1. PRIVACY POLICY

This Privacy Policy provides information to data subjects Kitron is in contact with in any way, including users of the Website, job applicants, visitors on Kitron's premises and individuals acting as or on behalf of customers and suppliers (“data subject” or “you”), about Kitron’s processing of personal data, including which personal data we collect, why we process your personal data and your rights connected to the processing of the personal data.

2. DATA CONTROLLER FOR YOUR PERSONAL DATA

For the purpose of this Privacy Policy, Kitron (Kitron ASA, with org. no 976 605 713, and subsidiaries*) are data controllers for the personal data processed about you. Kitron will process your personal data in accordance with applicable laws on privacy.

* Kitron AS, Kitron AB, Kitron A/S, Kitron UAB, Kitron GmbH, Kitron Sp. z o.o., Kitron Czech a.s.

3. PERSONAL DATA, PURPOSE AND LEGAL BASIS FOR PROCESSING

Kitron process your personal data in connection with the following processing activities:

• Contractual relationship: In a contractual relationship between Kitron and individuals, the processing of your name and other contact information is necessary for the execution or the performance of the contract (GDPR Article 6 (1) (b)). If you do not provide Kitron with the personal data, Kitron may not be able to enter into or fulfil the contract with you.

• Contract management and business relationship: In connection with the administration and management of contracts with Kitron's customers, suppliers, business partners, etc., and for business and partner relationship purposes, Kitron may process personal data such as name, e-mail, phone number and position of contact persons at such customers, business partners, in addition to personal data contained in contracts, ongoing commercial correspondence, invoices, minutes of meeting, etc. The legal basis is Kitron's legitimate interest in entering into business relationships, fulfilling contracts and administrating such relationships (GDPR Article 6 (1) (f)).

• Visit to Kitron’s premises: Kitron may process your personal data, such as name, business, phone number, timing and duration of visits to our premises, as well as camera surveillance images when you enter/leave Kitron’s premises and enter into an NDA between you and Kitron in connection with your visit to Kitron’s premises. The purpose of the processing is to ensure the security of our premises and employees in accordance with Kitron’s security strategy and prevent loss or damages to Kitron or Kitron’s property. The legitimate interests of Kitron will constitute the legal basis for processing as a supplement to consent (GDPR Article 6 (1) (f) and (a)). If you do not provide Kitron with the personal data, Kitron may deny you access to our premises.

• Respond to inquiries: Kitron may process personal data in order to follow up inquiries from potential candidates, website users, and others who contact Kitron. Kitron may process personal data such as name, e-mail, phone number and other personal data provided in connection with the inquiry. The legal basis for such processing is Kitron's legitimate interest in providing support to answer and manage inquiries and other communication (GDPR Article 6 (1) (f)).

• Use of the Website: Kitron may process personal data about visitors to the Kitron's website. Kitron use cookies and other information-gathering methods for system administration purposes of making the website usable, marketing and statistics, where personal data such as IP address and other information about your computer may be collected. The legal basis for the processing is Kitron's legitimate interest in making the website usable (GDPR Article 6 (1) (f)) or your consent (GDPR Article 6 (1)(a)). You can read more about our use of cookies in our Cookie Policy - https://kitron.com/cookie-policy

• Marketing, newsletters, press releases and/or stock market announcements, etc.: If you have subscribed for marketing, our newsletter, press releases and/or stock market announcements, we may process your name, e-mail address, other preferred contact information in order to submit such materials to you. Such processing is based on your consent (GDPR Article 6 (1) (a)). When subscribing you are giving us consent to send you the relevant information, you can withdraw your consent at any time by unsubscribing by following the link in each e-mail.

• Recruitment: If you apply to a position in Kitron, Kitron may process your personal data in order to assess your application to current or future vacancies such as references, CV, name, title/position, e-mail, phone number, employer's name, former employer’s names, education, etc., and other information you may provide or which we need to verify to assess your application. The legal basis for such processing is normally that it is necessary in order to take steps at the request of the candidate prior to (potentially) entering into an employment contract (GDPR Article 6 (1)(b)). The processing may also be based on our legitimate interest in finding the best candidate for the position (GDPR Article 6 (1) (f)), or your consent (GDPR Article 6 (1) (a)). If you do not provide Kitron with the above-mentioned personal data, Kitron will not be able to assess your application or offer you a job.

• Social media: Kitron has pages on social media. As administrator of Kitron's accounts, Kitron are to some extent joint controller with the relevant social media provider for processing of personal data generated through such pages. In connection with these pages, Kitron process personal data such as your name, your comments, likes or other information you make available to us via these pages. In this relation, the personal data will also be shared with the social media platform and other users on social media. For example, when you "like" or join our Facebook page or other social media accounts, this will be shared with the relevant platform. The same applies to any activities on our social media accounts, such as content posted by you or posts that you like. The legal basis for such processing is Kitron's legitimate interest in managing and having pages on social media in order to easily reach out to and market our products to (potential) customers (GDRP Article 6 (1) (f)).

• Ensure compliance and legitimate interests: Kitron may also process personal data in order to comply with statutory obligations to which Kitron is subject, and to safeguard own or third parties' legitimate interests, e.g. in relation to a transfer of undertaking, merger or demerger, establishing a legal claim or preventing unauthorized access to or disclosure of personal data (GDPR Article 6 (1) (f)).

• Legal obligations: Kitron may process personal data due to legal obligations applicable to the operation of Kitron (GDPR Article 6 (1) (c)), such as accounting obligations.

4. RECIPIENTS OF PERSONAL DATA

We will only disclose your personal data to third parties to the extent we have a legal basis for such disclosure.

We use data processors, usually IT providers, to process personal data on our behalf. The relationship with such suppliers is governed by a data processor agreement, which inter alia ensures information security for your personal data.

We may share personal data with our advisors and business partners to the extent necessary to conduct our business in a manner common in our industry, which may also include third parties in connection with possible mergers, transfers of undertakings or acquisitions of our business (GDPR Article 6 (1)(f)).

Your personal data will be disclosed to and processed by Kitron employees, who through their roles are associated with the purpose of processing. Personal data will be shared between the different Kitron Group companies stated in section 2. for the purpose of providing services, internal and external, from and to the different group companies. The legal basis for such processing is Kitron's interest in service provision from and to the whole group of companies (GDPR Article 6 (1)(f)).

5. YOUR RIGHTS

As a data subject, you are entitled to request access to the personal data Kitron process about you and request that Kitron updates or corrects your personal data if the requirements for such rights are fulfilled. You may also withdraw any consent to processing at any time. In some circumstances, you are also entitled to request that your personal data is erased, request restriction of processing or object to processing and/or request data portability.

To utilize your rights, you may contact Kitron via the contact information stipulated below under section 11.

6. RETENTION PERIOD

We will retain your personal data for as long as it is necessary to fulfil the purposes for processing as defined above unless deleted earlier at your request.

The personal data in a job application will be deleted when the application procedure for the position in question has been finalised if you are not offered the position, unless you consent to that we retain the application for up to 12 months after the submittal for the purpose of offering you any future vacancies.

The personal data provided by you when visiting Kitron’s premises is stored for as long as it is necessary to fulfil the purposes as defined above, and a maximum of one year after your last visit.

Recordings from camera surveillance will be deleted within 7 days after the recordings have been made unless it is likely that the recordings will be handed over to the police in connection with the investigation of criminal offences or accidents. In such cases, Kitron can store the recordings for up to 30 days.

Personal data processed in relation to a contract, including for the execution, fulfilment or management of the contract, will be stored for as long as the contractual relationship exists and thereafter as long as the legal limitation period runs.

Personal data will be retained until deleted/removed by you. In addition, we will continuously review our pages to remove personal data that is no longer relevant to the page, e.g., because it is outdated.

The retention period for personal data processed in relation to cookies can be found in Kitron's Cookie Policy - https://kitron.com/cookie-policy

7. TRANSFER TO THIRD COUNTRY

Kitron transfer your personal data to recipients outside the EU/EEA (third country). The personal data we collect about you can be stored, processed, and transferred between all the countries in which we operate, to be used in accordance with this Privacy Policy. All processing in a third country will be subject to mechanisms ensuring sufficient security for your personal data in accordance with GDPR Chapter V, such as EU Standard Contractual Clauses or an adequacy decision from the EU Commission. You can contact us if you need more information about the transfer of personal data outside the EU/EEA or the legal basis for such transfer.

8. THIRD-PARTY WEBSITES AND SOCIAL MEDIA

The Kitron Website may include links to other third-party sites. These third-party sites have their own privacy policies that determine how the third-party site is operated and how personal data is collected and processed. If you submit personal information to any of these third-party sites, your information is governed by their privacy policies. We take no responsibility for such third-party sites, how they are operated and how they process your personal data. We recommend that you familiarize yourself with such third-party sites’ privacy policies and terms of use when visiting and using such sites.

9. RIGHT TO LODGE COMPLAINT WITH A SUPERVISORY AUTHORITY

If you believe that our processing of your personal data infringes relevant data protection regulations, you are entitled to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of the alleged infringement, or other relevant supervisory authority.

10. MODIFICATIONS TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy from time to time. The most recent revision shall supersede any earlier versions. The current version of the Privacy Policy will be available on the Kitron Privacy Policy page on www.kitron.com at all times. We will notify the user of any changes to the Privacy Policy that will require your consent.

11. QUESTIONS – CONTACT

If you have any questions relating to this Privacy Policy or want to exercise your rights in accordance with section 5, you should contact Kitron via the address dpr@kitron.com.


Last updated by Kitron: 14.03.2024