Privacy Notice for our Employees and Applicants

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“Remarkably Human” is one of the core principles Asurion’s culture strives towards and is front of mind in the way we handle and protect not only our customers’ personal data, but yours, as our valued Employees and Applicants, as well. With that goal in mind, we are providing this Privacy Notice (“Notice”) to describe how Asurion collects, uses, discloses, and handles your personal data, and information about privacy rights you may have, depending upon where you live. 

A Few Terms

When we use “Asurion”, or terms like “we”, “us”, or “our” in this Notice, we’re referring to Asurion, LLC and our subsidiaries and affiliates.

When we use the term “Applicant” in this Notice, we’re referring to those individuals who have submitted information to Asurion (such as a resume or job application) in order to apply to be an Employee, or who have otherwise given consent to be considered as an applicant for a position.

When we use the term “Employee”, we’re referring to those individuals who have been or are currently employed at Asurion as well as members of our extended workforce including independent contractors, contingent or agency workers and interns.

When we use terms like “you” and “your,” we’re talking about you as an employee of Asurion or as an Applicant for an open position with Asurion.

When we refer to “personal data,” we mean any information that relates to an identified or identifiable person, whether that person is identifiable directly or indirectly.

Accessibility

If you are visually impaired, you may access this Privacy Notice through your browser’s audio reader. 

Sources of Personal Data

Asurion may obtain your personal data, in accordance with applicable data privacy and employment laws, in the following ways:

• Directly from you
• Indirectly, such as from prior employers, recruitment agencies, and other third parties
• From public sources such as public records and public forums, including social media and
• From Asurion-issued devices and other electronics you utilize in your role as an Asurion employee

It’s important that the information contained in our records is accurate and current. If the personal data you have provided to us happens to change during the course of your employment, please keep us informed of such changes or take ownership of the personal data you share with us by editing or updating your Asurion profile on our employee portal. 

Categories of Personal Data We Collect

We may collect the following categories of personal data about you, depending on whether you are an Asurion Employee or Applicant and depending on the nature of your position and role within our company and the requirements of applicable laws.

• Identification Data such as your name, government identifiers, employee identification numbers and badge numbers.
• Contact Data including your physical address, phone number, email address, and emergency contact details.
• Hiring Data including information related to Applicant qualifications, your resume/CV, education history, past employment, references, immigration status and documentation, residency permits and visas, national identification documents, passport, and other official documentation in support of authentication or eligibility for employment (e.g. Form I-9 in the US).
• Employment Data such as information related to your role at Asurion such as your position, role changes, resignation/termination notices, office location, employment contracts, performance and disciplinary records, academic/professional qualifications, criminal records data, immigration status and documentation, residency permits and visas, national ID/passport, applicable occupational health assessments and work-related accidents.
• Benefits Data including information related to employment benefits we provide to you such as spouse and dependent information, health information (including vaccination status when required for regulatory compliance purposes), vacation, leaves of absence, and accommodations information.
• Performance Management Data such as information related to performance evaluations or reviews, disciplinary actions and grievances, and training and development plans.
• Financial Data including banking details, tax information, payroll information, withholdings, salary, expenses, company allowances, and commission and equity grants.
• Demographic Data such as date of birth, gender, race/ethnicity, veteran status, disability, sexual orientation and gender expression, as well as information relating to other demographic categories. Employees can always view and update their demographic data in our employee portal.
• Location Data, such as from Asurion-owned vehicles, Asurion-issued computing devices or from mobile devices with specific applications installed for our at-home experts, field technicians, or those traveling on Asurion business.
• Audio and Visual Information such as audio recordings of interactions you may have with Asurion customers and video recordings captured at our offices, corporate headquarters, warehouses, stores and other physical sites.
• Systems and Asset Use Data such as information required to provide access to Asurion's computing resources such as IP addresses, log files, login information, websites visited, systems accessed, software/hardware inventories, internal communications and information collected by internal Asurion applications provided to employees such as employee communications tools and platforms. This also includes asset allocation data and data used for security and business continuity purposes and information required to use Asurion sites including access and security controls.
• Other Information You Might Choose To Share With Us such as answers to feedback surveys, and participation in programs like Compassion Forward.
• Biometric Information such as a fingerprint or a facial scan to confirm your identity. 

How We Use Your Data

We only process your personal data when we have a legitimate business reason or a legal requirement to do so. The main reasons for processing include:

• Hiring. During the hiring process, we process Applicant personal data to determine suitability and eligibility for a role. This includes verifying qualifications. It may also include administering background checks, drug testing and establishing your right to work in a specific jurisdiction.
• Compensation and Benefits. We use this information to manage payroll, taxes, and benefits as well as to process work-related claims, such as worker compensation, insurance claims, expense and travel management and leaves of absence.
• Training. We use this information to help us with creating and updating Employee training and other development opportunities and enforcing mandatory training completions.
• Performance Reviews. We use this information to review how you are performing at work and to help determine your work performance requirements and career development needs.
• Legal Requirements. We use this information to comply with laws and regulations (e.g. labor and employment laws, health and safety, tax, anti-discrimination laws) or to exercise or defend our legal rights.
• Contacts. We use this information internally to compile employee directories or send items or documents to email or home addresses.
• Security and IT. We use this information to maintain the security of Asurion’s assets, resources, and premises and, provide you with access to them, to manage our general operations, to provide services to you as necessary for your role, and to protect your personal safety.
• Emergencies. We use this information to help us establish emergency contacts for you and respond to and manage emergencies, crises, and business continuity.
• Investigations and Disciplinary Actions. We use this information when necessary to investigate and support decisions on disciplinary actions or terminations, conduct grievance management, or when necessary to detect fraud or other types of wrongdoing.
• DEI Goals. We use this information as necessary to help us understand the diversity of our workforce and to support business diversity, equity, and inclusion initiatives. In some circumstances, we may also need to use this data to comply with local laws. We generally collect this information on a voluntary basis, and you are not required to provide it unless it is necessary for us to comply with a legal obligation. We will not disclose this data without your permission unless we are legally required to do so.
• Monitoring. Our normal monitoring use cases are outlined in the Employee Handbook, in the section titled Workplace Monitoring.
• Day to day Business Operations. We may use this information for other legitimate purposes that are reasonably required for day-to-day operations at Asurion, such as managing our relationship with our employees, accounting, financial reporting, business analytics, employee surveys, operational and strategic business planning, mergers and acquisitions, real estate management, business travel, and expense management and to enable the management and operation of information technology and communications systems and networks, improve and maintain effective administration of the workforce, develop and improve products, services, and operations, enable reporting and communications, risk management and insurance functions, and the maintenance of records relating to business activities, obtain and maintain licenses, permits and authorizations applicable to Asurion operations. 

Legal Basis to Process

If you are from a jurisdiction that requires a legal basis for processing personal data (such as the EEA, UK, Japan, the Philippines or Brazil), Asurion’s legal basis will depend on the personal data concerned and the context in which we collect it.

We mainly rely on your consent to process your personal data by providing you this employee privacy notice prior to or during your onboarding and collecting your written consent to its contents. We will further rely on your consent any time we process sensitive personal data related to your current health status.

We will normally collect personal data from you only where we need the data to carry out our employment contract with you, to comply with our legal obligations or exercise rights in the field of employment, or where the processing is in our legitimate interests, provided this is not overridden by your data protection interests or fundamental rights and freedoms.

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and let you know whether providing your personal data is mandatory or not, as well as the possible consequences if you do not provide it.

Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of a third party) that are not listed in the “How We Use Your Data” section above, 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 data, please contact us using the contact details provided in the "Contact Us" section below. 

Data Controllers

If you are located in the EEA or the UK, the data controller of your personal data will be the corporate entity that manages the hiring process or employs you (e.g. Asurion Europe Limited for employees based in the UK).

How We Disclose Your Personal Data

Asurion will only disclose your personal data to those who have a legitimate business need for it, as in some circumstances Asurion could be legally responsible for these parties’ processing activities. Whenever we permit a third party to access your personal data, we will ensure the personal data is used in a manner consistent with this privacy notice (and any applicable internal data handling guidelines consistent with the sensitivity and classification of the personal data). We will obtain your consent for any disclosure of your personal data where required by law. Your personal data may be disclosed to our subsidiaries and affiliates and other third parties, including service providers, for the following legitimate purposes:

• Other Employees, Contractors or Asurion Affiliates to establish, manage, or terminate your employment with Asurion.
• Consultants and Advisors to seek legal advice from external lawyers and advice from other professionals such as accountants, management consultants
• Professional Services Vendors to enable them to provide services to you on behalf of Asurion such as recruitment providers, financial investment services, insurance providers, payroll support services, healthcare providers and other benefits providers.
• Partners in Corporate Transactions and their Professional Advisors in connection with the sale, assignment or other transfer of all or part of our business.
• Vendors, Service Providers, Customers and Clients to support Asurion’s day-to-day operations and to carry out the purposes of our personal data processing as described in the section “How We Use Your Data” above.
• Government Authorities or Law Enforcement if we in good faith believe we are compelled by any applicable law, regulation, legal process or government authority or where necessary to exercise, establish or defend legal rights, including to enforce our agreements and policies.
• Other Third Parties to protect Asurion’s rights or property, to protect Asurion, our other customers, or the public from harm or illegal activities, to respond to an emergency which we believe in good faith requires us to disclose personal data to prevent harm, or with your consent. 

How We Protect Your Personal Data

We have a robust security program that uses appropriate technical, administrative, and physical controls to protect your personal data against accidental or unlawful destruction, loss, disclosure, alteration, or use. These controls vary based on the sensitivity of the personal data involved and the current state of technology.

Prior to engaging any third-party service provider, Asurion performs due diligence to evaluate their defensive posture and executes an agreement requiring each third-party service provider to: 

• Provide at least the same level of privacy protection as is required by Asurion and notify Asurion if it can no longer comply and meet its obligation; 
• Process any data received from Asurion for limited and specified purposes and notify Asurion if it can no longer comply and meet its obligation; 
• Process Asurion’s personal data as directed by Asurion; 
• Upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing. 

How Long We Keep Your Personal Data

The amount of time we retain a particular category of personal data will vary depending on the purpose for which it was collected, our business need for it and our legal obligations with respect to it. We seek to minimize our retention of data wherever possible.

Asurion Employees. Generally, we keep your data until the end of your employment or contract with us, plus the period of time required by the law of the country or state in which you are employed or a reasonable period of time to respond to any inquiries and deal with any legal, financial or administrative matters, that might arise.

Applicants. If you apply for a job with us, we retain your data to determine your eligibility for a current or future role with us. The retention periods vary depending on your location and local legal requirements.

Where we have no continuing legitimate business need or legal requirement to process your data, we will either delete or anonymize it or, if this is not possible (for example, because your data has been stored in backup archives), then we will securely store your data and isolate it from any further processing until deletion is possible.

If you have specific questions about how long we retain your data for other jurisdictions please contact us using the contact information provided in the “Where To Turn With Questions” section below.

How We Handle International Transfers of Personal Data

As a global organization, we may need to transfer your personal data outside your home jurisdiction to Asurion affiliates, including our headquarters in the US. These countries may have data protection laws that are different from the laws of your region. We will only transfer personal data to another country in accordance with applicable data protection laws, and with confidence that the adequate protections are in place for the data.

Internal Transfers. If we need to transfer your personal data from one Asurion affiliate to another, we rely on contractual agreements, specifically Standard Contractual Clauses, where they are required by law. Our privacy practices also comply with the APEC Cross Border Privacy Rules (“CBPR”). The APEC CBPR system provides a framework for organizations to ensure protection of personal data transferred among participating APEC economies. More information about the APEC framework can be found here.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our US-based third-party dispute resolution provider at Truste. Certain methods of dispute resolution may be available to you, including binding arbitration.

External Transfers. If we need to transfer your personal data internationally outside Asurion to a processor who handles that data on our behalf, we rely on contractual agreements, such as Standard Contractual Clauses, where they are required by law.

Exercising Your Rights Under Privacy Laws

Whether you are an Asurion Employee or Applicant, depending upon where you live, you may have certain rights provided by applicable privacy laws. Where applicable, and subject to certain limitations and exceptions, the rights may include:

• The right to correct your data if it’s out of date, incomplete, or inaccurate;
• The right to request confirmation that we are processing your data and be provided with access to the data we process about you;
• The right to have your data deleted;
• The right to restrict the processing of your data;
• The right to transmit your data to another organization;
• The right to object to the processing of your personal data;
• The right to withdraw consent for data you’ve provided to us on a consensual basis; and
• The right to obtain information about the entities we have disclosed your data to.

A note for our employees - We want to empower you with regard to your personal data. We provide you with a number of tools to help you update, access, or delete some of your data on a self-serve basis through our internal employee portal.

Requests to exercise these rights can be submitted through Asurion’s Privacy Rights Portal, by calling 1-844-798-7701 or by emailing us at privacy@asurion.com. Asurion will respond to these requests in the manner prescribed by law. You will never be discriminated against for exercising any of these rights.

Asurion will take reasonable steps to validate your identity before responding to a privacy rights request. The information required from you to validate your request will usually be information like your name, email address, or other similar contact information. In some cases, additional personal data from you to validate your identity.

Authorized Agents. If you are a resident of California, a properly authorized agent may be able to exercise privacy rights on your behalf. Authorized agents must contact us by submitting a request through our webform and indicate that they are submitting the request as an agent. We reserve the right to require the agent to validate their identity and to require the agent to demonstrate authority to act on your behalf by providing signed permission from you. We may also require you, if you are able, to verify your own identity directly with us or to directly confirm with us that you provided the authorized agent permission to submit the request.

Changes to this Notice

We update this Notice periodically to comply with global laws and regulations and our changing business practices. You will find the date of the most recent update at the top of the current Notice. Please visit this site periodically to read the Notice. We will comply with applicable laws to the extent they require any additional means of alerting you to changes to the Notice.

How Does Asurion Handle Disputes Relating to Personal Data?

Appealing Decisions We’ve Made About Your Data. We hope we can provide you the answers you’re looking for when you exercise your privacy rights or contact us with questions or complaints related to our data protection practices. However, if you wish to appeal a decision you have received from us about a privacy rights request you submitted or to express concerns related to our data protection practices, you can do so by contacting our Privacy Team via email at privacy@asurion.com.

Right to Complain to a Supervisory Authority or Dispute Resolution Provider. Should we be unable to resolve your concern with us directly, you may have the right to lodge a complaint with or appeal to the supervisory authority in the state or country where you work or where you consider any data protection rules to have been breached.

EU-US Data Privacy Framework Certification 

Asurion complies with the EU-US Data Privacy Framework (EU-US DPF) and the UK Extension to the EU-US DPF as set forth by the US Department of Commerce.  Asurion has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF.  If there is any conflict between the terms in this privacy policy and the EU-US DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit Data privacy framework website. 

The DPF is issued by the US Department of Commerce. Asurion is likewise subject to the investigatory and enforcement powers of the US government, including the US Department of Commerce and the US Federal Trade Commission. Individuals may raise complaints with Asurion’s US-based third-party dispute resolution provider at TRUSTe, as described above. 

Where to Turn with Questions

You can contact Asurion’s Privacy Office with questions about this Notice or the use of personal data related to our websites, products, or services, or contact our data protection officer, by sending an email to privacy@asurion.com or by calling 1-844-798-7701, or by mail at:

Asurion

c/o General Counsel

cc: Asurion Trust Office

140 11th Ave. North

Nashville, TN 37203