Privacy Statement and Personal Information Collection Notice

PERSONAL INFORMATION COLLECTION NOTICE

Olam Group Limited and its affiliates world-wide (hereafter referred to as “Olam,” “us,” “we,” “our”) understand the importance of privacy to you. This personal information collection notice sets out what personal information we may collect, in support of Olam’s recruitment process and, where applicable, your initial onboarding process as an employee, including through the use of our dedicated electronic portal (the “Purpose”).

Your personal data including your name, age, occupation, professional information, other biographical, biometric information including facial recognition and/or fingerprint that may identify you (“Personal Data”) will be collected and stored by us and made accessible to our employees and partners in order to evaluate your qualifications and suitability for employment with Olam, and if employment is offered to you, in order to provide you with certain benefits and resources available to you as an employee. We ask that you hereby acknowledge the collection, use and disclosure of your Personal Data for the specific Purposes below, in accordance with this Personal Information Collection Notice and Olam’s Global HR Privacy Statement for Olam Careers and Olam Talent Hub (the “Privacy Statement”)

Personal Data Use

We will use and share your Personal Data as follows

Legal bases for processing

Assess your qualifications for employment with Olam and communicate with you during the recruitment process

We will use your education, training, qualifications, previous work history, prior Olam job application history, references, recommendations, verbal and written comments and submissions made or given during interviews and other interactions with Olam in order to assess whether you meet our qualifications for employment at Olam and we will use your contact information to communicate with you during the recruitment process or in case we want to reach out to you in future for the same.

Olam’s legitimate interest in fully assessing applications for employment to identify the right people for its business.
To comply with our legal obligations.
To enable us to perform any contract with you.
Your consent (where given and recognised as a legal basis).

Verify your qualifications, identity, and eligibility to work

We will use your biographical information including name, title, address, telephone number, personal email address, date of birth, gender, marital status, nationality, and languages spoken as well as education certificates, transcripts, and references, to verify your qualifications and identity. We will also access information displayed on LinkedIn and other social media or public forums to verify your qualifications and identity and identify any supplemental information that may inform our decision-making process. We will also use official documentation such as passports and identification cards to confirm your identity and eligibility to work.

Olam’s legitimate interest in fully assessing applications for employment to identify the right people for its business.
To comply with our legal obligations.
To enable us to perform any contract with you.
Your consent (where given and recognised as a legal basis).

Provide you with access to benefits and resources

If you are granted an offer of employment and you accept, we use your biographical information including name, photo, title, address, telephone number, personal email address, date of birth, gender, bank account details as well as official documentation such as passports, identification cards, and other licenses to provide you access to certain benefits and resources such as talent management, processing of employment visas, payroll, health insurance, and tax filings.

Olam’s legitimate interest in managing its workforce, operating its business and ensure employees are properly remunerated.
To comply with our legal obligations.
To enable us to perform any contract with you.
Your consent (where given and recognised as a legal basis).

Improve the Olam recruiting process and candidate outcomes

We will use your written and spoken feedback to assess and improve our recruiting and on-boarding processes. Where applicable, we will retain your candidate information for potential consideration of future roles, as per our Privacy Statement.

Olam’s legitimate interest in managing its workforce, operating its business and improve candidate outcomes.
Your consent (where given and recognised as a legal basis).

Security

We will use your biographical information including name, photo, title, address, telephone number, personal email address, date of birth, gender and biometric information including facial recognition and/or fingerprint data to give you access to our facilities and resources and to provide a safe working environment for our employees. We will also use your emergency contact information in case of emergencies.

Olam’s legitimate interest in managing its workforce, operating its business, ensure appropriate training and supporting the welfare of its employees by mitigating risks to health and safety and ensuring fitness for work.
To comply with our legal obligations.
To enable us to perform any contract with you.
Your consent (where given and recognised as a legal basis).

When Personal Data is shared with third parties such as our HR partners (affiliates, advisors, IT vendors) in furtherance of the Purpose and the specific uses consented to above, each of these partners would ordinarily be data processors and will have to abide by the user Personal Data as a set forth above in Paragraph 1 and as detailed in the Privacy Statement.

You may withdraw consent given, request for access and/or correction of Personal Data and/or request for information regarding our policies and practices at any time by contacting us at DataPrivacyQueriesHR@olamnet.com. While no disclosure requested is obligatory, failure to supply Personal Data and/or subsequent withdrawal of your consent may affect our ability to provide certain services that you may have separately requested from us (as the case may be). In such instances where you revoke consent, we may retain such Personal Data in order to fulfil our legal/contractual obligations to you, if any, but will not use Personal Data for any other purpose unless compelled to do so by law.

A copy of Olam's Privacy Statement is provided for your reference below. The Privacy Statement explains how we handle and protect Personal Data. While your Personal Data will be shared with the persons indicated above, your Personal Data that is held by us will be kept confidential and will be stored in accordance with applicable privacy laws.

In certain jurisdictions, consent may not always serve as the sole or primary legal basis for processing your Personal Data in certain circumstances, such as when processing the Personal Data of employees. However, in all jurisdictions, all Personal Data set forth and requested here in Paragraph 1 is processed for our legitimate business needs and purposes and/or to enable us to comply with our contractual obligations to you (as applicable). If this applies to you, by clicking “Agree and Continue” below, you acknowledge you understand the bases on which we collect and process your Personal Data.

If you have any questions or concerns or do not consent to the collection or processing of any or all of your Personal Data for the Purposes stated, please do not enter the portal before speaking to your Olam recruitment or HR contact at the given email address.

Global HR Recruitment Privacy Statement

Olam respects the privacy of our candidates for employment. This privacy statement makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise and/or, where applicable, the initial on-boarding process if you become an employee.
Olam Group Limited and the relevant Olam entity in the respective country as applicable, you applied to or becomes your employer, will be the data controller. Olam Group Limited operates as parent company for all Olam legal entities. This privacy statement does not replace or substitute any other local privacy statement or policies applicable to the collection of personal data outside of the recruitment or initial employee onboarding processes.

Data protection principles

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that is explained below, and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

The kind of information we hold about you

The information you have provided to us in your curriculum vitae and cover letter.
Your biographical information including name, title, address, telephone number, personal email address, date of birth, gender, marital status, nationality, and languages spoken.
Recruitment related data such as education and training, qualifications, previous work history, prior Olam job application history.
Background data such as references, vetting and verification information, and information displayed on LinkedIn and other social media or public forums.
Feedback information such as your feedback and opinions (e.g. surveys) on the recruitment process.
Any other information you provide to us during an interview or through emails or on other application materials.

Emergency contact information in case of emergencies;
Specific bank information to process payroll;
Passport details to confirm identity and employment eligibility for immigration and travel purposes;
Family/dependent details for employee benefit purposes;
National ID information, driver’s license, ID card to confirm identity and employment eligibility;
Your photo for security and employee directory and organizational chart purposes;
Education certificates to verify education history;
Birth certificate of children for dependent proof for tax purposes, employee benefits and immigration purposes;
Marriage certificate for marriage proof for tax purposes, employee benefits, and immigration purposes.
Your biometric information including facial recognition and/or fingerprint to provide office access.

In certain circumstances we may process personal data of third parties provided by you, such as references. Before you provide data relating to third parties to us, you should ensure you are permitted to do so and provide them with the information contained in this notice.
We may also collect, store and use information about your health, race or ethnicity, religious beliefs or sexual orientation known as "special categories" of more sensitive personal information to the extent this information is volunteered to us and subject to any local employment law or privacy requirements.

How is your personal information collected?

You sharing it with us through applications, online portals, emails, interviews, meetings or written submissions as part of the recruitment or initial employee on-boarding processes.
The recruitment agency where you have applied or an Olam contact.
Background check provider including criminal background check, if applicable.
Data from publicly accessible sources.
We may also obtain some information from other third parties, for example, references from a previous employer, tax authorities, benefit providers, your named references, credit reference agencies.

How we will use information about you

Assist in recruitment planning, including creation of your profile in the Olam Talent Community.
Assess your skills, qualifications, and suitability for work for roles you apply for, or for other suitable positions we may notify you about in future.
Carry out credit, background and reference checks, where applicable.
Communicate with you about the recruitment process.
Keep records related to our hiring processes.
Comply with legal or regulatory requirements.
Comply with our workplace safety measures.
Improve business processes, including reviewing our recruitment processes and tools.
Process payroll and employee benefits.
Process immigration and work permissions.
Process tax obligations.
Onboard your details if you become an employee so that we can administer any contract we enter into with you, and comply with applicable employment law.
Provide you access to our office premises once you become an employee.

It is in our legitimate interests to decide whether to appoint you for work since it would be beneficial to our business to appoint someone for that work. We also need to process your personal information to decide whether to enter into a contract with you.
If you become an employee, we will need to process your personal information to keep our employees safe and to provide you with benefits and resources for you to succeed in your role with us.

If you fail to provide mandatory personal information

How we use particularly sensitive personal information

We will use your biometric information to provide you to access to the office premises.
We will use information about your health/disability status to consider whether we need to provide appropriate accommodations during the recruitment process, or for the purposes of employment, for example whether adjustments need to be made during a test or interview or for the purposes of being able to carry out the relevant role.
We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting (where applicable and required).

the processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or us in the field of employment law, social security and social protection law, to the extent permissible under applicable laws;
the processing is necessary for reasons of substantial public interest;
the processing is necessary to protect your vital interests or of another person where you are physically or legally incapable of giving consent (for example in exceptional situations such as a medical emergency);
the processing is necessary for the establishment, exercise or defence of legal claims; or
we obtain your consent to certain processing. You should be aware that without prejudice to the above paragraph concerning failure to provide mandatory information, it is not a condition or requirement of your application to agree to any request for consent from us.

Information about criminal convictions

We may be legally required to carry out criminal record checks for those carrying out work. The role is eligible for a check as per the local laws of the region where you have applied.
The role requires a high degree of trust and integrity and so we would like to ask you to seek a basic disclosure of your criminal records history.

Where required by applicable law, we will seek your consent separately and/or comply with applicable local laws before processing any criminal record check data.

Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing

Whom we may share your personal information with

Respective Olam teams depending upon the geographical area that you have applied or, if you become an employee, on the global businesses in which you perform your work;
Other third-party service providers such as agencies that conduct online tests, IT support, insurers, bankers, etc. who provide services necessary for the purposes mentioned in this privacy statement.

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes as mentioned in this notice and in accordance with our instructions.
We may be required to disclose certain personal information to other third parties, including but not limited to regional governmental authorities (1) as a matter of law (e.g., to tax and social security authorities); (2) to protect our legal rights; (3) in an emergency where your health or security of is endangered; or, (4) for any other purpose required by applicable laws.

Overseas transfers
The information you provide here may be shared for recruitment purposes with one or more of Olam companies throughout the world (including Olam Shared Service Centers) each of which is an independent legal entity and is acting as data controller. This means that the information you provide here may be accessible by Olam companies outside of the country in which you are located. In some cases, the local laws regarding data protection will not necessarily be as strong as they are in the country in which you are located. However, we will ensure that if information is transferred outside your country of residence it will still be treated in accordance with this Privacy Statement. Where your personal information is transferred outside the EEA to an Olam affiliate or an entity in a country that is not subject to an adequacy decision by the EU Commission, your personal data will be protected by EU Commission approved cross-border safeguards including standard contractual clauses for cross-border data transfer.

Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will we use your information for?
Olam will retain your personal information for no longer than is necessary for the purposes for which the data was collected and in accordance with our internal retention policies and procedures. How long we keep your personal information will vary and will depend on the purpose and use of information collected. There are also legal requirements that we keep some types of data for specific periods of time. We also retain your personal information so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. We may securely retain your candidate profile and recruitment information so we may contact you again if another suitable position arises. We will securely destroy your personal information in accordance with our internal retention policies, unless you contact us to agree a different duration.

Your rights in connection with personal information
Under certain circumstances, by law, and subject to our legal rights and obligations, you have the right to:
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party in a machine-readable format.
Right to withdraw consent given by you. This enables you to withdraw your consent for processing your information for the purposes of the recruitment exercise
Right to Complaint to a Supervisory Authority: You have the right to lodge a complaint with an applicable supervisory authority.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, restrict the use of information, request that we transfer a copy of your personal information to another party or withdraw your consent, you may write us at: DataPrivacyQueriesHR@olamnet.com or telephone on: (+65) 6339 4100.

General
Your data will not be sold to any third party or Olam entity. In a case where your data is collected or processed in a jurisdiction that requires additional controls with respect to processing of personal information (apart from the controls mentioned in this statement), the respective Olam entity will ensure compliance to the relevant requirements.

GDPR: Additional information

Where GDPR/UK GDPR is applicable and you are in the EU/UK, and/or where a data controller is an Olam company established in the EU/UK, then:

Legal Basis for Processing

We will not process personal data without having a lawful reason to do so. All of the information we collect from you in the recruitment and on-boarding processes, as set-forth above, is done so on the basis of our legitimate interest or those of third parties, subject to any of your overriding rights or interests. In some instances, there may be multiple bases for processing your information such as legitimate interest, your consent, in order to perform under a contract with you, or as required by law.

Your Rights

The law gives you certain rights in respect of the information we collect from you. Among these rights, you have the right to ask us for a copy of your personal data, to verify, correct, or restrict (stop any active) processing of your personal data. In addition, you can object to the processing of your personal data in some circumstances (namely, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
ou have choices about the personal information you provide Olam. You may choose not to provide information that we request, but if you do so, we may not be able to provide you a relevant service or a particular feature for an Olam website, app, or product. If you want to exercise or inquire as to any of these above-mentioned rights, you can email us at the address below.
In your email, clearly state your request and specify the Olam website or app your request refers to and we will direct your request to the appropriate data controller. If you have unresolved concerns, you have the right to complain to an appropriate data protection authority where you live, work or where you believe a breach may have occurred.

Email: DataPrivacyQueriesHR@olamnet.com

Data Controller

Olam Group Limited and the relevant Olam entity in the respective country as applicable. you applied to or becomes your employer, will be the data controller. Olam Group Limited operates as parent company for all Olam legal entities. You can email us at DataPrivacyQueriesHR@olamnet.com for further information including appropriate contact information for your relevant data controller.

As explained above, we will share your personal information for certain specified purposes. Where your personal information is transferred outside the EEA to an Olam affiliate or an entity in a country that is not subject to an adequacy decision by the EU Commission, your personal data will be protected by EU Commission approved cross-border safeguards including standard contractual clauses for cross-border data transfer.

Additional Information for California Residents

Your Rights

California residents may have, pursuant to the CCPA, the following rights with respect to your personal information with Olam, which apply differently in different circumstances: right to access, right to information, and the right to deletion. Olam does not and will not sell personal information. Most of these rights are not absolute. We will not discriminate against you or deny products or services from you for exercising any or all of these rights. For more information or to exercise any of these rights, you may contact us at DataPrivacyQueriesHR@olamnet.com.

Or you may write to us at:
Olam Americas, Inc.
205 East River Park Place
Suite 310
Fresno, CA 93720

Toll-free number (USA): (833) 718-1023

Our Data Collection Activities in California

We have set out below categories of personal information we collected about California residents in the preceding 12 months and, for each category of personal information collected, the sources of that information, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared the personal information.

Section	Category of personal information	We collected such personal information to use for the following business or commercial purposes:	We have collected such personal information from the following categories of sources:	We shared such personal information with the following categories of third parties:
1	Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Clients/job applicants/other third parties To manage our business operations and administer our client relationship. To provide relevant marketing to you (e.g. information about events or services that may be of interest. To address compliance and legal obligations (e.g. checking identity of new clients, prevention of fraud/money laundering). To consider individuals for employment and contractor opportunities and manage on-boarding procedures. Employees Administering and providing compensation, benefits and other work related allowances. Administering the workforce (e.g. managing work activities, performance evaluations and promotions, preparing corporate organisation charts, managing entity and intra-entity staffing and team management, managing and monitoring business travel, carrying out workforce analysis, talent management and career development, managing employee leave, succession planning, providing employment references, administering ethics and compliance training, facilitating and providing services for the re-location and movement of employees and their families locally and internationally. Complying with employment law obligations. Communicating with employees and their designated contacts in the event of an emergency. Responding to legal and/or regulatory requests for information. Complying with corporate financial responsibilities (audit, accounting and tax requirements). Managing corporate information technology (e.g. IT support, corporate directory, IT security). Conducting security screenings (to the extent permitted by law)	From the data subject, our affiliates, counterparties to transactions or disputes with the data subjects, employers, agents or professional advisers authorised to disclose data on behalf of the data subject and from other publicly available or subscription based sources.	Our affiliates. Suppliers and service providers where necessary to perform functions on our behalf (e.g. infrastructure/IT services providers, providers of services relating to client intake, global travel, finance, customer relationship management, business analytics and marketing and conference and event hosting). Financial institutions (for invoicing and payment). Corporate purchasers - as part of any sale of company assets, transition of service to another provider or in the event of insolvency, bankruptcy or Mandatory disclosures and legal claims (e.g. to comply with any subpoena, court order or other legal process or to comply with any regulatory, governmental or other legally binding request).
2	Any categories of personal information described in subdivision (e) of Section 1798.80: “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.”	See section 1 above.	See section 1 above.	See section 1 above.
3	Characteristics of protected classifications under California or federal law (classes include race, color, religion, national origin, sex (including pregnancy, childbirth, and related medical conditions), disability, leave, age, citizenship status, genetic information, ancestry, breastfeeding, marital status, gender identity, gender expression, sexual orientation, medical condition including AIDS/HIV, political activities and affiliations, military and veteran status, and status as a victim of domestic violence, assault, or stalking).	Solely as strictly necessary for the purposes described in section 1 above regarding employee data and as otherwise required in connection with managing the employment relationship (e.g. sick leave, sick pay, accidents at work, other employment related claims, accommodating disability within the workplace, maternity leave, etc.). Solely to the extent required to comply with the firm's legal or other best practice obligations (e.g. AML, equality laws, monitoring diversity and inclusion, etc.).	See section 1 above.	Affiliates. Suppliers and service providers where necessary to perform functions on our behalf. Mandatory disclosures and legal claims (e.g. to comply with any subpoena, court order or other legal process or to comply with any regulatory, governmental or other legally binding request).
4	Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	See section 1 above.	See section 1 above.	See section 1 above.
5	Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.	To make our website more intuitive and easy to use. To protect the security and effective functioning of our website.	Via the our website.	To our service providers to the extent necessary for the provision of IT services on our behalf. Affiliates
6	Audio, electronic, visual, thermal, olfactory, or similar information.	Audio/visual - where required for legal/regulatory reasons.	Conference calls and video conferences with clients and other third parties.	Affiliates. To our service providers to the extent necessary for the provision of IT services on our behalf. Mandatory disclosures and legal claims (e.g. to comply with any subpoena, court order or other legal process or to comply with any regulatory, governmental or other legally binding request).
7	Professional or employment-related information.	See section 1 above in relation to employees and job applicants.	See section 1 above in relation to employees and job applicants.	See section 1 above in relation to employees and job applicants.
8	Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).	See section 1 above in relation to employees and job applicants.	See section 1 above in relation to employees and job applicants.	See section 1 above in relation to employees and job applicants.

Additional Information for Residents of Nevada

Pursuant to Nevada Revised Statutes Chapter 603A, residents of Nevada may have the right to opt-out of the sale of their personal information, however Olam does not and will not sell personal information. We will not discriminate against you or deny products or services from you for exercising these rights. For more information or to review and make any changes to your personal information, or to exercise any of your rights, you may contact us at DataPrivacyQueriesHR@olamnet.com.

Changes to this policy

We reserve the right to update this policy from time to time by posting the updates to this policy on our website or app. Any updates will become effective immediately after posting and will apply to all information collected about you, or where required, upon your consent. You are free to decide whether or not to accept a modified version of this policy. If you do not agree to the modifications, you must cease further use of our website or app.