EMPLOYEE ACCESS | CLIENT LOGIN | SBM SHOP ABOUT SERVICES JOIN US SOURCING GET IN TOUCH Privacy Policy General Last Updated: May 15, 2020 This Privacy Policy (“Policy”) applies to personal data that is collected by SBM Management Services, LP, and SBM and its subsidiaries, affiliates and related entities (collectively, “SBM,” “we,” “us” and “our”). Notification of changes We reserve the right to amend or vary this Policy from time to time to reflect evolving legal, regulatory or business practices. When we update our Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make (which, for minor changes, may include posting the revised Policy to our Site with immediate effect). Please check this page periodically for changes. We will obtain your consent to any material Policy changes if and where this is required by applicable data protection laws. You can see when this Policy was last updated by checking the “last updated” date displayed at the top of this Policy under the “General” heading. Who we are SBM, together with its subsidiaries, affiliates and related entities is a leading global provider of facilities management services. Our commitment to privacy We take our responsibility to protect the personal data provided to us seriously. This Policy explains how we do that. It sets out what we do with the personal information we hold, how we protect it, and it explains your privacy rights (if applicable). We are committed to safeguarding the privacy of your personal data. Please read the following Policy to understand how we collect and use your personal data, for example when you contact us, visit or use one of our websites, mobile applications, portals, or other parts of our network (each a “Site”), apply for a job, or use our products and services, regardless of how you access them. This Policy also explains the rights available to you in respect of your personal data. California residents should review the California Privacy Rights section below for specific provisions that apply to them. The personal information we collect: When we collect personal data, we are open about how we will use it. through our Sites - for example names, addresses or email details and other information you may upload to our Sites; from meetings with staff or business contacts, such as exchanging business cards, or collecting information at conferences or business events; and that you provide to us in connection with the services we provide. For example, we may collection from you in connection to services that we provide to our customers. Data that you provide voluntarily to us When you use our Sites, products or services, or you otherwise communicate with us, we may ask you to provide certain personal data voluntarily, including but not limited to your name, company position, postal address, telephone number, mobile number, fax number, email address, credit card or other payment details, age or date of birth, account usernames, passwords or gender. For example, we may ask you to provide some or all of this personal data when you register an account with us, subscribe to our marketing communications, purchase products or services and/or submit enquiries to us. We use this information to create and administer your account, send you marketing communications, provide you with the products and services you request, and to respond to your enquiries. Data collected automatically When you use our Sites, products or services, we may collect certain data automatically from your computers or devices (including mobile devices). The data we collect automatically may include your IP address (explained further below), device type, operating system details, unique device identification numbers (including mobile advertising identifiers), browser-type, browser language, operating system, geographic location (as explained further under the heading “Location information”) and other technical information. We may also collect data about how your device has interacted with our Sites, products or services, including the pages or features accessed and links clicked, the amount of time spent on particular pages, mouse hovers, the date and time of the interaction, error logs, referring and exit pages and URLs, and similar information. Collecting this data enables us to better understand the visitors who use our Sites, products, and services, including where they come from and what features are of interest to them. We use this information for our internal analytics purposes, and to improve the quality, relevance and security of our Sites, products and services. For example, every time you connect to the Sites, we store a log of your visit that shows the unique number your machine uses when it is connected to the Internet—its IP address. This log tells us what your machine has looked at, whether the page request was successful or not, and which browser your machine used to view the pages. This data is used for statistical purposes as well as to help customize the user experience as you browse the Sites and subsequently interact with SBM. This helps us to understand which areas of the Site are of particular interest, which pages are not being requested, and how many people are visiting the Sites in total. It also helps us to determine which products and services may be of specific interest to you. We may also use this information to block IP addresses where there is a breach of the terms and conditions for use of the Sites. Data Uploaded to Our Sites By Our Customers Our Sites may offer functionality for our customers to upload personal data of their employees and other persons. In such cases, we are acting as a service provider to our customers. Our customers are responsible for ensuring that they have provided all required notices and obtained all necessary consents from any individuals whose personal data has been uploaded to our Sites. If you are an individual that wishes to exercise your rights with respect to such personal data that a customer has uploaded to the Sites, you may contact the customer directly or contact us as set forth in this Policy. Data that we obtain from third-party sources From time to time, we may receive personal data about you from third-party sources (including without limitation our customers, recruitment agencies, credit check agencies, agencies providing compliance checks, lead generation providers, resellers and other partners who sell our products and services to you), but only where such third parties have confirmed that they have your consent or are otherwise legally permitted or required to disclose your personal data to us. The types of personal data we collect from third parties include contact details, CVs, credit history, and order information, and we use the information we receive from these third parties to assess your suitability for a job position, carry out compliance checks required under applicable law (such as anti-bribery and corruption checks), make credit decisions, maintain and improve the accuracy of the records we hold about you, and market our products and services to you. As noted above, customers may upload to the Sites or otherwise provide us personal data regarding their own employees or employees of SBM in connection with the services we provide those customers. We also receive personal data from other members of the industry that forms part of or otherwise helps us to develop, test and enhance our own product offerings, some of which could contain personal data (where permitted by applicable law). We may combine information that we collect from you with information about you that we obtain from such third parties. Location information We may collect different types of data about your location, including general information and more specific information (for example GPS-based functionality on mobile devices when used to access a Site, product, or service). This data may be used to monitor and manage access and use of our services, such as accessing and inputting information into online platforms we may offer, or customize the services provided to you, such as location-based information, advertising and features. If you are using a mobile device to access online platforms we may offer, your location information may be shared with our customers. In other cases, your location information may be shared with our agents, vendors or advertisers. If you access the Site or our products and Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. However, this may prevent you from using certain features of our Site. See your device manufacturer's instructions for further details. Other specific ways we collect and use your personal data Job applications If you are making a job application or inquiry, you may provide us with a copy of your resume or other relevant information. We may use this information for the purpose of assessing your application or inquiry. We may also keep this information on file to contact you about future opportunities, unless you ask us not to do this. Please note that personal data collected from our employees is subject to our internal employee privacy policy and not this Policy. Please also note you may be given the opportunity to apply for job openings online through an applicant tracking system operated a third party which shall collect relevant information related to a job application or inquiry. Partner Portal Our resellers, distributors and other partners may visit our partner portal Site. We may use the information provided on that Site for partner relationship management, billing, forecasting, trend analysis, renewal management, and marketing in order to sell and provide the products and services. Account management If you obtain products or services from us, we may use your contact details and (where applicable) payment information for the purposes of (i) providing training, customer support and account management, (ii) order processing and billing, (iii) verifying your usage of the products and services in accordance with the terms and conditions of your agreement with us, (iv) carrying out checks for export control, anti-bribery, anti-corruption, the prevention of modern slavery and other compliance purposes in accordance with requirements under applicable law; (v) contacting you (including by email communication) regarding license expiry, renewal and other related notices, and (vi) maintaining our company accounts and records. Market research and surveys If you participate in surveys, we may use your personal data that you provide for our internal business analysis and training purposes in order to improve our understanding of our users’ demographics, interests and behavior, to measure and increase customer satisfaction, and to improve our products and services. Competitions, contests and promotions If you participate in a competition, contest or promotion conducted by us or on our behalf, we may use your personal data in order to administer such competition, contest or promotion. We may also use your personal data as explained further under the heading “Marketing and promotions”. Chat rooms Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information to open areas of our Site, online help, or other chat rooms, that information can be viewed publicly and may be collected and used by third parties without our knowledge or consent, and may result in unsolicited messages from other individuals or third parties. Our legal basis for processing your data Where required by law, we rely upon a number of different legal bases for processing personal data and special category personal data—these include processing personal data where it is in our legitimate interests to do so, where this is necessary for the fulfilment of a contract or providing services, or where the processing is necessary to carry out our obligations under employment law. Where we rely on our legitimate interests, this means that we use personal information to run our business and to provide the services we have been asked to provide. We only collect information that has been supplied voluntarily; you do not have to provide us with personal data. However, if you do not provide us with information we need by law or require to do work, we may not be able to offer certain products and services. However, we will normally collect personal data from you only where we need the personal data to perform a contract with you, comply with legal obligations or provide our services to our customers, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person. If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at privacy@sbmcorp.com. How we use your data We use your personal data in compliance with all the relevant laws and may use it in one or more of the following ways: We may use the personal data to provide services to our customers, create accounts for our Site, to provide access to online services and to process transactions with you. We may use the contact information you supply to respond to your requests and inquiries. We may use identification verification documents to meet with regulatory and legal requirements to verify who you are as a condition of providing SBM services and products. We may use personal financial data to assess your eligibility for SBM products and services. We use personal data to provide you with marketing and advertising about SBM's services, provided that you can opt out of email marketing at any time from our marketing department by using the unsubscribe mechanism in the email communication or contacting the marketing department at marketing@sbmcorp.com Personal data may be used to make your online experience as smooth as possible—for example by setting cookies and tailoring what you see on the Sites. Personal data may be used to safeguard the security of our premises and those we maintain for third parties—for example through the use of CCTV and video monitoring. Whom we share personal data with We may share, transfer or disclose your personal data to the following categories of recipients: to SBM employees who require it to perform their jobs and provide services to our customers; to our affiliated entities, third-party service providers, suppliers, agents and other organizations who provide data processing and other services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Sites, products or services), or who otherwise process personal data on our behalf for purposes that are described in this Policy or notified to you when we collect your personal data (such as advertising, sweepstakes, analytics, research, customer support, fraud prevention and legal services); to any governmental department, agency, court or other official bodies or other third parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation (such as in response to a subpoena, warrant, court order or other legal process), (ii) to exercise, establish, participate in, or defend our legal rights, or limit the damages we sustain in litigation or other legal dispute, or (iii) to protect your vital interests, privacy or safety, or those of our customers or any other person; to a potential or actual buyer or transferee (and its agents and advisers) in connection with any proposed or actual transfer of control, purchase, merger, reorganization, consolidation or acquisition of any part of our business, or in connection with any bankruptcy proceeding, provided that we inform the buyer or transferee it must use your personal data only for the purposes disclosed in this Policy; and to any other person with your consent to the disclosure. Except as set out above, we will not disclose your personal data save where we need to do so in order to enforce this Policy, our agreements with you, our rights generally, or where required or permitted by applicable local or foreign law. Whenever we share personal data, we take all reasonable steps to ensure that it is treated securely and in accordance with this Policy. This may include without limitation aggregating or de-identifying information so that it is not intended to be used by the third party to identify you. International transfers of data/Where we keep and process your information As a global company, we and our service providers operate, and our Site, products and services are accessed from, all over the world. When you give us personal data, that data may be used, processed or stored anywhere in the world, including in countries that have data protection laws that are different to the country in which you reside. By using our Site, products and services, you agree to the transfer of your personal data to such other countries, including to the United States. Where required by law, we have taken appropriate safeguards to ensure that your personal data will remain secure and protected in accordance with this Policy and applicable laws. Data retention We retain personal data we collect from you for as long as necessary for the purposes for which the personal data was collected or where we have an ongoing legitimate business need to do so (for example, to provide you with a product or service you have requested, to ensure that transactions can be processed, settled, refunded, charged back or to identify fraud), or to comply with applicable legal, tax or regulatory requirements. Even if you close your account, we will retain certain information in order to meet our obligations. When we have no ongoing legitimate business need to process your personal data, we will either securely destroy, erase, delete or anonymize it, or if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. Use by children The Sites, the products and the services are not intended for persons under the age of 16. By using the Sites, product or service, you hereby represent that you are at least 16 years old. Stopping us contacting you If you have provided us with consent to supply you with marketing and information, you can withdraw your consent at any time by unsubscribing from the e-mail or contacting us at privacy@sbmcorp.com. Links This Policy applies to personal data collected by us. If we provide a link to a third-party site (whether through our Sites, a product or service, or in an e-mail we send you), please be aware that we are not responsible for the content or privacy practices of such third-party site. We encourage our users to be aware of this when they leave our Site, and to read the privacy policy of other sites that collect personal data. We are not liable for any disputes, loss or damage that may arise from or in connection with your use of such third-party sites. Keeping your information safe We commit to maintaining the deployment of appropriate security to protect personal information wherever it is located, and whether it is in electronic or manual form. This includes implementing and maintaining reasonable and appropriate physical, administrative, technical and organizational measures in accordance with applicable law. We may use a variety of mechanisms depending on where the information is stored and the relationship between SBM and any recipient organizations. These safeguards vary based on the sensitivity of the information that we collect, process and store, and the current state of technology. While we strive to protect your personal data, no data transmission or storage can be guaranteed as 100% secure. If you have been given or have created log-in details to provide you with access to certain parts of our Site (for example our partner portal), you are responsible for keeping those details confidential in order to prevent unauthorized access to your account. Your data protection rights You have the following data protection rights with respect to your personal data: You can request access, deletion or portability of your personal data by contacting us at privacy@sbmcorp.com You may also ask us to correct or update your personal data, object to processing of your personal data, or ask us to restrict processing of your personal data by contacting us at mailto:privacy@sbmcorp.com. If you have an account with us, you can also update your information by updating your account profile. You have the right to opt-out of marketing communications we send you at any time. You can usually exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. Alternatively, or to opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us at privacy@sbmcorp.com. If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time by contacting us at privacy@sbmcorp.com. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. You have the right to complain to a data protection authority in your jurisdiction of residence about our collection and use of your personal data. For more information, please contact your local data protection authority. All requests should be submitted by email to privacy@smbcorp.com or by completing this form. We respond to all requests we receive from individuals wishing to exercise their data protection rights to the extent required and in accordance with applicable data protection laws. We reserve the right to deny requests, in whole or in part, as permitted by such data protection laws and will provide you an explanation for the denial of such request. California Privacy Notice This California Privacy Notice supplements the Policy and contains the disclosures required under the California Consumer Privacy Act (“CCPA”). For individuals who are California residents, the CCPA requires certain disclosures about the categories of personal information we collect and how we use it, the categories of sources from whom we collect personal information, and the third parties with whom we share it. Please note that for California residents and for purposes of this California Privacy Notice only, the term personal information means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household as defined in the CCPA. All other capitalized terms have the same meanings as given them in the Policy. If you are a California resident who has provided personal information to SBM, or a California resident that reasonably believes that SBM collected or stores their personal information, you may exercise your rights under the CCPA and submit your requests) by emailing us at privacy@sbmcorp.com. This notice, and the rights specified in this notice, do not apply to personal information collected from or about employees, officers, directors or contractors of SBM that is exempt under California Civil Code section 1798.145(h) or collected from or about employees, officers, directors or contractors of customers of SBM that is exempt under California Civil Code section 1798.145(n). You have the right to request that we: (a) Disclose what personal information we collect, use, disclose or sell; (b) Disclose the specific pieces of personal information that we have collected on you (if any); and (c) Delete personal information we have collected on you (if you satisfy the conditions set out in the CCPA). NOTE: we do not sell your personal information as that term is defined in the CCPA. In order to submit a request, we will need to verify your identity. If you have an account with us that is password-protected, we may verify your identity through our existing authentication practices for your account. If you do not have an account with us, and your request concerns “categories” of personal information collected, we can request from you two data points of personal information to verify your identity. If you do not have an account with us, and your request concerns specific personal information, we can request from you at least three data points of personal information as well as a signed declaration with penalty of perjury to verify your identity. Please note that following your verified request, we will send you your personal information from the following e-mail address: privacy@sbmcorp.com. (Any response to your request, including any personal information may be sent as an encrypted file.) Please note that once you have submitted a request, we will send you a receipt, acknowledging your request, within 10 days. If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please send us an e-mail to privacy@sbmcorp.com as an error may have occurred. We will process and respond to your request within 45 days after it is received (in some cases, as allowed under the CCPA, this process may be extended by an additional 45-90 days). Please note, that regarding requests to know under subsections (a) and (b), you may only make two such requests in a 12-month period, and the information provided need only cover the 12-month period prior to our receipt of your request. We hereby inform you that you have a right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. If you exercise any of your rights under the CCPA, we may not deny you goods or services for that reason, or subject you to different prices than those paid by other consumers, unless provided otherwise under the CCPA, Federal or State law. Notice of Information We Collect Pursuant to California Civil Section 1798.100(b), this serves as notice of the categories of personal information that we collect from California consumers, the purposes for which the information was collected, the categories of third parties to whom disclosed and the categories of the sources of such information within the last twelve (12) months: Category Collected Business or Commercial Purpose Categories of Third Parties to Whom Disclosed Categories of Sources of Personal Information A. Identifiers. Yes. To provide our Sites and services to you and our customers, to perform our contractual obligations, to process job applications, to communicate with customers regarding their services, to respond to inquiries, and to send marketing and other communications to our customers. SBM employees and affiliates, and service providers. Consumers themselves, SBM employees and affiliates, SBM customers and other third parties. B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Yes. To provide our Sites and services to you and our customers, to perform our contractual obligations, to process job applications, to communicate with customers regarding their services, to respond to inquiries, and to send marketing and other communications to our customers. SBM employees and affiliates, and service providers. Consumers themselves, SBM employees and affiliates, SBM customers and other third parties. C. Protected classification characteristics under California or federal law. No. Not applicable. Not applicable. Not applicable. D. Commercial information. No. Not applicable. Not applicable. Not applicable. E. Biometric information. No. Not applicable. Not applicable. Not applicable. F. Internet or other similar network activity. Yes. To provide our Sites and services, to track, monitor and manage use of our Sites and services, to improve and develop existing and new features and functionality of our Sites and services, to personalize our Sites and services for users and to market to users of our Sites and services. SBM employees and affiliates, internet service providers and other service providers. From use of the Sites by Consumers themselves, SBM employees and affiliates, and service providers. G. Geolocation data. Yes. We collect this data to manage and monitor uses of our Sites and services, including the use of mobile devices that access online platforms. SBM employees and affiliates, SBM customers, and service providers. H. Sensory data. Yes. We may use photographs on identification badges for access to facilities where we provide services and video monitoring in such facilities for purposes of security and managing and monitoring our services. In addition, users of our Sites, including our online platforms, may be able to upload photos and videos relating to the services provided to them. Such information is used for monitoring and managing the services. SBM employees and affiliates, SBM customers, and service providers. Consumers themselves, SBM employees and affiliates, SBM customers and other third parties. I. Professional or employment-related information. Yes. To process job applications submitted through our Sites if such information is provided by the applicant. To SBM employees, affiliates, and service providers. Consumers themselves. J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). No. Not applicable. Not applicable. Not applicable. K. Inferences drawn from other personal information. No. Not applicable. Not applicable. Not applicable. How else to contact us? We have appointed individuals who are responsible for the protection and security of your personal data. You may contact our Data Protection Officer if you have any questions, comments, concerns, grievances or complaints about this Policy or the manner in which we treat your personal data, or if you want to request any information about your personal data or believe that we are holding incorrect personal data on you, in the following manner: Data Protection Officer Address: 241 Arnold Avenue, McClellan, CA 95652 Email Address: privacy@sbmcorp.com. If you wish to unsubscribe from marketing communications, please email privacy@sbmcorp.com. If you have any other questions about your personal information, please contact us by email at privacy@sbmcorp.com. 5241 Arnold Avenue McClellan, CA 95652 © 2021 SBM Site Services. All rights reserved. Privacy Policy If you have a disability and need assistance in accessing any portion of this website, please call 1-877-235-6039