Privacy Policy

SCOPE

This privacy policy (“Policy”) applies to the collection, use, and disclosure of personal information by Sykes Enterprises, Inc., or any of its subsidiaries or affiliates (“SYKES”) when you use our Web sites operated by SYKES that link to this Policy (the “Sites”), and the services associated therewith. This privacy policy applies to all personal information received by us in the United States originating from the United States or from the European Economic Area, in any format, including electronic, paper or oral. Please take a moment to read this Policy to learn more about our information practices. When you use the Sites you are interacting with a United States based company.

CHANGES TO THIS POLICY

We reserve the right to change the provisions of this Policy at any time by posting the revised Policy on the Sites and indicating on the Policy the date it was last updated. We encourage you to review this Policy whenever you visit our Sites to determine if any changes have been made and to make sure that you understand how personal information you provide will be treated.

PERSONAL INFORMATION

As used herein, the term “personal information” means information that specifically identifies an individual (such as user’s name, address, e-mail address, telephone number or other identifier that permits the physical or online contacting of a specific individual) or that is associated with an identifiable person (such as demographic information or information about a person’s activities when such information is linked to personally identifying information). Personal information does not include “aggregate” information, which is data we collect about the use of the Sites or categories of Sites users, from which any personal information has been removed. We collect aggregate data for a number of purposes, including helping us understand trends and user needs so that we can better consider new publications, products and services, and tailor existing publications, products and services to user desires. This Policy in no way limits or restricts our collection of aggregate information.

COLLECTION OF PERSONAL INFORMATION

We may collect personal information in a number of ways when you visit our Sites or use the various services available on our Sites. We may collect certain information you voluntarily provide to us which may contain personal information. For example, if you register for the Sites, we may collect your name, address, email address, telephone number, date of birth, and city and country and we may collect other demographic information that you provide. Personal information may also be collected in connection with leaving comments, posting content, sending an email or message to another user or participating in any interactive areas or features on the Sites. The collection of personal data is done solely for normal business operations and as part of supporting our clients where appropriate.

In addition, from time to time we may collect demographic, contact or other personal or demographic information you provide in connection with your participation in surveys, contests, promotional offers and other activities on the Sites. The information we collect from you is provided by you voluntarily, although if you choose not to provide information, your access to and participation in certain services, features, or activities on the Sites may be restricted.

We may also receive information from third parties with whom we have business relationships. If we combine this information with the other personal information we have collected from you, this Policy governs our use and disclosure of such information.

SPECIAL NOTICE REGARDING CHILDREN

Our Sites are not designed for, nor do we knowingly collect, personal information from children under the age of 13. If you are under 13 years of age, please do not provide your personal information to us.

USE OF COOKIES, IP ADDRESSES AND WEB BEACONS

The Sites may contain “cookies.” A cookie is a piece of data that is stored on your hard drive and records your preferences and other data

about your visit to the Sites. If we combine cookies with or link them to any personally identifiable information, we will treat this information as personal information; otherwise it is treated as and used in the aggregate. Most internet browsers will allow you to erase cookies from your hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. If you block cookies, some portions of the Sites may not function properly, and some features of the Sites may be slowed down or less efficient.

USAGE AND DISCLOSURE OF PERSONAL INFORMATION

In general, we use personal information we collect to facilitate your use of the Sites, to provide you with information, products and services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to administer and assist us with the operation of the Sites and of our business, to conduct business analytics to understand trends, identify efficiencies and promote quality assurance. For example, we may use the information we collect to:

• contact you about your use of the Sites, such as for administrative purposes or to provide you with customer service;
• provide you with the services, products or information you requested;
• respond to your emails, submissions, comments, requests or complaints;
• contact you about our products, services, activities, events, promotions or offers and for other marketing, informational, product development and promotional purposes;
• request feedback and to enable us to develop, customize and improve our information and services; and
• enhance compliance with the policies, rules, and other agreements governing the Sites in order to protect the online community and the overall integrity of the Sites.

SHARING OF PERSONAL INFORMATION

If we collect any personal information, we share and disclose such personal information only as described in this Policy (as amended from time to time). We may share personal information with third party vendors, consultants and other service providers who are engaged by or working with us in connection with the operation of the Sites or performing any services on our behalf. For example, we may use a third party to screen certain content before it is posted to, or to remove postings from, the Sites. In addition, we may offer various features through a third party service provider. When you use these services, you are providing information directly to the provider of these services, and the provision of such information is subject to such party’s own privacy policy. We are not responsible for any information you provide to these parties directly, and we encourage you to become familiar with their practices before disclosing information directly to such third parties with which you come into contact.

We also may disclose personal information when we are required to or we believe it is appropriate to comply with the law (e.g., a lawful subpoena, warrant or court order); to enforce or apply this privacy Policy or our other policies or agreements; to initiate, render, bill, and collect for amounts owed to us; to protect our or our customers’ rights, property or safety; to protect our customers from fraudulent, abusive, or unlawful use of our Site; or if we believe that an emergency involving the danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of personal information. In addition, information about our customers, including personal information, may be disclosed or transferred as part of any merger, acquisition, debt financing, sale of company assets, as well as in the event of an insolvency, bankruptcy or receivership in which personally identifiable information could be transferred to third parties as one of the business assets of the Company.

The Sites may contain links to other sites, or other interactive forums hosted by a third party. Please be aware that although we may participate in or utilize such other sites, we are not responsible for the privacy policies or any other practices of such other sites. We encourage you to be aware when you leave our Sites and to read the privacy policies of any Web site that collects personally identifiable information. Similarly, if you entered the Sites through a link on another Web site, we are also not responsible for the privacy practices of that site, and you should review the privacy policy of the originating site before providing any personal information to that site. This Policy applies solely to information collected by us.

ONLINE COMMUNITIES

The Sites may include certain online communities and other interactive features, such as user profiles, forums, message boards and chat rooms. You may be asked to choose a user or member name in order to participate in certain features of the Services, which will be available to the general public while you participate in some features of the Services, such as the online communities. We recommend that you not use your real name or other personally identifying name. Information you post in such public areas of the Sites is publicly available and may be viewed by and shared with other users. You can restrict user access to certain information through the privacy preferences setting on your account. However, although we strive to use commercially reasonable efforts to implement these privacy preferences, no system or security measure is perfect or impenetrable. You should always be cautious when giving out personal information to others in public online forums. We are not responsible for protecting such information that you may disclose to third parties through the Sites (e.g. sending your contact information to another user through the chat service).

PROTECTING PERSONAL INFORMATION

We strive to protect personal information while it is under our control. Your account information is accessible online only through the use of a password. To help protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of, and acts on the Sites by any person using your password. Please advise us immediately if you believe your password has been compromised or misused.

CORRECTION OF PERSONAL INFORMATION, QUESTIONS

If you would like to verify, correct or delete any personal information we have collected or if you have any questions or concerns regarding this Policy or SYKES treatment of personal information, please contact us at privacy@sykes.com or by writing to us at Data Privacy at SYKES Enterprises Incorporated, 400 North Ashley Drive, Tampa, Florida 33602. Please note that in certain circumstances, we may not, or may not be able to, remove or change certain information. When we receive formal written complaints at this address, it is SYKES’ policy to contact the complaining user regarding his or her concerns in reasonable period time. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using American Arbitration Association as a third party resolution provider.

In the event you are contacting us from the European Union and would like to verify, correct or delete any personal information we have collected or if you have any questions or concerns regarding this Policy or SYKES treatment of personal information, please contact us at dataprotection.gemea@sykes.com or by writing to us at Data Privacy at SYKES Global Services Limited, 599 Calder Road, Edinburgh EH11 4GA, UK. Please note that in certain circumstances, we may not, or may not be able to, remove or change certain information. When we receive formal written complaints at this address, it is SYKES’ policy to contact the complaining user regarding his or her concerns in reasonable period time. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using American Arbitration Association as a third party resolution provider. Alternatively, you have the right to lodge a complaint with the Supervisory Authority who is responsible for monitoring the application of GDPR in your jurisdiction.

EU-US PRIVACY SHIELD

PRIVACY STATEMENT

Sykes Enterprises, Incorporated and its affiliates certifies that it adheres to the privacy shield framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union. To learn more about the Privacy Shield program, and to view SYKES certification, please visit https://www.privacyshield.gov/.

We offer individuals the opportunity to choose whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, we give individuals the opportunity to affirmatively or explicitly consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. We shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information. We use personal information we collect to facilitate your use of the Sites, to provide you with information, products and services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to administer and assist us with the operation of the Sites and of our business. For example, we may use the information we collect to:

contact you about your use of the Sites, such as for administrative purposes or to provide you with customer service;

• provide you with the services, products or information you requested;
• respond to your emails, submissions, comments, requests or complaints;
• contact you about our products, services, activities, events, promotions or offers and for other marketing, informational, product development and promotional purposes;
• request feedback and to enable us to develop, customize and improve our information and services; and enhance compliance with the policies, rules, and other agreements governing the Sites in order to protect the online community and the overall integrity of the Sites.

Sykes may need to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements

We shall ensure that any third party for which Personal Information may be disclosed are subject to law providing the same level of privacy protection as is required by EU-US–Privacy Shield and agree in writing to provide an adequate level of privacy protection. We may be liable in cases of onward transfers to third parties without your permission

SYKES allows an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

In compliance with the Privacy Shield Principles, SYKES commits to resolve any complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact SYKES at:

privacy@sykes.com.

SYKES has further committed to refer unresolved Privacy Shield complaints to American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your

Under certain conditions, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

EU Specific Rights conferred by GDPR

In addition to your rights to verify, correct and delete your personal information, if you are a resident of the EU and your data is subject to GDPR, you may also be entitled to request additional actions be taken.

You have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest or pursuant to the legitimate interests of us or a third party, we will stop using that personal information at your request unless there are overriding legitimate grounds to continue.

In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information, but you don’t want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information (with your consent) for legal claims or where there are other public interest grounds to do so.

If we process personal information that you provide to us on the basis of consent or because it is necessary for the performance of a contract to which you are party, and in either case that processing is carried out by automated means, then you have the right to have that personal information transmitted to you in a machine-readable format. Where technically feasible, you also have the right to have that personal information transmitted directly to another controller.

If we use your personal information on an automated basis to make decisions, which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision. This right only applies where we use your information with your consent or as part of a contractual relationship with you

Where we use your personal information with your consent, you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.

CALIFORNIA PRIVACY RIGHTS

Under California law, customers who are California residents are entitled to annually request and obtain information about the personal information we shared, if any, with other businesses for their own direct marketing. If applicable, the information would include the categories of personal information and the names and addresses of those businesses with which we shared personal information for the immediately prior calendar year. To make such a request, please send an email to privacy@sykes.com. Written requests may be sent to Data Privacy at SYKES Enterprises Incorporated, 400 North Ashley Drive, Tampa, Florida 33602. Please note that not all information sharing is covered under the California law, and only information on covered sharing will be included in our response.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT NOTICE

We do not respond to “do not track” signals or similar mechanisms.