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DATA PRIVACY POLICY

This Data Privacy notice is provided to comply with the Federal Law on the Protection of Personal Data in Possession of Private Parties (the “FLPPDPPP"). 

1. Identity and domicile of the responsible company

OPEN ALLIANCE SOLUTIONS, S. DE R.L. DE C.V. ("Company" or "we"), a company with address located at Bosque de Ciruelos #180, PP 101, Colonia Bosques de las Lomas, Delegacion Miguel Hidalgo, C.P. 11700 in Mexico City, is responsible that the personal data related to the Company's candidates and/or employees is processed and protected in accordance with the principles and measures established by the FLPPDPPP, its Regulations and any other applicable provisions. This Data Privacy Notice pretends to provide information to our candidates and/or employees ("candidates", "employees" or "you") about the privacy policies and practices in the Company and the rights to which you 
are entitled.  

2. Data we obtained from you

For the purposes of this Data Privacy Notice, the Company may obtained from you  the following  personal data: 

  • a. Identification data: First and last names, date and place of birth, age, nationality, Unique Population Registration Number ("CURP"), Federal Taxpayer's no ("RFC"), gender and official identification, among others, that allow the identification of an individual.  
    b. Academic Data: This information includes academic history (which may include professional degree and level of education, among others.) 
    c. Contact data:  domicile, email account and home and mobile numbers. 
    d. Employment data: Employment experience, salary/benefits and cause of termination.  
    e. Health data: Consists on information related to your current and past health condition, and the results of medical tests or toxicological tests applied to  you.  
    f. Union affiliation data: Consists on information related to your affiliation to a union.  
    g. Electronic records: Consist on data (images, sounds, voice and computer records) obtained through our systems, platforms and monitoring applications and surveillance systems. 
    h. Financial and proprietary information: These data include bank account numbers, information related to pension plans and insurances necessary for Company to comply with its obligations with you.  

It is important to mention that the data referred in section "e" and "f" above is considered by the FLPPDPPP as "sensitive personal data". Therefore, the Company requires your express consent to obtain process and transfer this data. 

I agree that my sensitive personal data is used in accordance with the purposes of this Data Privacy Notice.  

DATA PRIVACY POLICY (CONTINUED)

Moreover, the Company will request to you to provide contact and identification information of their relatives or of a third party as contact in case of emergency. In view of the above, please make sure that the data of third parties is accurate, complete correct, and it is updated. 
 
3. Means through which we obtain your personal data
 
The Company may obtain your personal data through the following means: 
  • Personally from you during the hiring process and during the term of the labor relationship.  
  • Directly for the holder, through our internet, by mobile, monitoring systems and video surveillance and computer platforms and applications of the Company. 
  • Indirectly, through reports and information that are delivered by companies we hire to carry out tests and exams of different nature to you, or when we obtain data that is stored in sources of public access. 
4. Purposes for which the Company processes your personal data
 
The Company processes your personal data for the following purposes: 
  • a. For purposes of selection and recruitment 
    b. For the proper administration of the labor relationship, including for conforming and maintaining an updated version of your file and to pay salaries and benefits
    c. For the administration of life and medical insurances
    d. To identify your capabilities, abilities, and labor skills and evaluate your  professional performance
    e. To monitor the use given by the employees to the workplace, information, and communication infrastructure of the Company and the equipment that the Company delivers to the employee, or those devices property of the employee that the Company allows the employee to connect to the Company's network; the monitoring is carried out in order to protect our computer systems, asset, property, and safety of the Company and its employees (including the integrity, labor conditions and assets of our personnel)
    f. To verify and audit the fulfillment of our employees to our internal policies, including: (a) make sure that our employees have the proper health condition to provide their services; (b) carry out internal investigations and audits related to compliance, quality and misconducts and illegal conduct within the Company, among others
    g. To confirm the activities carried out by our employees are performed with the necessary care and attention in order to avoid any accidents for the Employee or coworkers. 
    h. To manage the necessary activities to comply with labor and social security obligations.  
5. Transfer of personal data
 
The Company may communicate or transfer your personal data to different entities, for the purposes referred herein. This transfers are carried out to the extent they are necessary for the maintenance or fulfillment of the labor relationship between the Company and you It is important to mention that any of the following transfers may be made on a national or international basis. 
  • a. Data Remissions- The Company may remit the total or partial of your personal data to the service provider that supports the Company in any process. These providers include, for example: (i) companies that provide a service related to processing of information or data; (ii) companies or laboratories that carry out psychometric, psychological, medical, toxicological clinical tests, among others; (iii) firms that provide accounting, legal, tax, and immigration services; (iv) insurance carriers and agents; before transferring information to providers, we make sure to execute the necessary agreements with them, in such a way that they are obliged to protect your personal data. 
    b. Transfer of personal data to our affiliates- As long as the Company is part of an international corporate group, the personal data of employees may be communicated or transferred to other entities of the same corporate group, established either in Mexico or abroad. Our affiliates make reasonable efforts to implement the necessary measures and policies to protect the personal data of our employees; these policies are consistent with our policies and are designed to comply with the provisions of the data protection laws in each country. 
    c. Transfer of personal data to third parties-
      In some cases, your personal data may be communicated or transferred to third parties different from the above mentioned; we will only transfer your data whenever we obtain your consent or whenever it is necessary to transfer it in accordance with Article 37 of the FLPPDPPP. You  specifically agree for your personal data to be transferred to third parties in the following cases: (i) whenever the Company has to transfer your data to the competent authorities, including social security, fiscal, labor, judicial authorities, among others; (ii) to the insurance carries, banks, and other companies whenever they result necessary to fulfill with contractual and legal obligations;  (iii) when the data needs to be transferred to a third party in the context of a corporate transaction (including mergers, acquisitions, among others). In these cases, the companies that may receive your information are the potential acquirers and advisors (legal, accounting and financial advisors, among others), who participate in the transaction. We will only communicate your personal data to third parties whenever such information is necessary to evaluate and complete the transaction (i.e. to facilitate a proper employer substitution).  
6. Your ARCO Rights
 
You will have, at all time, the right to request the Company the access to their personal data and/or the rectification of the same; Moreover, you may request that your personal data be cancelled, to oppose to the treatment given by the Company for specific purposes, and/or revoke the consent given by you to treat your personal data for a specific purpose (the "ARCO Rights"); please consider that your ARCO Rights are subject to the limitations foreseen by the law. To exercise your ARCO Rights, you must deliver your request to the Company by email to the following email address mark.carberry@kiewit.com. This email address is also habilitated so you can ask questions and give complaints to the Company related to their privacy rights.  
 
In the event you decide to exercise your ARCO Rights, our personnel may inform: (i) the information that you must provide to verify your identity or the faculty of your representative, and the information and documentation that must be delivered together
with your request; (ii) the time will take to provide a response to your request; (iii) the way you must file your request, including the format, if  there is one available; and (iv) the method or means of reproduction used to make available the information requested (usually will be simple copies or electronic documents). 
 
7. Options available to you to revoke your consent, limit the use and disclosure we made to your personal data
 
If you desire to revoke your consent previously granted for the processing of your personal data or limit the way in which we use or disclose your personal data in a particular way, please contact us to the email address referred here above.  
 
8. Safety measures
 
The Company will adopt the necessary safety, technical, administrative and physical measures in terms of the FLPPDPPP, to 
protect your personal data.  
 
9. Modifications to the Data Privacy
 
The Company may modify this Data Privacy Notice at any time. The new version of the Notice will be published in the intranet and/or visible spaces within the premises of the Company and/or will be sent to you by email or other internal method of communication. The modification of this Data Privacy Notice will be in effect the following day in which the new version is published or is sent. Each version will contain the date of the last update, so you can identify that the policy has been amended or updated. In the event you disagree with such modifications, please contact us to the referred email address. 
 
I have read and consent the processing of my personal data in accordance to the purposes and/or transfers herein included.