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PRIVACY POLICY



1. INTRODUCTION

 As a globally integrated company, Concentrix’s business processes increasingly
go beyond the borders of one country. This globalization demands not only the
availability of communication and information systems across the Concentrix
group of companies, but also the world-wide processing, sharing and use of
multiple types of information including information about an individual whose
identity is apparent (either directly and indirectly), or can be reasonably be
ascertained from the information available or likely to be available (Personal
Information).

This Policy letter sets forth the general principles which underlie Concentrix’s
specific practices for collecting, using, disclosing, storing, retaining,
disposing, accessing, transferring or otherwise processing Personal Information.


2. APPLICABILITY

This Policy applies to all Concentrix personnel, operating units, and wholly
owned subsidiaries worldwide and (as transferred and agreed) with
suppliers/business partners who must act consistently with the principles
contained in the policy. Country and industry-specific laws and regulations
shall take precedence over this policy, to the extent applicable. The
application of these principles is more particularly described in the applicable
Concentrix Corporate Instructions (and any accompanying implementation
Guidelines) relating to processing Personal Information. Please read this policy
along with the company guidelines for use and processing of Personal Information
to understand how Concentrix plans to achieve the set principles.


3. PRIVACY POLICY STATEMENT

Concentrix remains committed to protecting the privacy and confidentiality of
Personal Information of its Employees (including prospects and contractors),
Clients, Client Customers, Business Partners and other identifiable individuals
that it may receive, use, access, process, transfer or store as part of its
business. Uniform practices for collecting, using, disclosing, storing,
retaining, disposing, accessing, transferring or otherwise processing such
information assists Concentrix to process Personal Information fairly and
appropriately.

Concentrix may collect personal information from various persons as part of the
services it may render to them, or in the course of its business. Based on the
information being collected and nature of services or requirement, Concentrix
will apply suitable mechanisms to ensure that Concentrix has a lawful basis for
receiving, accessing, using, processing, transferring, storing and/or disposing
such personal information.


4. GENERAL PRIVACY PRINCIPLES

These general principles apply to the processing of Personal Information
world-wide by Concentrix.

A. Accountability:

Concentrix understands its accountability and responsibility for any Personal
Information that it may receive, use, process, store as part of its business.
 Accordingly, it will:

I. have appropriate corporate instructions, guidelines and other measures to be
able to demonstrate that Personal Information is used/ stored / processed /
retained / disposed / transferred in compliance with applicable law and other
applicable guidelines;

II. designate an individual or individuals who are accountable for the
organization’s compliance with the Privacy principles; and

III. ensure the availability of required policies, procedures and contacts for
management of personal information; these being reviewed at a minimum annually
or as and when there is a change warranted.

B. Consent, Fairness and Purpose:

Concentrix will only collect adequate, relevant and necessary Personal
Information, and will process such Personal Information fairly and lawfully for
the purposes for which the Personal Information was collected.

When collecting Personal information, the purposes, legal basis, and where
required by applicable law, the consent of the individual, will be specified and
/ or obtained upon or before its initial collection and / or disclosure as well
as before any previously collected Personal Information is Processed for a new
or different purpose.

Individuals can withdraw consent at any time, subject to legal or contractual
restrictions and reasonable notice. Upon receipt, Concentrix will inform
individuals of the implications of withdrawal.

C. Accuracy:

Concentrix will keep Personal Information as accurate, complete and up-to- date
as is necessary for the purpose for which it is processed; and provide
appropriate channels for the same.

D. Disclosure and Data Sharing:

Concentrix will make Personal Information available inside or outside Concentrix
under appropriate circumstances for business purpose only or as authorized by
law. This may require Concentrix to transfer personal information to countries
other than Concentrix operation’s country of business (including transfer to
other entities or third parties).

Concentrix will implement privacy principles for the use / processing/ transfer
/ storing/ disposal of personal information as may be prescribed under
applicable laws.

E. Cross-Border Data Flows:

When conducting business, working on Company projects, or implementing new
processes or systems, an operation may require the transfer of personal
information to other entities or third parties that are located outside of the
Concentrix operation’s country of business. While permissible data transfer
mechanisms are defined by applicable law or regulation, examples include:

i. a data transfer agreement with the party who will access or obtain the
personal information; or

ii. notice to and/or approval from a country’s local data protection authority;
or

iii. notice to and/or consent from the individual whose data is to be
transferred.

F. Security:

Concentrix will implement reasonable technical and organizational measures to
safeguard Personal Information and instruct third parties processing Personal
Information on behalf of Concentrix to process and manage it in a manner which
is consistent with Concentrix standards (for Concentrix owned information) or
Concentrix Client standards (for Client information), as may be applicable.

G. Access:

Upon request, Concentrix will, within a reasonable time, manner, and in a
readily intelligible form provide individuals appropriate access to Personal
Information retained by Concentrix. Concentrix has the right to deny the
request; however, the reasons of denial will be provided. Concentrix will erase,
rectify, complete, or amend the data pursuant to a justified request.

H. Retention and Disposal:

Concentrix will retain Personal information in a form that permits
identification for no longer than as necessary for the fulfillment of the stated
purpose, and should be disposed thereafter.

I. Transparency:

Concentrix will be transparent, and make readily available to individuals,
specific information related to management of Personal Information.

J. Custodianship:

Concentrix will follow appropriate policies and practices agreed with its
clients for the safe handling of Personal Information that it processes on
behalf of its clients.


5. ENFORCEMENT AND REDRESSAL

Concentrix will provide appropriate robust mechanisms for assuring compliance
with the Principles, and address grievance and / or provide recourse for
individuals who are affected by non-compliance with the Principles.


6. CONTACTING CONCENTRIX’S DATA PRIVACY OFFICE

If you have any questions, requests or grievances pertaining to this Privacy
Policy or other privacy matters you may contact Concentrix’s Data Privacy Office
or Lionel Thibert, Vice President, Regulatory Compliance & Privacy at
DPO@concentrix.com or at Concentrix, 39899 Balentine Dr. Ste 235, Newark, CA
94560.


ENCARREGADO DE PRIVACIDADE DE DADOS NO BRASIL

Em atendimento à LGDP, art. 41, o Diretor de Privacidade de Dados ou DPO da
Concentrix no Brasil e na América Latina é Juan Andrés Trujillo Sánchez, cujas
informações de contato são as seguintes:

Número de telefone: 57 (310)-280-3099
Endereço físico:
Endereço Eletrônico: proteccion.dedatos@concentrix.com

O DPO tem as seguintes obrigações para cumprir a LGDP:

 * tratar de reclamações e comunicações entre proprietários, prestar
   esclarecimentos e providenciar;
 * Receber comunicações das autoridades nacionais e providenciar e orientar os
   funcionários e contratados da entidade a respeitarem as práticas a serem
   tomadas em relação à proteção das pessoas;
 * Exercer outras atribuições determinadas pelo controlador ou estabelecidas em
   normas complementares.


MORE INFORMATION:

 * GDPR
 * GDPR FAQ
 * Privacy Policy – India
 * NPC Seal of Registration Concentrix CVG Malaysia (Philippines)
 * NPC Seal of Registration Concentrix CVG Philippines, Inc.
 * NPC Seal of Registration Concentrix CVG Singapore Holdings Pte Ltd ROHQ
 * NPC Seal of Registration Concentrix Daksh Services Philippines Corporation
 * NPC Seal of Registration Concentrix Services B.V. Philippine Branch
 * NPC Seal of Registration Concentrix Services Philippines, Inc.
 * NPC Seal of Registration Concentrix Services Pty Ltd ROHQ
 * NPC Seal of Registration Concentrix SREV Philippines, Inc
 * NPC Seal of Registration Encore Receivable Management, inc.




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