WeGrow Privacy Policy

NEORIS WEGROW PRIVACY POLICY

NEORIS considers that one of the main elements that fosters trust in relationships with third parties is constituted by the appropriate safeguarding of information and the effective limitation of its use according to the legal dispositions or contractual relationships that, in each case, shall apply.

For this reason, NEORIS is committed to safeguarding and managing the confidentiality of information obtained in a frame of relations with third parties, and to not use it for different reasons than those for which the information was obtained.

This Privacy Policy complements the terms and conditions of use (“Terms”) established for the use of NEORIS WEGROW in a Software as a Service “SaaS” basis (“NEORIS WEGROW”). By using NEORIS WEGROW, User acknowledges and accepts NEORIS’ processing of its personal data according to the Terms and this Privacy Policy.

User guarantees absolute confidentiality of the information that may be accessed as a result of the use of NEORIS WEGROW and will comply with all technical and organizational obligations applicable regarding data processing. Therefore, by using NEORIS WEGROW, User expressly declares to have read, comprehended and accepted the information of protection of data provided by NEORIS as follows:

Who is the Data Controller?

Entity: Neoris N.V., 980424232, and its subsidiaries.

Address: Strawinskylaan 1637 Tower B, Lev, 1077 Amsterdam (Netherland).

Phone: +31-205022812

Email: derechosarco@neoris.com

Data Protection Officer: dpo@neoris.com

Who is the User?

User shall mean any person that downloads NEORIS WEGROW and that mantains a current labor or commercial relationship with NEORIS.

What data is used by NEORIS?

By accesing this platform, NEORIS will be able to process the following data:

• Your contact information: full name and corporate email, date of birth, gender
• Your access information: username, password, IP address and technical characteristics for accessing
• Your professional information: title, department and other information related to your work or organization;
• Your technical skills and other information about your professional profile
• Content, communications and other data you submit within the context of your professional relationship
• Communications with others within the platform, evaluations and opinions related to colleagues
• Your evaluations of colleagues and other personnel within the organization

What is the purpose of processing this personal data?

The processing of personal data is done with the purpose of evaluating and diagnosing skills and competencies from User in their professional and work-related context, within the terms of the Terms and according to the functionality of NEORIS WEGROW.

Based on the information provided through NEORIS WEGROW a profile of the employee or collaborator will be created in order to comply with the processing described. In no case shall automatic decisions be taken based on said profile.

Furthermore, the processing of personal data from User will be done for technical aspects of NEORIS WEGROW, such as the communication with users and administrators; security improvements; development of new tools, products or services; the identification and solutions of errors or bugs that may happen; and the analysis of data and systems.

Additionally, User authorizes NEORIS to anonymize the data for analytical purposes. Such analysis will not contain real personal data from User which may be used by NEORIS for research and development, internal demand planning, sector development, anonymous comparisons with other anonymized data, and in general, for the development of new functionalities and improvements to NEORIS WEGROW and/or other systems.

If, in the future, NEORIS expects to use the data for a different purpose, User will be notified by email, prior to such subsequent treatment, information about the other purpose and any pertinent additional information.

What is the legitimization of data processing?

Regarding the necessary data of User to provide its responsibilities, the legal base for processing your data is the labor or commercial contract between User and NEORIS. User is required to facilitate such personal data, because, otherwise, an evaluation and diagnosis of the labor or commercial relationship could not be established.

In relation to the secondary purposes that allow NEORIS WEGROW to the processing  of data the legal base is the legitimate interest of NEORIS to manage its commercial activity. In certain cases, the main purpose is not dependent on the secondary purposes.

The use of NEORIS WEGROW is completely voluntary of the User.

Which destinations will the data be communicated with?

For internal administrative reasons, the correct managing of the information systems at NEORIS and to facilitate the global communications and cooperation in the societies within the business group, your personal data will be communicated with: Neoris Outsourcing Services, S.A. de C.V. (Mexico); Neoris Consulting Services, S.A. de C.V. (Mexico); Neoris One, S.A. de C.V. (Mexico); Neoris Argentina, S.A. (Argentina); Neoris Consulting Argentina, S.A. (Argentina); Neoris One Argentina, S.A. (Argentina); Neoris Perú, S.A.C (Perú); Neoris Colombia, S.A.S. (Colombia); Neoris de Chile, Ltda. (Chile); Neoris Venezuela, C.A. (Venezuela); Neoris do Brasil, Ltda. (Brasil); Neoris USA, Inc. (USA); Neoris Logistics, Inc. (USA); Neoris ME JLT. (UAE); Neoris Consulting Services India Private Limited (India); Neoris UK Ltd. (England); Neoris Consulting and information Technology Services, LLC (Hungary); Neoris Czech Republic s.r.o. (Czech) y Neoris España, S.L. (Spain).

Additionally, NEORIS informs that all necessary data will be assigned to the correspondant fiscal and labor administration in order to comply to all labor, fiscal and social security norm, or in such case, to third party professional services providers that may be required, such as, among others, law firms or auditors.

NEORIS also has Data Processors that may have access to your data according to a contractual agreement for specific purposes and based on instructions and guarantees for security and confidentiality previously established with such third party.

How long will the data be stored?

The personal data provided to NEORIS will be stored while there is a current labor or commercial relationship with NEORIS. Once this period ends, the data will be kept during the timeframe specified by the applicable regulations, as well as during the timeframes for prescription stated for the civil, criminal, and administrative actions or another type that could be derived from the contractual relation.

What are your rights when you facilitate your data?

Right of accessing personal data. User has the right to obtain confirmation  if NEORIS is treating or not personal data that concern them, and in that case, the right to request access the information.

Right to rectification, erasure and the right to be forgotten. User also has the right to request the correction of inaccurate data or, in such case, request data deletion when, among other reasons, the data are no longer necessary for the purposes they were collected.

Right to limit the processing. In certain circumstances, User can also request NEORIS the limitation of processing of your data.

Right to data portability. User has the right to request NEORIS to send its data to another organization, if it so request it.

Right to object. In certain circumstances and for reasons related to User’s particular situation, it can object to the processing of its data.

In order to exercise any of these rights, User needs to contact NEORIS through the email address derechosarco@neoris.com and such request will be processed . If User considers that its rights have not been exercised, User can contact NEORIS’ Data Protection Officer (dpo@neoris.com) or present a complaint in the appropriate Supervisory Authority.