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Data Privacy Notice

Last updated: April 16, 2020

Syniverse Global Data Privacy Notice for Employees, External Staff and Candidates

  1. Statement

Syniverse is made up of different legal entities, and this Notice is issued on behalf of the Syniverse group so when we mention “Syniverse,” “we,” “us,” or “our” in this document, we are referring to the relevant company in the Syniverse group responsible for processing your personal data. This notice describes how Syniverse ("Syniverse", "we" or "us") handles personal information about our staff and job applicants (collectively referred to as "you"). The term "staff member" includes those who work on a non-permanent basis, including contingent workers, temporary and contract workers, independent contractors, consultants, professional advisors, secondees and interns.

This notice does not form part of any contract of employment or other contract to provide services. This notice is not intended and shall not be read to create any express or implied promise or contract for employment, for any benefit, or for specific treatment in specific situations. Nothing in this notice should be construed to interfere with our ability to process your data for purposes of complying with our legal obligations, or for investigating alleged misconduct or violations of company policy or law, subject to compliance with local legal requirements.

Syniverse’s processing of personal data is in all cases subject to the requirements of local law, internal policy, and any consultation requirements with worker representatives (where appropriate). To the extent this notice conflicts with local law in your jurisdictions, local law controls.
We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. This notice sets out the personal information that we collect and process about you, the purposes of the processing and the rights that you have in connection with it.

If you are in any doubt regarding the applicable standards, or have any comments or questions about this notice, please contact us at the contact details in Section 10 below.

  1. Types of personal information we collect

In the course of your employment at Syniverse, or when making an application for employment, we may process personal information about you and your dependents, beneficiaries and other individuals whose personal information has been provided to us.

The types of personal information we may process include, but are not limited to:

  • Identification data – such as your name, gender, photograph, date of birth, staff member IDs.
  • Contact details – such as home and business address, telephone/email addresses, emergency contact details.
  • Employment details – such as job title/position, office location, employment contract, performance and disciplinabeckry records, grievance procedures, sickness/holiday records.
  • Background information – such as academic/professional qualifications, education, CV/résumé, criminal records data (for vetting purposes, where permissible and in accordance with applicable law).
  • National identifiers – such as national ID/passport, immigration/visa status, social security numbers (US only).
  • Spouse & dependents’ information, marital status.
  • Financial information – such as banking details, tax information, withholdings, salary, benefits, expenses, company allowances, stock and equity grants.
  • IT information – information required to provide access to company IT systems and networks, such as IP addresses, log files and login information. For further information on how IT information is processed, please see the Syniverse Information and Technology Acceptable Use Notice.

If you are a contingent worker, the type of personal information we process is limited to that needed to manage your particular work assignment with Syniverse.

Special Category Data includes any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data for the purposes of unique identification, trade union membership, or information about your health/sex life ("Special Category Data"). As a general rule, we try not to collect or process any Special Category Data about you, unless authorized by law or where necessary to comply with applicable laws.

However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Special Category Data for legitimate employment-related purposes: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations, or information about your physical or mental condition to provide work-related accommodations, health and insurance benefits to you and your dependents, or to manage absences from work.

As part of the hiring process Syniverse does obtain references from previous employers and uses third party vendors to carry out background screening of prospective employees from publicly available sources to verify the background and educational information provided to us.

  1. Purposes for processing personal information

Recruitment purposes

If you are applying for a position at Syniverse, then we collect and use this personal information primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying our reference checks or background checks (where applicable) and to generally manage the hiring process and communicate with you about it. If you are accepted for a position at Syniverse, the information collected during the recruitment process will form part of your ongoing staff member record. If you are not successful, we may still keep your application for a reasonable period of time to allow us to consider you for other suitable openings within Syniverse in the future.

Employment or work-related purposes

As a staff member at Syniverse, we collect and use your personal information for the purpose of managing our employment or working relationship with you – for example, your employment records and contract information (so we can manage our employment relationship with you), your bank account and salary details (so we can pay you), your equity grants (for stock and benefits plans administration) and details of your spouse and dependents (for emergency contact and benefits purposes).

We process our staff members' personal information through a global human resources system ("HR System"), which is a tool that helps us to administer HR and staff member compensation and benefits at an international level and which allows staff members to manage their own personal information in some cases. This will involve transferring your personal information to our servers in the US. Our parent company in the U.S, Syniverse Technologies, LLC, may host these servers or utilize third-party servers, but in either case will be responsible for the security access of personal information on the HR System.

Syniverse global directory

We maintain a global directory of staff members which contain your professional contact details (such as your name, location, photo, job title and contact details). This information will be available to everyone in the Syniverse group to facilitate global cooperation, communication and teamwork.

Other legitimate business purposes

We may also collect and use personal information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently – for example, for general HR resourcing on a global level, IT security/management, accounting purposes, or financial planning. We may also process your personal information to investigate violations of law or breaches of our own internal policies. In the event of a natural disaster or other life/safety emergency or other similar circumstances, we may use your personal information, including location based information, to notify you of such event or circumstances, to account for our employees or to protect the life and safety of employees and others.

Law-related purposes

We also may use your personal information where we consider it necessary for complying with laws and regulations, including collecting and disclosing staff member personal information as required by law (for example, for tax, health and safety, and anti-discrimination laws), under judicial authorization, or to exercise or defend the legal rights of the Syniverse group of companies.

  1. Who we share your personal information with

We take care to allow access to personal information only to those who require such access to perform their tasks and duties and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this notice and that the security and confidentiality of the information is maintained.

Transfers to other group companies

As mentioned above, we will share your personal information with other members of the Syniverse group around the world in order to administer human resources, staff member compensation and benefits at an international level on the HR System, as well as for other legitimate business purposes, such as IT services/security, tax and accounting, and general business management.

Transfers to third party service providers

In addition, we make certain personal information available to third parties who provide services to us. We do so on a "need to know basis" and in accordance with applicable data privacy law. For example, some personal information will be available to our staff member stock and benefit plans service providers and third party companies who provide us with payroll support services, relocation, tax and travel management services.

Transfers to other third parties

We may also disclose personal information to third parties on other lawful grounds, including:

  • To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant.
  • In response to lawful requests by public authorities (including for national security or law enforcement purposes).
  • As necessary to establish, exercise or defend against potential, threatened or actual litigation.
  • Where necessary to protect Syniverse, your vital interests, such as safety and security, or those of another person.
  • In connection with the sale, assignment or other transfer of all or part of our business.
  • With your consent.

  1. Legal basis for processing personal information - EEA only

If you are in the European Union or any other state of the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you (i.e., to administer an employment or work relationship with us), or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at Section 10 below.

  1. Transfer of personal information abroad

As we operate at a global level, we may need to transfer personal information to countries other than the ones in which the information was originally collected. When we export your personal information to a different country, we will take steps to ensure that such data exports comply with applicable laws. For example, if we transfer personal information from the European Economic Area to a country outside it, such as the United States, we will implement an appropriate data export solution, such as entering into EU standard contractual clauses with the data importer, or taking other measures to provide an adequate level of data protection under EU law. Syniverse Technologies, LLC has put in place model clause contracts between it and its EEA affiliates to enable transfers of employee personal information from the EEA to the United States.

  1. Data retention periods

Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally, this means your personal information will be retained until the end or your employment, employment application, or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters (e.g., judicial or disciplinary actions), to document the proper termination of your employment or work relationship (e.g., to tax authorities), to provide you with ongoing pensions or other benefits, or to allow us to consider you for other suitable positions within Syniverse in the future.

  1. Your data privacy rights (EEA only)

If you are a resident of the European Union or any other state of the European Economic Area, you may exercise the rights available to you under applicable data protection laws as follows:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided at Section 10 below.
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided at Section 10 below.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries are available here.)
  • https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

  1. Updates

This notice may be updated periodically to reflect any necessary changes in our privacy practices. In such cases, we will indicate when it was most recently updated. We encourage you to check back at this website periodically in order to be aware of the most recent version of this notice.

  1. Contact details

Please address any questions or requests relating to this notice the following or alternatively, you can raise any concerns with your line manager, local HR department or local Data Protection Officer (DPO) if you have one:

Global Data Protection Officer
Syniverse Technologies
Headquarters
8125 Highwoods Palm Way
Tampa, Florida, 33647
U.S.A.
Email: dpo@syniverse.com

Data Protection Officer
Syniverse Technologies Sarl
15 Rue Edmund Reuter
L-52326 Contern
Luxembourg
dpo@syniverse.com

The data controller of your personal information is as follows:

Syniverse entity

Address and Registration No.

Lead Supervisory Authority

Syniverse Technologies Sarl

15, Rue Edmond Reuter, L-5326 Contern, Grand Duchy of Luxembourg

Commission Nationale pour la Protection des Données (“CNPD”) in Luxembourg

Syniverse Technologies Messaging ApS

c/o TMF Denmark A/S, Købmagergade 60,1. tv, 1150 København , Denmark

Commission Nationale pour la Protection des Données (“CNPD”) in Luxembourg

Syniverse Technologies GmbH and Syniverse Technologies Messaging GmbH

Königswinterer Straße 242-252, Bonn, 53227

Germany

Commission Nationale pour la Protection des Données (“CNPD”) in Luxembourg

Syniverse Technologies BV

Herikerbergweg 238, Luna Arena, 1101CM Amsterdam, Netherlands

Commission Nationale pour la Protection des Données (“CNPD”) in Luxembourg

Syniverse Technologies Solutions Limited

18 Mansell Street, London, United Kingdom E1 8AA

UK Information Commissioners' Office

Syniverse Technologies Services (India) Private Limited

9th Floor, iLabs Center, Plot No. 18, Software Units Layout Madhapur, Hyderabad 500 081 Telangana, India

Not applicable

Syniverse Technologies Network Solutions (Singapore) Pte. Ltd.

8 Marina Boulevard #05-02, Marina Bay Financial Centre, Singapore

Personal Data Protection Commission ("PDPC") in Singapore

Syniverse Technologies (China) Limited

18th Floor, AXA Tower, Landmark East,100 How Ming Street, Kwun Tong, Kowloon, Hong Kong PRC

Office of the Privacy Commissioner for Personal Data ("PCPD") in Hong Kong

Syniverse Technologies (Beijing) Limited

2002-2006, Floor 20, JinYu Mansion,No. 129 West Xuanwumen West Street, Xicheng District Beijing, China

Not applicable