Note: The information in this notice is a legal requirement. These notes help you follow what information it covers in each section.

If you sign up to receive communications through Namdeb Engage (the service), De Beers Group and our associated companies{" "} ("Company", "we", "us" and "our") will process your personal data as set out in this Privacy Notice.
This Privacy Notice is supplementary to the usual Employee Privacy Notice which is available on Eureka! or from your local HR team{" "} ("Privacy Notice"), and the content of the Privacy Notice continues to apply to the processing of your personal data, in addition to the information set out below.
The following Privacy Notice describes how and why data is processed in connection with the service. It is intended to comply with our obligations to provide you with information about the processing of your personal data under privacy laws.
If you have any questions about this Privacy Notice, have any concerns relating to your personal data or would like to access the information it contains in a different format please contact our data protection team at{" "} dataprotection@angloamerican.com .
Use of the service is entirely optional.

Note: This section is about what personal information we have about you and why we need it.

This service involves us sending relevant communications to employees who have signed up to this service online or through the mobile app. We do this to ensure that we maintain a dialogue with you, and can provide you with information that may be relevant to you. The communications are sent on an ad hoc basis, as and when necessary, either through SMS/text messages or through the in-app function.
We process your personal data which we already have on our HR systems, plus any additional information that you provide to us when you sign up to receive the communications in connection with the service. If you no longer wish to receive the communications, you should uninstall the app and/or reply with STOP to any SMS news messages.
The types of personal data we process in connection with the service is limited to the data that we need to validate your eligibility for the service, and to send the communications that are relevant to you. This includes:

Name, Surname and date of birth, to verify your eligibility for the service;
Organisational data, such as business unit, mine, operational area, level (band), employee number, country, job title / role, employee status, department, function and personal area, payroll area, union membership, to send you tailored communications that are relevant to you;
Gender, to send you tailored communications that are relevant to you; and
Mobile telephone number, which is essential for you to log onto the service, and to receive the communications which are sent by SMS/text.

Note: This section is about where your personal information comes from

The personal data described in section 2 above is data we already hold about you, or data that is collected from you directly when you complete the registration process for the service or update your details online or through the app. No other data is collected or held in connection with this service.

Note: This section is about why we need your personal data

Your personal data is processed in solely in connection with this service.
We process your personal data on the basis of our legitimate interests. Namely, our interests in providing you with information that is relevant to you and your work.

1. We do not currently rely on automated decision making in connection with the service.
2. We process your personal data on the basis of our legitimate interests. Namely, our interests in providing you with information that is relevant to you and your work.

Note: This section is about how long we keep your personal information

The Company endeavours to ensure that personal data are kept as current as possible and that irrelevant or excessive data are deleted or made anonymous as soon as reasonably practicable.
Personal data is retained for as long as you remain in our employment.
Please note that some data may need to be kept for longer periods, pursuant to the Privacy Notice. In particular, we may keep some specific types of data for different periods of time, as required by applicable law or in order to comply with legal and regulatory obligations and for other legitimate business reasons.

Note: This section is about who can see your personal data

Within the Company, your personal data can be accessed by or may be disclosed internally on a need to know basis to:

system administrators; and
where necessary for the performance of specific tasks or system maintenance by staff in the Company teams such as the IT Department and the Company’s global information systems support team.

Your personal data will also be accessible to the third-party vendor of the website and mobile app, Wyzetalk (https://www.wyzetalk.com/). Their processing activity includes hosting the personal data you provide to us and any activity that is required as part of the administration and management of the app, website or the hosting system. From time to time, Wyzetalk may be asked to assist us with updating user records, targeting outbound communications, managing content and feature permissions and reporting.

Note: This section is about where your personal information is stored

The majority of the processing activity that we undertake takes place within the country you are based in, the United Kingdom and South Africa. In addition, Wyzetalk is located in South Africa.
As a result, your personal data may be transferred to countries outside of the country in which you work or outside of the European Union to countries whose data protection laws may be less stringent than yours. In such a case, the Company will ensure that appropriate or suitable safeguards are in place to protect your personal information and that transfer of your personal information is in compliance with applicable data protection laws.
Where required by applicable data protection laws, the Company has ensured that the relevant companies (including Wyzetalk and other Company associated companies) sign standard contractual clauses as approved by the European Commission or other supervisory authority with jurisdiction over the relevant Company exporter or have internal corporate binding rules to govern such transfers. You can obtain a copy of any standard contractual clauses in place which relate to transfers of your personal data by contacting{" "} dataprotection@angloamerican.co.uk .

Note: This section is about what happens if we make changes to this notice

The Company may change or update this Privacy Notice at any time.
Should we change our approach to data protection, you will be informed of these changes or made aware that we have updated the Privacy Notice so that you know which information we process and how we use this information.
This Privacy Notice was last updated and reviewed on 10 September 2019.