Privacy Policy
Last Updated: October 30, 2018
PURPOSE OF THIS POLICY
Sodexo takes the protection of your personal data very seriously.
We developed this policy to inform you of the conditions under which we
collect, process, use and protect your personal data. Please read it
carefully to familiarize yourself with the categories of personal data
that are subject to collection and processing, how we use these data and
with whom we are likely to share it. This policy describes how you can
get in touch with us on any questions you might have concerning your
personal data.
This policy may be amended, supplemented or updated, in particular to
comply with any legal, regulatory, case law or technical developments
that may arise. However, your personal data will be processed in
accordance with the policy in force at the time of the data collection,
unless a compulsory legal prescription determines otherwise and must be
enforced retroactively.
DEFINITIONS
“Personal data”
means any information relating to an identified natural person or one
that can be directly or indirectly identified by reference to an
identification number or to one or more factors specific to this person.
Personal Data will share the same definition as “Personally Identifiable
Information.”
“us” or “our”
those entities of Sodexo that are based in the United States or Canada
(hereinafter designated as “Sodexo”) for all dimensions and activities.
“you”
any website or application user/visitor.
“Website”
means either (1) the website where this privacy policy appears at the
footer or (2) the Application where this policy is linked.
COLLECTION AND SOURCE OF PERSONAL DATA
We use Personal Data to operate, administer and improve the Website,
deliver the services or carry out the transactions you have requested,
improve our services, provide you with more effective customer service,
perform research and analysis aimed at improving our products, services
and technologies, satisfy our legitimate business interests (including
performing trend analysis and market studies), set prices, accomplish
the billing function, display content and advertising that are
customized to your interests and preferences, and comply with government
regulations. We also use personal information about you to communicate
with you about the Website, transactions with you, and additional
products and services you may find of value. To do all of this, we
combine personal and non-personal information, collected online and
offline, including information from third party sources.
We will most likely collect your personal data directly (via the data
collection forms on our Website) or indirectly (via our service
providers and/or technologies on our Website).
We undertake to obtain your consent and/or to allow you to refuse the
use of your data for certain purposes whenever necessary.
You will in any event be informed of the purposes for which your data
are collected via the various online data collection forms.
SOCIAL NETWORKS
You have the option to click on the dedicated icons of social networks
such as Twitter, Facebook, Linkedin, etc. that appear on our Website.
Clicking on those links or enabling those connections may allow the
social network to collect or share data about you. We do not control
these third-party websites and we encourage you to read the privacy
notice of every website you visit.
Social networks create a friendlier atmosphere on the Website and assist
in promoting the Website via sharing. Video sharing services enrich the
video content of the Website and increase its visibility.
When you click on these buttons, we may have access to the personal
information that you have made public and accessible via your profiles
on the social networks in question. We neither create nor use any
separate databases from these social networks based on the personal
information that you have published there and we do not process any data
relating to your private life through these means.
If you do not want us to have access to your personal information
published in the public spaces of your profile or your social accounts,
then you should use the procedures provided by the social networks in
question to limit access to this information.
LINKS TO OTHER SITES
Occasionally, we provide links to other websites for practical and
informative purposes. These websites are mostly Sodexo websites, however
some of them operate independently from our websites and are not under
our control. These websites are run by third parties with their own
confidentiality recommendations or terms of use which we strongly advise
you to read. We do not accept any liability with regard to the content
on these sites, for the products and services that may be offered there
or for any other use thereof.
TYPES OF PERSONAL DATA COLLECTED AND USED BY US
-
Sodexo collects and processes personal data obtained directly from our
employees for the purposes of human resource management including
hiring, deployment, compensation, benefits, leave management,
performance management, discipline and termination, as well as
emergency contact;
-
Sodexo collects personal data that our customers provide to us in
connection with the services that we provide to them; and
- Sodexo collects personal data through visits to this Website.
On this Website, we may specifically collect and process the following
types of personal data:
-
the information that you provide when filling in the forms on the
Website (for example, for subscription purposes, to participate in
surveys, for marketing purposes, etc.);
- the information that you provide for authentication purposes;
-
the information that you provide for order fulfillment or to provide a
service;
-
records and copies of your correspondence (including email addresses),
if you contact us; and
-
via “posts”, comments or other content that you post on the Website.
Personal data identified by an asterisk in the data collection forms are
compulsory as these are necessary to fulfill any orders placed. In the
absence of this compulsory information, these transactions cannot be
processed.
PERSONAL DATA THAT WE AUTOMATICALLY COLLECT
We collect some information automatically when you visit the Website to
personalize and enhance your experience. We collect this information using
various methods such as:
Cookies
A “cookie” is a small information file sent to your browser when you
visit our Website and stored on your computer. This file contains
information such as the domain name, the internet access provider and
the operating system as well as the date and time of access by the user.
Cookies cannot damage your computer in any way.
Cookies are not used to determine the identity of an individual who
visits our Website. Cookies allow us to identify, in particular, your
geographic location and the display language in order to improve your
online browsing experience. They also enable us to process information
about your visit to our website, such as the pages viewed and the
searches made, in order to improve our Website content, to follow your
areas of interest and offer you more suitable content.
If you do not want to receive cookies from our Website, you can adjust
your browser settings accordingly. To manage your choices, each browser
has a different configuration. These configurations are described in
your browser’s help menu, which will explain how to change the settings
to your desired cookies configuration.
We recommend, however, that you do not deactivate our cookies. Keep in
mind that if you block, turn off or reject our cookies, some of our
webpages will not display correctly or you will no longer be able to use
some of the services we offer. In this case, we cannot be held liable
for any consequences related to the reduced functionality of our
services arising from our inability to store or consult the cookies
required for its functioning and which you have declined or deactivated.
Lastly, by clicking on the dedicated icons of social networks such as
Twitter, Facebook, Linkedin, etc., if these are displayed on our
Website, and if you have agreed that cookies may be downloaded while you
are browsing our Website, the social networks in question may also
download cookies to your devices (computer, tablet or mobile phone).
These types of cookies are downloaded to your device only on condition
that you have given your consent by continuing to browse our Website.
You can, however, at any time revoke your consent to these social
networks downloading these types of cookies.
IP Address
An IP address is a unique identifier used by some electronic devices to
identify and communicate with each other on the internet. When you
consult our Website, we can use the IP address of the device used by you
to connect you to the Website. We use this information to determine the
general physical location of the device and to know in which
geographical areas visitors are located.
Statistics
The Website uses Google Analytics to generate statistical reports. These
reports tell us, for example, how many users consulted the Website,
which pages were visited and in which geographical areas Website users
are located. The information gathered via the statistics may include,
for example, your IP address, the Website from which you arrived at our
Website and the type of device that you used. Your IP address is hidden
on our systems and will only be used if necessary to resolve a technical
problem, for Website administration and to gain insight into our users’
preferences. Website traffic information is only accessible to
authorized staff. We do not use any of this information to identify
visitors and we do not share this information with third parties.
PURPOSES FOR WHICH WE USE PERSONAL DATA
We use your personal data specifically for the following purposes:
- to present our Website and its contents to you;
-
to respond to your requests such as requests for information,
searches, the newsletter or other content;
-
to provide the services and offers ordered on our Website and/or in
one of our establishments;
- to conduct surveys and gather statistics;
- to personalize and enhance your experience on our Website;
-
to offer you our products and services and/or our partners’ products
and services; and
-
any other purpose of which we will inform you, if applicable, when we
collect your data.
LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
We process your personal data as part of the performance and management
of our contractual relationship with you, in our legitimate interest to
improve the quality and operational excellence of the services we offer
to you, or in compliance with certain regulatory obligations.
Your personal data may also be processed based on your prior consent in
the event that under certain circumstances, your consent would be
requested.
DISCLOSURE OF PERSONAL DATA
The security and confidentiality of your personal data are of great
importance to us. This is why we restrict access to your personal data
only to members of our staff who need to have this information in order
to process your orders or to provide the requested service.
We will not disclose your personal data to any unauthorized third
parties. We may, however, share your personal data with entities within
the Sodexo group and with authorized service providers (for example:
technical service providers hosting, maintenance, consultants, etc.)
whom we may call upon for the purpose of providing our services. We do
not authorize our service providers to use or disclose your data, except
to the extent necessary to deliver the services on our behalf or to
comply with legal obligations. Furthermore, we may share personal data
concerning you (i) if the law or a legal procedure requires us to do so,
(ii) in response to a request by public authorities or other officials
or (iii) if we are of the opinion that transferring these data is
necessary or appropriate to prevent any physical harm or financial loss
or in respect of an investigation concerning a suspected or proven
unlawful activity.
We may partner with third parties to provide advertisements to visitors
through the Website. These third parties are only provided the
information necessary to perform their services and are only permitted
to use such information for the provision of such services. We may also
aggregate general statistics that we gather about visitors, sales,
traffic patterns, and services and provide these statistics to third
parties; however, when we do, these statistics will not include any
personal information that identifies individuals.
You also may provide information to be published or displayed
(hereinafter, “posted”) on public areas of the Website, or transmitted
to other users of the Website or third parties (collectively, “User
Contributions”). Your User Contributions are posted on and transmitted
to others at your own risk. Please be aware that no security measures
are perfect or impenetrable. Additionally, we cannot control the actions
of other users of the Website with whom you may choose to share your
User Contributions. Therefore, we cannot and do not guarantee that your
User Contributions will not be viewed by unauthorized persons.
STORAGE PERIOD OF YOUR PERSONAL DATA
We will store your data only for as long as necessary to fulfill the
purposes for which it was collected and processed. This period may be
extended, if applicable, for any amount of time prescribed by any legal
or regulatory provisions that may apply.
PERSONAL INFORMATION AND CHILDREN
The Website is for use by adult persons who have the capacity to
conclude a contract under the legislation of the country in which they
are located.
This Webste is not directed towards children under 16 years of age. No
one under age 16 may provide any information to the Website. We do not
knowingly collect personal information from children under 16. If you
are under 16, do not use or provide any information on this Website or
through any of its features/register on the Website, including your
name, address, telephone number, or email address. If we learn we have
collected or received personal information from a child under 16 without
verification of parental consent, we will delete that information. If
you believe we might have any information from or about a child under
16, please contact us at
privacy.noram@sodexo.com.
TRANSFER OF PERSONAL DATA
As Sodexo is an international group, your personal data may be
transmitted to internal or external recipients that are authorized to
perform services on our behalf and that are located in countries outside
the country where data was collected (such as in the United States or
Canada). In the event that personal data is transferred internationally,
the government, courts, law enforcement or regulatory agencies of the
transferred to jurisdiction may be able to obtain disclosure of the data
through the laws of that jurisdiction.
To guarantee the security and confidentiality of personal data thus
transmitted, we will take appropriate measures to ensure that these data
receive adequate protection, such as signing standard European
Commission contractual clauses or other equivalent measures.
SECURITY
We implement reasonable technical and organizational security measures
to ensure security and confidentiality in processing your personal data.
To this end, we take all necessary precautions given the nature of the
personal data and the risks related to its processing, in order to
maintain data security and in particular to prevent distortion, damage
or unauthorized third-party access (physical protection of the premises,
authentication procedures with personal, secured access via identifiers
and confidential passwords, a connection log, encryption of certain
data, etc.). We also request that our third-party service providers use
commercially reasonable security measures to protect your information
from unauthorized access or use.
However, no method of electronically transmitting or storing data is
ever completely secure, and therefore, we cannot guarantee that your
information will never be accessed, used, or disclosed in a manner that
is inconsistent with this Privacy Policy.
UNSUBSCRIBING
If you have subscribed to certain services via our Website and you no
longer want to receive emails, please consult the “unsubscribe” page
corresponding to the service you are subscribed to.
HOW TO CONTACT US
If you have any questions or comments with regard to this policy, please
do not hesitate to contact us at the following address
privacy.noram@sodexo.com
or contact our Group Data Protection Officer by sending an email at the
following email address:
dpo.group@sodexo.com.