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Holcim Privacy Policy

In effect since: January 2023

 

Holcim Ltd and its Affiliates (together referred to as "Holcim" or "we") are committed to protecting your personal data and being transparent about the manner your personal data are being processed. As a rule, Holcim Affiliate operating in the country where you are located act as the data controller, responsible for the processing of your personal data. The contact details of each Holcim European Union Affiliate are available at https://www.lafargeholcim.com/directory.

We take outmost care to process your personal data in accordance with the principles set forth in the data protection legislation applicable in the countries where Holcim operates, including (EU) Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR").

This Privacy Policy regards the personal data of the following categories of individuals:

  • customers or potential customers;
  • representatives or contact persons of Holcim customers or potential customers;
  • suppliers and subcontractors and other business partners;
  • representatives or contact persons of Holcim suppliers, subcontractors and other business partners;
  • applicants;
  • participants in the education and community partnerships;
  • employees, contractors and workers;
  • family members and dependents of the employees, contractors and workers;
  • former employees, contractors and workers;
  • shareholders, company directors and office holders;
  • education and community partnerships;
  • event attendees;
  • journalists and media representatives;
  • visitors of our premises;
  • users of our Internet websites;
  • general public.

 

The Privacy Policy is intended to provide details of all processing activities that we perform and therefore the Privacy Policy is structured by reference to the type of relationship or interaction that you have with Holcim. This mean that not all of the sections, nor the processing purposes in this Privacy Policy will be relevant to everyone.

 

This Privacy Policy describes: 

  • the purposes for which we collect and use your personal data;
  • the processing grounds for such purposes;
  • the categories of personal data we collect from you and process and the sources from which they originate;
  • whether the provision of your personal data is necessary and the possible consequences of your refusal to provide such data;
  • to whom we disclose or we may disclose your personal data;
  • the countries where we transfer your personal data;
  • the duration of processing of such data;
  • your rights as data subject and the manner in which you may exercise.

I. PURPOSES, GROUNDS FOR PROCESSING AND CATEGORIES OF PERSONAL DATA

1. If you are a customer or potential customer of Holcim

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Customer Due Diligence and Reporting

We process your personal data to undertake due diligence before commencing the contractual relationship with you.

If and to the extent requested or permitted by law, this may include anti-money laundering checks, anti-bribery, corruption checks or other similar types of checks.

We perform such due diligence to ensure that the relationship with you is appropriate and that any potential risks are identified and managed prior to commencing the contractual relationship with you.

Name, e-mail, phone, fax, address, data resulting from the due diligence carried out, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from other sources and not directly from you, respectively from our service providers, business partners and from publicly available sources.

Depending on the jurisdiction where the processing takes place, the processing is either necessary:

·       to comply with a legal obligation incumbent to us or

·       to achieve our legitimate interests of taking the necessary measures to protect our business, including to preserve our business operations and to grow such. 

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable. 

Providing the services requested by you

We process your personal data for the following purposes:

·     negotiating the terms of the relationship with you and concluding the agreement;

·     providing the services requested by you and managing the aspects arising from our contractual relationship;

·     communicating with you in connection with any aspect related to the services requested by you (e.g., providing you with pricing information, delivering the products purchased, managing and facilitating the relationship and raising invoices);

·     facilitating payment for goods and services;

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

 

we rely on the performance of the agreement concluded with you.

 

Customer administration

We process your personal data for customer administration purposes, namely for:

·     creating, managing and maintaining a Customer Relationship Management  database (CRM), including relevant organizational charts;

·     keeping records relating to our customers, including minutes of meetings and other notes;

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

 

We rely on our legitimate interests of operating our business, which includes taking the necessary steps for facilitating our customer relationship management. 

 

Management of legal claims and risks

We process your personal data for in connection with our legal rights and obligations, for the following purposes:

·     taking the necessary measures to enforce or defend any legal claims made by, against or otherwise involving you;

·     periodical reporting at group level.

 

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

We rely on our legitimate interests of operating our business, which includes taking the necessary measures to protect our business. 

 

 

Whistleblowing

We use a specific platform to enable reporting of suspected misconduct related to potential breaches of applicable laws, Holcim code of business conduct and other Holcim policies and directives and to conduct investigation on the reported issues. 

Name, e-mail, phone, fax, address, passport number, national identity number, professional address, date of birth, salary or compensation information, function within the organisation,  financial account information, data reported regarding suspected misconduct, data related to potential breaches of applicable laws, Holcim code of business conduct and other Holcim .

Some of this personal data are collected from other sources and not directly from you, respectively from the whistleblower, other business partners and from publicly available sources.

Depending on the jurisdiction where the processing takes place, the processing is either necessary:

·       for ensuring compliance with a legal obligation incumbent to us or

·       to achieve our legitimate interests of taking the necessary measures to protect our business, which includes maintaining our reputation and to act appropriately in all the countries in which we do business. 

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable. 

Data processing as obligation imposed by the law

We process your data in the context of providing the services in order to ensure compliance with the legal obligations incumbent to us, for example, in order to comply with lawful requests from public authorities, courts of law, government regulations, or regulatory authorities (including without limitation data protection, tax and employment), whether within or outside your country.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose or resulted from our relationship.

This processing is necessary to ensure compliance with the legal obligation incumbent to us. 

 

Direct marketing

 

We process your personal data in order to provide to you in electronic form our newsletters promoting our services and products, but only if you have subscribed and, hence, given your express consent to such processing.

We use your personal data to decide which marketing communications will be send to you. Generally, these decisions do not have any legal effects concerning you or do not significantly affect you. In cases the decisions would entail such adverse effects to you, you will be provided, prior to the processing, with details on the logic involved, as well as the significance of the possible consequences of such processing, In these cases you have the right to obtain human intervention, to express your point of view and to  consent such decisions. 

For example, we may tailor the marketing communications you receive based on the industry you activate, job title and preferences that you have selected.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose or resulted from our relationship.

For sending marketing communication, we rely on your express consent to such processing.

You can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective communication or by using the contact details indicated in this Privacy Policy,

For deciding which marketing communication is suitable for you, we rely on our legitimate interests of undertaking appropriate promotional activities. However, where we are required to do so by applicable law, we will get your express consent for such segmentation, for example, in case the decisions taken following the segmentation process would have any legal effects concerning you or would significantly affect you.

Other marketing actions

We process your personal data in order to conduct certain marketing activities, such as customer satisfaction surveys, in order to help us understand what you think about our products or services. This may include telemarketing campaigns, online surveys etc. 

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose or resulted from our relationship.

Depending on the jurisdiction where the processing takes place, the grounds for processing are either:

·       the legitimate interests of Holcim or

·       your express consent to such processing.

The legitimate interests mentioned above consist of taking the necessary measures to permanently improve our services and products.

In case the processing is based on your consent, you can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective communication or by using the contact details indicated in this Privacy Policy,

2. If you are a representative or contact person of a Holcim customer or potential customer

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Customer Due Diligence and Reporting

We process your personal data to undertake due diligence before commencing the contractual relationship with the entity you represent or are employed by, which is a potential customer of Holcim.

If and to the extent requested or permitted by law, this may include anti-money laundering checks, anti-bribery,corruption checks or other similar types of checks.

We perform such due diligence to ensure that the relationship with you is appropriate and that any potential risks are identified and managed prior to commencing the contractual relationship with you.

Name, e-mail, phone, fax, address, data resulting from the due diligence carried out, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from other sources and not directly from you, respectively from the entity you represent or are employed by, our service providers, business partners and from publicly available sources.

Depending on the jurisdiction where the processing takes place, the processing is either necessary:

·       to comply with  a legal obligation incumbent to us or

·       to achieve our legitimate interests of taking the necessary measures to protect our business, including to preserve our business operations and to grow such. 

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable. 

Providing the services requested by the entity you represent or are employed by

We process your  personal data for the following purposes:

·     negotiating the terms of the relationship with the entity you represent or are employed by and concluding the agreement;

·     providing the services requested by you and managing the aspects arising from the contractual relationship with the entity you represent or are employed by;

·     communicating with you in connection with any aspect related to the services requested by you (e.g., providing you with pricing information, delivering the products purchased, managing and facilitating the relationship and raising invoices);

·     facilitating payment for goods and services;

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

We rely on our legitimate interest in providing our services according to our area of activity and managing the relationship with our customers.

 

Customer administration

We process your  personal data for customer administration purposes, namely for:

·     creating, managing and maintaining a Customer Relationship Management  database (CRM), including relevant organizational charts;

·     keeping records relating to our customers, including minutes of meetings and other notes;

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

For this processing, we rely on our legitimate interests of operating our business, which includes taking the necessary steps for facilitating our customer relationship management. 

 

Management of legal claims and risks

We process your personal data in connection with our legal rights and obligations, for the following purposes:

·     taking the necessary measures to enforce or defend any legal claims made by, against or otherwise involving you or the entity you represent or are employed by;

·     periodical reporting at group level.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

We rely on our legitimate interests of operating our business, which includes taking the necessary measures to protect our business. 

 

 

Whistleblowing

We use a specific platform to enable reporting of suspected misconduct related to potential breaches of applicable laws, Holcim code of business conduct and other Holcim policies and directives and to conduct investigation on the reported issues. 

Name, e-mail, phone, fax, address, passport number, national identity number, professional address, date of birth, salary or compensation information, function within the organisation, professional e-mail address, , financial account information data reported regarding suspected misconduct, data related to potential breaches of applicable laws, Holcim code of business conduct and other Holcim.

Some of this personal data are collected from other sources and not directly from you, respectively from the whistleblower, other business partners and from publicly available sources..

Depending on the jurisdiction where the processing takes place, the processing is either necessary:

·       for ensuring compliance with a legal obligation incumbent to us or

·       to achieve our legitimate interests of taking the necessary measures to protect our business, which includes maintaining our reputation and to act appropriately in all the countries in which we do business. 

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable. 

Data processing as obligation imposed by the law

We process your data in the context of providing the services in order to ensure compliance with the legal obligations incumbent to us, for example, in order to comply with lawful requests from public authorities, courts of law, government regulations, or regulatory authorities (including without limitation data protection, tax and employment), whether within or outside your country.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

This processing is necessary to ensure compliance with a legal obligation incumbent to us. 

 

Direct marketing

 

We process your personal data in order to provide to you in electronic form our newsletters promoting our services and products, but only if you have subscribed and, hence, given your express consent to such processing.

We use your personal data to decide which marketing communications will be send to you. Generally, these decisions do not have any legal effects concerning you or do not significantly affect you. In cases the decisions would entail such adverse effects to you, you will be provided, prior to the processing, with details on the logic involved, as well as the significance of the possible consequences of such processing, In these cases you have the right to obtain human intervention, to express your point of view and to  consent such decisions. 

For example, we may tailor the marketing communications you receive based on the industry you activate, job title and preferences that you have selected. 

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

For sending marketing communication, we rely on your express consent to such processing.

You can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective communication or by using the contact details indicated in this Privacy Policy,

For deciding which marketing communication is suitable for you, we rely on our legitimate interests of undertaking appropriate promotional activities. However, where we are required to do so by applicable law, we will get your express consent for such segmentation, for example, in case the decisions taken following the segmentation process would have any legal effects concerning you or would significantly affect you.

Other marketing actions

We process your personal data in order to conduct certain marketing activities, such as customer satisfaction surveys in order to help us understand what you think about our products or services. This may include telemarketing campaigns, online surveys etc. 

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

Depending on the jurisdiction where the processing takes place, the grounds for processing are either:

·       the legitimate interests of Holcim or

·       your express consent to such processing.

The legitimate interests mentioned above consist of taking the necessary measures to permanently improve our services and products.

In case the processing is based on your consent, you can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective communication or by using the contact details indicated in this Privacy Policy,

3. If you are a supplier, a subcontractor or other business partner of Holcim

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Customer Due Diligence and Reporting

We process your personal data to undertake due diligence before commencing the contractual relationship with you.

If and to the extent requested or permitted by law, this may include anti-money laundering checks, anti-bribery, corruption checks or other similar types of checks.

We perform such due diligence to ensure that the relationship with you is appropriate and that any potential risks are identified and managed prior to commencing the contractual relationship with you.

Name, e-mail, phone, fax, address, data resulting from the due diligence carried out, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from other sources and not directly from you, respectively from our service providers, business partners and from publicly available sources.

Depending on the jurisdiction where the processing takes place, the processing is either necessary:

·       to comply with  a  legal obligation incumbent to us or

·       to achieve our legitimate interests of taking the necessary measures to protect our business, including to preserve our business operations and to grow such. 

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable.  

Maintaining our contractual relationship with you

We process your personal data for the following purposes:

·     negotiating the terms of the relationship with you and concluding the agreement;

·     maintaining our contractual relationship with you;

·     communicating with you with respect to any relevant business-related matters.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

We rely on the performance of the agreement concluded with you.

 

Management of contractual partners database

We process your personal data for management of contractual partners database, namely for:

·     creating, managing and maintaining a database of our contractual partners;

·     keeping records relating to our contractual partners, including minutes of meetings and other notes.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

We rely on our legitimate interests of operating our business, which includes taking the necessary steps for facilitating the relationship with our contractual partners. 

 

Management of legal claims and risks

We process your personal data in connection with our legal rights and obligations, for the following purposes:

·     taking the necessary measures to enforce or defend any legal claims made by, against or otherwise involving you;

·     periodical reporting at group level;

·     checking and keeping records to ensure that our suppliers and subcontractors have appropriate qualifications and training to ensure safe working on our sites (supplier training records).

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

We rely on our legitimate interests of operating our business, which includes taking the necessary measures to protect our business. 

In respect of the supplier training records, the processing thereof may be based, depending on the jurisdiction, on the legal obligations incumbent to us.

 

Whistleblowing

We use a specific platform to enable reporting of suspected misconduct related to potential breaches of applicable laws, Holcim code of business conduct and other Holcim policies and directives and to conduct investigation on the reported issues. 

Name, e-mail, phone, fax, address passport number, national identity number, professional address, date of birth, salary or compensation information, function within the organisation, , financial account information data reported regarding suspected misconduct, data related to potential breaches of applicable laws, Holcim code of business conduct and other Holcim .

Some of this personal data are collected from other sources and not directly from you, respectively from the whistleblower, other business partners and from publicly available sources..

Depending on the jurisdiction where the processing takes place, the processing is either necessary:

·       for ensuring compliance with a  legal obligation incumbent to us or

·       to achieve our the legitimate interests of taking the necessary measures to protect our business, which includes maintaining our reputation and to act appropriately in all the countries in which we do business. 

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable. 

Data processing as obligation imposed by the law

We process your data in the context of providing the services in order to ensure compliance with the legal obligations incumbent to us, for example, in order to comply with lawful requests from public authorities, courts of law, government regulations, or regulatory authorities (including without limitation data protection, tax and employment), whether within or outside your country.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

This processing is necessary to ensure compliance with the legal obligation incumbent to us. 

 

Direct marketing

 

We process your personal data in order to provide to you in electronic form our newsletters promoting our services and products, but only if you have subscribed and, hence, given your express consent to such processing.

We use your personal data to decide which marketing communications will be send to you. Generally, these decisions do not have any legal effects concerning you or do not significantly affect you. In cases the decisions would entail such adverse effects to you, you will be provided, prior to the processing, with details on the logic involved, as well as the significance of the possible consequences of such processing, In these cases you have the right to obtain human intervention, to express your point of view and to  consent such decisions. 

For example, we may tailor the marketing communications you receive based on the industry you activate, job title and preferences that you have selected. 

 

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose

For sending marketing communication, we rely on your express consent to such processing.

You can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective communication or by using the contact details indicated in this Privacy Policy.

For deciding which marketing communication is suitable for you, we rely on our legitimate interests of undertaking appropriate promotional activities. However, where we are required to do so by applicable law, we will get your express consent for such segmentation, for example, in case the decisions taken following the segmentation process would have any legal effects concerning you or would significantly affect you.

Other marketing actions

We process your personal data in order to conduct certain marketing activities, such as customer satisfaction surveys in order to help us understand what you think about our products or services. This may include telemarketing campaigns, online surveys etc. 

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose or resulted from our relationship.

Depending on the jurisdiction where the processing takes place, the grounds for processing are either:

·       the legitimate interests of Holcim or

·       your express consent to such processing.

The legitimate interests mentioned above consist of taking the necessary measures to permanently improve our services and products.

In case the processing is based on your consent, you can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective communication or by using the contact details indicated in this Privacy Policy,

4. If you are a representative or contact person of a Holcim supplier, subcontractor or other business partner

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Customer Due Diligence and Reporting

We process your personal data to undertake due diligence before commencing the contractual relationship with the entity you represent or are employed by.

If and to the extent requested or permitted by law, this may include anti-money laundering checks, anti-bribery,corruption checks.

We perform such due diligence to ensure that the relationship with you is appropriate and that any potential risks are identified and managed prior to commencing the contractual relationship with you.

Name, e-mail, phone, fax, address, data resulting from the due diligence carried out, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from other sources and not directly from you, respectively from the entity you represent or are employed by,, our service providers, business partners and publicly available sources.

Depending on the jurisdiction where the processing takes place, the processing is either necessary:

·       to comply with  a  legal obligation incumbent to us or

·       to achieve our legitimate interests of taking the necessary measures to protect our business, including to preserve our business operations and to grow such. 

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable. 

Maintaining our contractual relationship with the entity you represent or are employed by

We process your personal data for the following purposes:

·     negotiating the terms of the relationship with the entity you represent or are employed by and concluding the agreement;

·     maintaining our contractual relationship with the entity you represent or are employed by;

·     communicating with you with respect to your requests and any other relevant business-related matters;

·     facilitating payment for goods and services.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

We rely on our legitimate interest in managing the relationship with the entity you represent or are employed by.

 

Management of contractual partners database

We process your personal data for management of contractual partners database, namely for:

·     creating, managing and maintaining a database of our contractual partners;

·     keeping records relating to our contractual partners, including minutes of meetings and other notes.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

We rely on our legitimate interests of operating our business, which includes taking the necessary steps for facilitating the relationship with our contractual partners. 

 

Management of legal claims and risks

We process your personal data in connection with our legal rights and obligations, for the following purposes:

·     taking the necessary measures to enforce or defend any legal claims made by, against or otherwise involving you;

·     periodical reporting at group level;

·     checking and keeping records to ensure that our suppliers and subcontractors have appropriate qualifications and training to ensure safe working on our sites (supplier training records).

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

For this processing, we rely on our legitimate interests of operating our business, which includes taking the necessary measures to protect our business. 

In respect of the supplier training records, the processing thereof may be based, depending on the jurisdiction, on the legal obligations incumbent to us.

 

 

Whistleblowing

We use a specific platform to enable reporting of suspected misconduct related to potential breaches of applicable laws, Holcim code of business conduct and other Holcim policies and directives and to conduct investigation on the reported issues. 

Name, e-mail, phone, fax, address, passport number, national identity number, professional address, date of birth, salary or compensation information, function within the organisation,  financial account information data reported regarding suspected misconduct, data related to potential breaches of applicable laws, Holcim code of business conduct and other Holcim .

Some of this personal data are collected from other sources and not directly from you, respectively from the entity you represent or are employed by, the whistleblower, other business partners and from publicly available sources..

Depending on the jurisdiction where the processing takes place, the processing is either necessary:

·       for ensuring compliance with a legal obligation incumbent to us or

·       to achieve our legitimate interests of taking the necessary measures to protect our business. which includes maintaining our reputation and to act appropriately in all the countries in which we do business. . 

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable. 

Data processing as obligation imposed by the law

We process your data in the context of providing the services in order to ensure compliance with the legal obligations incumbent to us, for example, in order to comply with lawful requests from public authorities, courts of law, government regulations, or regulatory authorities (including without limitation data protection, tax and employment), whether within or outside your country.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

This processing is necessary to ensure compliance with a legal obligation incumbent to us. 

 

Direct marketing

 

We process your personal data in order to provide to you in electronic form our newsletters promoting our services and products, but only if you have subscribed and, hence, given your express consent to such processing.

We use your personal data to decide which marketing communications will be send to you. Generally, these decisions do not have any legal effects concerning you or do not significantly affect you. In cases the decisions would entail such adverse effects to you, you will be provided, prior to the processing, with details on the logic involved, as well as the significance of the possible consequences of such processing, In these cases you have the right to obtain human intervention, to express your point of view and to  consent such decisions. 

For example, we may tailor the marketing communications you receive based on the industry you activate, job title and preferences that you have selected. 

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

For sending marketing communication, we rely on your express consent to such processing.

You can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective communication or by using the contact details indicated in this Privacy Policy.

For deciding which marketing communication is suitable for you, we rely on our legitimate interests of undertaking appropriate promotional activities. However, where we are required to do so by applicable law, we will get your express consent for such segmentation, for example, in case the decisions taken following the segmentation process would have any legal effects concerning you or would significantly affect you.

Other marketing actions

We process your personal data in order to conduct certain marketing activities, such as customer satisfaction surveys in order to help us understand what you think about our products or services. This may include telemarketing campaigns, online surveys etc. 

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

Some of this personal data are collected from the entity you represent or are employed by.

Depending on the jurisdiction where the processing takes place, the grounds for processing are either:

·       the legitimate interests of Holcim or

·       your express consent to such processing.

The legitimate interests mentioned above consist of taking the necessary measures to permanently improve our services and products.

In case the processing is based on your consent, you can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective communication or by using the contact details indicated in this Privacy Policy.

5. If you are an applicant

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Recruitment and selection

If you apply for a job within Holcim or register an interest in working for us, we use your personal data to carry out our recruitment and selection processes. These processes include identifying you and communicating with you in respect of your application, considering you against our criteria associated to the position you apply for and other applicants and taking the final recruitment decisions.

If your job application is not successful, we wish to retain your personal data for up to 1 year in order to consider you for similar positions with those you have applied for initially.

Title, forename, middle name(s) and surname, birth name, any additional names, gender, nationality, second nationality, date of birth, age, address, telephone number, e-mail, national identification number, immigration and eligibility to work data, languages spoken, driving license, qualifications, references, CV and application, interview and assessment data, other data you may provide directly to us, as needed to fulfill this purpose.

Depending on the jurisdiction where the processing takes place, the processing of your personal data for these purposes is either:

·       necessary to achieve our legitimate interests of receiving job applications for the vacant positions in our organization or

·       based on your express consent to such processing.

In case the processing is based on your consent, you can always withdraw your consent by the means indicated when your consent as required or by using the contact details indicated in this Privacy Policy.

 

Background checks

Before your engagement with us begins, we may undertake background checks. This may include, where relevant and appropriate, reputation checks, driving license checks, identity fraud checks, criminal record checks (if and to the extent permitted by applicable laws), relevant employment history, relevant regulatory status and professional qualifications.

Title, forename, middle name(s) and surname, birth name, any additional names, gender, nationality, second nationality, date of birth, age, address, telephone number, e-mail, national identification number, immigration and eligibility to work data, languages spoken, driving license, qualifications, references, CV and application, interview and assessment data, other data you may provide directly to us, as needed to fulfill this purpose. Some of this personal data are collected from references, respectively from publicly available sources.

Depending on the jurisdiction where the processing takes place, the processing is either necessary:

·       to ensure compliance with a legal obligation incumbent to us or

·       to achieve our legitimate interests of taking the necessary measures to ensure that only suitable and appropriate applicants are selected. 

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable. 

6. If you are a participant in the education and community partnerships

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Recruitment and selection

If you apply to careers programs (internships, work experience, apprentice and graduate programs), as well as to any community partnership programs organized by Holcim or with the implication of Holcim, we process your personal data to carry out the recruitment and selection processes.

If your application is not successful, we wish to retain your personal data for up to 1 year in order to consider you for similar positions with those you have applied for initially.

Title, forename, middle name(s) and surname, birth name, any additional names, gender, nationality, second nationality, date of birth, age, address, telephone number, e-mail, national identification number, immigration and eligibility to work data, languages spoken, driving license, qualifications, references, CV and application, interview and assessment data, other data you may provide directly to us, as needed to fulfill this purpose.

Depending on the jurisdiction where the processing takes place, the processing of your personal data for these purposes is either:

·       necessary to achieve our legitimate interests of receiving applications for the education and community partnerships or is

·       based on your express consent to such processing.

In case the processing is based on your consent, you can always withdraw your consent by the means indicated when your consent is required or by using the contact details indicated in this Privacy Policy.

 

Background checks

Before your engagement with us begins, we may undertake background checks. This may include, where relevant and appropriate, reputation checks, driving license checks, identity fraud checks, criminal record checks (if and to the extent permitted by applicable laws), relevant employment history, relevant regulatory status and professional qualifications.

Title, forename, middle name(s) and surname, birth name, any additional names, gender, nationality, second nationality, date of birth, age, address, telephone number, e-mail, national identification number, immigration and eligibility to work data, languages spoken, driving license, qualifications, references, CV and application, interview and assessment data, other data you may provide directly to us, as needed to fulfill this purpose. Some of this personal data are collected from references, respectively from publicly available sources.

Depending on the jurisdiction where the processing takes place, the processing is either necessary:

·       to ensure compliance with a legal obligation incumbent to us or

·       to achieve our legitimate interests of taking the necessary measures to ensure that only suitable and appropriate applicants are selected. 

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable. 

7. If you are an employee, contractor and worker

Activity

Purposes

Categories of personal data and sources

Grounds for processing

HR administration

 

We process your personal data for managing your employment or other type of relationship with us, for the following main purposes:

·     general HR and personnel administration, payroll and benefits, expense reimbursement, travel and time-keeping, training and development, performance management, sickness and absence management, emergency contact, grievance and disciplinary procedures, equal opportunity monitoring and business continuity planning;

·     personnel planning, assignment and development, considering your suitability for any of our current or future employment opportunities, assigning you to project teams, know-how pools or other internal groups and to confirm your references, character and educational background;

·     secondment, relocation and business travel purposes, dealing with local authorities or organizations, doctors, relocation agencies, travel agents and other service providers;

·     organizational purposes, planning, controlling, budgeting, benchmarking and restructuring;

·     security purposes, maintaining and protecting our property, ensuring integrity and security of and controlling access to our premises, facilities, IT and communication systems, platforms and secured websites and applications websites and other systems or facilities (including monitoring by camera or other means of surveillance), investigating, preventing and detecting security threats, fraud, theft or other criminal or malicious activities;

·     legal documentation purposes, to ensure compliance with legal documentation and document retention obligations (such as record keeping obligations);

·     organizational compliance, in particular monitoring and assessing compliance with our policies and standards (e.g., implementing an internal reporting and case management system - Integrity Line Platform - which enables reporting of suspected misconduct related to potential breaches of applicable laws, the Holcim Code of Business Conduct and other Holcim policies and directives and conducting investigation on the reported issues in a professional, fair and independent manner)

·     regulatory compliance, ensuring compliance with our legal and regulatory obligations and requests anywhere in the world, including reporting to or being audited by national and international regulatory, enforcement or exchange bodies which may include conducting reference checks, background checks, public register checks, conflict checks, credit checks, criminal records checks (where applicable) and other due diligence as required under applicable law and regulations;

·     general compliance, ensuring compliance with legal compliance obligations, such as compliance screening or recording obligations (e.g. under antitrust laws, export laws, trade sanction and embargo laws, or to prevent white-collar or money laundering crimes), which may include checks of your contact or identity data against applicable sanctioned-party lists and contacting you to confirm your identity in case of a potential match or recording your interactions with third parties as may be relevant for antitrust purposes and

·     disputes and enforcement of claims, including supporting us in dealing with and solving disputes, complying with orders of courts, authorities or other public bodies, enforcing our contractual agreements and to establish, exercise or defend legal claims.

Title, forename, middle name(s) and surname, birth name, any additional names, gender, nationality, second nationality, date of birth, age, home contact details (e.g. address, telephone number, e-mail), national identification number, immigration and eligibility to work data, languages spoken, driving license, qualifications, references, CV and application, interview and assessment data, other data you may provide directly to us or that results in the context of our relationship.

Some of this personal data are collected from references, respectively from publicly available sources.

 

 

Depending on the jurisdiction and the specific purpose, the processing is either necessary:

·       for the performance of your agreement with Holcim,

·       for compliance with a legal obligations incumbent to us or

·       for achieving our legitimate interests.

In addition, if required by law, the processing of your personal data will be based on your consent, where you have expressly given that to us.

Our legitimate interests consist of managing our workforce and operating our business, for instance, undertaking normal business operations and maintaining a dialogue with our employees, contractors and workers, ensuring that each employee, contractor and worker undertakes appropriate duties, is properly trained and undertakes its role correctly and in accordance with appropriate procedures.

In case some of the personal data have a special regime under the data protection laws, we will process such data to the extent one or more of the guarantees prescribed by the law for processing such data are applicable. 

8. If you are a family member or a dependent of employees, contractors and workers of Holcim

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Management of emergency contact

We process your personal data to contact you in case of an emergency, in order to let you know of any accidents or issues at work suffered by our employees, contractors and workers.

Contact data provided by our employees, contractors and workers.

Depending on the jurisdiction where the employees, contractors and workers carry out their activity, the processing of your personal data for this purpose is either necessary:

·       for compliance with a legal obligation incumbent to us or

·       for achieving our legitimate interests of ensuring that our employees, contractors and workers are kept safe.

Administration of benefits

We process your personal data to provide and administer your benefits arising from your capacity as a family member or dependent of our employees, contractors and workers. Such benefits may include medical subscriptions, pension or life assurance entitlement.

Contact data provided by our employees, contractors and workers and any other data that you provide directly to us.

Depending on the jurisdiction where the employees, contractors and workers carry out their activity and according to the type of benefit provided by Holcim, the processing of your personal data for this purpose is either necessary:

·       for compliance with a legal obligations incumbent to us

·       or necessary for achieving our legitimate interests of managing our workforce and operating its business, which includes also ensuring you with access to benefits.

9. If you are a former employee, contractor and worker of Holcim

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Archiving

We process your personal data for achieving purposes.

Personal data included in the personnel file or in other documents or supports, if necessary to achieve the purpose.

Depending on the jurisdiction where you have carried out your activity, the processing of your personal data for this purpose is either necessary:

·       for compliance with a legal obligation incumbent to us or

·       for achieving our legitimate interests consisting of operating its business. 

Data processing as obligation imposed by the law

We process your personal data in order to ensure compliance with the legal obligations incumbent to Holcim in the capacity of your former employer.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose or that were processed by us during the past relationship with you.

 

The grounds for processing is the legal obligation incumbent to us.

10. If you are a shareholder holding shares in Holcim

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Manage your relationship with Holcim

We process your personal data for:

·     managing your relationship with Holcim as a company director or an office holder;

·     maintaining our group companies’ statutory registers;

·     managing compliance with any regulatory and statutory obligations deriving from our relationship; 

·     archiving and managing your directorship/office record, as appropriate;

·     creating and administrating minutes of meetings.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

 

Depending on the jurisdiction where you carry out your activity, the processing of your personal data for this purpose is either necessary:

·       for compliance with a legal obligations incumbent to us or

·       for achieving our legitimate interests consisting of operating our business, which includes managing our relationship with our directors and office holders.

11. If you are a company director or an office holder

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Manage your relationship with Holcim

We process your personal data for:

·     managing your relationship with Holcim as a company director or an office holder;

·     maintaining our group companies’ statutory registers;

·     managing compliance with any regulatory and statutory obligations deriving from our relationship; 

·     archiving and managing your directorship/office record, as appropriate;

·     creating and administrating minutes of meetings.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

 

Depending on the jurisdiction where you carry out your activity, the processing of your personal data for this purpose is either necessary:

·       for compliance with a legal obligations incumbent to us or

·       for achieving our legitimate interests consisting of operating our business, which includes managing our relationship with our directors and office holders.

12. If you are an event attendees

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Event management

We process your personal data in the context of your participation to the events organized by or with the involvement of Holcim, for the following purposes:

·     managing a database of potential guests and attendees;

·     issuing invitations;

·     managing and administering the event or conference;

·     preparing materials for the events comprising pictures, names, biopics and contact details of the attendees, if the case.

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

 

This processing is necessary for achieving the legitimate interests pursued by Holcim consisting of operating its business, which includes holding promotional or educational events.

To the extent necessary under the law, we will process your personal data based on your express consent. In this case, you may withdraw your consent by using the methods made available for each event or by using the contact details indicated in this Privacy Policy.

Taking close-up photos / video recordings

We may process your personal data in the context of taking close-up photos / video recordings during your participation to the events organized by or with the involvement of Holcim.

Photo / video image as well as other personal data you may provide directly at your own initiative.

 

In this case, we base our data processing on your consent given by your unequivocal action of entering on the designated areas marked for taking close-up photos/ making video recordings.

You may withdraw your consent by using the methods made available for each event or by using the contact details indicated in this Privacy Policy.

13. If you are a journalists and media representatives

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Management of contacts

We process your personal data in order to maintain a database of journalists and other media representatives and to communicate with you on different subjects of interest (e.g., to share updates on our business activities, performance)

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

 

This processing is necessary for achieving the legitimate interests pursued by Holcim of managing and promoting our business activities.  

14. If you are a visitor of our premises

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Management of security

We process your personal data in order to ensure the security of our premises, assets and personnel. For this purpose, we:

·     maintain a visitors' access log at all of our premises so that we have a record of all visitors to our premises;

·     operate Closed Circuit television (CCTV) systems on our premises and around the perimeter of the same (which cover also walkways and other public areas).

Name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill this purpose.

 

Depending on the jurisdiction where Holcim premises is located, the processing of your personal data for this purpose is either necessary:

·       for compliance with the legal obligations incumbent to us or

·       for achieving our legitimate interests consisting of  the protection of our premises, assets and personnel.

         

Facilitating your visit

We process your personal data in order to take the necessary actions to facilitate the purpose of your visit, for example, by providing access to our technical equipment and networks.

Name, e-mail, phone, fax, address, data resulting from the use of our technical equipment and networks, other personal data you may provide directly to us, as needed to fulfill this purpose.

 

The processing of your personal data for this purpose is necessary for achieving our legitimate interests consisting of making your visit as much as pleasant.

 

15. If you are a user of our Internet website(s)

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Visiting our Internet website

We process the personal data we collect from you when you visit our internet website, in order to ensure you the appropriate use of all functionalities available on the website, to monitor the traffic and improve the content of the website. For these purposes, we use cookies, as detailed in the Cookies Policy.

Personal data that you provided to us by filling in forms on the websites, information about your visits to the website such as traffic data, location data, and other communication data and information on the devices we used to access the website.

The processing of your personal data for this purpose is based on our legitimate interest in ensuring the proper functioning of our Internet website, as well as its improvement.

16. If you are a member of general public

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Management of communication received from members of general public

We process your personal data to receive and respond to your requests or communication and to take the necessary actions to manage the communication. 

We process your personal data to keep a record of your communication if requested by law or in case such processing is necessary to enforce or defend any legal claims made by, against or otherwise involving you.

Personal data that you provided to us within the request or communication and during the correspondence with you.

We base this data processing activity on our legitimate interest in operating our business, which include receiving and keeping records of the communications received, managing and taking all necessary measures enforce or defend any legal claims made by, against or otherwise involving you.

17. For all above categories of data subjects

Activity

Purposes

Categories of personal data and sources

Grounds for processing

Changes in structure or similar transactions involving Holcim

We may also process your data in the context of changes in structure or similar transactions involving Holcim.

Personal data processed for the initial purposes as indicated above in subsection 1-16.

In this case, the grounds for processing may be represented by:

·     the legal obligation (in case Holcim is legally obliged to disclose certain personal data to public authorities);

·     the performance of the agreement concluded by Holcim in the context of such transaction (if you are a party to such agreement) or the legitimate interest of Holcim to carry out the transaction in the most effective manner (in the rest of the cases).

II. PROVISION OF PERSONAL DATA

PROVISION OF PERSONAL DATA

When we request you to provide us your personal data, Holcim kindly asks you to provide all categories of personal data we request. 

You will be free to refuse the provision of your personal data, however if you do withhold specific data we may not be able to continue our relationship with you or otherwise provide you the services requested from us, when:

  • the processing is necessary to comply with a legal obligation or to perform the agreement to which you are a party, or
  • we shall not be able to achieve the processing purposes described above without processing such data.

 If you provide us personal data of other natural persons, we kindly ask you to communicate to them the modality in which Holcim intends to process their personal data, as described in this Privacy Policy, before such disclosure.

III. DISCLOSURE OF YOUR PERSONAL DATA

DISCLOSURE OF YOUR PERSONAL DATA

To achieve the aforementioned purposes and to the extent necessary, we disclose or we may disclose your personal data to the following categories of data recipients:

  1. other companies that are part of the Holcim group;
  2. central/local public authorities, government agencies, governmental providers of healthcare services, social security authorities and other authorities;
  3. providers of payment services;
  4. providers of analysis services;
  5. providers of IT support services, storage and hosting services;
  6. accountants, attorneys and providers legal and financial services;
  7. providers of travel and accommodation services;
  8. providers of tax and financial services, providers of benefits, payroll managers;
  9. providers of HR services;
  10. agents, consultants, contractors and other third parties that provide services to Holcim;
  11. brokers, banks, insurance agents;
  12. professional organizations (trade unions);
  13. other contractual partners of Holcim to whom data should be disclosed so that they may provide the services covered by the relevant contracts;
  14. any other individuals or entities to whom data should be disclosed upon request from you. 

We disclose your personal data to the above-mentioned data recipients:

  • if we are under an obligation or have permission to do so by law or in the context of legal proceedings, for instance to enforce a court ruling or to comply with a request made by a law enforcement agency;
  • if we deem that the disclosure is necessary or appropriate in order to prevent physical harm or financial loss;
  • in relation to an investigation into a fraudulent activity or other unlawful activity, actual or suspect;
  • if we sell or transfer our business or assets, entirely or partially (including in the event of a reorganization, winding-up or liquidation of business);
  • for other legitimate interests justified by Holcim.

IV. TRANSFER OF YOUR PERSONAL DATA

TRANSFER OF YOUR PERSONAL DATA

We transfer or we may transfer your personal data recipients located in other countries than the country where the personal data was originally collected. It is possible that such countries do not have the same data protection laws as the ones from the country where you have initially provided the personal data. In this case, we will implement appropriate guarantees, in accordance with the law, to your personal data irrespective of the countries to which they are transferred.

If you are a resident of the European Economic Area and the GDPR applies to you, we may transfer your personal data to the following Holcim Affiliates:     

Holcim Affiliate

Contact details of Holcim Affiliate

Holcim Ltd

Grafenauweg 10, 6300 Zug, Switzerland

Holcim Group Services Ltd

Grafenauweg 10, 6300 Zug, Switzerland

Holcim Technology Ltd

Im Schachen, Holderbank Aargau 5113 Switzerland

Holcim European Business Services s.r.o.

Hlavná 69/111 040 01 Košice, Slovakia

Holcim Services EMEA Digital Center

Albasanz 14, Madrid 28037

Holcim Services (South Asia) Limited

Level 3, Tower 1, Phase 2, Logitech Park Andheri Kurla Road, Andheri (E) Mumbai, Maharashtra, 400072 India

Holcim Global Digital Hub

Level 3, Tower 1, Raiaskaran Tech Park, Andheri Kurla Road, Mumbai 400072 India

V. DURATION OF THE PROCESSING

DURATION OF THE PROCESSING

We will retain your personal data for as long as is reasonably necessary for the purposes explained in this Privacy Policy. For example, your personal data is retained during your relation with Holcim, and afterwards for a subsequent period necessary for ensuring compliance with the applicable law.

VI. YOUR RIGHTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA

YOUR RIGHTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA

Right of access

Allows you to obtain confirmation that your personal data are being processed by us and, if affirmative, the relevant details of such processing activities, as well as copy of your personal data.

Right to rectification

Allows you to rectify your personal data if inaccurate.

Right to erasure

Allows you to obtain the erasure of your personal data in certain cases (e.g., if the data are no longer necessary in relation to the purposes for which it was collected).

Important! We will not be able to act on such requests in all cases, such as where the law compels us to keep data for a certain period, or where the data are necessary for a legitimate interest such as the defense of a right in court.

Right to restriction

Allows you to request us not to use your personal data in any way except to store it until another request from you is resolved, namely: (i) you have requested the rectification of the data; (ii) you have opposed the erasure of the data in the case of unlawful processing; (iii) you have required us to provide you with certain data for the defense of a right; (iv) you have objected to the data processing.

Right to object

Allows you to object to further processing of your personal data within the conditions and limits set forth by law.

Important! The law compels us to act on such requests only for direct marketing processing (e.g., if you receive emails with our informative notes, you can unsubscribe). In the other cases, we will balance our interests and your particular situation in order to make a final decision. Therefore, please explain why you object to the processing when making such a request.

Right to portability

Allows you to receive the personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another data controller.

Important! The law compels us to act on such requests only for the data previously processed based on your consent or on the performance of the contract concluded with us and only if the processing is carried out by automated means.

 

You may exercise your aforementioned rights and find out more about the processing of your personal data by sending a request to This email address is being protected from spambots. You need JavaScript enabled to view it.

You also have the right to file a complaint with the competent data protection authority.

This Privacy Policy is in force as of January 2023.

We may amend this Privacy Policy from time to time, for example, to keep it up to date or to comply with legal requirements or changes in the way we operate our business.

 

 

If you have any questions in relation to your rights or special requests with respect to your personal data, please contact our Data protection responsible – Bojana Draganić, e-mail address: This email address is being protected from spambots. You need JavaScript enabled to view it. ; telephone: +381 21 874 389; address: Trg Beočinske fabrike cementa 1, Beočin.