This Global Privacy Policy (the “Policy”) explains how SW Tenet (we, SW Tenet) collect, use and disclose your personal information. We believe it is our duty to ensure the necessary protection and appropriate use of personal data received from you directly or through authorized third parties. When collecting and processing your personal data in accordance with this Policy, we do so as authorized under applicable data privacy laws, whether as data controller or joint controller, or data processor (similar terms may be used under applicable law).
This Policy does not apply to your use of any third-party sites linked to from our website.
SW Tenet reserves the right to amend or change this policy anytime to ensure that it reflects the way we process your personal data.
When processing your personal data we are guided by the following basic data protection principles:
When collecting your personal data, we rely on the following legal grounds:
We process your personal data only when it is required to achieve a predetermined purpose, is required by law or professional standards.
We process personal data if you provide it to us directly or through third parties authorized by you. But in some cases, we may already have personal data (for example, if you are a former employee of SW Tenet or you already have business relations with SW Tenet), but they are not processed for longer than the purposes or laws require.
The information we collect about you depends on the nature of your relationship with SW Tenet and the purpose of processing. Below you may get acquainted with our data procession purposes clustered in major groups.
Types of personal information: personal and contact information, professional or employment related information, payment information.
Legal basis: legitimate interest or consent (if required).
Types of personal information: personal and contact information, professional or employment related information, financial information, specific business information.
Legal basis: legitimate interest or consent (if required).
Types of personal information: personal and contact information, professional or employment related information.
Legal basis: consent.
Types of personal information / Legal basis: the information on the purposes, categories of personal data processing and legal grounds is provided in the Company’s internal regulations.
Types of personal information: will depend on the certain legal requirement.
Legal basis: legal obligations.
Types of personal information: analytic information.
Legal basis: consent.
We never specifically collect and store data on persons under 18 years of age, except for the collection and storage of such data as part of the provision of professional services
We may process sensitive personal data (such as biometrical data or special category or criminal offence data) only when it strictly required for maintenance of our business, on the consent basis and in accordance with applicable law.
We operate on worldwide basis therefore we reserve right to transfer your personal data to SW Tenet entities, service providers and third parties when it is necessary to accomplish the specific business purposes for which personal data were collected, in particular, to manage our services or to improve our business operations, or required by law, or in other cases, acceptable under applicable data privacy legislation. When transferring your personal data, we always rely on your consent or other legal grounds provided by applicable legislation for such transfer. If provided by applicable legislation, we would also implement guarantees for such transferring, including SCC guarantees.
In particular, we may transfer your personal information to the following third parties:
Our service providers: for example, (IT) systems providers, our hosting providers, payroll providers, legal advisers, and other goods and services providers. We shall only transfer your personal information to them when ensure that they meet our standards on data processing and security and only in amount that is required for them to provide services.
Successors of the business: We will also disclose personal information in connection with the sale, assignment, or other transfer of any element of SW Tenet’s business to which the personal information relates.
Courts, tribunals, law enforcement or regulatory bodies: We will disclose personal information when it is necessary to comply with requests of courts, tribunals, government or law enforcement agencies.
Auditors: We will disclose your personal data information where necessary for the conduct of company audits or to investigate a complaint or security threat.
Insurance market participants: In order to make the insurance program work effectively, the insurance market participants will require that we disclose personal information about you to them. The information will be used by the them in the underwriting and ongoing administration of the insurance program, where there is a claim that you are relevant to and to allow the insurance market participants to comply with their legal and regulatory obligations.
We shall endeavor that such transfer complies with any applicable laws and regulations, to ensure safety and confidentiality of your personal information, and we also implement technical, organizational or contractual measures to ensure an adequate level of protection for your personal information.
When transferring your personal information to SW Tenet entities, we rely on specific data protection laws and regulations, provided by applicable local and native laws for each operating country.
When processing your personal data, SW Tenet guarantees compliance with following rights:
We recognize the high importance of your personal information security, and we have adopted and implemented measures to protect personal data from loss, unauthorized use, modification or erasing and to ensure that such information is processed in accordance with applicable data privacy laws.
We may collect certain types of information, such as IP address, when you visiting our website through use of cookies to analyze trends in the use of websites and their effectiveness, for example, to determine the number of unique online visitors to our websites and collect information on their geographical location. You can give your consent to the cookies processing by first reviewing the procedure for the cookies processing set forth in the Cookies Policy.
If you have any questions or comments regarding our work with your personal information, please contact the Personal Data Privacy Officer at info@tenetcons.com. You can also use this address to report any issues related to our compliance with this Policy.