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Privacy Statement

Sigma Systems Inc. and its subsidiaries (‘Sigma Systems’ or ‘Sigma’) respects your privacy and we acknowledge that you have certain rights related to any personal information we collect from you, and we have certain obligations in respect of the same. Sigma Systems supports the various international and local privacy laws and has procedures in place to meet the requirements of those laws.

This Privacy Statement supports our privacy principles and informs you about our practices for gathering, storing, and using the personal information of individuals who use our websites, apply for or use our employment or outsourcing services, and those who are representatives of our customers (including prospective customers), service providers, and suppliers.

We encourage you to review this information so that you may understand how we collect, use, and share your personal information.

If we change anything important about this statement (the information we collect, how we use it, or why we use it) we will highlight those changes in the Change History section at the end of this Privacy Statement and provide a prominent link to it for a reasonable length of time following the change and prior to the change taking effect.

If you have questions, please email the Data Protection Officer or write us:
Sigma Systems, Inc. in the U.S. can be contacted at 293 Boston Post Road West, Suite 301, Marlborough, MA 01752.

Information We Collect

 

Sigma collects, stores, and uses personal data to provide our recruiting, employment, outsourcing, and consulting services. We collect personal data about individuals who use our websites, apply for employment or engagement with us, or placement by us through our recruitment services, employees, and those who are representatives of our customers (including prospective customers). Sigma does not knowingly direct its services or obtain information from children under age 13.

Most of this data is provided by you directly when you contact us, submit an application, attend an in-person recruiting event, through phone conversations, contact us about our services, or during your outsourcing or employment relationship.

We also collect data about individuals who are employed or engaged by our customers in connection with our provision of outsourcing and consulting services to those customers. This is generally obtained through our interactions with customers, suppliers, and service providers.

When you interact with a Sigma website or application, we collect data related to how you interact with that service by, for example, our use of cookies placed on your device.

We have set out further details below on the types of personal data we collect, store, and use and the reasons we use your personal data.

Why We Use Your Information

 

We will use your personal data where:

• You have given your consent to the relevant processing activity for the purposes of which we have informed you. Where this is the case, you always have the right to withdraw that consent.
• It is necessary for the performance of and compliance with your employment contract or other applicable engagement contract with us or in order to take steps prior to entering into that contract or another contract with you.
• We need to process your information in order to comply with a legal or regulatory obligation (for example, complying with duties under employment, social security, social protection, and tax legislation for example, complying with our obligations under equality legislation or in relation to statutory sickness or maternity rights);
• Exceptionally it is necessary for vital interests relating to you or another person (for example, avoiding serious risk of harm to you or others); or
• It is necessary for our legitimate interests (or those of a third party) provided that our legitimate interests are not overridden by your interests or rights which require protection of your data.

We will use special categories of personal data where:

• You have provided your explicit consent. Where this is the case, you always have the right to withdraw that consent.
• We need to do so to carry out our legal obligations (e.g., in the context of employment, social security and social protection law, or for a collective agreement) for example, complying with our obligations under equality legislation or in relation to statutory sickness or maternity rights.
• It is necessary for the establishment, exercise, or defense of legal claims.
• It is necessary for the purposes of preventative or occupational medicine, for the assessment of your working capacity, medical diagnosis, or provision of health care (for example, in relation to Occupational Health referrals and reports);
• Where it is needed for reasons of substantial public interest, such as for equal opportunities monitoring.
• Exceptionally, where it is necessary for vital interests relating to you or another person (for example, avoiding serious risk of harm to you or others) and where you are not capable of giving consent; or
• Where you have already made the relevant personal information public.
• We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Legitimate Interests

As mentioned above, we can, sometimes, use your personal information where this is necessary for our legitimate interests (or those of a third party). This includes where use of your personal information is necessary to:

• Manage training and development requirements.
• Maintain product development and enhancement, along with effective marketing through analytics and profiling for business intelligence.
• Deal with disputes and accidents and take legal or other professional advice; comply with another country’s laws and regulations.
• prevent fraud and financial crime; and ensure network and information security.

If you would like further information on our legitimate interests as applied to your personal information, please contact the Data Protection Officer. Failure to provide information where required
Where we are requesting information from you in order to employ or engage you, or in order to place or job-match you, if you do not provide the information that we have identified as required we may be unable to properly assist with your request for employment, placement, or job-matching to be performed by Sigma Systems.

Retaining Your Information

 

We will retain your personal information for as long as is necessary in connection with our agreement with you, to provide you with the services requested, or for other necessary purposes such as compliance with a law, regulation, or other legal authority, or as is otherwise permitted to be maintained for other legal purposes, such as audit, security, fraud prevention, or preserving and defending Sigma’s legal rights.

Additionally, job applicants and individuals whose assignment has ended will be maintained in Sigma’s talent pool to be potentially contacted about other employment opportunities. European talent pools will retain your applicant data for no longer than three years. Individuals located outside of Europe will be retained in alignment with local legal requirements, but in all cases no longer than ten years. Where applicable, Sigma will remove your information from the talent pool upon verified request.

Shared

Sigma Systems holds its employees, agents, and suppliers accountable for maintaining the trust that you place in us with your personal information. For individuals, Sigma shares the data that is necessary to perform its staffing and outsourcing services with other Sigma Systems entities, customers, suppliers, or with service providers that may be engaged to assist in managing the processes required to provide these services. Any engagement of a customer, supplier, or service provider will be governed by appropriate contractual requirements prohibiting the use of your information for any purposes beyond those specifically directed by Sigma and requiring that they ensure sufficient administrative and technical security mechanisms are in place to prevent your information from being improperly used, disclosed, or accessed.

Your Rights and Choices

 

We respect your right to access and control your information. The amount of personal information you are required to supply when requesting our services is consistent with Sigma’s interests in providing our services to you. Sigma complies with applicable data protection laws and regulations.

We process personal data about you for the purposes set out in this Privacy Statement, including to provide recruitment, placement, employment, or outsourcing services, operate our business, comply with our legal and contract obligations, and fulfill other legitimate interests of Sigma. In most countries in which Sigma has an employment contract with you, the processing of contact, payroll, and benefit information is a contractual or statutory obligation, and failure to provide information to allow processing may restrict your ability to be employed by Sigma.

You may have certain rights in relation to your personal data. The availability of these rights and the ways in which you can use them are set out below in more detail.

Mexican Privacy Policy

 

Sigma Systems, Inc., hereinafter “SIGMA”, domiciled at 293 Boston Post Road West, Suite 301, Marlborough, MA 01752, and with its webpage address at http://www.sigmainc.com is responsible for the use of general, financial, patrimonial, or sensitive personal data that you have disclosed or may come to disclose in connection to your employment relationship with Sigma, or with the job application you provided, if any, pursuant to the terms established by the Mexican Federal Law for Protection of Personal Data in Possession of Private Parties (“LFPDPPP”).

You are entitled to limit the use or disclosure of your personal data for those purposes not required for our legal relationship, to avoid receiving job offers or promotional messages from Sigma to your phone number, mobile phone number, and/or e-mail address, expressing your refusal to continue receiving this type of messages through your e-mail by sending us such request to the following e-mail: privacy@sigmainc.com . In addition to the foregoing, we inform you that at any time, you may revoke your authorization for the use of your personal data by sending an e-mail to Privacy@sigmainc.com

In accordance with the LFPDPPP, you are entitled to access your personal data in Sigma´s possession as well as to obtain details about their use, rectify them in case they are inaccurate or incomplete, cancel them when you consider that they turn out to be excessive or unnecessary for the purposes that justify their gathering, or oppose to their use for specific purposes (ARCO rights).

In order to allow Sigma to process your request, such request e-mail should be accompanied by the following information: (i) copy of official identification with photograph (IFE, current passport, professional certificate or military card), (ii) full name, (iii) complete current domicile, (iv) fixed and/or mobile phone number and (v) the reasons for requesting; Sigma to access (whenever you want Sigma to inform you about the existence of your personal data); to rectify (whenever you want Sigma to rectify your personal data as they may be inaccurate or incomplete); to cancel (whenever you want Sigma to partially or completely eliminate your personal data); or to oppose (when you require Sigma to cease the use of your personal data).
In the event your request is authorized, in terms of the LFPDPPP, the return of the personal data will be free of charge, and you will have to pay the reasonable mailing expenses only or the cost of copies or other formats that are generated. Your request will be attended within a period no greater than 20 (twenty) business days.

If you consider that your right to data privacy has been infringed by any conduct of employees or by our actions or responses or you believe that there is a violation to the provisions established by the LFPDPPP regarding the use of your personal data, you may submit a complaint or a claim before the Federal Institute of Access to Information and Data Protection. For further information visit www.ifai.org.mx.

California Privacy Policy

For individuals located in California, Sigma is committed to your rights under the California Consumer Privacy Act, and wants to ensure your aware that, if applicable, you have the following rights:
Right of access: You have the right to request access to personal information that we collected for the previous 12 months. Please note that if your access request requires the disclosure of personal information of another individual, we won’t be able to comply with all of your access request. Similarly, if responding to your access request would cause us to violate any law, rule, regulation, or law enforcement request, Sigma would not be able to fulfill your request.
Right of deletion: You have the right to request that we delete personal data that we collected from you. However, we are not required to comply with your request if one of several exceptions apply, including circumstances where is necessary for us or our service provider to maintain your personal data in order to complete the transaction with you; internal use that is reasonably aligned with your expectations; compliance with a legal obligation; or other use your personal data internally that is compatible with the context in which you provided it.
Right to opt-out: You have the right to opt-out of the sale of your personal data to Third Parties at any time. This means that once you exercise your right to opt-out of the sale of your personal information, we are required to honor your request. Sigma does not sell personal information to Third Parties.
Right not to be discriminated against for exercising these rights: You have the right to be free of discrimination for exercising your consumer privacy rights. We will not deny you goods or services, charge different amounts or provide a different quality level of goods or services for exercising your rights unless the difference is reasonably related to the value of your data.
Because processing your information is necessary to the performance of recruitment, placement, and employment or outsourcing services that we provide to you, a request to erase your information may result in Sigma being unable to continue providing its services such as recruitment, placement, employment, or outsourcing services. Subject to applicable law, Sigma may limit or deny requests or charge reasonable fees.

Other Privacy Rights

Under the laws of some jurisdictions, you may have the right to request additional information about the personal data we collect, request access to the personal data we process, correct an error or omission, delete personal data, or object or limit further processing. Sigma adheres to applicable data protection laws and will respect individual rights requests under those laws.
Because processing your information is necessary to the performance of recruitment, placement, and employment, or outsourcing services that Sigma provides to you, a request to exercise certain rights may result in Sigma being unable to continue providing its services such as recruitment, placement, employment, or outsourcing services. Subject to applicable law, Sigma also may limit or deny requests or charge reasonable fees.

Direct Marketing

We may periodically use your contact information to send you updates via e-mail in order to alert you to opportunities or services relevant to your interactions with us, such as jobs in our database that match your selected criteria.
At the point where we request personal information about you, our site also gives you the opportunity to decide which communications you wish to receive. When your interactions with Sigma Systems have resulted in your registration for multiple services or resources it may be necessary to opt out from each service separately.
You can opt-out of receiving direct marketing from us at any time. Each marketing communication will provide instructions on how to opt out of receiving similar e-mails from the registered service or resource. You can also opt-out by contacting the Data Protection Officer at privacy@SigmaInc.com.

European Privacy Rights

For individuals located in the European Economic Area (“EEA”),;United Kingdom, or Switzerland, Sigma complies with data protection laws in your country, and if applicable, you have the following rights:;
Access: You have the right to request access to your personal data. You are entitled to ask us if we are processing your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it.;
Correction: You are entitled to request that we correct inaccuracies (rectification) of your personal data. In response to your request, we will update any incomplete or inaccurate personal data we hold about you to ensure it is accurate and correct.;
Erasure: You have the right to request erasure of your personal data in certain circumstances, and subject to our obligations to maintain your information under applicable laws or if retention of your personal data is required in connection with claims.
Restriction: You are entitled to ask us to suspend the processing of certain of your personal data, for example if you want us to establish its accuracy or the reason for processing it.;
Transfer: You may request to receive information you provided to us in a machine-readable portable format or the transfer of certain personal data to another party.
Automated decisions: You may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.

Right to object

For individuals located in the EEA,; United Kingdom, or Switzerland, you have a right to object to Sigma processing your information in certain circumstances.
You have a right to object to Sigma’s processing of your personal data where this is based on Sigma’s legitimate interests (or those of a third party). You may challenge our reliance on legitimate interests.
However, we may be entitled to continue processing your personal data based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes
You have the right to lodge a complaint with a Data Protection Authority, in particular in the Member State in the European Union (or United Kingdom, as applicable) where you are habitually resident, where we are based, or where an alleged infringement of Data Protection law has taken place.
Because processing your information is necessary to the performance of recruitment, placement, and employment or outsourcing services that we provide to you, a request to withdraw consent, object to processing, or erase your information may result in Sigma being unable to continue providing its services such as recruitment, placement, employment, or outsourcing services. Subject to applicable law, Sigma may limit or deny requests or charge reasonable fees.

Cookies

We record the number of visitors to the relevant sections of our website and track movement between the sections by means of Cookies.

Cookies are small data files containing information placed on your computer and are automatically downloaded to your device in order to recognize you as someone that has visited our website previously. We use cookies that identify your browser or device. They collect and store information when you visit our website about how you use it.

For more information about cookies, the types of cookies we use, and how we use them, please see our Cookie Policy.

Passwords must be kept confidential and not disclosed to a third party. Sigma does not ask you for your password.

Protecting Your Information

Sigma Services takes care to secure your personal information.

We regularly monitor industry standards for securing information and review our physical, technical, and organizational security practices in order to determine how best to prevent the loss, misuse, alteration, unauthorized access, destruction, or disclosure of your personal information.

Any personal data sent to us, either in writing or e-mail, may be insecure in transit and we cannot guarantee its delivery.

Passwords must be kept confidential and not disclosed to a third party. Sigma does not ask you for your password.

Updates to this Privacy Statement

Sigma may update this Privacy Statement from time to time, so please review it frequently.

If we change our Privacy Statement, we will post the revised version here and will describe the changes in the Change History section.

If we make significant changes to our Privacy Statement, we may also notify you by other means prior to the changes taking effect, such as, prominently posting a notice of such changes on our websites, providing notice of the change through our online portals, or by directly contacting you.

If you would like to access previous versions of this Privacy Statement contact the Data Protection Officer at privacy@SigmaInc.com.

How to Contact Sigma

If you have any questions or comments about this Privacy Statement, would like to exercise any of your rights under applicable data protection law, or believe that Sigma has not adhered to this Privacy Statement, please e-mail our Data Protection Officer at privacy@SigmaInc.com. Additionally, individuals can contact Sigma Services in the U.S. at:

Sigma Services, Inc.
ATTN: Privacy Officer
293 Boston Post Road West, Suite 301
Marlborough, MA 01752