“BOOTS ON THE GROUND” APPLICATION
PRIVACY POLICY
The Holcim Group Affiliate operating in the country where you are
located (hereinafter individually referred to as the “Controller”, “Us”,“We” or “Our” ), acting as your employer, is the data controller responsible
for the processing of your personal data you provide while using the “Boots on
the Ground” application (hereinafter the “BoG App”). The contact details of each
Holcim Group Affiliate main operating entities in the countries where Holcim
Group is present are available HERE.
LafargeHolcim
Global Hub Service Private Limited (hereinafter “LHGH”), Level 3, Tower 1, Phase II, Logitech Park, A.K. Road,
Sakinaka, Andheri (E), Mumbai 400072, India acting as developer of the BoG App
is the data processor of your personal data you provide in the BoG App.
We are committed to protecting your personal data and being transparent
about the manner your personal data are being processed while you use the BoG
App. We take outmost care to process your personal data in accordance with the
principles set forth in the data protection legislation applicable in the
countries where Holcim Group operates, including (EU) Regulation 2016/679 on
the protection of natural persons with regard to the processing of personal
data and on the free movement of such data, and repealing Directive 95/46/EC
("GDPR").
This Privacy
Policy regards the personal data of the employees and workers of the
Controller, who were granted access to use the BoG App.
This Privacy Policy describes:
●
the purposes for
which We collect and use your personal data;
●
the processing
grounds for such purposes;
●
the categories of
personal data We collect from you and process and the sources from which they
originate;
●
whether the
provision of your personal data is necessary and the possible consequences of
your refusal to provide such data;
●
to whom We disclose
or We may disclose your personal data;
●
the countries
where We transfer your personal data;
●
the duration of
processing of such data;
●
your rights as
data subject and the way you may exercise them.
|
In the context of your interaction with the BoG App We use your personal
data in the following cases:
|
Activity |
Purposes |
Categories
of personal data and sources |
Grounds
for processing |
|
Health
& Safety compliance |
We process your personal data for
managing your employment or other type of relationship with Us, for the
following main purposes: ●
organizational
compliance, in particular monitoring and
assessing compliance with Our Health & Safety policies and standards
(e.g., implementing an internal reporting tool through BoG App for relevant
employees which enables reporting of unsafe working conditions, actual/
potential hazards, actual/ suspected H&S misconduct, perform Visible
Personal Commitments observation in the BoG App, conducting H&S
observation tours, recording the findings and proposing improvements) ●
regulatory
compliance, ensuring compliance with Our
Health & Safety legal and regulatory obligations and requests anywhere in
the world, including reporting to or being audited by national and
international regulatory, enforcement or exchange bodies which may include
conducting due diligence as required under applicable law and regulations; ●
disputes
and enforcement of claims,
including supporting Us in dealing with and solving disputes, complying with
orders of courts, authorities or other public bodies, enforcing Our
contractual agreements and to establish, exercise or defend legal claims. |
forename, middle name(s) and
surname, email, other data you may provide directly through the BoG App. |
Depending on the jurisdiction and
the specific purpose, the processing is either necessary: ●
for the performance of your agreement with Us, ●
for compliance with a legal obligations incumbent to Us or ●
for achieving Our legitimate interests. Our legitimate interests consist
of managing Our workforce and operating Our business, for instance,
undertaking normal business operations and maintaining a dialogue with Our
employees, contractors and workers, ensuring that each employee, contractor
and worker undertakes appropriate duties, is properly trained and undertakes
its role correctly and in accordance with appropriate procedures. In case some of the personal data
have a special regime under the data protection laws, We will process such
data to the extent one or more of the guarantees prescribed by the law for
processing such data are applicable. |
|
Changes
in structure or similar transactions involving the Controller |
We may also process your data in
the context of changes in structure or similar transactions involving Us. |
forename, middle name(s) and
surname, email, other data you may provide directly through the BoG App. |
In this case, the grounds for
processing may be represented by: ●
the
legal obligation (in case We are legally obliged to disclose certain personal
data to public authorities); ●
the
performance of the agreement concluded by Us in the context of such
transaction or Our legitimate interest to carry out the transaction in the
most effective manner. |
|
When We request you to provide Us your personal
data in the BoG App, We kindly ask you to provide all categories of personal
data We request. You will be free to refuse the provision of your personal
data, however if you do withhold specific data, We shall not be able to achieve
the processing purposes described above without processing such data.
|
To achieve the aforementioned purposes and to the
extent necessary, We disclose or We may disclose your personal data provided in
or through the BoG App to the following categories of data recipients:
We disclose your personal data to the
above-mentioned data recipients:
●
if We are under an obligation or have permission to do so by law
or in the context of legal proceedings, for instance to enforce a court ruling
or to comply with a request made by a law enforcement agency;
●
if We deem that the disclosure is necessary or appropriate in
order to prevent physical harm or financial loss;
●
in relation to an investigation into a fraudulent activity or
other unlawful activity, actual or suspect;
●
if We sell or transfer Our business or assets, entirely or
partially (including in the event of a reorganization, winding-up or
liquidation of business);
●
for other legitimate interests justified by Us.
|
We transfer or We may transfer your
personal data to recipients located in other countries than the country where
the personal data was originally collected. It is possible that such countries
do not have the same data protection laws as the ones from the country where you
have initially provided the personal data. In this case, We will implement
appropriate guarantees, in accordance with the law, to protect your personal
data irrespective of the countries to which they are transferred.
If you are a
resident of the European Economic Area and the GDPR applies to you, or
Switzeland, We may transfer your personal data to the following LafargeHolcim
Affiliates:
|
LafargeHolcim Affiliate |
Contact details of LafargeHolcim
Affiliate |
|
Holcim Ltd |
Grafenauweg 10, 6300 Zug, Switzerland |
|
Holcim Group Services Ltd |
Grafenauweg 10, 6300 Zug, Switzerland |
|
Holcim Technology Ltd |
Im Schachen, Holderbank Aargau 5113 Switzerland |
1.
LafargeHolcim European Business Services
|
Protifašistických bojovníkov 11 040 01 Košice, Slovakia |
2.
LafargeHolcim IT EMEA
|
Albasanz 14 28037 Madrid, Spain |
3.
Holcim Services (South Asia) Limited
|
17th Floor, Phase I & II, Reliable Tech Park, Thane Belapur Road,
Airoli, Navi Mumbai-400708 / India |
4.
LafargeHolcim Global Hub Services Private Limited
|
Level 3, Tower I, Phase II, Logitech Park, A.K. Road, Sakinaka,
Andheri (E), Mumbai – 400072, India |
|
We will retain your personal data provided in the BoG
App for as long as is reasonably necessary for the purposes explained in this
Privacy Policy. For example, your personal data is retained during your
relation with Us, and afterwards for a subsequent period necessary for ensuring
compliance with the applicable law.
|
If you are a
resident of the European Economic Area and the GDPR applies to you, or if you
are a resident of another country which enacted a data protection law that
provides any of the below listed rights in you favor, you will enjoy the
benefit of these rights.
|
Right of access |
Allows you to obtain confirmation that your
personal data are being processed by Us and, if affirmative, the relevant
details of such processing activities, as well as copy of your personal data. |
|
Right to rectification |
Allows you to rectify your personal data if
inaccurate. |
|
Right to erasure |
Allows you to obtain the erasure of your
personal data in certain cases (e.g., if the data are no longer necessary in relation
to the purposes for which it was collected). Important! We will not be able to act on such
requests in all cases, such as where the law compels Us to keep data for a
certain period, or where the data are necessary for a legitimate interest
such as the defense of a right in court. |
|
Right to restriction |
Allows you to request Us not to use your
personal data in any way except to store it until another request from you is
resolved, namely: (i) you have requested the rectification of the data; (ii)
you have opposed the erasure of the data in the case of unlawful processing;
(iii) you have required Us to provide you with certain data for the defense
of a right; (iv) you have objected to the data processing. |
|
Right to object |
Allows you to object to further processing of
your personal data within the conditions and limits set forth by law. Important! The law compels Us to act on such
requests only for direct marketing processing (e.g., if you receive emails
with Our informative notes, you can unsubscribe). In the other cases, We will
balance Our interests and your particular situation in order to make a final
decision. Therefore, please explain why you object to the processing when
making such a request. |
|
Right to portability |
Allows you to receive the personal data
concerning you that you have provided to Us, in a structured, commonly used
and machine-readable format or to transmit this data to another data
controller. Important! The law compels Us to act on such
requests only for the data previously processed based on your consent or on
the performance of the contract concluded with Us and only if the processing
is carried out by automated means. |
You may exercise your aforementioned rights and find out more about the
processing of your personal data by sending a request to
privacy.lh@lafargeholcim.com
You also have the
right to file a complaint with the competent data protection authority.
This Privacy Policy is in force as of June 2021.
We may amend
this Privacy Policy from time to time, for example, to keep it up to date or to
comply with legal requirements or changes in the way We operate Our business.