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DATA PRIVACY AT CONDUENT

We respect and are committed to safeguarding the confidentiality, data privacy,
and security of the information that our customers have entrusted to us,
including the confidential information, personally identifiable information,
proprietary information, and trade secrets gathered across all of our business
operations.

Conduent’s commitment to data privacy goes beyond the minimum legal and
regulatory requirements and strives for best-in-class data protection and
privacy management. This commitment is overseen at the executive level by the
Chief Privacy Officer who reports to the General Counsel and the Chief
Information Security Officer who reports to the Chief Information Officer (with
the GC and CIO both reporting directly to the Chief Executive Officer of the
company.) The board receives quarterly reports or a read-only report. The Audit
Committee agenda includes coverage of data privacy at every Board Meeting.

Conduent Online and Third-Party Privacy Policy

View our online privacy policy covering the websites that belong to Conduent and
how we handle website interactions, as well as personal data we process about
other individuals who Conduent keep in contact with.

Introduction

This privacy notice applies to the personal data collection, use, and disclosure
practices of Conduent and its affiliated entities (“Conduent”, the “Company”,
“we”, “us”, “ours”) pertaining to Conduent websites where this notice is
displayed. It also applies to the collection, use and disclosure of information
that we collect about our contacts, such as our vendors, clients and those who
make enquiries to us. This notice does not apply to our employee personal data
or candidate recruiting practices.  Please refer to other privacy notices
pertaining to those activities.   This notice does not cover the privacy
practices relating to personal data collected through websites of Conduent
subsidiaries or affiliates who publish their own policies different from this
notice.

Where the concept of “controller” and “processor” apply under applicable law,
the Conduent entity collecting your personal information through this website is
deemed a controller (having discretion about the uses of your personal
information).  The controller may transfer your personal information to Conduent
affiliates and others as provided in this notice.  Those other entities may be
deemed joint-controllers or processors depending upon the purposes for which
your personal information is disclosed to them.

 

Privacy Complaints and Inquiries.

Conduent commits to resolve complaints about your privacy and our collection or
use of your personal information. Inquiries or concerns regarding this privacy
policy or Conduent’s data handling practices should be directed to the relevant
data protection office detailed below.

The PhilippinesRonald Jomocan



Data Protection Officer

Ronald.jomocan@conduent.com

 

European Economic AreaFieldfisher LLP



Data Protection Officer

ConduentDPO@conduent.com

 

United KingdomFieldfisher LLP



Data Protection Officer

ConduentDPO@conduent.com

 

All other countriesChief Privacy Officer



DataPrivacy@Conduent.com

 

You can also contact us if you have privacy enquiries or concerns through the
Conduent Business Ethics and Compliance Office. To report your inquiries or
concerns to the Business Ethics and Compliance Office please contact the
Conduent Ethics Helpline. The Conduent Ethics Helpline is confidential and
anonymous, if you so desire, and is available online and via a toll-free number
listed below.

 * Web Reporting: conduent.com/ethicshelpline .
 * North America (US including Puerto Rico, Canada, and Jamaica) Toll-Free
   Number: 1-844-330-0221.
 * Direct Dial Toll-Free Numbers Outside North America available at
   www.conduent.com/ethics.

 

You may also contact us via postal mail at:

Conduent Incorporated

Business Ethics and Compliance Office

100 Campus Drive, Suite 200

Florham Park, NJ 07932

USA

 

Collection of Personal Information

Website users

You may choose to give us personal information online such as to allow us to
communicate with you or provide you with services. Our online forms ask for
relevant information, such as name, email, street address, and phone number. If
you make a purchase, we may ask for your credit card number and billing
information. We may also collect information about your visits to our websites,
including your Internet Protocol (IP) address, browser type and language,
location information and details of your browsing patterns. This is more fully
described under the section entitled “Cookies, Web Beacons and AdChoices” below.
We collect this information to determine such things as the number of visitors
to various parts of our websites and to personalize your experience on our
sites, and tailor our interactions with you.

If you do not want to give personal information to Conduent online, you may
communicate with us through the postal addresses or the phone or fax numbers
that we also provide on our websites or in this Notice.

This website is not directed toward children under 13 years old. Conduent does
not knowingly collect personal information from minors under the age of 13. 
Where required in accordance with applicable law, Conduent will provide other
and further notices, and collect such express consent, as may be deemed
appropriate.

Personal information that is submitted in a business capacity may be merged with
available business data base directories.

Our contacts

You may choose to give us personal information to allow us to establish and
manage our relationship with our customers, service providers, and other
partners. This may include information such as your name, email, street address
and telephone number. Depending on how we interact with you, you may also
provide us with your employment details such as employer and job title, and also
financial information such as your bank account details.

In addition, we may correspond with you and that may contain certain personal
data that we exchange in the ordinary course of business such as to schedule
meetings and calls, or to obtain services from you or your employer.

If you attend one of our events (including online) we may collect certain
information from you including your name and contact details. If you attend one
of these events as a speaker, we may also use your image or photograph.  In
addition, for online events, the software we use may automatically collect
certain information regarding your use and interaction with the software and the
event.

If we ask you to provide any other personal information not described above,
then the personal information we will ask you to provide, and the reasons why we
ask you to provide it, will be made clear to you at the point we collect your
personal information.

When we send you marketing communications, the software may automatically
collect certain information regarding your interaction with the email.

From time to time, we may receive personal information about you from third
party sources (including from your employer and on occasion other suppliers and
partners), but only where we have checked that these third parties either have
your consent or are otherwise legally permitted or required to disclose your
personal information to us.

Why Does Conduent Collect Personal Information?

Conduent maintains the information it receives online in strict confidence.
Personal information you submit to Conduent is not sold to or shared with third
parties, except to our subsidiaries, affiliates, agents, and partners as
described in this policy.

Conduent reserves the right to notify you about administrative matters that
pertain to your Conduent products or services. We may disclose your personal
information as required by law or regulation, in connection with law
enforcement, fraud prevention, or other legal action, or if Conduent reasonably
believes it is necessary to protect Conduent, our customers, or the public. In
the event of a merger or acquisition of one, or more, Conduent affiliates or a
substantial portion of its assets, Conduent may disclose, transfer, or sell
personal information collected online as needed to assess such transactions and
to the surviving or acquiring party, respectively. Personal information
collected online will remain subject to promises made in this notice.

If you would like to contact us without submitting personal information through
this website, you can reach a Conduent representative by calling 1-844-ONE-CNDT.

In addition to the purposes otherwise discussed in this notice, we use personal
information submitted through this site to:

 * respond to your questions;
 * provide customer support;
 * share news, updates, or helpful tips about Conduent products and services;
 * inform you of special promotions;
 * sign up for online services;
 * customize, analyse, and improve our products, services, technologies,
   communications, and relationships with you;
 * monitor interaction with, and the success of, any marketing activities or
   online events;
 * deliver products and services requested by you;
 * obtain products and services requested by us;
 * protect our legal rights to the extent authorized by applicable law;
 * provide security mechanisms and fraud control measures to the extent
   authorized by applicable law; and
 * protect the rights and vital interests of you and other people.

Data retention

We retain personal information we collect from you where we have an ongoing
legitimate business need to do so, for example responding to your queries or
providing you with a service you have requested. Note that we may need to retain
personal information for longer periods to comply with applicable legal, tax or
accounting requirements.

When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymise it or, if this is not possible
(for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it
from any further processing until deletion is possible.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described
above will depend on the personal information concerned and the specific context
in which we collect it.

However, we will normally process personal information about you only:

 * where we need the personal information to perform a contract with you, for
   example when you request services from us
 * where the processing is in our legitimate interests and not overridden by
   your rights, for example when we respond to your queries, improve our
   website. provide security mechanisms and fraud control measures or in the
   context of providing or receiving services or for the purpose of the
   collaboration or partnership
 * where we have your consent to do so
 * where we have a legal obligation to collect personal information from you,
   for example in relation to financial or tax matters
 * where, in rare cases, it is necessary to protect the health or wellbeing of
   another person

If we ask you to provide personal information to comply with a legal requirement
or to perform a contract with you, we will make this clear at the relevant time
and advise you whether the provision of your personal information is mandatory
or not (as well as of the possible consequences if you do not provide your
personal information).

If we collect and use your personal information in reliance on our legitimate
interests (or those of any third party), we will make clear to you at the
relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal
basis on which we collect and use your personal information, please contact us
using the contact details provided above.

Communication Preferences, Sharing and User Generated Content

Conduent may send commercial email to you advertising our products and services.
You can also subscribe to various product and service-specific communications on
our websites. If you receive direct marketing email from Conduent and wish to
discontinue these mailings, you may unsubscribe at www.conduent.com/unsubscribe,
and/or in any unsubscribe opt-out method provided in the communications.

You may also mail an unsubscribe request to:

Marketing Privacy Preferences

Conduent

100 Campus Drive, Suite 200

Florham Park, NJ 07932

USA

Where allowed by applicable law, the unsubscribe options provided to you may not
apply to communications primarily for the purpose of administering order
completion, contracts, support, product safety warnings, software updates where
you are provided with appropriate choice in accordance with applicable law, or
other administrative and transactional notices, the primary purpose of which is
not promotional in nature.  This means that even if you opt-out of receiving
direct marketing communications, we may still need to retain some of your
personal information necessary to communicate with you on these topics where
required for these purposes.

Conduent does not share your personal information obtained through this site for
the purpose of third-party direct marketing.

If you are a California resident under the age of 18, and a registered user of
any sites where this notice is posted, California Business and Professions Code
Section 22581 permits you to request and obtain the removal of content or
information you have publicly posted, if the site allows public postings.  To
make such as request please send an email to the How to Contact Us section for
subject access rights requests.  To make such a request, please provide a
detailed description of the specific content or information for which you seek
removal.  Please note such a request may not ensure complete or comprehensive
removal of the content you may have posted and that there may be circumstances
where the law does not require or allow removal even if requested.

International Transfers of Personal Information

As a global Company we may need to transfer your personal information so that it
is accessible and available to people who work for Conduent affiliates and to
third-parties who are located in countries different from the country in which
you are located.  Some of these countries may not be deemed to provide the same
level of protections for your personal information as the country in which you
are located or from which your personal information was originally collected. 
When such transfers are made or contemplated, we will take steps designed to
ensure that such personal information is transferred only in accordance with
applicable laws.

If we need to make such transfers, whether to a Conduent affiliated company or
to a third-party, we will take steps designed to ensure that the recipient of
access to that personal information has information security, privacy, and
contractual controls in place designed to adequately protect the information. 
Where, and as, applicable before transferring your personal information, we will
take steps designed to ensure one, or more, of the following: (i) the recipient
is located in a country found to have a data protection legal framework
providing adequate protection; (ii) we shall enter into appropriate approved
contractual clauses allowing the transfer; (iii) we have binding corporate rules
in effect with the recipient for the type of data and use involved in the
transfer; (iv) we have your specific consent (where required by applicable law
for the type of data); (v) we are making the transfer under another legally
allowed purpose under applicable laws which may include entering into or
performing a contractual obligation in your interest, for important reasons of
public interest, for legal claims or to defend legal interests, to protect your
vital interests or those of your beneficiaries when you, or they, are unable to
provide consent and, otherwise as required by recognized international legal
requirements.

Security of Personal Information

Conduent uses technical, organizational, and physical measures designed to
protect the integrity, confidentiality, security, and availability of personal
information.  Among other measures, only authorized personnel of Conduent and of
our third-party service providers with a legitimate need to know are provided
access to personal data, and these employees and third-party service providers
are required to treat this information as confidential where applicable. Despite
these precautions, we cannot guarantee that unauthorized persons will not obtain
access to your personal data.

If you arrange for services through this website, it may be necessary for us to
transfer your personal information to our affiliates or third parties for the
purposes of their assisting us with fulfilling the services.

Your Rights

If you are a resident in the European Economic Area, the UK, or another country
where similar rights may apply, you may have certain rights such as:

You may have a right to access, correct, update or request deletion of your
personal information.  If you have such right, you can do so by contacting us
using the contact details provided under the “How to contact us” heading above.

In addition, you may be able to object to processing of your personal
information, ask us to restrict processing of your personal information or
request portability of your personal information.  You can exercise these rights
by contacting us using the contact details provided under the “How to contact
us” heading above.

You may have the right to opt-out of marketing communications we send you at any
time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out”
link in the marketing communications we send you.  To opt-out of marketing
generally, please contact us using the contact details provided under the “How
to contact us” heading above.

If we have collected and process your personal information with your consent,
then you can withdraw your consent at any time.  Withdrawing your consent will
not affect the lawfulness of any processing we conducted prior to your
withdrawal, nor will it affect processing of your personal information conducted
in reliance on lawful processing grounds other than consent.

You have the right to request access to your personal data and obtain
information on and a copy of that personal data.  You may request rectification
of that data if it is inaccurate or incomplete.

You have the right to complain to a data protection authority about our
collection and use of your personal information.  For more information, please
contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their
data protection rights in accordance with applicable data protection laws.

 

Data Security Risk Approach 

Conduent’s security program is aligned with applicable industry regulatory
requirements, including but not limited to NIST, HITRUST, GDPR, HIPAA, ISO, and
PCI. The program encompasses information security and cyber operations
capabilities that protect Conduent and our clients. It is continuously reviewed
and strengthened as necessary to ensure responsiveness to and protection against
emerging threats. Conduent maintains a highly qualified workforce and utilizes
external experts to support the program. We administer internal education,
training, and communication programs to ensure ongoing awareness and vigilance.
We maintain and communicate formal documented policies and standards. We monitor
and assess the overall operating effectiveness of our program through risk
assessments that include identification and remediation of vulnerabilities and
threats. We maintain and test our cyber incident response plan, and undertake
various independent reviews in conjunction with PCI DSS, external audits,
internal audits, and client assurance efforts. Various additional operational
protections, controls, and processes exist, including but not limited to malware
protection, intrusion prevention, and detection protocols, user access reviews,
network segmentation, implementation and maintenance of network and application
firewalls, vulnerability scanning, data encryption, penetration testing, and
patching.


COOKIES, WEB BEACONS AND PRIVACY CHOICES

What is a browser cookie?

Cookies are pieces of information that may be loaded to your browser or device
when you visit a website. These types of cookies may involve our submitting
information to you or receiving information from you to us or may involve
transmitting information directly to another third-party from our website.
Depending upon the browser or setting you use, you can choose to have your
device warn you when cookies are being sent, you may block certain cookies, or
block cookies altogether. If you turn off all cookie functionality some of the
features on our websites may not function properly.

How does Conduent use cookies?

Conduent uses cookies to recognize repeat visits to our websites and to
facilitate navigation and online shopping. The cookies store your country and
language, along with an assigned random session ID. In some cases, the cookies
store name and address information, so you do not have to re-enter this
information in multiple forms.

The cookie information that Conduent collects helps us track the number of
visitors to our websites over time and determine whether these were new or
repeat visits.

Conduent also works with third-party advertising partners that use cookies to
deliver Conduent advertising on other websites and to measure the performance of
our advertising campaigns.

We use several categories of cookies and each performs different functions.  You
can learn more about cookies and their functions generally by visiting a website
such as allaboutcookies.org.

What is a Web Beacon?

A web beacon is an electronic image that can be used to recognize a cookie on
your computer or other device when you view a web page or open an email message.

How does Conduent use Web Beacons?

Where allowed by, and consistent with, applicable law Conduent and our
third-party advertising partners may use web beacons on our websites, in our
emails, and in our advertisements on other websites to measure the effectiveness
of our websites and our advertising. For example, web beacons may count the
number of individuals who visit our websites from a particular advertisement or
the number of individuals who open or act upon an email message.

Can I block cookies and web beacons?

Yes, the ability to enable, disable or delete cookies can be controlled through
your website browser and where otherwise provided in certain locations, through
our website technology including pages advising you of the use of tracking
technologies and seeking consent, where required, to our use of those
technologies. Consult the “Help” menu of your browser application for details or
follow details on webpage notices.  Where required by applicable law, Conduent
will honor do not track signals sent from browsers where it is clear a user has
made individual consent to block tracking technologies.  If you block the use of
cookies, that may impact the use of some of the features on certain Conduent
websites. You can make some web beacons unusable by disabling cookies.

Links to non-Conduent websites.

Other websites that may be accessed through our website, such as through social
media buttons or other links, may collect certain information about you through
the use of cookies, web beacons, and other features. We do not have access to or
control over the cookies or other features that these third-party sites may use,
and the information practices of these third-party websites are not covered by
this notice. Please contact them directly for more information about their
privacy practices.

Privacy Choices: How does Conduent use Interest-Based Advertising?

Websites cooperate with online advertisers to collect information about visitors
to present ads that are more useful and relevant. This is known as
interest-based advertising or online behavioral advertising. Conduent and our
third-party advertising partners may use cookies and web beacons to deliver
interest-based ads that are relevant and targeted to our customers and
prospects.

What information do Conduent websites collect for interest-based advertising?

Conduent and our third-party advertising partners may use cookies or web beacons
to collect information for the purposes of interest-based advertising based on
your visits to Conduent.com and other websites. These cookies identify the pages
you view, the links and ads you click on, other actions you take on those
websites, and the referring website. Similarly, online advertisers use cookies
to deliver advertising to you for companies other than Conduent based on your
visits to Conduent.com and other websites. When delivering interest-based ads,
Conduent adheres to the Self-Regulatory Program for Online Behavioral
Advertising.

Can I control the interest-based advertising that Conduent web sites collect
about me?

Yes, Conduent provides a tool to opt-out of data collection by companies that
adhere to the Self-Regulatory Program for Online Behavioral Advertising.  Where
applicable, we also provide methods for express consent to load cookies that are
not strictly necessary for website operation purposes.

Policy Updates

Conduent reserves the right to make changes to this policy. If we make changes,
we will revise this Online Privacy Policy to reflect such changes and revise the
effective date of the policy.

 

Last Updated:  July 15, 2022

CONNECT WITH AN EXPERT

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Contact Online

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