Personal Data that We Process (this may include data that you provide to us, that we collect about you, or that we assign to you.)

We collect, use, and maintain (collectively “process”) different types of personal data about you in in the operation of our business. If you are an employee, we process personal data about you (and your dependents, beneficiaries and other individuals associated with your employment) primarily for managing our employment relationship with you and your workplace facilities/information systems interactions. If you are External Staff, the type of personal data we process is limited to what is needed to manage your engagement with Intellis and access to Intellis facilities and information systems. If you are a candidate, the type of personal data we process is limited to what is needed to engage with you about Intellis career opportunities, consideration of your application for employment to specific roles at Intellis, including candidate screening, interview scheduling and management, lawful background checks, and to on board you at Intellis if you receive and accept an offer of employment with us.

The data we process can include the following, but is not limited to:

Name and contact data. Your first and last name, employee identification number, email address, postal address, phone number, photo, beneficiary and emergency contact details, and other similar contact data. Additionally, you may opt to provide Intellis with additional contact information such as personal email address(es) and/or cell phone number(s).

Demographic data. Your date of birth and gender. We may also collect and process "Sensitive Personal Information" about you in accordance with local requirements and applicable law. This may include any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, trade union membership, or information about your health, disabilities, or sexual orientation. We will use this information to comply with anti-discrimination laws and government reporting obligations and to help insure equal employment opportunities. We may also request information about your physical or mental condition to provide work-related accommodations, to provide health and insurance benefits to you and your dependents, or to manage absences from work. We may further request, where permitted by law and on a voluntary and consensual disclosure basis, sensitive personal information such as information about your racial/ethnic origin, sexual orientation, veteran status, and disability status. We will use this information on a de-identified and aggregated basis to help provide a more diverse and inclusive workplace through our Diversity, Inclusion and Accessibility programs.

National identifiers. Your national ID/passport, citizenship status, residency and work permit status, social security number, or other taxpayer/government identification number.

Employment details. Your job title/position, office location, employment contract, offer letter, hire date, termination date, performance history and disciplinary records, leave of absence, sick time, and vacation/holiday records.

Spouse/partner and dependents’ information. Your spouse and dependents’ first and last names, dates of birth, and contact details.

Background information. Academic and professional qualifications, education, CV/Resume, credit history and criminal records data (utilized for background check and vetting purposes where permissible and in accordance with applicable law and consultation requirements).

Video, voice and image. We may collect and use video, voice and image data, subject to the requirements of local law, internal policy, and any consultation requirements with worker representatives (where appropriate).

Financial information. Bank account details, tax information, salary, retirement account information, company allowances and other information necessary to administer payroll, taxes and benefits.

Workplace, Device, Usage, and Content data. Emails sent and received, building and information system access, Intellis device, system and application usage (including telemetry) when accessing and using Intellis corporate buildings and assets.

We may also collect personal data about you from third parties or public sources as needed to support the employment relationship or to engage with you concerning job opportunities at Intellis. For example, before and during the course of your employment or assignment with Intellis, we may collect information from public social media sources, such as your LinkedIn profile, for recruitment purposes. We also may conduct lawful background screenings, to the extent permitted by law, through a third-party vendor for information about your past education, employment, credit and/or criminal history. In the event of a natural disaster or other life/safety emergency, we may rely on public social media posts or other public sources to account for employees if otherwise unable to contact them. Additionally, if there is an investigation of an employee matter, we may obtain information relevant to the incident from external sources including private parties, law enforcement or public sources like news sources and public social media posts.

In some limited circumstances, we may collect personal data for research purposes or other non-employment related purpose, with your consent.

Why We Process Personal Data

We collect your personal data for the purposes set out below. Failure to provide your personal data when requested may prevent us from being able to carry out these tasks and/or comply with our legal obligations.

1. To administer your employment contract, offer letter or other commitments we’ve made to you

We collect and use your personal data primarily for the purpose of managing our employment or working relationship with you, and to fulfill our obligations under your employment contract, or applicable Intellis policies, including payroll, benefits administration, pension and retirement administration, tax reporting, and the like. A few examples: your employment contract, your offer letter (e.g. so we can on-board you), promotion history and performance reviews (e.g. so we can manage our employment relationship with you), and your bank account and salary details (e.g. so we can pay you or providing HR benefits).

1. Other overriding and legitimate business purposes

We also may collect and use your personal data when it is necessary for other legitimate purposes, such as general HR administration, our global directory of employees and external staff, general business management and operations, disclosures for auditing and reporting purposes, internal investigations, management of network and information systems security and business operations, provision and improvement of employee services, physical security and to protect the life and safety of employees and others. We may also use special applications and systems that record employee performance metrics, such as sales related or code databases for business operations purposes as well as for the purposes of reviewing, rewarding and coaching employees on their performance and for administration and assessment of training. We may also process your personal data to investigate potential violations of law or breaches of our internal policies.

1. Legally required purposes

We also may use your personal data when we consider it necessary for complying with laws and regulations, including collecting and disclosing personal data as required by law (e.g., for minimum wage, working time, tax, health and safety, anti-discrimination laws, global migration), under judicial authorization, or to exercise or defend the legal rights of Intellis.

1. Other uses of your data (where permissible and in accordance with applicable law and consultation requirements)

We also may collect your internal usage of Intellis products, services and internal applications and tools including business data created by employees and external staff, to measure and improve these products; use of your data for product improvement may include human and machine review of such data to train AI models and improve machine learning for Intellis products and services. Where required by law, we will seek your consent to such uses; and where your consent is sought, we will ensure your consent is knowing, truly voluntary, and that you suffer no adverse consequence from any decision to withhold or revoke your consent.

Change of purpose

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need it for another purpose that is compatible with the original purpose and there is legal basis for the further processing. For example, you may provide personal information to Intellis while researching job openings, but once you apply for a specific role, Intellis may need process your personal information based on other legal basis for processing.

How and Why We Share Personal Data

Intellis will only share your personal data with those who have a legitimate need for it. Whenever we permit a third party to access personal data, we will make sure the data is used in a manner consistent with this notice (and any applicable internal data handling guidelines consistent with the sensitivity and classification of the data). Your personal data may be shared with our subsidiaries and affiliates and other third parties, including service providers, for legitimate purposes as follows:

1. In order to carry out the uses of personal data described above (See section titled: Why We Process Personal Data);
2. To enable third parties to provide services to us. Categories of recipients of data would include financial investment service providers, insurance providers, pension administrators and other benefits providers, payroll support services, relocation, tax and travel management services, health and safety experts, and childcare providers;
3. To comply with our legal obligations, regulations or contracts, or to respond to a court order, administrative or judicial process, such as a subpoena, government audit or search warrant. Categories of recipients would include counter-parties to contracts, judicial and governmental bodies;
4. In response to lawful requests by public authorities (such as national security or law enforcement);
5. To seek legal advice from external lawyers and advice from other professional advisers such as accountants, management consultants, etc.;
6. As necessary to establish, exercise or defend against potential, threatened or actual litigation (such as adverse parties in litigation);
7. Where necessary to protect Intellis, your vital interests, such as safety and security, or those of another person;
8. In connection with the sale, assignment or other transfer of all or part of our business (such as a potential purchaser and its legal / professional advisers); or
9. Otherwise in accordance with your consent.

Please note that where legal requirements limit the sharing of your data, Intellis will respect such requirements.

Workplace Security and Monitoring

Intellis monitors its IT and communications systems through automated tools such as network authentication and wireless connectivity hardware and software, anti-malware software, website filtering and spam filtering software, security software for cloud-based applications, and mobile device management solutions. The primary purpose of this monitoring is to protect Intellis, its employees, customers and business partners, for example:

1. For system, applications, and network security, including in particular the security of Intellis’s IT system and assets, and the safety and security of its employees, external staff and other third parties;
2. For network and device management and support;
3. For proof of business transactions and recordkeeping;
4. For the protection of confidential information and company assets;
5. For investigating wrongful acts or potential violations of company policy; and
6. For other legitimate business purposes as permitted under applicable law.

You should be aware that any message, files, data, document, facsimile, audio/video, social media post or instant message communications, or any other types of information transmitted to, through or from, received or printed from, or created, stored or recorded on our IT and communications systems and assets (included via the use of personal devices accessing corporate IT systems) are presumed to be business-related and may be monitored or accessed by us in accordance with applicable law and workplace agreements (such as works council agreements), and subject to Intellis’s own policies concerning access to and uses of such data.

Security of Your Personal Data

Intellis is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. For example, we store the personal data you provide on computer servers with limited access that are located in controlled facilities, and, when we transmit certain highly confidential or sensitive personal information, we protect it through the use of encryption.

Our Retention of Personal Data

Personal data will be stored according to applicable laws or regulatory requirements and kept as long as is necessary to fulfill the purposes for which the personal data was collected. Generally, this means that your personal data will be retained as documented in our corporate data retention schedule and applicable riders and supplements.

Personal Data that We Process (this may include data that you provide to us, that we collect about you, or that we assign to you.)

We collect, use, and maintain (collectively “process”) different types of personal data about you in in the operation of our business. If you are an employee, we process personal data about you (and your dependents, beneficiaries and other individuals associated with your employment) primarily for managing our employment relationship with you and your workplace facilities/information systems interactions. If you are External Staff, the type of personal data we process is limited to what is needed to manage your engagement with Intellis and access to Intellis facilities and information systems. If you are a candidate, the type of personal data we process is limited to what is needed to engage with you about Intellis career opportunities, consideration of your application for employment to specific roles at Intellis, including candidate screening, interview scheduling and management, lawful background checks, and to on board you at Intellis if you receive and accept an offer of employment with us.

The data we process can include the following, but is not limited to:

Name and contact data. Your first and last name, employee identification number, email address, postal address, phone number, photo, beneficiary and emergency contact details, and other similar contact data. Additionally, you may opt to provide Intellis with additional contact information such as personal email address(es) and/or cell phone number(s).

Demographic data. Your date of birth and gender. We may also collect and process "Sensitive Personal Information" about you in accordance with local requirements and applicable law. This may include any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, trade union membership, or information about your health, disabilities, or sexual orientation. We will use this information to comply with anti-discrimination laws and government reporting obligations and to help insure equal employment opportunities. We may also request information about your physical or mental condition to provide work-related accommodations, to provide health and insurance benefits to you and your dependents, or to manage absences from work. We may further request, where permitted by law and on a voluntary and consensual disclosure basis, sensitive personal information such as information about your racial/ethnic origin, sexual orientation, veteran status, and disability status. We will use this information on a de-identified and aggregated basis to help provide a more diverse and inclusive workplace through our Diversity, Inclusion and Accessibility programs.

National identifiers. Your national ID/passport, citizenship status, residency and work permit status, social security number, or other taxpayer/government identification number.

Employment details. Your job title/position, office location, employment contract, offer letter, hire date, termination date, performance history and disciplinary records, leave of absence, sick time, and vacation/holiday records.

Spouse/partner and dependents’ information. Your spouse and dependents’ first and last names, dates of birth, and contact details.

Background information. Academic and professional qualifications, education, CV/Resume, credit history and criminal records data (utilized for background check and vetting purposes where permissible and in accordance with applicable law and consultation requirements).

Video, voice and image. We may collect and use video, voice and image data, subject to the requirements of local law, internal policy, and any consultation requirements with worker representatives (where appropriate).

Financial information. Bank account details, tax information, salary, retirement account information, company allowances and other information necessary to administer payroll, taxes and benefits.

Workplace, Device, Usage, and Content data. Emails sent and received, building and information system access, Intellis device, system and application usage (including telemetry) when accessing and using Intellis corporate buildings and assets.

We may also collect personal data about you from third parties or public sources as needed to support the employment relationship or to engage with you concerning job opportunities at Intellis. For example, before and during the course of your employment or assignment with Intellis, we may collect information from public social media sources, such as your LinkedIn profile, for recruitment purposes. We also may conduct lawful background screenings, to the extent permitted by law, through a third-party vendor for information about your past education, employment, credit and/or criminal history. In the event of a natural disaster or other life/safety emergency, we may rely on public social media posts or other public sources to account for employees if otherwise unable to contact them. Additionally, if there is an investigation of an employee matter, we may obtain information relevant to the incident from external sources including private parties, law enforcement or public sources like news sources and public social media posts.

In some limited circumstances, we may collect personal data for research purposes or other non-employment related purpose, with your consent.

Why We Process Personal Data

We collect your personal data for the purposes set out below. Failure to provide your personal data when requested may prevent us from being able to carry out these tasks and/or comply with our legal obligations.

1. To administer your employment contract, offer letter or other commitments we’ve made to you

We collect and use your personal data primarily for the purpose of managing our employment or working relationship with you, and to fulfill our obligations under your employment contract, or applicable Intellis policies, including payroll, benefits administration, pension and retirement administration, tax reporting, and the like. A few examples: your employment contract, your offer letter (e.g. so we can on-board you), promotion history and performance reviews (e.g. so we can manage our employment relationship with you), and your bank account and salary details (e.g. so we can pay you or providing HR benefits).

1. Other overriding and legitimate business purposes

We also may collect and use your personal data when it is necessary for other legitimate purposes, such as general HR administration, our global directory of employees and external staff, general business management and operations, disclosures for auditing and reporting purposes, internal investigations, management of network and information systems security and business operations, provision and improvement of employee services, physical security and to protect the life and safety of employees and others. We may also use special applications and systems that record employee performance metrics, such as sales related or code databases for business operations purposes as well as for the purposes of reviewing, rewarding and coaching employees on their performance and for administration and assessment of training. We may also process your personal data to investigate potential violations of law or breaches of our internal policies.

1. Legally required purposes

We also may use your personal data when we consider it necessary for complying with laws and regulations, including collecting and disclosing personal data as required by law (e.g., for minimum wage, working time, tax, health and safety, anti-discrimination laws, global migration), under judicial authorization, or to exercise or defend the legal rights of Intellis.

1. Other uses of your data (where permissible and in accordance with applicable law and consultation requirements)

We also may collect your internal usage of Intellis products, services and internal applications and tools including business data created by employees and external staff, to measure and improve these products; use of your data for product improvement may include human and machine review of such data to train AI models and improve machine learning for Intellis products and services. Where required by law, we will seek your consent to such uses; and where your consent is sought, we will ensure your consent is knowing, truly voluntary, and that you suffer no adverse consequence from any decision to withhold or revoke your consent.

Change of purpose

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need it for another purpose that is compatible with the original purpose and there is legal basis for the further processing. For example, you may provide personal information to Intellis while researching job openings, but once you apply for a specific role, Intellis may need process your personal information based on other legal basis for processing.

How and Why We Share Personal Data

Intellis will only share your personal data with those who have a legitimate need for it. Whenever we permit a third party to access personal data, we will make sure the data is used in a manner consistent with this notice (and any applicable internal data handling guidelines consistent with the sensitivity and classification of the data). Your personal data may be shared with our subsidiaries and affiliates and other third parties, including service providers, for legitimate purposes as follows:

1. In order to carry out the uses of personal data described above (See section titled: Why We Process Personal Data);
2. To enable third parties to provide services to us. Categories of recipients of data would include financial investment service providers, insurance providers, pension administrators and other benefits providers, payroll support services, relocation, tax and travel management services, health and safety experts, and childcare providers;
3. To comply with our legal obligations, regulations or contracts, or to respond to a court order, administrative or judicial process, such as a subpoena, government audit or search warrant. Categories of recipients would include counter-parties to contracts, judicial and governmental bodies;
4. In response to lawful requests by public authorities (such as national security or law enforcement);
5. To seek legal advice from external lawyers and advice from other professional advisers such as accountants, management consultants, etc.;
6. As necessary to establish, exercise or defend against potential, threatened or actual litigation (such as adverse parties in litigation);
7. Where necessary to protect Intellis, your vital interests, such as safety and security, or those of another person;
8. In connection with the sale, assignment or other transfer of all or part of our business (such as a potential purchaser and its legal / professional advisers); or
9. Otherwise in accordance with your consent.

Please note that where legal requirements limit the sharing of your data, Intellis will respect such requirements.

Workplace Security and Monitoring

Intellis monitors its IT and communications systems through automated tools such as network authentication and wireless connectivity hardware and software, anti-malware software, website filtering and spam filtering software, security software for cloud-based applications, and mobile device management solutions. The primary purpose of this monitoring is to protect Intellis, its employees, customers and business partners, for example:

1. For system, applications, and network security, including in particular the security of Intellis’s IT system and assets, and the safety and security of its employees, external staff and other third parties;
2. For network and device management and support;
3. For proof of business transactions and recordkeeping;
4. For the protection of confidential information and company assets;
5. For investigating wrongful acts or potential violations of company policy; and
6. For other legitimate business purposes as permitted under applicable law.

You should be aware that any message, files, data, document, facsimile, audio/video, social media post or instant message communications, or any other types of information transmitted to, through or from, received or printed from, or created, stored or recorded on our IT and communications systems and assets (included via the use of personal devices accessing corporate IT systems) are presumed to be business-related and may be monitored or accessed by us in accordance with applicable law and workplace agreements (such as works council agreements), and subject to Intellis’s own policies concerning access to and uses of such data.

Security of Your Personal Data

Intellis is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. For example, we store the personal data you provide on computer servers with limited access that are located in controlled facilities, and, when we transmit certain highly confidential or sensitive personal information, we protect it through the use of encryption.

Our Retention of Personal Data

Personal data will be stored according to applicable laws or regulatory requirements and kept as long as is necessary to fulfill the purposes for which the personal data was collected. Generally, this means that your personal data will be retained as documented in our corporate data retention schedule and applicable riders and supplements.