Cookies are small text files that may be sent to and registered on your computer by the websites you visit (including online platforms, such as the Portals), to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.

Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.

According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “technical cookies” – i.e. cookies which are only used to send messages through an electronic communications network, or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to login) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).

Types of cookies used by the Portals

The Portals uses the following types of cookies:

  • Browsing or session cookies, which are strictly necessary for the Portals’ operation, and/or to allow you to use the Portals’ content and Services.

– First-party cookies present on the Portals

In detail, the first-party cookies present on the Portals are as follows:

Technical nameCookie type, function and purposeDuration
Session CookieSession cookie.User Session duration only

– Cookie settings

You can block or delete cookies used on the Portals via your browser options. Your cookie preferences will be reset if different browsers are used to access the Portals. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:

CAUTION: If you block or delete technical and/or function cookies used by the Portals, the Portals may become impossible to browse, certain services or functions of the Portals may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Portals.

3. Purposes of processing

Personal Data collected via the Portals are used by Safeguard Global in order to allow the creation or use of a registered account, which is needed in order to access the Portals.

Personal Data displayed on the Portals are processed by Safeguard Global, on behalf of its customers, in connection with the Services provided by Safeguard Global, and are displayed in order to provide visibility to those customers (and their employees / workers) on the specifics of the performance of the Services – namely, on the fulfilment of the customers’ contractual and legal obligations surrounding compensation of employees / workers.

As Safeguard Global typically acts as a data processor, it relies on the legal bases for processing Personal Data which are relied on by the data controller (Safeguard Global’s customer) – generally, the need to perform the employment contract with the data controller’s employees / workers, or the need to comply with legal obligations to which the data controller is subject.

4. Recipients of Personal Data

Personal Data collected via the Portals will be accessed by persons authorised by Safeguard Global to process them, as needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., Safeguard Global employees).

These Personal Data may be shared with third parties which are engaged by Safeguard Global to assist in providing the services (e.g., hosting providers, technical maintenance providers), and which generally act as sub-processors.

Finally, these Personal Data may be shared with other companies within the Safeguard Global Group, for internal administrative purposes, and with competent public entities, bodies or authorities, in accordance with the applicable law or binding orders of those entities, bodies or authorities;

Personal Data displayed on the Portals will be shared with third parties in accordance with the terms agreed between Safeguard Global and the data controller (i.e., Safeguard Global’s customer), as necessary to provide the Services.

Please refer to the Safeguard Global customer you are affiliated to for more information on this.

5. Transfers of Personal Data

Considering Safeguard Global’s worldwide presence and business operations, the recipients with which your Personal Data may be shared (see Section 4 above) are located in several different countries. Safeguard Global implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand.

Please refer to the Safeguard Global customer you are affiliated to for more information on this

6. Retention of Personal Data

Personal Data collected and displayed on the Portals will be retained for as long as Safeguard Global continues to provide Services to a given customer, or until that customer requests that these Personal Data be returned and/or deleted (unless local retention requirements demand a longer retention period).

Please refer to the Safeguard Global customer you are affiliated to for more information on this.

7. Data subjects’ rights

As a data subject, are entitled to exercise the following rights before the data controller (i.e., the Safeguard Global customer you are affiliated to), at any time:

  • Access your Personal Data (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
  • Correct or update your Personal Data, where it may be inaccurate or incomplete;
  • Request erasure of your Personal Data, where you feel that the processing is unnecessary or otherwise unlawful;
  • Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
  • Exercise your right to portability: the right to obtain a copy of your Personal Data which you have provided, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
  • Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent the processing of your Personal Data; or
  • Withdraw your consent to processing (where consent is relied on as a legal basis).

In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data has been carried out unlawfully.

Please refer to the Safeguard Global customer you are affiliated to for more information on this

8. Amendments

This Privacy Policy entered into force on 1 August 2018.

Safeguard Global reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Safeguard Global will not inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Portals. Safeguard Global therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Safeguard Global collects and uses Personal Data, on behalf of its customers.