Introduction

WoMarine recognizes and supports the privacy interests of all persons, and respects these interests when WoMarine collects and processes Personal Information. In particular, WoMarine respects the privacy of its customers, suppliers and employees and other individuals with whom WoMarine has business interactions. In addition to the restrictions and obligations of this Policy, WoMarine complies with the applicable national laws that protect the privacy of Personal Information and all laws and regulations in the jurisdictions in which WoMarine conducts its business.

Scope

This Policy applies to:

(1) Personal Information that is collected, maintained, used or otherwise processed by any Global Business Unit, Function/Business Support Activity or Affiliate of WoMarine;

(2) Personal Information in any format, including computerized records and electronic information as well as paper-based files; and

(3) Personal Information that WoMarine collects and uses for its own business purposes.

The terms of this Policy are also intended to apply to agents and contractors that handle and process Personal Information on behalf of WoMarine.

Definitions

For purposes of this Policy, the following definitions shall apply:

“Personal Information” (or person’s information) - also called Personally Identifiable Information (PII) or Personal Data- means any information that can be used to identify directly or indirectly a person. It includes any information that enables an individual to be identified either from that piece of data alone, or from that data and other data that is available or likely to be available such as his/her name, home address, email, identification number, salary and benefits information. There is no distinction between Personal Information about an individual in their private, public or work roles, as all are covered by this Policy.

“Processing” means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means, such as collection.

“Sensitive Personal Information” means Personal Information that reveals medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life or sexual orientation of the individual.

Privacy principles

(1) Collection or use of data - Purposes

WoMarine collects and uses the Personal Information to support and further its businesses. WoMarine  processes Personal Information only for limited, explicit and legitimate purposes and always in accordance with applicable law. The types of information and the purposes for which we collect Personal Information may include:

For Employees

WoMarine collects and uses Personal Information as needed for human resources and employment processes from current and prospective employees and independent contractors.

For Customers, Suppliers and Distributors

Although our customers, suppliers and distributors are mostly companies, WoMarine collects Personal Information about individuals who are employed by them. This business contact information and other personal details are used to administer existing and future business arrangements.

Others

Additional Personal Information may be collected, used and disclosed for the purposes for which it was collected and for legal compliance purposes, including regulatory reporting, investigation of allegations of wrongdoing, and the management and defense of legal claims and actions, and compliance with subpoenas, court orders and other legal obligations. For example, we may collect information about individuals that visit our website.

WoMarine collects this information only in a reasonable and lawful manner.

(2) Privacy notices -Transparency

Where required, WoMarine informs individuals about its processing of their information and also makes this information available upon request. In particular, its privacy notices contain:

the type of information we collect;

the purposes for which we collect Personal Information;

the types of parties to whom we disclose Personal Information;

the privacy and information safeguards we employ; and

how to access, correct or erase Personal Information (if appropriate).

WoMarine also offers transparency with regard to international information transfers. Where possible, privacy notices include information about how Personal Information may be used within the WoMarine Group and by third parties, the purposes of such transfers, the potential recipients, and the safeguards that WoMarine has put into place to help ensure an adequate level of protection for the transferred information.

(3) Lawfulness and fairness of the processing

WoMarine processes Personal Information lawfully and fairly in relation to the individual. This implies that all processing is based on legitimate grounds, such as the necessity of the processing for (i) preparing and/or performance of a contract with the individual, (ii) compliance with a legal obligation imposed on WoMarine, (iii) protection of vital interests of the individual, (iv) performance of a task carried out in the public interest, or  (v)  legitimate  interests  pursued  by  WoMarine  or  by  a  third  party  except  where  such interests are overridden by the interests or fundamental rights and freedoms of the individual which require protection of Personal Information.

In addition, where consent of an individual for the collection, use, or disclosure of Personal Information is required by law, contract or agreement, WoMarine must receive such consent prior to the processing or transfer of the Personal Information.

(4) Sensitive information

There are certain types of Personal Information that WoMarine considers to be particularly sensitive and for which WoMarine provides additional and appropriate privacy protection and confidentiality. WoMarine will only collect and use this Sensitive Personal Information where there is a legal basis, or where the individual’s consent has been obtained or where there are compelling business reasons if legally permitted.

(5) Accuracy of information

WoMarine employs reasonable means to keep Personal Information reasonably accurate, complete, and up- to-date, as needed for the purposes for which it was collected.

(6) Information disclosure

Internal Disclosure

In general, Personal Information may be shared within WoMarine, where legally permitted for reasonable and appropriate corporate purposes. However, even within WoMarine, access to Personal Information is restricted to those employees, agents, or contractors who need access to carry out their assigned functions.

External Disclosure

Disclosure of Personal Information beyond the employees, agents, or contractors of WoMarine, may be made only as permitted or required by law or legal process, or pursuant to an agreement, business necessity, or with the consent of the individual. In particular:

 Employees

WoMarine may disclose Personal Information about workers and employees to a range of third parties who provide its employees with services, such as payroll or benefits management.

 All Individuals

Personal Information may always be disclosed in connection with legal compliance initiatives, in response to a government request for information or as part of the due diligence, negotiation and completion of a sale or transfer of all or part of our businesses.

(7) The location of Personal Information and international transfer

Personal Information may be stored and processed at WoMarine national, regional or global headquarters, at the locations of a WoMarine Affiliate or of our service providers, at one or more of our international data centers and in the cloud via our service providers and always in accordance with the applicable laws.

The international footprint of WoMarine involves a large number of transfers of Personal Information between different WoMarine entities, as well as to third parties located in various countries. WoMarine endeavors to ensure that appropriate safeguards are implemented to secure such information transfers in conformity with applicable laws.

(8) Protecting Personal Information

To help protect the confidentiality of Personal Information, WoMarine employs security safeguards appropriate to the sensitivity of the information. These safeguards include reasonable administrative, technical and physical measures to protect the confidentiality and security of Personal Information against anticipated threats and unauthorized access to the Personal Information. WoMarine also maintains an effective Data Protection & Privacy incident and breach management program. When required by applicable law, WoMarine will report Personal Information breaches to the relevant authority and/or to inform the affected person.

(9) Access and Correction - Rights of individuals

WoMarine shall generally provide individuals upon request with an opportunity to examine their own Personal Information, confirm the accuracy and completeness of their Personal Information, and have their Personal Information updated, if appropriate. WoMarine provides individuals with a reasonable opportunity to object to the collection, use, and disclosure of their Personal Information.

(10) Retention

WoMarine endeavors not to retain the Personal Information longer than is allowed under applicable laws.

Responsibilities/Accountabilities

It is the responsibility of all employees to assist in the protection of Personal Information, by acting in accordance with this Policy. Each employee is also responsible for helping to ensure that the Personal Information WoMarine holds is accurate and up-to-date.

Any violation of this Policy may result in appropriate actions, including disciplinary actions, mitigation actions and discontinuation of business relations, subject to and in conformance with applicable laws.