Retail Leadership Excellence Programme

Introduction
Who we are and how you can contact us
When does the policy apply
How we do collect your personal data
Type of personal data and information which we do collect
Why we do collect your personal data
How we use your personal data
Forwarding your personal data
How long do we store your personal data
Privacy and security of your personal data
How you can access your personal data and exercise your relating rights
Alterations to this policy

Introduction

Value Retail takes the protection of personal data seriously and aims at protecting your privacy. These data belong to you and, we respect this fact. This privacy policy (the ”policy”) contains detailed information on when and why we collect your personal data, how we use them, how we share them, how we protect them and bring them into accordance with the applicable privacy policy. This policy does also justify your right to require us the deletion, updating, transfer or the access to your personal data.

This policy refers to Value Retail’s Leadership Excellence Programme (the ”program”). The program consists of regular evaluations of your performances by use of our manager competency model enabling us to recommend and deliver complementary training and development requirements so that you dispose of the qualifications, skills and expertise to further on meet the high performance-standards as an employee of one of our Village brand partners.

Further privacy policies may also apply to your personal data – for example, the privacy policy that applies to the village where you work and, the privacy policy issued by your employer (or your Village brand partner).

Who we are and how you can contact us

This policy outlines how Value Retail Management Limited (and its associated businesses) collects, uses and controls your personal data. Value Retail Management Limited owns and manages the program, together with its associated businesses and, we act always as one responsible person for your personal data as “mutually responsible”. According to the Value Retail Village where you work as an employee for one of our Village brand partners, one of our associated businesses will be assigned to conduct assessment and training activities or to support them as a mutually responsible.

For any question you may have with regards to this policy or the program you may refer to Value Retail Management Limited or, to exercise your rights explained in this policy, by addressing an email to the following address: RetailExcellence@valueretail.com.

As mutually responsible entities, we agreed among ourselves on arrangements to secure the handling of your personal data in line with the regulations and the applicable privacy policies. These arrangements reflect our respective role and responsibilities towards you and your personal data. These arrangements between us do in no way affect your rights resulting from the privacy policy. For further information regarding these arrangements, please contact us by email to the address as above mentioned.

You employer (our Village brand partner) processes personal data about you in terms of your employment relationship with him and is at any time the responsible data controller of these data. Every interaction and every exchange of personal data between our Village brand partner and Value Retail is subject to the contractual agreement between us as independent data controllers.

If you’re based in Germany:

Value Retail has been appointing Dr Felix Wittern as the data protection officer. Please contact Dr Wittern either at Fieldfisher (Germany) LLP, Am Sandtorkai 68, 20457 Hamburg or by an email to datenschutzbeauftrager@valueretail.com.

When does the policy apply to you

This policy applies to you during your employment relationship with one of our Village brand partners as well as during the evaluations of your competencies in use of our manager competency model and when you attend training events implemented by Value Retail.

Not every individual evaluated in this program holds the title “store manager”. The reason is that we evaluate the employees of Village brand partners who have been formally named by the brands and, who take the following responsibilities:

responsible for the everyday operations and the management of the subsidiary or of several subsidiaries;
responsible for any employment matters of the subsidiary, including the hiring of personnel, performance management, training and personnel development as well as shift scheduling. Large-sized subsidiaries may include assistants to managers and superiors as well as store and category managers;
responsible for the appearance/presentation of the subsidiary and advertisements;
responsible for the product management, including the configuration and receipt of price changes, the handling of damaged products and returns;
responsible for managing the guest experience, including complaints and feedback;
responsible for targets and analysis of any KPIs; and
responsible for the budgeting and the definition of plans to reach these budgets.

How we do collect your personal data

We collect personal data about you provided by your employer, in case assessments are carried out and when you visit training events. These personal data are collected and generated by our employees.

Type of personal data which we do collect

We solely collect personal data and information as may be necessary for your performance evaluation and individual training concepts.

These are the personal data we collect in the context of evaluation processes:

first and last name
business email address
business mobile number
the name of the Value Retail Village where you conduct business
name of your employer (our Village brand partner)
position (job title)
for how long you cover the current position
any essential functional shifts during the last year
the date of your last evaluation
the measurement of your personnel management, mindset, skills, attitude and professional knowledge (which are part of your manager competency model) and, to which extent they apply to your function.

These are personal data we perhaps collect when you attend our training events:

first and last name
business email address
business mobile number
the name of the Value Retail Village where you conduct business
name of your employer (our Village brand partner)
position (job title)
information about the training event (date, time, name of the training event)
attendance record
performance
test or evaluation results

Why we do collect your personal data

We have a legitimate interest in collecting and processing the personal data as stated in this policy, for the following is feasible:

the maintenance of high performance-standards on behalf of the store managers by the emphasizing and developing of strengths and regulations and the support of areas with improvement potential;
securing that all store managers with a below-average performance benefit of appropriate support, complementing training and attention to improve their performance;
the application of an appropriate, aligned and conform evaluation process for all store managers who are working for our Village brand partners;
the creation of evaluation summaries and their issue and forwarding to their employer as well as to other Value Retail employees;
the alignment and evaluation of the store manager performance on the brand partner or Village level or the level of the Value Retail Group, to understand if the program goals are achieved to define trends and improvement potential and to inform stakeholders and the upper management.

The use of your personal data is subject to compliance with the applicable privacy policy and must represent at least one specific legal reason for the processing of data. Examples of such legal reasons represent our legitimate business interests, the prevention and detection of criminal offenses or, the compliance with contractual obligations or applicable labour laws.

We process the personal data of store managers of our Village brand partners for our legitimate business interests. We conducted an assessment to ensure your rights and liberties do not prevail in our interests in processing your personal data according to the pleadings stated in this policy. This evaluation has been raised to implement our method of processing your personal data to ensure your rights are adequately protected. For further information about this assessment, including the exercise of your right to appeal against our decision, please contact us via the contact details stated in the paragraph “Who we are and how you can contact us”.

Besides, we may need your personal data under certain conditions to meet our legal obligations, including those in respect of the handling of complaints and investigations or legal disputes.

How we use your personal data

We use your personal data to provide a discerning performance evaluation process which is custom-tailored to our Villages and to the hospitality and performance we expect from our Village brand partners. The performance evaluation process applies in several steps which have been thoroughly reviewed, to ensure your rights and liberties in terms of your personal data are adequately protected. The overview of this process is shown below:

Biannually, the managers of Value Retail conduct and submit an evaluation of the store managers of the Village brand partners within their responsibility. The evaluation consists of questions in the categories, personnel management, mindset, skills, expert knowledge and attitude as well as a free text area for additional comments in each category.
The training manager of the brand holds a meeting with Village representatives of the sectors visual merchandising, retail management, senior management and hospitality management. These managers discuss and confirm or change the evaluations of the Value Retail managers stated in step 1. This process (named as “calibration process”) ensures achieving a fair and coherent evaluation within each evaluation cycle and that every Value Retail manager, who is in regular communication with the store manager, can actively participate.
At the end of the calibration process, the software issues a chart showing the overall evaluation in each category, including indications about which key competence training topics are the most relevant. Based on this, the training managers of the brand can validate and recommend tailored training components complementing the strong points of the store manager and, addressing areas with improvement potential. A “results report” is issued, including all detailed data as herein stated.
According to the requirements of your employer, we provide him either directly with the results report or arrange a meeting with you, to discuss the recommended training components in person. The recommended training is not mandatory, and participation on your part is dependent on your employer's decision and your personal decision.
We issue two different types of cluster cards, one for the Village and one for our brand partners (if the brand partner is present in more than one Village). The cards give insights into the performance of each store manager in comparison to the respective group. One ranking in the chart may cause more frequent evaluations. A higher rate helps Value Retail to understand whether the recommended trainings and coaching have the desired effect and, also in determining where the store manager may need additional support if there is evidence of a minor improvement or no improvement at all.

Sharing your personal data

We forward the results of the conducted evaluations together with the training recommendations to your employer and to other companies of our group (given that Value Retail has a relationship with these companies). Then, your employer is also the data responsible for the personal data forwarded by us and they will be handled according to his privacy policy and procedure. We forward your personal data to other companies of Value Retail which, for administrative reasons like the management of training events and reporting, need to access them.

In some circumstances, we may share your data with consultants and professional advisors supporting us when required. Please contact us in case you’d like to receive more information about this.

Furthermore, we may in limited cases disclose your data:

towards suppliers processing information and/or personal data on our account related to our use of technology platforms;
if we must disclose or forward your data to meet legal obligations (for example the disclosure towards government authorities and regulatory authorities);
for the protection of rights, property or the safety of our company, our guests or third parties;

We review any third parties appointed by us to ensure they can provide sufficing guarantees with regards to the confidentiality and safety (especially related to technical and organizational matters) of your personal data. We have made written contracts with them containing the warranty in terms of the protection of your personal data and the compliance with our data privacy and any relevant international restrictions of data transfers.

Any information having been collected, generated, circulated and stored for this program are gathered in applications which are contractually provided to us by Cornerstone OnDemand Inc., and are stored in data centres inside the EU. Here you’ll receive a description of these services.

How long do we store your personal data?

We apply accurate analysis methods to make sure that we store your personal data no longer than as may be necessary:

We store personal data as part of the evaluations performed by us for the duration of your tenure with your employer in one of our Villages. If you leave our Village, we delete your personal data within six months.
We store your personal data with regards to recommended trainings, performed pieces of training and training results for the duration of your tenure with your employer in one of our Villages. If you leave our Village, we delete your personal data within six months.
We store your personal data in our email systems according to our storage policies and plans.
We store personal data on our cluster cards for a two-year period.

Privacy and security of your personal data

We are obliged to keep your personal data safe during their entire life cycle, and we take corresponding precautions to protect them against loss, misuse and alteration.

We have implemented guidelines, rules as well as technical and organizational measures in terms of data safety, to protect your personal data against the following:

unauthorized access.
improper use or transfer.
unauthorized alteration.
illegal deletion or accidental loss.

Any of our employees and contractual partners, whom we may pass on your personal data, are obliged to guarantee the confidentiality of your personal data.

How you can access your personal data and exercise your relating rights

You have the following right with regards to your personal data processed by us. You may exercise these rights by sending an email to: RetailExcellence@valueretail.com.

__ Please keep in mind, that in case your request relates to data processed by your employer, we can neither access nor control these data. Your employer is the data responsible for these personal data, and we, therefore, cannot process your inquiry.__

1. Right to information on your personal data processed by us. The right of evident, transparent and coherent information about how we collect and use your personal data. Therefore, we inform you in this respect by reference to this privacy policy.

2. Right to information on the personal data we may process. Upon request, we inform you if we process your personal data and, as the case may be, put at your disposal a copy of the relevant personal data (together with specific further details). If you require multiple copies, we may charge an appropriate fee.

3. Right to alteration of your personal data we may process. If your personal data stored by us are incorrect or incomplete, you have the right to require the adjustment of these data. In case we may have forwarded your personal data to third parties, we will inform them about the alterations where practicable. Upon request, we will also provide you with the information, wherever possible and legitimate, to whom we have forwarded your personal data to enable you to contact the recipient of your data.

4. Right to deletion of your personal data processed by us. Also referred to as “Right to be forgotten”. You can require us to delete or remove your personal data, under certain circumstances, for example, if we do not need them any longer or if you revoke your permission (where applicable). If we have forwarded your personal data to third parties, we will inform them about the deletion request where practicable. Upon request, we will also provide you with the information, wherever possible and legitimate, to whom we have forwarded your personal data to enable you to contact the relevant (natural or legal) persons directly.

5. Right to limitation of the processing of your personal data. If you require us to stop processing your personal data, we may possibly not be able to provide you with all the advantages offered by the program.

You can invite us to suspend or prevent the processing of your personal data, under certain circumstances, for example, if you object to the accuracy of these personal data or you disagree with the processing of your data. We are entitled, nevertheless, to store your data further on. We will inform you before removing a limitation. If we have forwarded your personal data to third parties, we will inform them about the limitation, where practicable. Upon your request, we will also provide you with the information, wherever possible and legitimate, to whom we have forwarded your personal data to enable you to contact the relevant (natural or legal) persons directly.

6. Right to appeal against the processing of your personal data. If you require us to cease the processing of your personal data, we may possibly not be able to provide you with all the advantages offered by the program.

You may require us to cease the processing of your personal data, and we will comply with your request if by processing your personal data we can appeal to our legitimate interests, but not when we can make proof of mandatory legal reasons to proceed with the processing. Our interests must take priority to your interests, rights and liberties or must serve to the enforcement, exercise or defence of titles.

7. Right in terms of automated decision-making and profiling by the use of your personal data. You have the right to not comply with a decision, in case it refers to automated processing, including profiling, entails legal consequences or compromises you in similar form.

8. Right of a complaint before a data protection supervisory authority. If you raise doubts against any clause with regards to our privacy policy practice, including the way how we process personal data, you may report these doubts to your responsible data protection supervising authority. You will find the relevant contacts in the below overview.

The State Representative for Data Protection Baden-Wuerttemberg

Country	Supervisory Authority	Website
United Kingdom	The Information Commissioners’ Office (ICO)	https://ico.org.uk/
Irland	The Data Protection Commission (DPC)	https://www.dataprotection.ie/docs/Home/4.htm
France	Commission Nationale de l’Informatique et des Libertés (CNIL)	https://www.cnil.fr/fr
Italy	Garante per la protezione dei dati personali (Garante)	https://www.garanteprivacy.it/web/guest/home
Spain	Agencia Española de Protección de Datos (AEPD)	https://www.agpd.es/
Belgium	Gegevensbeschermingsautoriteit (GBA) Autorité de protection des données (APD)	https://www.gegevensbeschermingsautoriteit.be/ https://www.autoriteprotectiondonnees.be/
Germany The data protection for organisations in the private sector gets monitored by regional data protection authorities. Value Retail acts in two regions in Germany and, therefore, falls under the responsibility of two supervisory authorities.	Bayern Bayerisches Landesamt für Datenschutzaufsicht (BayLDA) Bavarian State Office for Data Protection Supervision Baden-Württemberg Der Landesbeauftragte für den Datenschutz Baden-Württemberg	https://www.lda.bayern.de/de/index.html https://www.baden-wuerttemberg.datenschutz.de/

Alterations to this policy

We may make alternations to this privacy policy at any time. This policy was updated on April 9, 2019.

To ensure you’re at any time informed about how we use your personal data, we will update this policy from time to time, to take account of alterations in terms of the use of your personal data. We may also change this policy to take account of applicable laws or legal regulations. In case the way of how we process your data may change significantly, we will inform you where possible and appropriate.