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Safran Employees Privacy Statement (California)

This privacy statement describes how SAFRAN collects and uses personal information about SAFRAN’s current, former, permanent and temporary employees, contractors and job applicants for use solely in the employment context. This Privacy Statement applies to the following SAFRAN entities: Safran Cabin Inc., Safran Cabin Materials, LLC, Safran Ventilation Systems USA, LLC, Northwest Aerospace Technologies, Inc., Greenpoint Technologies, Inc., and MAG Aerospace Industries LLC. “Personal information” means information that identifies, relates to, or is reasonably capable of being associated with a particular individual or household. We take the privacy of your Personal Information seriously. Please read this Privacy Policy as it includes important information regarding your Personal Information.


SAFRAN may collect your personal information from a variety of sources, including directly from you when you voluntarily provide it or when prompted by us, automatically when you interact with us, and/ or from third-party sources.


How we use your personal information
We use the personal information that we collect about you solely within the context of your employment relationship with us, including the following purposes:
– process employment applications (e.g. verify employment history, qualifications, experience, and references);
– administrative management of personnel, pay and benefits (e.g. recruitment, mobility, pay, project, program and performance management, career management, learning management, attendance time, private health insurance, retirement, life insurance, employee savings scheme, workers compensations, emergency management, reporting, digital safe, dispute management);
– provide secured IT tools including messaging, instant messaging, internet, phone and mobile phone, printing system, management of the Intranet (Insite et Inshare) and creation of the employee’s profile
– Creation of an account of different applications at Group or Company level
– perform our obligations and exercise our rights under the employment or other contract with you;
– provide services you request from us;
– comply with legal obligations to which we are subject including verifying identities and legal work status, and detecting fraud, and employment-based immigration sponsorship;
– comply with federal, state or local law, regulatory inquiries or reporting requirements, or subpoenas exercising or defending legal claims;
– engaging in the interactive process to determine reasonable accommodation (e.g. for disability or religious accommodations) and/or investigations in connection with employee grievances or complaints;
– complying with audit requirements (internal or legally-required);
– conducting a disparate impact analysis associated with business needs;
– protect and secure our personnel and rights and those of others;
– protect and secure our goods, property and information systems;
– to otherwise fulfill or meet the reason for which the information is provided.

Information SAFRAN collects
The categories of information SAFRAN may collect about you are such as the following:
– personal details (e.g. name, surname, maiden name, age, date of birth, gender, Social Security Number (SSN), government-issued identification, citizenship, signature);
– contact details (e.g. phone number, email address, postal address);
– family contact personal details (e.g. emergency contact details);
– financial information (e.g. salary amount, bank details, benefit details, tax payment details);
– insurance information (e.g. medical insurance numbers and coverage, claims information);
– other information about you and your family (e.g. marital status, family status, demographic information, immigration status, medical information);
– educational and career background (e.g. your curriculum vitae, experience information, references, skills, compliance and training records, aptitude testing results);
– employment details (e.g. job title, employee number, employment history);
– biometric information (when required for purposes of security and employee timekeeping records);
– information regarding usage of our IT services and networks (e.g. browsing history when using our devices);
– geolocation information (e.g. when you use a company-provided phone);
– other relevant information needed for your job application or employment with us (e.g. job location, professional memberships, work accommodations, etc.);
– protected classification or characteristics under California or federal law (e.g. age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information);

Disclosure to third parties
Safran may share some of your collected Personal Information with its service providers for the limited and specified business purposes set forth herein.

SAFRAN may share some of your collected Personal Information with outside counsel in order to exercise or defend legal claims. Except otherwise required or allowed by law, we do not share, sell, use, or otherwise disclose your Personal Information for any non-employment related purposes.

PROCEDURE
SAFRAN has a Group Personal Data Protection Policy and a Group procedure GRP-0169 “Personal data protection management” that are used to establish rules applicable to the companies and to provide reasonable assurance that Group companies comply with the General Data Protection Regulation (GDPR) and other applicable local regulations such as the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). The documents are available at the following links:
- Group Personal Data Protection Policy:
https://insite.collab.group.safran/Group-wideFunctions/DataProtection/Documents/Politique%20_Protection_Donnees.pdf
- GRP-0169 "Personal data protection management”: https://onesafran.collab.group.safran/SAFR/Lists/ApplicableDocuments/000377.pdf

RIGHTS OF PERSONS CONCERNED
You have rights of access, correction, deletion, limitation, minimization, portability and information on your personal data. Your rights may be exercised by contacting the Safran personal data protection officer at: dpo.sca@safrangroup.com. Your identity will be subject to verification before any modification is made to the Personal Information. We will consider and respond to all requests in accordance with applicable law. You have the right not to be retaliated against for exercising these rights.

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We may retain Personal Information for an additional period as is permitted or required under applicable laws and regulations. Even if we delete your Personal Information it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

HOW WE STORE YOUR PERSONAL INFORMATION
We may store Personal Information itself or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy. We take all reasonable and appropriate measures to protect the Personal Information collected from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration and destruction. These measures take into account the risks involved in the processing and the nature of the Personal Information. To help maintain the security of your data, we use administrative, physical, and technical safeguards. These include utilizing policies to take reasonable precautions to (a) securely and confidentially maintain your Personal Information; (b) assess and protect against threats and hazards to the security or integrity of such data; and (c) prevent unauthorized access to or use of such data. Also, except where required or allowed by law, we limit use of your Personal Information to the minimum necessary to accomplish the purposes for which that data was collected and to be used as described here. We restrict access to your Personal Information to only those who need to access it to accomplish those purposes.

You, and regulatory bodies, will be alerted immediately upon any detection of a significant breach or security incident that impacts the use of your Personal Information.

CHANGES TO THIS STATEMENT
SAFRAN reserves the right to change this Privacy Policy from time to time. We reserve the right and sole discretion to update or modify this Privacy Policy at any time (collectively, "Modifications"). Modifications to this Privacy Policy will be posted to the Site with a change to the "Updated" date at the bottom of this Privacy Policy. In certain circumstances SAFRAN may, but need not, provide you with additional notice of such Modifications, such as via email. Please review this policy periodically, and especially before you provide any Personal Information.