Data Protection Policy.

DATA PROTECTION POLICY RELATED TO UNLIMITRUST CAMPUS APPLICATIONS

Please read this note carefully. Once you have read it, by clicking on “Accept”, you are giving your consent to the Data Protection Policy specified below:

The unlimitrust Campus Applications are owned and managed by Square One SA, a company incorporated in the trade registry of the Canton de Vaud with head office located at Avenue de Florissant 41, 1008 Prilly, c/o SICPA SA.

This Personal Data Protection Policy applies to the unlimitrust Campus Applications provided through:

Square One SA (“unlimitrust”) would like to provide you with some important information in connection with “unlimitrust” Campus Applications so that you are aware of the usage made of the data uploaded to unlimitrust Campus Applications. Okta and SpaceOS are third-party service providers of Square One SA, managing credentials, accesses and information exchange via the unlimitrust Campus Applications.

Important definitions

  • Personal Data is any information relating to an identified or identifiable person which identifies the person directly (e.g. the surname and the first name) or indirectly (e.g. connection data).
  • Processing (of Personal Data) is any operation or set of operations performed on Personal Data or on sets of Personal Data, whether by automated means or not, such as: collection, recording, organization, storage, disclosure by transmission, etc.
  • The Controller determines the purposes and means of Processing.
  • The Processor processes Personal Data on behalf of and upon the instructions of the Controller.

Purpose

unlimitrust (Data Controller) collects your Personal Data for the purpose of creating credentials in Okta and SpaceOS (Data Processors) to grant you access to the unlimitrust Campus Applications and facilitate your experience of the unlimitrust campus. Data sharing and collection enables the execution of the contract between you (or your employer) and unlimitrust. The Personal Data processed is provided by you (the user) and/or imported from Okta.

What data subjects are concerned?

  • Tenants Employees and tenants Guests on site,
  • Employees and Guests of Square One SA,
  • Service providers and staff on site.

What categories of personal data are collected and processed by SpaceOS?

Your Personal Data processed by SpaceOS includes:

  • First Name*,
  • Last Name*,
  • Email address*,
  • Position,
  • Biography,
  • Location,
  • Company,
  • Social media profile links,
  • Field of work,
  • Preferred UI Language*.

*mandatory data

Your Personal Data processed by Okta includes:

  • First name,
  • Last name,
  • Email address,
  • External company’s name,
  • Business role.

Okta will only collect and process additional Personal Data when/if you register it (i.e. day and month of birth, gender, business phone number or mobile phone number, security question, geolocation).

Where and how is the data stored?

Personal Data is processed and stored on a server outside of unlimitrust campus and located in Europe. Personal Data will be transferred, for the Purpose set out in this Data Protection Policy, to Okta and SpaceOS hosting service providers.

No international transfer of Personal Data will take place.

Appropriate technical, organizational and security measures have been implemented by unlimitrust to ensure protection against unauthorized processing of Personal Data and against accidental loss of, or damage to Personal Data. In particular, unlimitrust establishes technological, physical, administrative and procedural safeguards in line with industry recognized standards to protect and ensure the confidentiality, integrity or accessibility of the Personal Data processed; to prevent the unauthorized use of or unauthorized access to the Personal Data or to prevent a Personal Data breach (security incident); this in accordance with unlimitrust rules and applicable regulations.

Who are the recipients of your personal data?

The recipient of your Personal Data are the authorized staff of Okta, SpaceOS and unlimitrust, on a need-to-know basis.

How long is your personal data stored for?

On unlimitrust Campus Applications, as well as on Okta and SpaceOS, your data, and your Guests’ data, will be stored for the entire period during which you are employed. Data will be deleted within a maximum of 3 months after your departure.

What are your rights?

Regarding the use of the unlimitrust Campus Applications, you have the following rights under the conditions provided for in the regulations:

  • The right of access, rectification and deletion of your data;
  • The right to withdraw your consent (opt out) at any time;
  • The right to restrict the Processing of your data;
  • The right to object to the Processing of your data;
  • The right to data portability;
  • The right to file a complaint with the Data Protection Authority.

You can exercise these rights by e-mail at dpo@unlimitrust.com, specifying the right you wish to exercise and attaching proof of your identity (if necessary) or a power of attorney if you are being represented.