Personal Data Fair Processing Notice and Privacy Policy

1. Purpose

This Personal Data Fair Processing Notice and Privacy Policy (“Notice and Policy”) sets out how AlixPartners, LLP and all of its subsidiaries (collectively AlixPartners, the “Firm”, or “our” or “us” or “we”) handles the Personal Data of its People.

2. Scope

This Notice and Policy applies to:

All AlixPartners Partner & Managing Directors, officers and employees (whether full-time or part-time, permanent or temporary employees and including interns and working students) (collectively, “Employees”);¹
All temporary agency workers and contractors (including Senior Advisors, independent contractors, subcontractors and other similarly contracted workers) (collectively “Temporary Service Providers” or “TSPs”),

that have data Processed by AlixPartners (Employees and TSPs collectively referred to as “People”, “you” or “your”). This Policy does not apply to those People assigned to the Firm’s office in Paris, France. See the Paris Policy Page on Axis for the equivalent French policy on this topic.

This Notice and Policy sets out our processing of your Personal Data as a result of your working for, or applying to work for, AlixPartners. This Notice and Policy also sets out what AlixPartners requires from you when you handle and process other AlixPartners’ People’s Personal Data on our behalf in order for AlixPartners to comply with applicable laws. You must read, understand and comply with this Notice and Policy when processing Personal Data on our behalf and complete assigned training on its requirements. Your compliance with this Notice and Policy is mandatory. It is important to remember that ignorance of the law is no defence and non-compliance can bring with it fines, payment of damages, destruction of or inability to exploit valuable data or databases, damage to reputation and personal liability for certain individuals, as well as the loss of certain business opportunities where clients fully expect us to demonstrate compliance in this area before they entrust us with their data. Any breach of this Notice and Policy by an Employee may result in disciplinary action, up to and including termination of your employment. Any breach by a TSP may result in termination of your contract with AlixPartners.

This Notice and Policy does not apply to Personal Data belonging to our clients, business contacts, subscribers, visitors to our AlixPartners website, suppliers and visitors to our offices (“Data Subjects”). Please visit our Website Privacy Policy for more information on the processing of personal data related to the categories of Data Subjects listed above.

3. Personal Data Fair Processing Notice

AlixPartners is a global professional services firm comprising a group of companies established and incorporated in jurisdictions across the world. You have provided, and will in the course of your applying to work and/or working for AlixPartners, provide, certain information about yourself, or AlixPartners has obtained or may obtain (during the course of your working relationship with AlixPartners) such information from third parties.

AlixPartners is committed to protecting the privacy and security of your Personal Data. This Notice and Policy describes how AlixPartners collects and uses Personal Data about you before, during and after your working relationship with us, in accordance with the Data Protection Laws.

Each AlixPartners entity listed below is a “Data Controller”. This means that each entity is responsible for deciding how it holds and uses Personal Data about you. AlixPartners is required under data protection legislation to notify you of the information contained below and in this privacy notice.

AlixPartners, LLP
909 3rd Ave,
New York,
NY 10022,
United States
+1 212-490-2500
[email protected]

AlixPartners UK LLP
6 New Street Square
London, EC4A 3BF
United Kingdom
+44 20 7098 7400
[email protected]

This Notice and Policy applies to all our People. This Notice and Policy does not form part of any contract of employment or other contract to provide services. AlixPartners may update this Fair Processing Notice at any time.

It is important that you read and retain this Fair Processing Notice, together with any other privacy-related notices AlixPartners may provide on specific occasions when AlixPartners is collecting or processing Personal Data about you so that you are aware of how and why AlixPartners is using such information and what your rights are under the Data Protection Laws.

3.1 Data Protection Principles

AlixPartners will comply with applicable data protection law which requires AlixPartners to ensure that the Personal Data that AlixPartners holds about you must be:

Used lawfully, fairly and in a transparent way
Collected only for valid purposes that AlixPartners has clearly explained to you and not used in any way that is incompatible with those purposes
Relevant to the purposes AlixPartners has told you about and limited only to those purposes
Accurate and kept up to date
Kept only as long as necessary for the purposes AlixPartners has told you about
Kept securely

Depending on the nature of your working relationship with AlixPartners (i.e. whether you are a job candidate, Employee or Temporary Service Provider), we may process Personal Data about you that you have provided to us, or which we have obtained, or may obtain from third parties including the following (not all of which will be applicable to job candidates or TSPs):

Your address
Your personal contact details, including your email address and phone numbers
Your date of birth
Your career compensation history
Your immigration status and work permit information
Your educational history
Your career history, including your date of hire and previous jobs
Your gender
Your geolocation
Your national insurance number, social security number, national ID number or similar information
Your bank, building society or other financial institution details
Pre-employment assessment testing results and evaluation
Employment status
Employee number
Copy of driving license / passport
Recruitment or hiring information (including copies of right to work documentation, references and other information included in a resume/CV or cover letter or as part of the application process)

In the course of your working relationship with AlixPartners, further information about you could be generated, including, but not limited to the following (not all of which will be applicable to TSPs):

The compensation (e.g., salary, incentives, bonuses etc.) you receive from AlixPartners for your work or services (as the case may be)
Assessment and appraisal information regarding your performance
Training and development
Work attendance records
Location of your workplaces
Job titles, work history, working hours, holidays, training records and professional memberships
Disciplinary, grievance and investigation information to monitor compliance with internal policies and procedures and address concerns related to workplace related matters.
CCTV footage and other information obtained through electronic means such as entry card records
Information about your use of AlixPartners information and communications systems, in particular access information and rights, usage data, communication and content provided by your log data
Photographs of you taken in connection with your working for AlixPartners
Payroll information

Depending on the nature of your working relationship with AlixPartners (i.e. whether you are a job candidate, Employee, Contractor or any other type of worker), we may, when lawfully permitted to do so, also collect, store and use the following categories of Sensitive Personal Data.

For Employees, this may include, but is not limited to, the following:

Information about your race or ethnicity, religious beliefs, and sexual orientation
Trade union membership
Information about your health, including any medical condition, health and sickness records, including:
- where you leave employment and the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision
- details of any absences (other than holidays) from work including time on family-related leave, sick leave or other leaves of absence
- details of your health that may be relevant to insurance coverage
- details of your health that may be relevant to your ability to work and/ or any adjustments required to accommodate your health and/ or any medical condition; and
- where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
Information about criminal convictions and offences.

For Temporary Service Providers, this may include, but is not limited to, the following:

Information about your race or ethnicity, religious beliefs, and sexual orientation
Trade union membership
Information about your health, including any medical condition, health and sickness records, including
- details of your health that may be relevant to your ability to work and/ or any adjustments required to accommodate your health and/ or any medical condition and/or your ceasing to work for AlixPartners either temporarily or permanently.
Information about criminal convictions and offences.

AlixPartners and its subsidiaries have entered into an Intragroup Agreement incorporating the Standard Contractual Clauses. This agreement governs the collection, storage, use, retention, transfer and other processing of personal information transferred from the EEA or any jurisdiction in which we have an office to the U.S..

3.2 Purposes of AlixPartners use of your Personal Data

AlixPartners will only use your Personal Data when the law permits it. Most commonly, AlixPartners will use your Personal Data in the following circumstances:

Where AlixPartners needs to perform the contract it has entered into with you
Where AlixPartners maintains a professional relationship with you
Where AlixPartners needs to comply with a legal obligation, including to meet national security or law enforcement requirements
If permitted in the jurisdiction, where it is necessary for AlixPartners’ legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

(the foregoing together are known as “Purposes”)

Depending on the nature of your relationship with AlixPartners, below are some Purposes for which AlixPartners will process your Personal Data.

If you are an Employee:

Making decisions about your recruitment or employment
Determining the terms on which you work for AlixPartners
Paying you and deducting tax and other applicable social costs
Providing the benefits that the AlixPartners entity offers to you as part of your employment
Enabling your participation in Employee Resource Groups
Communicating to internal and external stakeholders about events, accomplishments, and other news of AlixPartners where you may be featured
Inviting you to participate in any equity plans or similar schemes operated by AlixPartners
Granting awards under any equity plans or similar schemes operated by AlixPartners
Administering your participation in any equity plans or similar schemes operated by AlixPartners, including communicating with you about your participation and collecting any tax due on any awards
Enrolling you in pension arrangements
Liaising with the trustees or managers of a pension arrangement operated by an AlixPartners entity, your private pension provider, and any other provider of employee benefits
Conducting performance reviews, managing performance, and determining performance requirements
Making decisions about salary and compensation
Gathering evidence for possible grievance or disciplinary hearings or to conduct investigations or address concerns related to workplace related matters
Managing absences
Complying with health and safety obligations
Conducting data analytics studies to review and better understand employee retention and attrition rates
Equal opportunities monitoring
Checking you are legally entitled to work in the locations you will be required to work
Administering the contract AlixPartners has entered into with you
Business management and planning, including accounting and auditing
Making decisions about your employment with AlixPartners, including termination of that relationship
Making arrangements for the termination of your employment with AlixPartners
Assessing qualifications for a particular role or piece of work, including decisions about promotions
Dealing with legal disputes involving you, or other People, including accidents at work
Ascertaining your fitness to work
Preventing fraud
Monitoring your use of AlixPartners’ information and communication systems to ensure compliance with AlixPartners’ IT policies (to the extent permitted by local law).
Ensuring network and information security, including preventing unauthorized access to AlixPartners’ computer and electronic communications systems and preventing malicious software distribution.
Enabling AlixPartners to perform its agreements with its clients, including meeting client specific requirements such as background checks, concluding the contracts with its clients, provision of services, and invoicing AlixPartners clients for fees for such services.

If you are a Temporary Service Provider:

Checking you are legally entitled to work in the locations you will be required to work
Administering the contract AlixPartners has entered into with you
Business management and planning, including accounting and auditing
Making decisions about your working relationship with AlixPartners, including termination that relationship
Making arrangements for the termination of your working relationship with AlixPartners
Assessing qualifications for a particular role or piece of work
Dealing with legal disputes involving you, or other People, including accidents at work
Ascertaining your fitness to work
Preventing fraud
Monitoring your use of AlixPartners’ information and communication systems to ensure compliance with AlixPartners’ IT policies (to the extent permitted by local law)
Ensuring network and information security, including preventing unauthorized access to AlixPartners’ computer and electronic communications systems and preventing malicious
software distribution
Enabling AlixPartners to perform its agreements with its clients, including meeting client specific requirements such as background checks, concluding the contracts with its
clients, provision of services, and invoicing AlixPartners clients for fees for such services.
Making a decision about your recruitment or appointment
Determining the terms on which you work for AlixPartners, including compensation
Paying you Communicating to internal and external stakeholders about events, accomplishments, and other news of AlixPartners where you may be featured
Gathering evidence to conduct investigations
Complying with health and safety obligations

Each AlixPartners entity is collecting, generating, processing, holding and receiving your Personal Data for the Purposes and may transfer your Personal Data to third-party services providers for the Purposes (including before and during your working relationship with AlixPartners and for a reasonable period thereafter) in particular:

AlixPartners collecting and using your Personal Data to administer and operate processes as your employer, client or recipient of your services
AlixPartners transferring your Personal Data to other AlixPartners entities, including providing your Personal Data to, in electronic format, AlixPartners, LLP (a company
incorporated in Delaware, USA (“AlixPartners, LLP”) in order for AlixPartners to operate centralised systems for managing its People.
AlixPartners storing and processing your Personal Data for the administration and management of your working relationship with AlixPartners
For Employees only: AlixPartners will collect and use your personal Data for human resources and human capital management purposes including review of your performance and your professional development within AlixPartners and any performance corrective measures that AlixPartners considers necessary; and
AlixPartners transferring your Personal Data to third parties that provide services to AlixPartners relating to the Purposes which, depending on the nature of your relationship with AlixPartners, may include the following (which may not all be applicable to both Employees and TSPs): human resources and human capital management services, payroll services, banks (for the purpose of invoice payment or payroll services), employee assistance, professional travel services, vendors and suppliers providing services to clients of AlixPartners, tax authorities, immigration advisors, benefits providers, marketing services, event managers, medical advisors, data storage facilities and cloud service providers.

AlixPartners will take steps to work with reputable third-party vendors that operate in accordance with all applicable laws and have robust data security systems and processes in place. We will also enter into data processing agreements with these third parties in accordance with privacy laws and to safeguard your Personal Data. For vendors located in third countries, AlixPartners will execute the required Standard Contractual Clauses and take appropriate steps to ensure that necessary supplemental technical and organizational measures are in place to maintain an < adequate level of data protection.

3.3 Failure to provide Personal Data

If you fail to provide AlixPartners with certain information when requested, AlixPartners may not be able to perform the contract AlixPartners has entered into with you (such as paying you or providing a benefit), or AlixPartners may be prevented from complying with its legal obligations (such as to ensure the health and safety of AlixPartners workers). In some circumstances, this failure may lead to termination of your working relationship with AlixPartners, as permitted by applicable law.

3.4 Change in Purpose

AlixPartners will only use your Personal Data for the purposes for which AlixPartners collected it unless AlixPartners reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose. If AlixPartners needs to use your Personal Data for an unrelated purpose, AlixPartners will notify you and such notification will explain the legal basis which permits AlixPartners to do so.

Please note that AlixPartners may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3.5 AlixPartners’ use of Sensitive Personal Data

Sensitive Personal Data requires higher levels of protection. AlixPartners needs to have further justification for collecting, storing and using this type of Personal Data. AlixPartners has in place an appropriate policy document and safeguards which AlixPartners is required by law to maintain when processing such data. AlixPartners may process your special categories of Personal Data in the following circumstances:

Information relating to leaves of absence, which may include sickness absence or family related leaves, will be used to comply with employment and other laws and AlixPartners policies (for Employees only)
If you require any adjustments to accommodate your health and/or any medical conditions
If you leave employment and participate in any equity plan or similar scheme operated by AlixPartners and the reason for leaving is determined to be ill-health, injury or disability, AlixPartners will use information about your physical or mental health, or disability status in reaching a decision about your entitlements under the plan (for Employees only)
Where it is needed in the public interest, such as for equal opportunities monitoring and reporting)
For facilitating your participation in benefit schemes including pension scheme(s), health insurance and/ or income protection insurance (for Employees only).
Where AlixPartners needs to carry out its legal obligations or exercise rights in connection with your employment or engagement
In limited circumstances, with your explicit written consent

Less commonly, AlixPartners may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. AlixPartners may also process if permitted by applicable law, such information about People or former People in the course of legitimate business activities with the appropriate safeguards.

3.6 Personal Data concerning criminal convictions

AlixPartners may only use information relating to criminal convictions where the law allows AlixPartners to do so. This will usually be where such processing is necessary to carry out AlixPartners’ obligations and provided AlixPartners does so in line with this Notice and Policy.

Less commonly, AlixPartners may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

AlixPartners envisages that it will hold Personal Data about criminal convictions, which will, because of its subject matter, amount to Sensitive Personal Data.

AlixPartners will only collect information about criminal convictions if it is appropriate given the nature of your role and where AlixPartners is legally able to do so. Where appropriate, AlixPartners will collect information about criminal convictions as part of the recruitment process or, in the case of TSPs, the process of engaging such TSPs.

3.7 Retention of your Personal Data

AlixPartners will only retain your Personal Data for as long as necessary to fulfil the purposes AlixPartners collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, AlixPartners considers the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which AlixPartners processes your Personal Data and whether AlixPartners can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, AlixPartners may anonymise your Personal Data so that it can no longer be associated with you, in which case AlixPartners may use such information without further notice to you. Once you are no longer a member of AlixPartners, AlixPartners will retain and securely destroy your Personal Data in accordance with our Record Retention Policy and applicable laws and regulations.

3.8 Yours duties and rights in relation to your Personal Data

Depending on the jurisdiction you are in and under certain circumstances, you may have the ability to exercise certain data rights. To understand the data rights afforded to you in your jurisdiction see Appendix A.

If you want to exercise your rights, please click on the appropriate jurisdiction.

If you are in the UK or the European Economic Area (EEA)², please click here.

If you are in Argentina, please click here.

If you are in California, please click here. Alternatively, you may call 212-490-2500.

If you are in any other jurisdiction, please click here.

You will not have to pay a fee to access the Personal Data (or to exercise any of the other rights). However, AlixPartners may charge a reasonable fee (if permitted by law) if your request for access is clearly unfounded or excessive. Alternatively, AlixPartners may refuse to comply with the request in such circumstances.

AlixPartners may need to request specific information from you to help AlixPartners confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data (including Sensitive Personal Data) by AlixPartners, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please select your appropriate jurisdiction and complete one of the forms above. Once AlixPartners has received notification that you have withdrawn your consent, AlixPartners will no longer process your information for the purpose or purposes you originally agreed to unless AlixPartners have another legal basis for doing so.

AlixPartners does not use automated decision-making in relation to your personal data to fulfill any of the Purposes outlined in this Notice and Policy. All decisions regarding your role, performance, and any work-related matters are made by individuals and not by any automated systems or algorithms.

If you would like to know more about any matters covered in this privacy notice, or, wish to discuss any matter set out in this privacy notice, please contact: [email protected].

4. AlixPartners Handling of Your Personal Data

We recognise that the correct and lawful treatment of our People’s Personal Data will maintain
confidence of our People in the Firm and will provide for successful business operations. Protecting the confidentiality and integrity of our People’s Personal Data is a critical responsibility that we take seriously at all times. The Legal, Compliance, and Risk Team (“Legal”) is responsible for overseeing this Notice and Policy and, as applicable, developing Related Policies and Privacy Guidelines. Legal has implemented the appropriate practices, procedures, controls and training for People that handle other People’s Personal Data in order to comply with the contents of this Notice and Policy. Legal can be reached at [email protected].

4.1 Personal Data and Protection Principles

We adhere to the following data protection principles relating to the processing of our People’s
Personal Data:

Personal Data is processed lawfully, fairly and in a transparent manner:
- AlixPartners and its People may only collect, process and share Personal Data fairly and lawfully and for specified purposes. Various privacy laws restrict our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent processing but ensure that we process Personal Data fairly and without adversely affecting the individual to whom the Personal Data relates
Personal Data is collected only for specified, explicit and legitimate purposes.
- Personal Data collected may only be used for the legitimate business purpose related to the Purposes listed in this Notice and Policy
Personal Data processing is adequate, relevant and limited to what is necessary for relation to the purposes for which it was collected:
- Personal Data must not be retained for longer than is necessary for the purposes for which the data is processed. AlixPartners and its People will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all AlixPartners’ applicable records retention schedules and policies. This includes requiring third parties (e.g. AlixPartners’ subcontractors) to delete such data where applicable.
Personal Data is accurate and where necessary kept up to date:
- It must be corrected or deleted without delay when we become aware that it is inaccurate.
Personal Data must not be kept in a form which permits the identification of the relevant
individuals for longer than is necessary for the purposes for which the data is processed.
Personal Data must be processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Personal Data must not be transferred to another country without appropriate safeguards being in place, including where relevant, executing the required Standard Contractual Clauses and implementing the appropriate supplementary measures to ensure an adequate level of data protection in the country where the data is processed
Personal Data must be made available on request to the individuals to whom the Personal Data relates and those

We have safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we process and identified risks (including use of encryption where applicable) in place. We will regularly evaluate and test the effectiveness of those safeguards to ensure the continued security of our Processing of Personal Data.

You must also play your part in protecting the Personal Data we hold. This means that you take certain measures to safeguard against the accidental loss of, or damage to, Personal Data, e.g. filing records promptly, cleaning your desk of papers at night and ensuring they are locked away, using shredders and not sharing your passwords. You must exercise particular care in protecting Sensitive Personal Data from loss and unauthorised access, use or disclosure.

You must comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the Data Protection Laws

4.2 Reporting a security breach

Data Protection Laws may require AlixPartners to notify authorities and Data Subjects of breaches of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data. We have put in place procedures to deal with any suspected Personal Data breach.

If you know or suspect that any type of personal data breach has occurred, do not attempt to investigate the matter yourself. Immediately contact [email protected]. You should preserve all evidence relating to the potential security breach.

4.3 Transfer Limitation

4.4 Data Subject’s rights and requests

Data Subjects have rights when it comes to how we handle their Personal Data.

You must immediately forward any request from individuals relating to their Personal Data that you receive to Legal Counsel – Privacy and Data Security at [email protected].

4.5 Compliance

AlixPartners must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. You must follow and comply with all such technical and organisational measures that AlixPartners implements.

4.6 Record Keeping

Data Protection laws require us to keep full and accurate records of all our processing of Personal Data.

You must keep and maintain accurate corporate records reflecting our Processing including records of any individuals’ consents and procedures for obtaining consents.

These records should include, at a minimum, clear descriptions of the Personal Data types, the types and categories of the individuals to which the Personal Data relates, the processing activities we are undertaking, the purposes of the processing, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data's retention period and a description of the security measures in place.

4.7 Training and Audit

AlixPartners is required to ensure all our People have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.

You must complete all mandatory data privacy related training and ensure your team undergo similar mandatory training in accordance with the AlixPartners’ mandatory training guidelines and AlixPartners’ CORE training.

You must regularly review all the systems and processes under your control to ensure they comply with this Notice and Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

4.8 Sharing Personal Data

AlixPartners and our People are bound by the duty of confidentiality when Processing all Personal Data. Generally, we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.

You may only share the Personal Data we hold with other People, or any agent or representative of AlixPartners if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions

You may only share the Personal Data we hold with third parties, such as our professional advisors or service providers if:

they have a need to know the information for the purposes of providing the contracted services;
sharing the Personal Data complies with the relevant individual’s consent or there is a clear lawful basis on which to share their Personal Data;
the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
the transfer complies with any applicable cross border transfer restrictions; and
a fully executed written contract that contains the appropriate language as required by the relevant Data Protection laws.

If in doubt, please contact [email protected].

5. Definitions

Data Controller – determines the purposes and means of processing Personal Data. Also known as a “Business” under California law

Data Processor – a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. Also known as a “Service Provider” under California law

Data Protection Laws – All privacy and data protection laws that must be complied with by AlixPartners

Data Subjects – the natural or legal person that Personal Data describes. Also known as a “Consumer” under California law

Employees – All AlixPartners Partner & Managing Directors, officers and employees whether full time or part-time, permanent or temporary employees and including interns and working students

Personal Data – any information relating to a Data Subject. Also known as “Personal Information” under California law

Processing – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

Sensitive Personal Data – a subcategory of Personal Data that, if compromised, could lead to a serious harm to the data subject. Also known as “Special Categories of Personal Data” under the GDPR

Temporary Service Providers (TSPs) – All temporary agency workers and contractors including Senior Advisors, independent contractors, subcontractors and other similarly contracted workers

6. Changes to This Notice and Policy

This Notice and Policy may be modified from time to time and the latest version of the Notice and Policy is accessible online on the Global Policy Resource Center page of AlixPartners’ intranet. You will be informed about the online posting of any new version implying material changes. You will be expected to be familiar with the current Notice and Policy. AlixPartners reserves the right to audit compliance with this Notice and Policy.

This Notice and Policy does not override any applicable national data privacy laws and regulations in countries where AlixPartners operates.

7. Document Review

This Notice and Policy will be reviewed at least every two (2) years. This Policy was last updated on 2025 – FEB – 04.

8. Enforcement

The Firm will take prompt and appropriate corrective action when it determines that a violation of this Notice and Policy has occurred. Any Employee, regardless of position or title, whom the Firm determines has violated this Notice and Policy, will be subject to discipline, up to and including termination. Any Temporary Service Provider who the Firm determines has violated this Notice and Policy will have their contract with the Firm terminated. Actions that violate this Notice and Policy will not be considered to be within the course of any Employee’s employment or in the discharge of any TSP’s duties.

9. Related Information

All policies, procedures, and standards referenced in this document are listed below and can be found on the firm’s Global Policy Resource Center.

Record Retention Policy
Data Protection Quick Guide

Appendix A

1. Data Rights for the UK, Switzerland, and the European Economic Area – the General Data Protection Regulation (GDPR)

Under certain circumstances, you have the right to:

Request access to your Personal Data (commonly known as a “Data Subject access request”). This enables you to receive a copy of the Personal Data AlixPartners holds about you and to check that AlixPartners are lawfully processing it
Request correction of the Personal Data that AlixPartners holds about you. This enables you to have any incomplete or inaccurate information AlixPartners holds about you corrected
Request erasure of your Personal Data. This enables you to ask AlixPartners to delete or remove Personal Data where there is no good reason for AlixPartners continuing to process it. You also have the right to ask AlixPartners to delete or remove your Personal Data where you have exercised your right to object to processing
Object to processing of your Personal Data where AlixPartners is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground
Request the restriction of processing of your Personal Data. This enables you to ask AlixPartners to suspend the processing of Personal Data about you, for example if you want AlixPartners to establish its accuracy or the reason for processing it; and
Request the transfer of your Personal Data to another party

2. Data Rights for Argentina – the Argentine Data Protection Regulations (ADPR)

Under certain circumstance, you have the right to:

Request access to your Personal Data (commonly known as a “Data Subject access request”). This enables you to receive a copy of the Personal Data AlixPartners holds about you and to check that AlixPartners are lawfully processing it
Request correction of the Personal Data that AlixPartners holds about you. This enables you to have any incomplete or inaccurate information AlixPartners holds about you corrected
Request erasure of your Personal Data. This enables you to ask AlixPartners to delete or remove Personal Data where there is no good reason for AlixPartners continuing to process it.
Notify the Argentine Personal Data Protection Agency of complaints and claims in connection to a breach of Personal Data protection laws and regulations

3. Data Rights for California – the California Consumer Protection Act (CCPA)

Under certain circumstance, you have the right to:

Request access to your Personal Data (commonly known as a “Data Subject access request”). This enables you to receive a copy of the Personal Data AlixPartners holds about you and to check that AlixPartners are lawfully processing it
Request the transfer of your Personal Data to another party.
Request erasure of your Personal Data. This enables you to ask AlixPartners to delete or remove Personal Data where there is no good reason for AlixPartners continuing to process it.
Request AlixPartners not sell or transfer your Personal Data

4. Data Rights for Dubai International Financial Centre ('DIFC')

Under certain circumstances, you have the right to:

Request access to your Personal Data (commonly known as a “Data Subject access request”). This enables you to receive a copy of the Personal Data AlixPartners holds about you and to check that AlixPartners are lawfully processing it
Request erasure of your Personal Data. This enables you to ask AlixPartners to delete or remove Personal Data where there is no good reason for AlixPartners continuing to process it. You also have the right to ask AlixPartners to delete or remove your Personal Data where you have exercised your right to object to processing
Object to processing of your Personal Data where AlixPartners is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground
Request the restriction of processing of your Personal Data. This enables you to ask AlixPartners to suspend the processing of Personal Data about you, for example if you want AlixPartners to establish its accuracy or the reason for processing it; and
Request the transfer of your Personal Data to another party.

5. Data Rights for Other Jurisdiction

If you are located in a jurisdiction not listed above, you may still have individual data rights. Please submit your Request for evaluation, and AlixPartners will respond in accordance with the applicable law.

¹ If you are a Partner & Managing Director of AlixPartners UK LLP, you should read references in this Notice and Policy to “Employee”, “employed” or “employment” by AlixPartners as applying to you, although you are a non-employed LLP member.

²EEA means the European Union (EU), Norway, Liechtenstein, and Iceland.