1. Purpose and Scope of the Statement
The Euronext Group (“Euronext”, “we”, “us”) is strongly committed to protecting your personal data and upholding your right to privacy. This Privacy Statement describes how we collect and process your personal data and provides an overview of your rights in relation to your personal data. It applies to information which you may provide directly to us or via third parties.
Euronext Group consists of Euronext N.V, a Dutch holding company, located at Beursplein 5, 1012 JW, Amsterdam, the Netherlands, and its affiliated companies, acting as controllers. A list of all group companies can be found in annex to this Statement.
2. Application of this Statement
This Privacy Statement applies to the way we collect and process your personal data. Personal data will be collected and processed by us when you or a company with which you are connected engage with us and/or avail of our services, e.g.:
- via our websites or other selected domains, including any linked pages owned and operated by Euronext or any successors thereof, or any application made available by Euronext for use on a tablet, mobile phone or other mobile device (individually and collectively, the " Euronext websites"),
- in the framework of the execution of a contract with a company with which you are connected (e.g. when we have a contract with your employer and the latter provides us your contact data in the execution of that agreement)
- by participating to one of our events
- etc.
We will collect personal data:
- from you: for example through Euronext websites, when you avail of our products and services, when you attend one of our events or an event hosted at our premises, when you correspond with us, etc.; and
- from third party sources such as but companies or companies applying for listing with which you are connected, Euronext members, Euronext clients for market data services, and/or from publicly available resources (e.g. registration offices, newspapers and other publications).
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 on an ad hoc basis
- You apply for an advertised job
- A recruiter provides your resume or details to Euronext
- Euronext 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 Pro-gram.
This Statement applies to any and all job applications submitted and recruitment initiatives coordinated by Euronext .
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 Statement 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.
3. The personal data we process
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 depending on the nature of the processing activity.
This processing shall be legally required depending of the regulated activity of the Euronext company concerned.
DEVICE INFORMATION |
We collect information about your computer/device browser via cookies used on Euronext websites. Please see section 4 of this Privacy Statement for further information. |
CONTACT AND COMPANY INFORMATION
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This may include general personal data about who you are such as your name, your contact details, identification number, your job title and position in a company.
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AML INFORMATION |
This may include your position as a director, officer or beneficial owner of a company, copy documentation confirming your identity (such as your passport or identity card) and copy documentation showing proof of your address and information collected through AML software and screening tools. |
INFORMATION COLLECTED IN CONNECTION WITH LISTING ON AN EURONEXT MARKET | This may include information about the issuer of the financial instruments, the board of directors, the management and the share-holders, collected from the documentation filed by the company or from other sources, such as information about criminal offences and convictions, as defined by the listing rules of the marketplace. |
MAR INFORMATION |
This may include general personal data about who you are such as your name, your contact details, your job title, identification number, position in a company and reason for being an insider as defined by law. |
MIFID II INFORMATION | This includes all personal data this regulation requires Euronext to process. |
MIFIR INFORMATION | This includes all personal data this regulation requires Euronext to process. |
CRM INFORMATION |
This may include your correspondence and communications with us and details of your connections with our staff and of your visits to our premises. |
SRD II INFORMATION | This includes all personal data this regulation requires Euronext to process. |
PUBLICLY AVAILABLE INFORMATION |
This may include information available: (i) on the websites or promotional material of companies or organisations with which you are connected; (ii) in news articles; or (iii) from registries such as the companies registration offices. |
VOICE DATA | We may record operative telephone calls by us, or to us, to the ex-tent it is necessary to do so to fulfil our legal duties. More information on this voice recording is provided in article 1.5 of the Euronext Rule Book available at euronext.com/en/regulation/euronext-regulated-markets. Any telephone records will include your telephone number, voice, and any data transmitted during the telephone call. |
MARKET SURVEILLANCE DATA | In connection with trading of financial instruments, we may collect your personal data from issuers, members, securities registers and public authorities in order to fulfil our legal duties to monitor market activity. |
INFORMATION IN MEETINGS AND/OR EVENTS |
We may collect specific information about you so that we may host you at our premises or at any event or seminar which we organise. We may also collect images (such as photographs and video footage) at IPO announcements and other Euronext events and CCTV footage when you visit our premises. |
OTHER INFORMATION |
We may also process any personal data which you or the company with which you are connected choose to provide us. |
4. Websites and Cookies
4.1 Euronext Websites
Euronext N.V. is responsible (the controller) for the websites of Euronext Group.
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 websites are general audience websites and Euronext 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:
Cookie Type | Description |
Strictly Necessary Cookies | These cookies are necessary for the website to function and cannot be switched off in our systems They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will then not work. These cookies do not store any personally identifiable information. |
Functional Cookies | These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly. |
Performance Cookies | These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance. |
Targeting Cookies | These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. |
You can decide if a cookie from Euronext websites can be stored on your device. Euronext 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.
4.3 Non-Cookies technologies
Euronext 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. How and Why we process your personal data
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.
LEGAL BASIS | PURPOSE |
CONTRACT
It is necessary to process your personal data to enter into and perform our contracts with you .
If you do not wish to provide us with your personal data for these purposes, we will not be able to enter into or perform our contract(s) with you. | We obtain, collect and process your personal data:
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LEGITIMATE INTERESTS
We process certain of your personal data on the basis of our legitimate interests, such as in pursuit of our business or security interests or in the framework of the execution of a contract with a company with which you are connected.
Where we process your personal data in pursuit of our legitimate interests we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. We will not process your personal data where our legitimate interests are outweighed by the impact on your rights and freedoms (unless otherwise required or permitted by law).
| We obtain, collect and process your personal data in order to:
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LEGAL AND REGULATORY OBLIGATIONS | As a regulated company, we obtain, collect and process your personal data to comply with legal and regulatory obligations applicable to Euronext.
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CONSENT | Where applicable, we obtain, collect and process your personal data on the basis of consent for some specific marketing purposes (i.e. proposal of products & services, invitation to events…).
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6. Disclosure of your personal data
We may disclose your personal data to other companies of the Euronext Group.
We may also disclose your personal data to third parties in relation with the purposes for which personal data are processed including:
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- regulatory authorities and law enforcement agencies;
- our trusted third party service providers and our IT service providers;
- third parties involved in financial market activities;
- third parties involved in hosting or organizing events or courses;
- professional advisors such as tax or legal advisors, consultants and accountants, and
- any prospective buyers of Euronext or the business of Euronext.
7. Transfer of your personal data
We store and process your personal data on servers located within the European Economic Area (the "EEA"). We only transfer your personal data outside the EEA where the European Commission has decided that the third country in question ensures an adequate level of protection in line with EEA data protection standards or where there are appropriate safeguards in place to protect your personal data.
We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described in this Privacy Policy and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information.
If you are located in the European Union (and Iceland, Liechtenstein and Norway) (“EU”), United Kingdom (“UK”) or Switzerland, with respect to transfers of personal information to the U.S., Euronext US Inc. and its subsidiaries Euronext FX Inc., Euronext Markets Americas LLC, Accuratus Tax and CA Services LLC, and Euronext Market Services LLC are certified under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework administered by the U.S. Department of Commerce, the European Commission, the UK Information Commissioner’s Office and the Swiss Federal Data Protection and Information Commissioner, respectively, regarding the transfer of personal information from the EU, UK and Switzerland to the U.S. Click here to view our Data Privacy Framework Privacy Policy.
8. Retention of your personal data
Generally we shall retain your personal data for a period of seven years after the later of: (i) the conclusion of your relationship with Euronext; or (ii) the conclusion of the relationship between Euronext and the company with which you are connected. However to determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.
9. Security of your personal data
Your personal data are dealt with in confidence and Euronext has taken appropriate technical and organizational security measures to protect your personal data against loss, misuse, alteration and/or destruction. These include, but are not limited to:
- Installing a firewall to prevent unauthorized access to our systems;
- Using secure servers;
- Ensuring the Personal Data are stored in physically secure accommodation.
Please be aware that the security measures mentioned above apply to systems under the control of Euronext, but that Euronext cannot ensure the security nor confidentiality of any information during its transmission when transmitted via means not under its control, notably the Internet, and that you are aware that data transmitted via such means may be intercepted by third parties.
If Euronext becomes aware of any security breach which results in unauthorized access of your personal data, Euronext will endeavor to inform you.
Euronext websites may provide hyperlinks to websites from other companies or persons. This policy does not apply to the use of such websites and we are not responsible or liable for any processing of your personal data via these third party websites.
In addition, if you share content from the Euronext websites via social media, your personal data will be visible to those visiting your personal pages on these social media websites. Euronext is not responsible or liable for any processing of your personal data via such media. This policy does not apply to the use of such social media.
10. Your rights and How to exercise them
The table below sets out the rights which you have to 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.
RIGHT | FURTHER INFORMATION |
RIGHT TO BE INFORMED | You have the right to know your personal data is being processed by us, how we use your personal data and your rights in relation to your personal data. |
RIGHT OF ACCESS | You have the right to ascertain what type of personal data Euronext holds about you and to a copy of this personal data. |
RIGHT TO RECTIFICATION | You have the right to have any inaccurate personal data which we hold about you updated or corrected. |
RIGHT TO ERASURE | In certain circumstances you may request that we delete the personal data that we hold on you. You have also the right to give post-mortem instructions regarding your personal data. . |
RIGHT TO RESTRICTION OF PROCESSING | You have the right to request that we stop using your personal data in certain circumstances including if you believe that the personal data we hold about you is inaccurate or that our use of your personal data is unlawful. If you validly exercise this right, we will store your personal data and will not carry out any other processing until the issue is resolved. |
RIGHT TO OBJECT | Where we rely on our legitimate interests to process your personal data, you have a right to object to this use. We will desist from processing your personal information unless we can demonstrate an overriding legitimate interest in the continued processing. |
RIGHT TO DATA PORTABILITY | In case the processing is based on your consent or a contract conclude with you, you may request us to provide you with certain personal data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your personal data directly to another controller where this is technically feasible. |
You can exercise any of these rights in accordance with the “Data Subject Rights Request Information Procedure".
•submitting a request through the following form.
•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.
Furthermore, you may also submit a complaint to the competent Data Supervisory Authority.
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 Euronext recruitment initiative
- You voluntarily submit your resume to a representative of Euronext on an ad hoc basis
- You apply for an advertised job
- A recruiter provides your resume or details to Euronext
- Euronext 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 coordinated by Euronext,
- 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 Statement, but will instead be governed by our Data Privacy Notice.
IMPORTANT: sections 4, 7, 9, 10, 12 and 13 of this Privacy Statement 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:
PERSONAL DETAILS | This may include general Personal Data such as your name, gender, residential address, email address, contact telephone numbers, nationality, marital status, etc. |
DETAILS ABOUT YOUR PREVIOUS EMPLOYMENT | Such as the former company names, length of service, business titles and details on your previous roles. |
QUALIFICATIONS | Such as your skills, education, the languages you speak (including your level of proficiency), your eligibility to work in a particular country (e.g. minimum legal age to work, citizenship or visa details), your experience in the job you apply for and other industries, etc. |
PREFERENCES | Such as positions you may be interested in, information about when you may be available to interview and/or start date for Euronext or work on ongoing basis (e.g. full or part time or on weekends), whether you are open to relocation or working remotely, whether you are willing to travel for work and whether you have your own transport. |
PUBLICLY AVAILABLE INFORMATION | Details about you which we gather from publicly available sources over the internet and your social media accounts where such searches are relevant to the job you have applied for within Euronext. |
MEDICAL RESULTS | Where legally applicable (Portugal, United Kingdom and Ireland), results on aptitude and/or pre-employment medical tests which we may ask you to undergo after accepting our offer of employment. |
OTHER INFORMATION | Details you may provide us in response to our queries or questions at interview stage (including information about you which we generate throughout the interview and/or recruitment process), at reference check stage, to complete psychometrics tests (where applicable) or details required where mandatory in the respect of local requirements laws (e.g. Fitness & Probity eligibility in Ireland) |
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 Statement, 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 Statement.
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. The third parties and those within Euronext with whom we may share your Personal Data ("Recipients") are detailed in section 6 (Disclosure of your Personal Data) of this Statement.
LEGAL BASIS
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PURPOSE
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LEGITIMATE INTERESTS It is necessary to process your Personal Data where it is necessary for the purpose of initiate and facilitating the recruitment process. | We obtain, collect and process your Personal Data:
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COMPLIANCE WITH A LEGAL OBLIGA-TION It is necessary to process your Personal Data in order to comply with legal obligations imposed on us as an employer under applicable Irish and European Union law. | We obtain, collect and process your Personal Da-ta in order to comply with legal obligations, which may include:
|
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 10 of this Statement 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 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 Retentinon 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 Statement
We may occasionally update this Privacy Statement to reflect changes in our business or to comply with applicable law and regulations. We therefore advise you to review this statement regularly to ensure that you are updated with any changes.
13. Questions and Requests
Should you have any questions or requests about this policy, please contact us via dpo@euronext.com.