STAR Zensar RnR

Privacy Notice

Why information about You will be collected. 2

Information about You that will be collected. 2

How personal information about You will be used. 4

Your rights regarding Your personal information. 6

Who to contact with data privacy questions or to exercise Your rights. 7

Why personal information about You will be collected

You (defined in this Privacy Notice as ???You???, ???Your??? or collectively as ???Participants???) have been invited to participate in [PROGRAM NAME] (defined in this Privacy Notice as ???the Program???) sponsored by [BIW CLIENT NAME] (defined in this Privacy Notice as ???the Sponsor???). ??Reference to ???the Sponsor??? in this Privacy Notice also includes the Sponsor's data processor, BI Worldwide (defined in this Privacy Notice as ???BI Worldwide??? or ???BIW???) If you choose to participate in the Program, then the Sponsor has a legitimate interest in the collection of your personal information to operate the Program.

The Sponsor has established the Program, a [TYPE OF PROGRAM: REWARDS AND RECOGNTION, TRAINING, TRAVEL, ETC.] program through which the Sponsor promotes engagement of Participants in [DESCRIBE TYPE OF ACTIVITY: ONLINE TRAINING, SELF-IMPROVEMENT, REWARDING EXCELLENCE].?? If applicable, the Program may allow Participants to earn certain branded award points (defined in this Privacy Notice as ???Award Points???) which can be redeemed for merchandise and/or travel awards using an on-line awards catalog linked to the Program website which is [PROGRAM URL] (the on-line awards catalog and Program website are collectively defined in this Privacy Notice as ???the Website??? or ???the Program Website???.

Personal information about You that will be collected

As a Participant in the Program, the Sponsor may already possess some personal information about You that may be combined with additional personal information that is collected in connection with the Program.

The Sponsor will collect and use personal information that Participants provide to the Sponsor directly through this Program when You:

???????????????? fill in forms, communicate with the Sponsor by phone, e-mail or otherwise

???????????????? register to use the Program Website

???????????????? enter details of activities or performance completed in connection with the Program

???????????????? if applicable, participate in the Program competitions, learning opportunities, promotions or surveys

???????????????? if applicable, place an order using the Website

The following types of personal information will be collected and processed by the Program:

[INCLUDE THE PERSONAL INFORMATION FROM THE FOLLOWING LIST THAT WILL BE USED BY THE PROGRAM:

Participant employee ID number, name, address, phone number, email address, employee performance, date of birth, gender, bank account details, passport number, social security number/national identify number, IP address, video/photos, race, religion, ethnicity, nationality, health data, sexual orientation, political/philosophical beliefs, trade union membership, criminal record check results, credit check results [ADD ANY OTHER PERSONAL DATA COLLECTED AND SPECIFIC TO THE PARTICIPANT OF THE BIW CUSTOMER PROGRAM].

Collection, processing, and storage of personal information are required to operate and administer the Program. BI WORLDWIDE is the data processor for the Sponsor and is under contract withthe Sponsor to operate and administer the Program and has a contractual requirement to collect the data.

You have the choice to not provide the personal information necessary to participate in the Program.?? If You choose not to provide the personal information requested, You may not be able to participate in, or receive any benefit(s) provided by the Program.

??

Personal information is saved for the length of time that is required for BIW to operate and administer the Program as defined within a written contract with the Sponsor.

Use of cookies by the Website

Cookies are small text files that are either stored in memory while you are connected with a website and then are deleted immediately afterward (???Session Cookies???), or placed on your device by websites that you visit to store some useful information that can be used on future visits to help ???remember??? specific choices or data entries you have made previously (???Persistent Cookies???). Cookies are widely used to help websites function as efficiently as possible, as well as to provide information to the owners of the website in some cases.

The table below provides greater detail regarding the cookies used by the Website.

[INTERNAL NOTE ONLY INCLUDE OR EXCLUDE EACH TYPE OF COOKIE USED BY THIS PROGRAM WEBSITE FROM THE TABLE BELOW IF YOU HAVE A COOKIE NOT LISTED, ADD A NEW ROW AND COMPLETE ALL COLUMNS.]??

Cookie Types	Name(s) used by this site	Purpose	Personal Data stored within the cookie
Authentication	[LIST THE NAME OF THE COOKIE USED FOR THIS PURPOSE (typically JSESSIONID)]	This cookie, often referred to as a user session cookie, helps the web server identify the user once logged in so that it can maintain the unique connection between the user and the web server for the duration of a visit. These cookies only exist as long as the user is connected to the web application.	[LIST ALL TYPES OF PERSONAL DATA STORED IN THIS COOKIE SUCH AS USER ID, NAME, IP ADDRESS, ETC. EVEN IF IT IS ENCRYPTED. ?? SIMPLY ENTER None IF THERE IS NO PERSONAL DATA STORED IN THE COOKIE]
User Input	[LIST ALL NAMES OF COOKIES USED FOR THIS PURPOSE]	These cookies are used to keep track of a user's input when filling online forms, shopping carts, etc., for the duration of a website visit, or they may be persistent cookies (cookies stored for a limited time on a user's computer) which can be re-used the next time the user logs in before the cookie expires.?? Sometimes these are used to help ???auto-fill??? fields a user has completed previously to help save time when entering data.	[LIST ALL TYPES OF PERSONAL DATA STORED IN THIS COOKIE SUCH AS USER ID, NAME, IP ADDRESS, ETC. EVEN IF IT IS ENCRYPTED. ?? SIMPLY ENTER None IF THERE IS NO PERSONAL DATA STORED IN THE COOKIE]
Load Balancing	[LIST ALL NAMES OF COOKIES USED FOR THIS PURPOSE.]	These cookies are required by systems used to balance the number of users connected each group of web servers associated with a website.?? They are required to make sure after a user connects that they are always communicating with the same web server. These cookies only exist as long as the user is connected to the web application.	[LIST ALL TYPES OF PERSONAL DATA STORED IN THIS COOKIE SUCH AS USER ID, NAME, IP ADDRESS, ETC. EVEN IF IT IS ENCRYPTED. ?? SIMPLY ENTER None IF THERE IS NO PERSONAL DATA STORED IN THE COOKIE]
Anonymous Website Analytics [IDENTIFY TH E ANALYTICS PROCESSOR, SUCH AS GOOGLE ANALYTICS, OR WATSON ANALYTICS]	[LIST ALL NAMES OF COOKIES USED FOR ANONYMOUS WEBSITE ANALYTICS]	These Persistent Cookies are used to collect non-personal information. The information helps us improve the Website performance. The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors of the Website have come from, and the pages they visited within the Website.	None
Personal Website Analytics [IDENTIFY TH E ANALYTICS PROCESSOR, SUCH AS GOOGLE ANALYTICS, OR WATSON ANALYTICS]	[LIST ALL NAMES OF COOKIES USED FOR PERSONAL WEBSITE ANALYTICS]	These Persistent Cookies collect both personal and non-personal information. The information helps us improve the Program or generate specific reports within the Program Website as directed by the Sponsor.	[LIST ALL TYPES OF PERSONAL DATA STORED IN THIS COOKIE SUCH AS USER ID, NAME, IP ADDRESS, ETC. EVEN IF IT IS ENCRYPTED. ?? SIMPLY ENTER None IF THERE IS NO PERSONAL DATA STORED IN THE COOKIE]
Pop-up Cookie ?? ??	[LIST ALL NAMES OF COOKIES USED FOR THIS PURPOSE]	This type of Persistent Cookie is used to determine whether or not to display a particular pop-up window when You return to the Website based upon how You closed the pop-up window during a previous visit to the Website.?? If You closed a pop-up window without making a specific decision (e.g. closed it by clicking the ???X??? rather than making a selection from the options presented), the cookie will be saved to Your device for [ENTER NUMBER OF DAYS] days so You will not see the same pop-up window again, from the same device, during that time.??	[LIST ALL TYPES OF PERSONAL DATA STORED IN THIS COOKIE SUCH AS USER ID, NAME, IP ADDRESS, ETC. EVEN IF IT IS ENCRYPTED. ?? SIMPLY ENTER None IF THERE IS NO PERSONAL DATA STORED IN THE COOKIE]
Cookie Preference	[NameUsedbyBIW]	This type of Persistent Cookie is used to remember Your choices made regarding optional cookies used by the Website. Where You have previously indicated a preference, Your preference will be stored in this cookie.	[LIST ALL TYPES OF PERSONAL DATA STORED IN THIS COOKIE SUCH AS USER ID, NAME, IP ADDRESS, ETC. EVEN IF IT IS ENCRYPTED. ?? SIMPLY ENTER None IF THERE IS NO PERSONAL DATA STORED IN THE COOKIE]

How personal information about You will be used

The Sponsor respects the privacy of Your personal information and will not be sharing it with third parties, except where necessary to operate the Program.?? BI WORLDWIDE administers the Program on behalf of the Sponsor and the Sponsor will be sharing Participant personal information with BI WORLDWIDE. Any personal information You provide via the Website will be processed by BIW on Sponsor's behalf, but BIW is under contract to assure Your personal information and data privacy rights are protected.

Your personal information will only be used for the intended purpose(s) for which it was originally collected, or for a closely related purpose in conjunction with the Program.

Your personal information will be used by BIW only as directed by Sponsor to the extent required to:

???????????????? allow You to participate in the Program

???????????????? assure You are provided with the Program content which is relevant to You

???????????????? notify You about changes to the Program Website or related services

???????????????? perform research and analysis on Participant performance or engagement with Sponsor and/or Sponsor's industry per direction from the Sponsor

???????????????? analyze and improve the Program

???????????????? if applicable, keep track of Your Award Pointsso you can redeem them using the catalog Website

Your personal information will be used for the following automatic processes for which you have the right to opt-in:

???????????????? [AUTOMATIC PROCESSES - ADD HOW PERSONAL INFORMATION PROVIDED BY THE PARTICIPANT WILL BE AUTOMATICALLY PROCESSED IN A MANNER THAT RESULTS IN A SPECIFIC DECISION OR CONCLUSION BEING MADE ABOUT THE PARTICIPANT.?? FOR EXAMPLE, THEIR data is analyzed by a computer process that results in automatically displaying merchandise options the participant might like based upon previous redemption.?? INCLUDE THE PERSONAL INFORMATION CATEGORIES USED IN EACH CASE]

Personal information You choose to post, share, upload, or make available via the Program may be visible to others who use the Program.

When it is necessary to share personal information from the Program with a third party, Your personal information will be properly protected, only the minimum personal information required will be shared, and it will be shared only on a need-to-know basis.

Your personal information may be shared:

???????????????? with the Sponsor of the Program

???????????????? with other companies within the Sponsor's corporate group

???????????????? with Your employer (and its management staff). If Sponsor is your employer, then personal information processed in connection with the Program (including information regarding the performance of your duties as an employee) may be processed by Sponsor for employment related purposes. This information could form part of your personnel record as an employee, and could be considered when evaluating the performance of your work. For further information, please see??Sponsor's employee handbook.

???????????????? with the Sponsor's suppliers and sub-contractors in conjunction with the Program

???????????????? with another business if Sponsor is involved in a takeover or merger with that business

???????????????? if the Sponsor is under a legal duty to disclose Your information (for example, as required by law enforcement or a court order)

???????????????? if Sponsor or a third party (including BIW) must enforce a contract

???????????????? if Sponsor or a third party (including BIW) must protect the rights, property, or safety of You or anyone else

???????????????? with providers of analytics services as described in the next paragraph

Sponsor will collect the following types of information and use analytics services to help make improvements to the Program and/or the Website, or to troubleshoot problems:

???????????????? personal information the IP address assigned to Your computer (an IP address is a unique number assigned to your computer when you use the internet)[PERSONAL ANALYTICS DATA - ADD ANY ADDITIONAL PERSONAL DATA USED BY THE PROGRAM FOR ANALYTICS] and any phone number You use to call Sponsor's customer service number

???????????????? technical information browser type and version, time zone setting, browser plug-in types and versions, operating system, and device type

???????????????? performance information information about Your use of the Program Website, including the date and time You connect, the pages of the Website You view, products from our catalog You viewed or searched, how long it took to display each page You viewed, errors, and the length of time You spent on certain pages

???????????????? [ADDITIONAL ANALYTICS USAGE ADD ANY ADDITIONAL SPECIFIC language as to how analytics will be used by the specific customer program IF NOT COVERED ABOVE.]

Your personal information is securely stored within [STORAGE LOCATION - LIST THE COUNTRY WHERE THE APPLICATION DATABASE IS STORED].

Your personal data (name, address, phone) will be transferred to the country or region where you reside as required to permit physical delivery of Program communications or merchandise awards.

[ADDITIONAL INTL TRANSFER(S) Your personal data (<lorem, ipsum>) will be transferred to <country> for the purpose of LOREM IPSUM]

[INTERNAL NOTE ONLY FOR COUNTRY TO COUNTRY DATA TRANSFERS OTHER THAN FOR SHIPPING OR IN-COUNTRY ORDER FULFILLMENT, BIW MUST OBTAIN PRIOR WRITTEN AUTHORIZATION FROM THE BIW CUSTOMER, AND FROM THE BIW DATA PROTECTION OFFICER.]??

When it is necessary to transfer Your personal information outside of the country in which it is stored, the Sponsor takes steps to make sure adequate levels of privacy protection in line with applicable data protection laws are in place. These privacy protection measures are contractually required of all parties involved in the transfer.

Your rights regarding Your personal information

The Sponsor respects Your rights to access and control Your personal information which include:

1) Right to information This right provides You with the ability to ask the Sponsor for information about what personal information about You is being processed and the rationale for such processing.

2) Right to access This request provides You with the right to see or view Your own personal information that is being processed, as well as to request copies of Your personal information.

3) Right to rectification This right provides You with the ability to ask for modifications to Your personal information if You believe that Your personal information is not up to date or accurate.

4) Right to withdraw consent This right provides You with the ability to withdraw previously given consent for processing of Your personal information for a specific purpose. Your request would then require the Sponsor to stop the processing of Your personal information that was based on the consent provided earlier.

5) Right to object This right provides You with the ability to object to the processing of Your personal information. Normally, this would be the same as the right to withdraw consent, if consent was appropriately requested and no processing other than legitimate purposes is being conducted. However, a specific scenario would be when You ask that Your personal information not be processed for certain purposes while a legal dispute is ongoing in court.

6) Right to object to automated processing This right provides You with the ability to object to a decision based solely on automated processing. Using this right, You may ask that Your input (for instance, a questionnaire You completed) to be reviewed manually, because You believe that automated processing of Your responses may not consider Your unique situation.

7) Right to be forgotten Also known as right to erasure, this right provides You with the ability to ask for the deletion of Your personal information. This will generally apply to situations where You no longer participate in the Program. It is important to note that this is not an absolute right, and also must take into consideration the Sponsor's rights.

8) Right for data portability This right provides You with the ability to ask for transfer of Your personal information. As part of such request, You may ask for Your personal data to be provided directly to You, or transferred to another data controller other than the Sponsor. When doing so, Your personal information must be provided or transferred in a machine-readable electronic format.

Who to contact with data privacy questions or to exercise Your rights

Under applicable data protection laws, the Sponsor is a ???Data Controller??? of Your personal information.

[INTERNAL NOTE ONLY INCLUDE OR EXCLUDE EACH BIW SUB-PROCESSOR FOR THIS PROGRAM.?? A TYPICAL LIST MIGHT INCLUDE THOSE IN RED TEXT BELOW convert red text to black if included.] ??

[SUB-PROCESSORS This Program includes self-registration for travel or an event, so an Event Registration provider is also defined as a Data Controller of Your personal information.

This Program includes the option to use a Mobile App named SpotMe with your mobile device.?? If You choose to use the SpotMe App then some of your personal information from the Registration Provider will be shared with SpotMe.

This Program includes travel via airlines, so an Airline Booking provider is also defined as a Data Controller of Your personal information.

END LIST OF TYPICAL SUB-PROCESSORS]

Data Controllers make decisions about how and why Your personal information is used by the Program, and have a duty to ensure Your rights are protected.

The Program and the Website are both owned and operated on the Sponsor's behalf by BI WORLDWIDE (BIW) with headquarters located at 7630 E. Bush Lake Road, Minneapolis, MN 55439.

If You have any questions or concerns related to how Your data is used bythe Program, You should contact the Sponsor directly by sending an email with your name and contact information to: [CUSTOMER DPO CUSTOMER DATA PROTECTION OFFICER (DPO) NAME, TITLE AND E-MAIL ADDRESS. OBTAIN FROM CUSTOMER]

[INCLUDE OR EXCLUDE EACH APPLICABLE BIW SUB-PROCESSOR'S DPO CONTACT INFORMATION FOR THIS PROGRAM.?? A TYPICAL LIST MIGHT INCLUDE THOSE IN RED TEXT BELOW ' convert red text to black if included and delete any you do not use with this program website] ??

[SUB-PROCESSOR DPOs

If You have any questions or concerns related to how Your data is used by the Event Registration provider Cvent, You should provide your name and contact information to:

Cvent Privacy Representative

1765 Greensboro Station Place, 7th Floor

Tysons Corner, Virginia 22102

privacy@cvent.com???? ??

If You have any questions or concerns related to how Your data is used by the Event Registration provider Lenos, You should complete their online form located here: https://digital.lenos.com/corp/LenosContact2017/Privacy-Form/privacy???? ??[NOTE: LENOS DPO CONTACT LINK IS SUBJECT TO CHANGE SO PLEASE VERIFY THE LINK SHOWN HERE IS STILL THE CORRECT ONE TO USE IF THIS IS APPLICABLE TO YOUR PROGRAM]

If You have any questions or concerns related to how Your data is used by the SpotMe Mobile App provider, You should send an email with your name and contact information to: Dr. Christan Rauda, Data Protection Officer, privacy@spotme.com

If You have any questions or concerns related to how Your data is used by the Airline Booking provider, You should send an email with your name and contact information to: dataprotection@Amadeus.com. ????

END LIST OF SUB-PROCESSOR DPOs]

If You are not happy with the response you receive from any of the Data Controllers you have contacted, or You believe that protection of Your personal information or privacy rights have been infringed, You should contact Your country's Data Protection Authority (DPA) or the Swiss Federal Data Protection and Information Commissioner. ??You can search for Your country's DPA by entering the name of your country combined with the words ???data protection authority??? or ???privacy office??? into an Internet search page such as www.google.com.