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mobile365 International Personnel

PRIVACY NOTICE

Effective: July 17, 2023

Overview

mobile365 USA, Inc., and its subsidiaries (“TMUS” or “we” or “our” or “us”) collect personal data about you as a former, potential, or current participant of our workforce, including applicants, candidates, employees, and contractors (collectively, “Personnel” or “you”). This notice describes how we use that personal data, to whom we disclose it, how you can exercise your data choices, and how you can contact us. This privacy notice applies only to personal data we collect about Personnel located outside of the United States, Puerto Rico, and U.S. Virgin Islands.

This notice does not cover:

  • Your interactions with mobile365 outside of the employment context, such as browsing mobile365’s website to check out our products and services or logging into your account as a customer. To learn more about our privacy practices related to those types of interactions, please see our mobile365 Privacy Notice. 

  • United States based personnel. To learn more about personal data we collect and use from our U.S. employees, contractors, or job applicants, please see our Employee and Contractor Privacy Notice or mobile365 Applicant Privacy Notice.

What data we collect

Personal data

Your “personal data” is any information that identifies, relates to, or describes you, or data that is reasonably capable of being directly or indirectly associated or linked to you. This notice also describes sensitive personal data that we collect in connection with your potential, current, or former employment with us. 

The categories of personal data we may collect and process about you might include:

Identifiers/contact information

Like your name, online identifiers such as an Internet Protocol (IP) address, account and usernames, aliases, telephone number, email address, home and postal addresses, signatures, and other identifiers described in the sensitive information category below.

Biometric information

Like fingerprints, voiceprints, and facial images from which an identifier template can be extracted.

Employment and performance information

Like date of hire, title, transfers and promotions, salary and rewards, training, absences and reasons for absences, letters of appreciation and commendation, grievances or disciplinary matters, and resignation or termination of employment, demographic data such as age, including date of birth, educational history, gender, marital status, spouse, dependents, and beneficiaries and certain sensitive data categories described below in the Sensitive Personal Data section, work permit status and related immigration information, attendance at corporate functions and sites, compensation history with us, performance information, aptitude, disciplinary information, training records and certifications.

Payroll, tax, and benefits information

Like your bank account details, payroll records, tax information, pension information, benefits elections, investment and portfolio information, vacation and leave of absence information, payroll deduction information, expense reimbursement information, and insurance-related information.

Travel information

Like your loyalty program numbers, dates and length of travel, hotel names and locations, and travel routes.

Medical and health-related information

Like your medical condition or disability, pregnancy status, health, sickness, vaccine record, injuries, temperature, communicable disease or other medical test results, beneficiary, and family information.

Personal or work vehicle information

Like your vehicle license plate number, year, make, model, and location.

Images and recordings of you

Like your photograph, voice, audio/video recordings and transcripts of our in-person or online events, meetings and/or calls, and security footage of you on our premises (e.g., CCTV).

Internet or other electronic network activity and analytics data

Like data related to employee or contractor communications and use of mobile365 systems, Wi-Fi, internet service, internal and external websites, equipment, applications, databases, network resources, and infrastructure (“mobile365 Systems”); building access, badge information, and software/hardware inventory information; and personal devices used to connect to mobile365 Systems; including usernames; passwords; system log data like IP address, browser type, and language, device information, access times, and referring website addresses; information collected through web beacons, like cookie IDs; information collected through mobile apps, like mobile device IDs; usage data, features used, and actions taken in mobile365 Systems, including page views, links clicked, and documents downloaded; contents, header, metadata, delivery and access information for voice calls, voicemail, emails, chats, messaging, documents, and other communications, data, and files stored or transmitted through mobile365 Systems.

Geolocation data

Like approximate location data such as based on your IP address, and location data such as office location, conference room booking locations, travel location information described above.

Other information

Other information you provide to us in the context of your onboarding, employment, contractor role, or that we collect for other human resources, business, security, travel, or safety-related purposes.

Sensitive personal data

We collect and process certain categories of personal data considered “sensitive personal data.” We may collect sensitive personal data as part of our relationship with you to support our legal and business activities, and as permitted by law.

Examples of sensitive personal data that we might collect include:

  • Racial or ethnic origin 

  • Trade union membership

  • Biometric information (for purposes of identification)

  • Health information (such as information you may provide as part of an accommodation request)

  • Data concerning or relating to sex life or sexual orientation (such as information you may provide as part of an accommodation request)

Sources of personal data

We collect personal data from a variety of sources, including:

  • Directly from you (the individual) 

  • Your previous and current employers

  • Service providers such as payroll services

  • Insurance and benefits providers

  • Travel partners (e.g., travel agents and portals, car service, and ride share companies)

  • Background check services

  • Online sources, including social networks 

  • Open government databases and other public sources

We also collect personal data through our use of cookies, web beacons, mobile analytics, and similar technologies to operate our websites, applications, and online services accessible to you in the context of our employment relationship. This includes analyzing and measuring device, application, and system usage, detecting and preventing illegal, fraudulent, or unauthorized activity, enforcing mobile365 policies, and protecting our devices, systems information, and infrastructure.

Use of personal data

We use personal data that we collect to administer and carry out the employment relationship, including for human resources and operational, business, safety, and security purposes, and other uses including as described in this notice.

Human resources uses, including:

  • Payroll and compensation

  • Benefits administration

  • Career planning and development

  • Equal employment opportunity, diversity, inclusion, and accessibility programs

  • Performance management and review

  • Administration and enforcement of mobile365’s Code of Conduct, policies, and standards

  • Legal and policy compliance administration and enforcement, including for the purpose of anti-discrimination laws and government reporting obligations

  • Recruitment

Business uses, including:

  • Managing, monitoring, measuring, analyzing, protecting, and improving, mobile365 Systems, assets, and resources, including managing and protecting unauthorized access and use of mobile365, personal, and customer data, devices, systems, and infrastructure; and protecting mobile365 Systems from intrusions

  • Managing, monitoring, measuring, analyzing, protecting, and improving campus, parking, buildings, office space, conference rooms, facilities, catering and café services, including monitoring and administering building occupancy and campus parking and transportation; operating and monitoring physical security systems, such as CCTV, key card entry systems, and guest logs; registering personal vehicles and logging exit and entry times; and emergency notification services

  • Managing and improving workplace satisfaction, efficiency, and effectiveness

  • Communications and collaboration

  • Delivery of information, goods, and services

  • Legal and policy compliance administration and enforcement, including monitoring access and use of mobile365 Systems

  • Research and improvement of mobile365 Systems, processes, products, services, and technology

We may use de-identified information in accordance with applicable law.

If you become a mobile365 employee or contractor, personal data we collected as part of the application and hiring process will become part of your employment file and will be used and disclosed in accordance with this notice.

Lawful basis for processing personal data

We collect, use, and disclose personal data as necessary to carry out the employment contract and relationship with you, comply with our legal requirements, and/or based on our legitimate interests.

Disclosure of personal data

We may disclose personal data, including sensitive personal data, to the following categories of recipients, for the uses described in this notice.

Our subsidiaries and affiliates

Service providers or agents working on our behalf (processors)

For example, companies mobile365 hires to provide recruiting, payroll, benefits, and administrative services, and protect and secure our systems and service.

Independent providers

For example, benefits partners mobile365 hires to facilitate benefits administration, (e.g., health and insurance providers) and independent providers of products and services (e.g., travel agents, ride share services). In certain instances, and to the extent that mobile365 provides personal data to such third parties, that personal data is governed by their privacy statements.

Parties to a corporate transaction or proceeding

For example, a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

Law enforcement and those with legal necessity

We access, transfer, disclose, and preserve personal data to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; to operate and maintain the security of mobile365 Systems, including to prevent or stop an attack on our computer systems or networks; to protect mobile365 and others rights or property, including enforcing our agreements, terms, and policies; or to act in urgent circumstances such as protecting the health or personal safety of a candidate, employee, contractor, agent, customer, user of mobile365 services, or member of the public.

We may provide features or services for employees and contractors to publicly display and disclose personal data, such as their name or username, profile or directory information, or other personal data that employees and contractors choose to disclose. Once you publicly disclose information, the legal protections for that data change. mobile365 is not responsible for what third parties do with information you disclose publicly using these tools.

We may share de-identified, pseudonymous, or anonymous information in accordance with applicable law.

Data retention

We retain personal data for business or tax needs, or legal reasons. For example, we retain personal data in accordance with our obligations under applicable labor and employment law and as necessary to administer and carry out the employment relationship and our post-employment obligations.

Data transfer and location

As part of our global operations, we may need to transfer and share personal data collected from you to our affiliates, processors, or third parties located in countries outside the jurisdiction in which the personal data was originally collected. These countries may have different data protection laws than the jurisdiction in which the data was originally collected. We rely on various legal grounds to ensure that these data transfers are lawful, which may include your explicit consent, the transfer is necessary for the performance of our employment contracts, or other employment related purposes during the hiring process, compliance with legal obligations, the protection of vital interests, the establishment, exercise, or defense of legal claims, or the pursuit of legitimate interests pursued by the third parties to whom the data is disclosed. We implement appropriate measures to ensure the protection of your personal data during transfers to other countries. We ensure that these entities offer an adequate level of data protection or that appropriate safeguards are in place to protect your personal data. By continuing your employment or engagement with our organization, you acknowledge and agree to the transfer and processing of your personal data as described in this data transfer and location clause.

Personal data we collect may be stored and processed in the United States or in any other country in which we or our affiliates, subsidiaries, or agents maintain facilities, some of which have not been found by the European Commission to have an adequate level of data protection. When we transfer personal data to a country outside the E.E.A., U.K., or Switzerland, we protect that information in accordance with applicable law.

If you have a question or a complaint related to our processing of personal data, you may contact us as indicated below. For complaints that cannot be resolved directly with mobile365, we will cooperate with the relevant Data Protection Authority to resolve any issues.

Privacy rights and data choices

If our processing of personal data about you is subject to applicable laws, you have certain choices with respect to that personal data. Such choices, as detailed below, include: 

  • the right to know (i.e., access) what personal data we have about you, 
  • the right to delete (i.e., erasure) certain personal data we have about you, and
  • the right to correct certain inaccurate data we have about you. 

Please note that your choices and contact methods may vary depending on where you reside and the laws that apply. If you have questions, or would like to submit a personal data request, please contact us at IntlPrivSpt@mobile365.com.

Access

To exercise the right to access your personal data, submit a personal data request by emailing IntlPrivSpt@mobile365.com. Once we receive your request and confirm your identity, we will disclose to you:

  • The categories of personal data we have collected 

  • The sources from which we collect personal data 

  • The types of third parties we shared your personal data with 

  • The types of personal data we disclose for business purposes 

mobile365 provides this information, where possible, in a format you can read, use, and transfer to other entities.

Delete

To exercise the right to delete your personal data, submit a personal data request by emailing IntlPrivSpt@mobile365.com. We may not delete all your personal data based on certain exceptions and legal obligations that apply. For example, we may keep personal data that is necessary to provide employment or contractor services, detect security problems, or to comply with laws.

Correct

To exercise the right to correct inaccurate personal data, submit a personal data request by emailing IntlPrivSpt@mobile365.com.

Other choices:

  • If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format.

  • If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing. 

  • You can object to, or obtain a restriction of, the processing of personal data under certain circumstances.

  • You can send us specific instructions regarding using your data after your death.

Please follow the instructions above or use the contact information below to exercise one or more of these rights. You might also have the right to complain to a supervisory authority, but we encourage you to contact us first with any questions or concerns.

Data security

We implement reasonable technical and organizational measures to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration, and destruction.

Future changes

From time to time, we may update this Privacy Notice for mobile365 International Personnel.

This Privacy Notice for mobile365 International Personnel does not form any part of any contract of employment.

Contact us

If you are not located in the U.S., you may use the following information to contact us:

Office of Privacy 
Attention: Chief Privacy Officer
By mail: 12920 Southeast 38th Street Bellevue, WA 98006
Email: IntlPrivSpt@mobile365.com