Legal Data Euronext Clearing

1. INTRODUCTION

1.1 This Privacy Policy explains how Cassa di Compensazione e Garanzia S.p.A., a company of the Euronext Group (as defined below) having its registered office in Via Tomacelli, 146 Rome ("EURONEXT CLEARING" or “we”, “us” or “our”) acting in its capacity of data controller collects information from you when you or a company with which you are connected:

1.1.1 use our products or services;

1.1.2 subscribe for alerts or newsletters from EURONEXT CLEARING;

1.1.3 apply for the participation to the services managed by EURONEXT CLEARING;

1.1.4 provide us information by filling in forms;

1.1.5. download documents from the Website (as defined below) and/or in connection with the services offered by Euronext Clearing or subscribe for alerts or newsletters from Euronext Clearing;

1.1.6. by participating to one of our events; 

1.1.7. visit or register to use https://www.euronext.com/en/post-trade/euronext-clearing (the “Websites”).

If you provide Personal Data directly to us or via third parties, in the following cases, please refer directly to section 11 that provides the information relating to these specific cases (“Applicant(s)”) : 

• You participate in a Euronext recruitment initiative,
• You voluntarily submit your resume to a representative of Euronext Clearing on an ad hoc basis, 
• You apply for an advertised job,  
• A recruiter provides your resume or details to Euronext Clearing
• Euronext Clearing finds your CV / details in online searches e.g. LinkedIn, 
• You are referred to an open position by an employee as part of the Euronext Referral Program. 

This Privacy Policy applies to any and all job applications submitted and recruitment initiatives co-ordinated by Euronext Clearing. 

IMPORTANT: should you send your resume via a recruiter with whom you have engaged with, we encourage you to read the relevant recruiter's data protection Privacy Policy to understand how your Personal Data is processed by such a recruiter who is a controller of your Personal Data independently of Euronext’s concerned entity.

1.2 As outlined below, the modalities of processing of your Personal Information (as defined below) will change depending on the applicable purpose of processing above.

1.3 Please read this Privacy Policy carefully and re-visit this page from time to time to review any changes that may have been made. 

1.4 Your data controller will be EURONEXT CLEARING that will process any Personal Data (as defined below) we collect about you in accordance with applicable data protection laws. EURONEXT CLEARING is part of the Euronext Group (“Euronext Group”) which consist of Euronext N.V, a Dutch holding company, located at Beursplein 5, 1012 JW, Amsterdam, the Netherlands, and its affiliated companies.

1.5 In the event of any conflict between this Privacy Policy and the terms of a contract you have with us, the relevant provision of that contract shall prevail. Nothing in this Privacy Policy shall apply to the extent that it is incompatible with applicable data protection laws.

1.6 Effective Date: September 2023

2. WHAT PERSONAL DATA DO WE COLLECT

2.1 "Personal Data" refers to information which does or is capable of identifying you as an individual. The Personal Data we may process, which we may collect either directly from you or a company with which you are connected or from a third party, may include some or all of the following data depending on the nature of the processing activity. 

This processing shall be legally required depending on the activity of Euronext Clearing. 

2.2 We will only collect information that is necessary for us to provide you with the product or service that you have requested. The type of information that we may collect will depend upon the nature of that service or product.

3. HOW WILL WE USE ANY PERSONAL INFORMATION THAT WE COLLECT AND ON WHICH LEGAL GROUND?

3.1 The following is an overview of EURONEXT CLEARING's purposes for processing Personal Data. Please remember that additional information may be provided to you in a separate notice, or in our terms and conditions. In addition to 1.5, in the event of any conflict between any separate notice and our terms and conditions, our terms and conditions shall take precedence.

3.2 The purposes for which we process your Personal Data are to:

The following table details the legal basis ("Legal Basis") according to which and the reasons why ("Purposes") we obtain, collect and process your Personal Data. 

3.3 Your Personal Data may be processed either electronically or in hard copy form, both inside and outside the EU and the EEA, in accordance with Section 6.

4. WEBSITE AND COOKIES

4.1    EURONEXT CLEARING WEBSITES

Euronext N.V. is responsible (the controller) for the websites of Euronext Clearing. 

By using these websites, you accept the practices described in this policy, we therefore advise you to carefully review all of its provisions.

Please note that the Euronext Clearing websites are general audience websites and Euronext Clearing does not knowingly collect personally identifiable information from persons under 18 years of age.

4.2    COOKIES TECHNOLOGIES

Cookies are small text files that are sent and stored on the user computer, smartphone or other device for accessing the Internet, whenever you visit a website. They are useful because they allow a website to recognize the user device, log when the user visits a particular page or provide a secure connection to a website, etc. 

Euronext websites use cookies for various purposes:

 

You can decide if a cookie from Euronext Clearing websites can be stored on your device. Euronext Clearing recommends that you leave the cookie active. By blocking, turning off or otherwise rejecting the cookie, some web pages may not display properly, or the user will not be able to use any website services that require you to sign in. At any moment, you can delete cookies through the configuration of the consent and privacy options available in your browser.

Cookie Removal Instructions: 

As part of our commitment to privacy and compliance with the General Data Protection Regulation (GDPR), we want to provide you with information on how to remove cookies from your browser. 

To remove cookies from the main browsers, please follow the instructions below: 

 

Google Chrome: 

1. Open Chrome and click on the three-dot menu icon in the top-right corner. 

2. Select "Settings" from the drop-down menu. 

3. Under the "Privacy and security" section, click on "Clear browsing data." 

4. Select the time range for which you want to remove cookies. 

5. Check the box next to "Cookies and other site data." 

6. Click on the "Clear data" button to remove the cookies. 

 

Mozilla Firefox: 

1. Open Firefox and click on the menu button (three horizontal lines) in the top-right corner. 

2. Select "Settings" from the menu. 

3. In the left sidebar, click on "Privacy & Security." 

4. Under the "Cookies and Site Data" section, click on the "Clear Data" button. 

5. Check the box next to "Cookies and Site Data." 

6. Click on the "Clear" button to remove the cookies. 

 

Safari: 

1. Open Safari and click on "Safari" in the top menu. 

2. Select "Settings" from the drop-down menu. 

3. In the Preferences window, click on the "Privacy" tab. 

4. Click on the "Manage Website Data" button. 

5. In the new window, select the website(s) for which you want to remove cookies. 

6. Click on the "Remove" button, then click "Done" to confirm. 

 

Please note that the above instructions may vary slightly depending on the browser version you are using. If you are using a different browser, we recommend referring to the browser's documentation or support website for specific instructions. 

 

Cookies list available here: https://www.euronext.com/en/privacy-statement#cookies_list 

4.3    NON-COOKIES TECHNOLOGIES

Euronext Clearing also enables the use of technologies that perform functions similar to cookie: 

• some are used to determine whether messages have been opened and links clicked on. They do not place information on your device, but may work in conjunction with a cookie to monitor website activity. 
• others are used for tracking and reporting aggregate usage patterns on the Euronext websites. No personal data is collected by these technologies.

5. DISCLOSURE OF YOUR PERSONAL INFORMATION

5.1 We may share your Personal Data within the Euronext Group, both inside and outside the European Economic Area as mentioned in Section 6, in order to provide you with our services. Access to your Personal data is limited to those employees, agents and contractors of the Euronext Group who need access to it in order to provide you with our services; to communicate with you (including, with your prior consent, to send you marketing communications); and to carry out legal or regulatory obligations.

5.2 We may also employ the services of third party service providers located both inside and outside the European Economic Area as mentioned in Section 5 to help us in certain areas, such as physical security, marketing and market research. Where third party service providers receive your information we will remain responsible for the use of your Personal data. We take appropriate steps to ensure that such third parties treat your Personal Data with the same consideration that we do.

5.3 We may from time to time be required to disclose your Personal data to law enforcement bodies, regulators, agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.

6. CROSS-BORDER TRANSFERS OF YOUR PERSONAL INFORMATION

6.1 We are an international organisation, with businesses both inside and outside of the European Economic Area ("EEA"). Third party service providers who handle data on our behalf may be based in locations around the world, and we may also be subject to scrutiny from courts or regulators in a number of different jurisdictions. For these reasons, your Personal Data may be transferred to other countries both inside and outside of the EU and the EEA. As privacy laws in other countries may not be equivalent to those in your home country, we only make arrangements to transfer data overseas where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that Personal Data handled in other countries will receive at least the same level of protection as it is given in your home country, for instance by entering into contracts incorporating the European Commission approved model contract clauses.

7. MODALITIES OF PROCESSING OF YOUR PERSONAL INFORMATION

7.1 Your Personal Data are processed by electronic and non-electronic means for the time strictly necessary to achieve the objectives for which that information has been collected. EURONEXT CLEARING implements appropriate technical and organizational measures so as to prevent losses and illegal or incorrect use of data, or non-authorized access.

8. RETENTION OF YOUR PERSONAL INFORMATION

8.1 We will retain your Personal Information for as long as is reasonably necessary for the purposes listed in Section 3 above. In particular:

• Personal Data collected for the mandatory purposes are retained for the period necessary to the provision of the required product or service, plus a maximum of 10 years from the termination of the services;

• Personal Data collected for the marketing purposes are retained for the period necessary to the provision of the required product or service and for the following 2 years;

At the end of the retention period your Personal data will be either deleted or anonymized and aggregated.

8.2 However, in some circumstances we may retain Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, tax or accounting obligations. In specific circumstances also we may also retain your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

9. PROTECTION OF YOUR PERSONAL DATA

9.1 We will hold your Personal Data securely whilst it is under our control, including where it is processed by third party service providers on our behalf. We train our employees in respect of their obligations under data protection laws and we ensure that only relevant EURONEXT CLEARING employees, contractors and agents have access to your Personal Data.

9.2 We take the security of our physical premises and our servers seriously and we will take all appropriate technical measures using recognized security procedures and tools in accordance with good industry practice to protect your Personal Data across all of these platforms.

10. YOUR RIGHTS

The table below sets out the rights which you must address any concerns or queries with us about our processing of your Personal Data. Please note that these rights are not absolute and are subject to certain exemptions under applicable data protection law. 

You can exercise the rights mentioned above in accordance with the “Data Subject Rights Request Information Procedure” through the modalities set out in Section 13 below or by submitting a request through the following form.

11. APPLICANTS

This section only applies to Personal Data which you may provide directly to us or via third parties, in the following cases: 

• You participate in a recruitment initiative 
• You voluntarily submit your resume to a representative of Euronext Clearing on an ad hoc basis  
• You apply for an advertised job  
• A recruiter provides your resume or details to Euronext Clearing
• Euronext Clearing finds your CV / details in online searches e.g. LinkedIn 
• You are referred to an open position by an employee as part of the Euronext Referral Program. 

This section applies: 

• to any and all job applications submitted and recruitment initiatives co-ordinated by Euronext Clearing, 
• up to the point at which we decide not to continue the recruitment process with you or when you start working for us (if applicable). On this latter case, the way we process your Personal Data will no longer be dealt with under this Privacy Policy, but will instead be governed by our Data Privacy Notice. 

IMPORTANT: sections 4, 5, 6, 7, 9, 10, 12, 13 and 14 of this Privacy Policy apply to Applicants. 

11.1 THE PERSONAL DATA WE PROCESS

As part of the recruitment and job application process, we collect the Personal Data that you / your agency / your referrer submit to us, which may include: 

If you apply for a position through the “Apply with LinkedIn” option, we may use the information you have previously provided to LinkedIn to populate your application. You are free to remove some details. 

The main mandatory information we need to proceed with your recruitment is your resume. You may remove Personal Data from your resume. 

It is necessary for us to process your Personal Data in order to assess your job application and/or include you in a recruitment initiative. Ultimately, it may also be necessary for us to process your Personal Data in order to take steps to offer and enter into a contract of employment with you. In the event that you do not wish to provide us with your Personal Data for the purposes outlined in this Privacy Policy, we will not be able to assess your job application and/or include you in a recruitment initiative and/or offer you a contract of employment. 

Please note that should you include information you think is relevant to your job application or the recruitment initiative, including cover letters, references from your previous employers and other documents you see fit. For information containing  Personal Data, we will hold and process any such Personal Data in accordance with the terms of this Privacy Policy. 

11.2 HOW AND WHY WE PROCESS YOUR PERSONAL DATA

The following table details the key context for which ("Legal Basis") and why ("Purposes") we collect, obtain and process your Personal Data within Euronext Clearing. The third parties and those within Euronext with whom we may share your Personal Data ("Recipients") are detailed in section 5 and 6 of this Privacy Policy. 

IMPORTANT:  

When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). 

We will only use your Personal Data for the purposes for which we collect it (as outlined in this section), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you in accordance with section 11 of this Privacy Policy and we will explain the legal basis which allows us to do so. 

11.3 DISCLOSURE OF YOUR PERSONAL DATA

We may disclose some or all of your Personal Data to the following parties: 

• Internal business units such as Human Resources, IT, Finance/Payroll, Managers, system administrators, our trusted third party service providers and our IT service providers; 
• Your previous employers when you have provided them as a reference third parties that may be contacted to provide additional information related to your previous work experiences; 
• Recruitment agencies; 
• Regulatory authorities;  
• Outsourced service providers who assist Euronext Clearing with recruitment initiatives and campaigns such as recruitment agencies, technical test assessment, background check and health assessment companies (where applicable);etc. 
• Professional advisors such as legal advisors, consultants and accountants. 

11.4 RETENTION OF YOUR PERSONAL DATA

Where you are a successful job applicant, the Personal Data generated by us and provided by you over the course of the job application/recruitment process will be retained by us for the purpose of your contract of employment. Such Personal Data will be retained in accordance with our Staff Data Protection Policy and Retention Policy (which will be available to you when you commence employment). 

Where you are an unsuccessful job applicant, we will retain your Personal Data for a period of up to 12 months after it is determined that your application has been unsuccessful for the purposes of both contacting you in relation to future vacancies within Euronext which we think may be of interest to you and, for the purpose of defending any potential employment equality claims. 

Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data. 

12. CHANGES TO THIS PRIVACY POLICY

12.1 Any changes we make to this Privacy Policy will be notified in advance and detailed on this page in order to ensure that you are fully aware of what Personal Data is collected, how it is used and under what circumstances it will be disclosed.

13. INFORMATION ABOUT THE DATA CONTROLLER AND CONTACT DETAILS

13.1 Your data controller will be Cassa di Compensazione e Garanzia S.p.A. In all cases, if you have any complaints or queries relating to the processing of your Personal Data by any member of EURONEXT CLEARING, or to exercise any rights in respect of your Personal Data, you should contact us in one of the following ways:

• by sending a request to us at dpo@euronext.com
• By sending a letter to the following address:

Euronext

Compliance Department

Data Protection Officer

14, place des Reflets – CS30064

92054 Paris la Défense.