EMPLOYEE PRIVACY NOTICE

I. INTRODUCTION

This Privacy Notice applies to you if you are a current or prospective employee and contractor of Hawk-Eye Innovations Limited

Hawk-Eye Innovations Limited, Jays Close, Viables, Basingstoke, RG22 4SB (“Hawk-Eye”) is the controller for your personal data.

This Privacy Notice explains:

What personal data Hawk-Eye collected;
Why Hawk-Eye processes your personal data;
From whom Hawk-Eye collects personal data about you;
With whom Hawk-Eye shares your personal data;
How Hawk-Eye protects your personal data if it is transferred outside the European Economic Area;
Your rights;
How long Hawk-Eye retains your personal data; and
Who to contact if you have queries.

We may provide you with more specific notices for some of the processing described in this Privacy Notice and, if we require your consent, will ask for this at the time we collect your personal data.

II. WHAT PERSONAL DATA DOES HAWK-EYE COLLECT?

Hawk-Eye collects and processes the following categories of personal data:

Identification information
Contact information
Compensation information
Benefits information
Organizational information
Job and Position information
Employment status information
Payroll, banking and tax information
Leaves and Absence information
Goals and performance information
Skills and experience information
Talent management information
Information about dependents (for example for next of kin, relocation or benefits purposes).

III. WHY DOES HAWK-EYE PROCESS YOUR PERSONAL DATA?

Hawk-Eye collects and processes personal data for the following purposes:

Where the processing is necessary for Hawk-Eye to administer its contract with you

As required to establish perform or terminate the employment contract and to enable you to perform your job. This includes: recruiting and hiring; administration of payroll, pension and benefits, mobility arrangements, absence, compensation and sales quota commission, medical insurance, occupational health, retirement plans, stock plans; management of expenses and professional travel; and handling disciplinary matters and grievances.

Where the processing is for a legitimate interest of Hawk-Eye

As required by Hawk-Eye to enable its business, including but not limited to undertaking performance and talent management, training and leadership development, managing appraisals and employee tests and assessments, handling employee recognition awards, and developing more efficient and personalised working practices by studying patterns of work and performance; providing access to Hawk-Eye’s offices and company vehicles; management of Hawk-Eye’s IT systems and infrastructure; ensuring quality of customer support services, by recording calls made by customer care and sales staff; managing individual mobility (where this is not required for the employment contract); to administer employee questionnaires and feedback, provide company directories and communication services such as e‐mail, telephone and internet access. This also includes protecting the security of Hawk-Eye’s premises, assets, systems, and intellectual property and enforcing company policies, including monitoring communications (where permitted by local law and where consent is not required) in accordance with our policies, investigating matters raised under our ethics and compliance reporting tools (this may also be necessary for Hawk-Eye to comply with its legal obligations) and in the course of internal audit. This also includes undertaking mergers, acquisitions, reorganisations or disposals. In addition to this, Hawk-Eye will process and store personal data of third parties, such as your family members, for emergency purposes.

Where the processing is necessary for Hawk-Eye to comply with legal obligations

To comply with applicable laws and protect Hawk-Eye’s interests and legal rights, including, but not limited to, in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation); to make deductions for tax and social security purposes; and to pay sickness and maternity pay and other statutory benefits.

Where you give your consent

With your consent, we collect your picture for use with your contact details in internal directories, in internal communications and newsletters and in external news and media in connection with events and updates about Hawk-Eye; to monitor your use of Hawk-Eye's IT and communication systems (where consent is required); to participate in diversity monitoring and statutory reporting initiatives, where Hawk-Eye asks for information about health, sexuality or ethnicity or religion in order to promote diversity (where permitted under local law); to carry out background checks, including criminal records checks to evaluate eligibility for employment (where such checks are permitted under local law); and where regular or onboarding health checks are required for your role (where consent is required).

Hawk-Eye will keep personal data collected in the course of your employment, together with data retained from the application and selection process, for the course of the employment relationship and, to the extent permitted, after termination of employment.

IV. FROM WHOM DOES HAWK-EYE COLLECT PERSONAL DATA ABOUT YOU?

In addition to personal data that you provide directly to Hawk-Eye, we will receive personal data about you from third party sources in certain circumstances. We will receive your CV, application and interview or assessment results if you are introduced to Hawk-Eye by a recruitment agency; we will receive feedback or concerning your performance where references are obtained, and will receive information about criminal offences where background checks are performed.

V. WITH WHOM DOES HAWK-EYE SHARE YOUR PERSONAL DATA?

Personal data will be transferred to Hawk-Eye's ultimate parent company Sony Corporation and its subsidiaries (the "Sony Group Companies"), its affiliates and contractors for the purposes described above. In particular, Hawk-Eye will transfer your personal data to (i) Sony Europe Limited, which carries out HR, finance, payroll, IT or Information Security services on behalf of Hawk-Eye; (ii) Sony Europe BV, which carries out HR, finance, payroll, IT or Information Security services on behalf of Hawk-Eye; (iii) Sony shared service centres or support centres, which carry out HR, finance, payroll, IT or Information Security support functions on behalf of Hawk-Eye; (iv) Sony Corporation of America in connection with certain personnel administration and employment-related activities; and (v) Sony Global Treasury Services Plc, which administers certain banking services on behalf of Hawk-Eye;

Information contained in internal directories may be accessed by staff of other Sony Group Companies. Other personal data will primarily be processed by employees of the Human Resources, IT, Finance, Legal and Facilities departments, where relevant and necessary. A list of Sony Group Companies and their addresses is available on request.

Hawk-Eye shares personal data about you with vendors who provide services to Hawk-Eye for the purposes described in this Privacy Notice, particularly in connection with:

Payment of compensation and provision of pension and benefit schemes;
Administering travel and expenses;
Supplying information technology systems or services;
Personnel administration services;
Employee training and staff surveys;
Provision of compliance programmes and hotlines;
Corporate finance and accounting; and
Legal and other professional advice.

We may use, and the companies with whom we share your personal information may use, AI as part of their data processing activities. We test and review these tools regularly from a legal, security, privacy and ethical perspective. We will always be transparent with you about our use of AI.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law and if required for the legal protection of Hawk-Eye’s legitimate interests in compliance with applicable laws.

VI. DO INTERNATIONAL TRANSFERS OF PERSONAL DATA TAKE PLACE?

As explained above, Hawk-Eye shares your personal data with Sony Group Companies including those located outside of the European Economic Area (EEA) and/or the United Kingdom, such as Japan, the US, Russia, the Philippines, China, India and Turkey. Information contained in internal directories may be accessed by staff of other Sony Group Companies on a worldwide basis. A list of Sony Group Companies is available on request.

Some of the vendors used by Hawk-Eye are also located outside the EEA and/or the United Kingdom in Japan, the US, Canada, the Philippines, China, India and Egypt.

Where Hawk-Eye transfers personal data to countries that do not provide a level of protection to personal data equivalent to that provided in the EEA and/or the United Kingdom, Hawk-Eye puts in place transfer mechanisms approved by the European Commission and/or UK Secretary of State to safeguard your personal data. For example, we rely on adequacy decisions such as those with the EU, UK and Japan and/or we use standard contractual data protection clauses, which have been approved by the European Commission and/or the UK Secretary of State. You can find out more information about these safeguards and obtain a copy of them, where relevant, by contacting Hawk-Eye using the details set out in the Contact Us section below.

VII. WHAT ARE YOUR RIGHTS?

Under applicable law, you may have the right to access, correct, erase or restrict our processing of personal data that relates to you or to ask us to pass your personal data to another organisation (data portability). You may also have rights to object to the processing of such personal data and to request an explanation about the processing or withdraw any consent you have provided. There are exceptions to these rights and they may be limited in some situations, for example, access to personal data may be denied if making the information available would unfairly reveal personal information about another person or if Hawk-Eye is legally prevented from disclosing such information.

Where you have given Hawk-Eye your consent to process your personal data, you may withdraw consent at any time. If you withdraw your consent to Hawk-Eye processing your personal data, this will not affect any processing which has already taken place at that time.

These rights can be exercised by contacting the Privacy Officer at privacyoffice.SEU@sony.com at any time. If you have unresolved concerns you also have the right to complain to data protection authorities in the country where you live, work or where you consider that a breach has occurred.

There may be circumstances where the provision of personal data is mandatory due to our legal and/or contractual obligations. We will always tell you exactly what data is required, why and what the consequences are of not providing that data; for example, we may not be able to manage the employment relationship, or to meet obligations places on us. In all other cases, provision of requested personal data is optional.

VIII. DATA RETENTION

We will retain your personal data for as long as you are an employee or contractor of Hawk-Eye and will delete your personal data in accordance with local laws and as further described in our Data Retention Policy.

IX. CONTACT US

If you have any questions or would like additional information about your personal data, please contact the Privacy Officer at privacyoffice.SEU@sony.com.