Applicant Privacy Notice

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This Applicant Privacy Notice describes how NCR Atleos Corporation and its subsidiaries (collectively, “NCR Atleos”) use your Personal Data in connection with NCR Atleos application, recruiting and hiring process. This notice supplements NCR’s Privacy Policy, which is available at www.ncratleos.com/privacy.

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Whenever you see the following terms in this notice, they have the following meaning.

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“Personal Data” means any data relating to you, whether you are directly identified by the data or can be identified by that data in combination with other data.

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“Process” means any action we may take on your Personal Data, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

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“Special Categories of Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; the Processing of genetic data or biometric data for the purpose of uniquely identifying a natural person; and data concerning health or data concerning a natural person’s sex life or sexual orientation.

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How We Obtain Personal Data

We Collect Personal Data That You Provide to Us. During the application, recruiting and hiring process, you may provide Personal Data to NCR Atleos in many ways, including by registering for an online account in the NCR Atleos Careers website, completing your profile in your account, applying for employment, or providing NCR Atleos with information about you, for example in your resume or curriculum vitae or during interview conversations. Personal Data we may ask you to provide may include your name, address, telephone number, email address, educational transcripts, and employment history.
We Collect Personal Data from Third Parties. During the recruitment and hiring process, NCR Atleos may collect or obtain Personal Data from third parties, for example, by performing or (with your prior written consent, where required by law) having performed a pre-employment verification or background check. The scope of review will vary based on jurisdiction, local law, and the requirements of the position, but examples of such data may include confirmation of education, driving records for NCR Atleos fleet vehicle program eligibility, records of criminal convictions for serious offenses, and credit history for positions involving financial risk.
We Collect Personal Data through Use of Cookies and Other Technologies. We may use cookies, alone or in combination with other data we may collect from other technologies (such as server logs) to make our website work or operate more efficiently, to personalize your experience, or to make our website more useful to you. Most browsers permit users to change their settings either to refuse all cookies or to selectively accept them. If you would like to change your browser’s cookies settings, please refer to the online help offered with your browser or to the manufacturer’s website. Note, however, if you decide to turn off cookies, there may be some features of our websites that may not be available to you and some pages may not display properly. For more information on how NCR Atleos uses cookies and other technologies, please see NCR Atleos Privacy Policy, which is available at www.ncratleos.com/privacy.

You may choose not to provide or authorize NCR Atleos to obtain Personal Data. If you decline to do so, however, it may affect NCR Atleos ability to review or progress your employment application where the Personal Data we require is relevant to NCR Atleos ability to evaluate your application.

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‍‍Why We Process Personal Data

Generally, NCR Atleos Processes information about you as necessary to facilitate the application, recruiting and hiring process. As such, we may Process your data based on one or more of the following legal justifications:

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We Process Personal Data with Your Consent: By opening an account on the NCR Atleos Careers site, you are consenting to allow NCR Atleos to Process your Personal Data to consider you for employment, including for open positions for which you have not submitted an application.

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You may withdraw your consent to this Processing at any time; however, doing so will not affect the lawfulness of NCR Atleos Processing before your withdrawal of consent, and doing so may affect NCR Atleos ability to progress your employment application if we are precluded from Processing information that is relevant to such application.

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We Process Your Data to Prepare to Enter Into, or to Enter Into, a Contract with You: In some countries, NCR Atleos is required to enter into employment contracts with its employees If you receive a job offer from NCR Atleos, and if NCR Atleos executes an employment contract with you, NCR Atleos Processes Personal Data such as your name, address, contact information, and other information as may be required to establish and perform its employment contract with you and for additional employment and business purposes.

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We Process Personal Data to Comply with Legal Requirements to which We Are Subject: NCR Atleos is subject to numerous legal requirements that require us to Process your Personal Data. Accordingly, we may Process your information for purposes of complying with these obligations where we are required to do so. For example, in some jurisdictions, we must collect information to comply with equal employment requirements, tax laws, and similar uses. In addition, NCR Atleos may be required as part of the onboarding process to:

Provide regulators with information about its compliance with equal employment requirements. In such cases, we may collect information relating to your gender, racial or ethnic background, or similar characteristics (see below on how we Process Special Categories of Data).
Remit information for or on your behalf to certain tax authorities. In this case, and as part of our onboarding process, NCR Atleos may be required to collect your tax identification number at the time of hire to facilitate its compliance with applicable tax laws.
Verify and demonstrate that you have a right to work in the jurisdiction in which you are seeking employment. As part of our onboarding process, NCR Atleos may request information about your authorization to work status to facilitate its compliance with these regulatory requirements.

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We Process Your Data for Our Legitimate Business Interests or Those of a Third Party: NCR Atleos Processes Personal Data in furtherance of our legitimate business interests, including to manage our recruitment and hiring process, to facilitate our compliance with our corporate governance requirements, to identify and contact candidates, to evaluate candidates and make hiring decisions, to keep records about our hiring practices, and to match individuals with career opportunities within NCR Atleos. We also may use the data to pursue or defend a legal claim or to support a potential merger, acquisition or reorganization of all or part of NCR Atleos business.

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Processing of Special Categories of Data and Other Sensitive Data

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NCR Atleos does not request or require information about Special Categories of Data during the recruitment and hiring process, unless we are required to do so by law or where you have otherwise explicitly consented. For example, in some countries NCR Atleos may ask for information about your race or ethnicity to comply with government reporting requirements; however, you may decline to provide this information. If you provide this information it will not be viewable to NCR Atleos personnel during the hiring or selection process. NCR Atleos may require data that may reveal your health if they are necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as they are authorised by local law or a collective agreement providing for appropriate safeguards for the fundamental rights and the interests of the data subject. Further, you may provide information about your health or physical limitations to facilitate consideration about your ability to perform certain required functions of the job for which you have applied or whether any adjustments to your workplace might be appropriate to accommodate for physical limitations.

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In addition, NCR Atleos may also Process Personal Data that may be subject to special protection under applicable law. For example, if required or permitted by local law, NCR Atleos may inquire about your criminal history. Such Personal Data may be used to determine your suitability for employment and will be Processed in accordance with applicable legal requirements.

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Disclosures and Transfers of Your Personal Data

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Your Personal Data will be shared only with NCR Atleos employees, contractors, and service providers who have a business need to know it. For example, we may share your data with:

employees of NCR Atleos group companies who support the recruitment or hiring Process and other NCR Atleos entities as required or permitted by applicable law;
attorneys, auditors, consultants, law enforcement and government officials, to protect our respective legal rights or property, and/or the rights or property of our customers, business partners, or suppliers, or other third parties;
potential purchasers or investors and their advisors in the case of an actual or potential purchase, divestiture, merger, change of control, transfer, or reorganisation;
service providers, in the course of their performance of services to NCR Atleos. Examples of such service providers include:
Recruitment systems and HR systems vendors
Recruiters
Payroll vendors (as part of the onboarding process)
Document management vendors
Relocation service providers (if applicable, as part of the onboarding process)
Background verification providers (with your consent, where required by law)
Benefits and insurance providers (as part of the onboarding process)
Providers of systems that facilitate complaint and inquiry management
IT providers, including security providers and email providers
Contracted Staff
Consultants

When we disclose Personal Data to third parties, it is our policy to transfer such data supported by appropriate safeguards. Examples of such safeguards include requiring the third party to implement appropriate security and privacy controls and including appropriate contract terms designed to hold the third party accountable for preserving the privacy, confidentiality, integrity and availability of Personal Data.

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NCR Atleos operates on a global basis, and your Personal Data may be transferred outside to other NCR Atleos group companies or to third party organizations located outside of your country. Some of these countries have laws that may not provide the same level of protection as the laws of your country. It is NCR Atleos policy to transfer such data supported by appropriate safeguards that are designed to respect your privacy. Each NCR Atleos group company has signed onto an Intra-group Data Transfer Agreement that requires the protection of Personal Data. Please contact NCR Atleos Privacy Office (AtleosPrivacy.Office@ncratleos.com) for more information about this agreement and for a list of all countries in which NCR Atleos does business. With respect to third parties, it is Company policy to enter into appropriate agreements designed to ensure the privacy and security of your data.

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Retention of Personal Data

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If you are hired, NCR Atleos will retain Personal Data provided during the recruiting process for use in connection with your employment and other legitimate business purposes. Such use is governed by and subject to NCR Atleos Employee Privacy Notice and corporate policies, which will be provided to you during the hiring process.

If you have applied for a position with NCR Atleos but are not hired, NCR Atleos may retain a copy of your Personal Data for up to two years in accordance with its policies and applicable law. With your separate consent, where required by law, we may, for example use this Personal Data for future vacancies.

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Your Individual Rights

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Many jurisdictions provide you with certain rights with regard to your Personal Data, subject to certain exceptions. NCR Atleos will comply with these laws. For example, in many countries, including the Member States of the European Union:

You have the right to obtain confirmation from us whether your Personal Data is being Processed by us, the right to request from us access to your Personal Data, and certain details about your information we Process.
You have the right to request that we rectify incorrect information about you and to have incomplete Personal Data completed.
You may have the right to have your data erased, for example where the data is no longer needed for the purpose for which they were collected; where you have withdrawn consent and there is no other legal ground for Processing; where you object to Processing based on our legitimate interests, and NCR Atleos has no compelling reason to continue with such Processing; where the Processing was illegal; or where erasure is required by law to which NCR Atleos is subject.
You may have the right to restrict Processing of your information, including while NCR Atleos undertakes to verify the accuracy of your data where you have contested its accuracy; where NCR Atleos Processing is unlawful and you have the right to erasure, but request that we restrict Processing instead; where the data are no longer needed for the purposes of the Processing by us, but they may be required by you for the pursuit or defense of a legal claim, or by NCR Atleos where its legitimate interests override your request for restriction.
You may have the right to data portability of information you have provided to NCR Atleos, for example, where we Process information by automated means based on your consent, or pursuant to a contract with you.
You may have the right to object to the Processing of your Personal Data, i.e. where your Personal Data is Processed for marketing purposes.

We may provide certain tools to enable you to exercise your rights in whole or in part. For example, you may access, modify or deactivate your profile at any time by logging into the NCR Atleos Careers website (www.ncratleos.com/careers) and accessing the “My Account Options” link. If you opt to deactivate your profile, it will become inaccessible to NCR Atleos recruiters and others involved in the hiring Process immediately. Your profile will be deactivated, and your data will be anonymized or deleted as a matter of course after 24 months of inactivity or upon your account deactivation.

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Automated Individual Decision Making. We may utilize automated Processing techniques for candidate applications for qualitative scoring or ranking in order to optimize the efficiency of our recruiting practices. We utilize these techniques, for example, to automatically determine whether candidates fulfil threshold requirements, such as grades, and if such threshold requirements are not fulfilled, an application may not be considered. Such Processing is overseen by our Human Resources personnel. However, our policy is never to make decisions based solely on these automated Processing techniques.

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Data Security and Confidentiality

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NCR Atleos has implemented and maintains, and requires its third-party vendors and service providers who may receive or Process your Personal Data to implement and maintain, reasonable and appropriate physical, technical and organizational measures designed to secure your Personal Data from accidental loss or unauthorized access, use, alteration or disclosure.

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Inquiries about this Data Protection Statement

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NCR Atleos strives to be transparent with our data handling practices, and we welcome any questions or concerns you may have. You may contact us as follows: global.hrcentral@ncratleos.com
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In some countries, such as the Member States of the European Union, you may also lodge complaints about NCR Atleos data handling practices if you do not believe we have complied with the law with your local privacy regulator.

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Note:  Cardtronics USA, Inc., is the legal entity name in the U.S. for the NCR Atleos business.

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Thank you for your business, and please do not hesitate to reach out to your NCR Atleos account executive if you have any questions.

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NCR Atleos Privacy Policy effective October 16,2023.

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NCR Atleos Corporation is committed to implementing leading data protection standards to protect the confidentiality and integrity of Personal Data (as defined below) that we Process (as defined below), including Personal Data to which NCR ATLEOS has access in connection with the provision of products and services to our customers. This policy governs NCR ATLEOS Corporation and its global subsidiaries, including Cardtronics PLC and the Cardtronics group of companies (collectively “NCR ATLEOS”) worldwide for all operations where NCR ATLEOS is the Controller of Personal Data.

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Definitions

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“Contract Data” means any Personal Data about our customers, our customers’ customers, or our customers’ personnel that NCR ATLEOS Processes in connection with providing products or services to a customer under a contract.

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“Controller” means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

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“Personal Data” means information relating to an identified or identifiable natural person to the extent such information is afforded the protection of law. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identification number, location data, an online identifier or to one or more factors specific to the individual’s physical, physiological, mental, economic, cultural, or social identity. In the state of California, Personal Data may also include categories of information that identify or could be linked to a particular consumer or household such as identifiers, bank account and payment card numbers, Protected Class characteristics, commercial information, biometric information, professional, educational or employment-related information, Internet or electronic network activity, and inferences used to create a profile about a consumer in accordance with applicable law.

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“Process” means any operation or set of operations that is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, blocking, erasure, or destruction.

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“Processor” means a natural or legal person, public authority, agency or other body which Processes Personal Data on behalf of a Controller.

“Special Categories,” “Sensitive Personal Data,” or “Characteristics of Protected Class(es)” (collectively, “Special Categories”) means, to the extent designated under applicable law, Personal Data revealing racial or ethnic origin, color, national origin; political opinions, religious, or philosophical beliefs; trade union membership; genetic data or biometric data for the purpose of uniquely identifying a natural person; data concerning age, disability, or health; or data concerning a natural person’s sex life or sexual orientation.

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“You” means any individual about whom NCR Atleos collects, uses, or discloses Personal Data except as described below.

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Collection of Personal Data

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The categories of Personal Data NCR Atleos may collect about you depend on whether you are a customer, user, employee, or visitor and the requirements of applicable law.

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You may provide Personal Data to NCR Atleos in a variety of ways, such as:

Creating an Account,Becoming a Channel Partner, or Setting Up a Merchant Account by registering for an online account or event and supplying your name, title, company, business function, physical and email addresses, telephone number, social security number, tax identification number, financial account information, user IDs, and/or password.
Entering into a Contract or other business relationship with us. We may collect contact information, financial data, and other similar data to manage our relationship with you or your business, take orders, process and deliver products and services to you including complaint and dispute resolution.
Communicating with Us. When you contact us to join a mailing list, inquire about or purchase a product or service, apply for employment, fill out an information form, or otherwise contact us with a question, comment, or request, and supply your name, title, company, physical and email addresses, telephone number, resume, user IDs, and/or password.
Using Our First-Party ATMs or ATM Networks. When you use our first-party ATMs or ATM network, we collect your card and account information for the purposes of completing the transaction.
Completing Surveys. If you decide to participate, you may be asked to provide certain information, which may include Personal Data.
Visiting Our Facilities. When you visit our physical facilities, you may provide us with certain information about you for security purposes. We may also employ closed-circuit video recording (i.e., “CCTV”) that may capture your image.
Registering for Sweepstakes or Contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.

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We may collect Personal Data about you in the following ways:

Information from Other Sources. NCR Atleos may collect information about you or obtain Personal Data about you from third parties for the purposes of providing you with information about NCR Atleos products and services that may be of interest to you, or to take steps to maintain the accuracy of the information we have about you. If you are in an employment or similar arrangement with a third party that provides products or services to NCR Atleos, that third party may share your Personal Data with NCR Atleos to further that contractual relationship.
Automatic Data Collection. NCR Atleos may also use certain technologies to automatically collect information about you while you are visiting an NCR Atleos website, application, product, or service, which as described in more detail below, may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers and related technologies (see below), mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the services, information about the links you click, and other information about how you use the services. Information we collect may be associated with accounts and other devices. In addition, we may automatically collect data regarding your use of our websites, applications, products and services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your Personal Data with information that others provide when they use our services.
Contract Data. NCR Atleos may collect Personal Data about your based on the direction of its customer(s). In such cases, it is our customers’ responsibility to ensure that their directions to NCR Atleos are consistent with the terms of any privacy policies or other guarantees they have made to you.

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As described above, NCR Atleos websites, applications, and services may employ a variety of tools, including cookies, to help us improve your experience and determine the effectiveness of certain of our marketing initiatives.

Cookies. A cookie is a small element of data that a website can send to a web browser, which is then stored on the browser user’s computing device. We may use cookies, alone or in combination with other data we may collect from other technologies (such as server logs) to make our websites work or operate more efficiently, to personalize a user’s experience, or to make our websites more useful to our visitors. You can learn more about cookies by visiting https://www.consumer.ftc.gov/articles/0042-online-tracking or www.youronlinechoices.eu.
Other Technology NCR Atleos May Use to Improve Your Experience. NCR Atleos, and our service providers, may also use other technology to improve your experience. As described below, these technologies include analysis tools, log file information, web beacons, web links, and local shared objects.
Analysis Tools. NCR Atleos may use analysis tools like Google Analytics or Adobe Analytics to help us analyze how visitors use our websites. Among other things, these tools use cookies to collect data about the number of visitors to the site, the web page that referred visitors to the site, and the pages that visitors view within the site. Both Google Analytics and Adobe Analytics use persistent cookies. To opt out of Google Analytics, visit http://tools.google.com/dlpage/gaoptout. To opt out of Adobe Analytics, visit http://www.adobe.com/privacy/opt-out.html.
Log File Information. NCR Atleos records log file information whenever you access our websites. Examples of log file information include your IP address, your browser type, the page from which you accessed our website, the pages you viewed while visiting our website, the last page you viewed before you exited our website, and the page you accessed after leaving our website.
Web Beacons, Pixel Tags, Clear GIFs, and Other Technologies. These technologies involve placing electronic (and usually transparent) images on a website or in an email. These images place certain information on your device such as cookies, the time and date of a page you viewed and the length of time you viewed the page, the IP address of the device that retrieved the image, the time the web beacon was viewed and for how long, and the type of browser that retrieved the image. We may use these technologies, for example, to determine whether you have opened or accessed links included in marketing communications from NCR Atleos. These technologies often work with cookies; therefore, if you do not want us to associate your cookie information with your visits to our website, you must turn off cookies in your browser.
Web Links. Emails from NCR Atleos may contain links that are designed to take you to a web page after redirection through NCR Atleos’s servers (or those of its suppliers). We use the information we obtain during the redirection process to determine whether a particular marketing initiative is effective and may collect information connected to your identity. If you do not want NCR Atleos to collect information about the links that you click, you can choose a text- based version of the message (if the option is available). You may also choose not to click the links we provide in the emails we send to you and search online for the relevant resource independently.
Local Shared Objects (“Flash Cookies”). NCR Atleos may use Adobe Flash Player® to deliver multimedia content, such as a video, to you. To improve your user experience, NCR Atleos may use Flash local shared objects (LSOs) – sometimes called “flash cookies” – to store your flash content information and preferences, similar to other types of cookies NCR Atleos employs. You can manage flash cookies by accessing the following link on Adobe’s website: http://www.macromedia.com/support/documentation/en/flas hplayer/help/settings_manager07.html.
Notice Regarding APIs and SDKs. We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our applications. APIs and SDKs may allow third parties including analytics and advertising partners to collect your Personal Data for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
Information from Other Sources. We may obtain Personal Data about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our website, applications, products and services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your username, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and services.

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When we Process Personal Data on behalf of our customers in the performance of a contract, the customer’s privacy policy applies to such Processing. NCR Atleos relies on its customers to provide NCR Atleos with Processing instructions that comply with those customers’ privacy obligations to you.

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Use of Personal Data

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NCR Atleos is committed to collecting Personal Data for specified and legitimate purposes, to limit its Processing to the stated purpose, and to not Process that data further in a manner incompatible with such purpose without your prior consent.

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Lawful Bases for NCR Atleos’s Processing. NCR Atleos will use Personal Data where reasonably necessary to fulfill NCR Atleos’s business needs (as described below), including to:

Perform a contract or other business relationship with you or take steps at your request prior to entering into a contract.
Comply with a regulatory or legal obligation.
Protect your vital interests or that of another natural person.
Perform a task carried out in the public interest.
Carry out Processing with your consent, which you may withdraw at any time as described below.
Further a legitimate interest of NCR Atleos or a third party including, but not limited to:
- Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
- Auditing related to transactions, short-term transient use in accordance with applicable law, debugging to identify and repair errors that impair existing intended functionality and undertaking activities to verify or maintain the quality or safety of a service or device;
- Detecting security incidents, protecting NCR Atleos personnel, property and assets from malicious, deceptive, fraudulent or illegal activity including threats or harm including to NCR Atleos’s information technology infrastructure, Intellectual property, or goodwill or reputation and prosecuting those responsible for that activity;
- Ensuring compliance with relevant corporate policies and terms; or
- Optimizing utilization of global corporate resources including the administration of business transactions, personnel and information technology systems.

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Additional Business Purposes. In addition to the foregoing, NCR Atleos may Process Personal Data in the following specific purposes and circumstances:

Sensitive Data. With respect to Special Categories of Personal Data or Characteristics of Protected Classes, NCR Atleos may Process such information in a manner that is consistent with applicable law.
Contract Data. As described above, NCR Atleos will use Contract Data consistent with applicable contractual obligations with its customers and applicable law. NCR Atleos also may use Contract Data to facilitate compliance with regulatory and legal requirements.
Deidentified Data. For deidentified or aggregated data, which was formerly Personal Data, but which can no longer identify individuals, NCR Atleos may conduct research and development, statistical, trend or pattern analysis in order to continuously improve our products, services, processes, and security procedures.
Sales and Marketing. NCR Atleos may use your Personal Data for sales and marketing purposes, including contacting you for feedback in customer satisfaction surveys or for market research purposes, providing you with marketing literature on products and services, notifying you of events, and providing you with information about NCR Atleos. You may always change your privacy preferences as set forth below. From time to time, NCR Atleos may co-brand an offering or a communication with a third party, which may also collect your Personal Data. In such cases, the use of your Personal Data by such third parties is covered by their respective privacy policies, and not this Privacy Policy. In cases where you choose to forward a page from this website to another individual (where such option is available), NCR Atleos may request certain Personal Data about that individual to complete your request, such as name and email address, but NCR Atleos will not make further use of such information. NCR Atleos’s use may include, but is not limited to, making sales calls, sending marketing communications, delivering or completing requested services or transactions, and tracking and analyzing a series of transactions.
Social Networking Tools. If NCR Atleos uses social networking widgets or tools to provide information to you, your information will be governed by the terms of use and the privacy policy for the applicable social networking platform.
Fulfilling Business Transactions. NCR Atleos may use your Personal Data to fulfil business transaction requests with you or your organization. With respect to our customers, such requests may include, but are not limited to, maintaining or servicing accounts, verifying customer information, processing payments, providing advertising and marketing services, providing analytics services, undertaking internal research of technological development and demonstration, providing products or services including delivering notifications of product issues, fixes or updates, or contacting you in response to your questions, comments, or requests. With respect to our suppliers, such requests may include issuing purchase orders, receiving invoices, or providing other information such as forecasts. If, in providing service or support (including support to assist you with the use of our websites or applications), we engage you telephonically or via electronic communications through tools such as email or online chat, we may monitor or record our interactions for purposes of quality assurance, training, or to document the details of the interaction or transaction.
Recruitment. If you seek employment with NCR Atleos, you may provide us with information about yourself, such as a resume. We may utilize automated processing techniques for candidate applications for qualitative scoring or ranking to optimize the efficiency of our recruiting practices. In such cases, however, this Processing is overseen by our Human Resources personnel. We may use this information throughout NCR Atleos to consider you for employment purposes and may keep your information on file for future consideration, to support NCR Atleos’s compliance with applicable legal requirements, and as otherwise set forth in this Privacy Policy or in a separate notice that may be provided to you.

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Transfers

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NCR Atleos is a global company with global operations, partners and suppliers. Where it is necessary for the efficient and effective performance of a business transaction or the fulfilment of one of the uses of Personal Data outlined above, NCR Atleos may need to transfer Personal Data from the country of collection to other countries, which may have data protection laws that are different from the laws where you live. Where such a transfer is made from one country or territory to another that is not deemed by the first exporting country (“Exporting Country”) to offer an adequate level of protection to the rights and freedoms of data subjects, NCR Atleos’s policy is to do so on the basis of contractual controls between the relevant group companies, partners, or suppliers designed to ensure that substantially the same level of protection is afforded to the Personal Data as in the Exporting Country. NCR Atleos’s contractual safeguards are based on the ‘standard contractual clauses’ issued by the European Commission and other data protection regulatory authorities of the Exporting Country.

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Disclosure of Personal Data to Third Parties

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We may share your Personal Data (including Contract Data) within NCR Atleos. We also may share Personal Data with the following categories of third parties:

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Service Providers. We may share Personal Data with third-party suppliers and service providers that help us Process Personal Data. Examples of categories of suppliers include: IT vendors (including IT and related services, security product providers, email providers, and application providers), customer service providers, contingent workers, consultants, professional advisors, and other vendors to support the provision of our products and services. It is NCR Atleos’s practice to enter into contracts with our suppliers and service providers that require them to handle your information in a manner consistent with NCR Atleos policy and applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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Business Partners. We may provide Personal Data to business partners with whom we jointly offer products or services. In such cases, our business partner’s name may appear along with ours.

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Bank Card Issuers. When you use one of our first-party ATMs, we will share the information captured with your card issuer or account provider for the purposes of validating the requested transaction.

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Advertising Partners. Third parties do not advertise on NCR Atleos’s websites. NCR Atleos, however, may contract with third parties who collect information about your online activities over time and across different devices and websites (including NCR Atleos websites). These third parties use cookies or web beacons across multiple websites, including NCR Atleos’s websites, to collect certain information about you (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day) to provide you with targeted ads based on your interests. We engage with these third parties to help us deliver targeted advertisements about NCR Atleos on other websites you visit. If we need to facilitate these third parties to place cookies on your device to enable this functionality, we will do so in accordance with this Privacy Policy.

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However, the third parties’ collection, use, and disclosures of your information is governed by their own privacy policies and statements.

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You have several choices to control the delivery of targeted ads to you by NCR Atleos, as described below.

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Disclosure in the Event of Merger, Sale or Other Asset Transfer. From time to time, NCR Atleos may contemplate entering into various business development activities which may include the sale, purchase, merger, or reorganization of one or more of its businesses. These business development activities may require the disclosure of Personal Data to the prospective or actual purchaser(s). When such disclosures are required, NCR Atleos will seek appropriate protections of your Personal Data.

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Disclosures to Protect Us or Others. In certain circumstances, NCR Atleos may use or release Personal Data to third parties when disclosure is required by a legal authority to which we are subject, such as pursuant to a statute, regulation, judicial proceeding, court order, or subpoena. We also reserve our right to use or provide your Personal Data to third parties, including law enforcement, auditors, consultants, and government officials, to protect NCR Atleos’s rights, property, or safety, and/or the rights or property of our customers, business partners, suppliers, or other third parties. We may also disclosure Personal Data to enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

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Your Privacy Rights

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Your Preferences. You have certain choices about your PersonalData. Where you have consented to the processing of your Personal Data,you may withdraw that consent at any time and prevent further processing as follows:

Email and Telephone Communications. From time to time, you may sign up to receive information or access to NCR Atleos services, or where law permits, we may provide you with information we believe may be of interest to you. In all cases, we will provide you with mechanisms to control your receipt of such communications or services. In addition, you may indicate to us that you no longer wish to receive emailed marketing communications from us by following the unsubscribe instructions included in the email communications we may provide to you, and you may always contact us directly as set forth in this Privacy Policy.
Contract Data. With respect to Contract Data, the NCR Atleos customer is responsible for your Personal Data, and, where applicable, Processing your privacy rights requests.
Mobile Devices. If you install an NCR Atleos mobile application, NCR Atleos may send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that at this time NCR Atleos does not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of technologies on your device or remove them by adjusting your preferences as your browser or device permits. If you would like to change your browser’s cookie settings, please refer to the online help offered with your browser or to your device manufacturer’s website. Please note, however, if you decide to turn off cookies, there may be some features of our websites that may not be available to you and some pages may not display properly. To learn more about managing cookies on your device, please visit http://www.allaboutcookies.org/manage-cookies/. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, www.networkadvertising.org/managing/opt_out.asp, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices, you may use your device's platform controls in your settings to exercise choice.

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Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements may also provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes. Furthermore, even if you exercise your choices, you may still receive generic, non-targeted ads from NCR Atleos.

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Your Individual Rights. In accordance with applicable law, we provide several mechanisms to allow you to:

Access Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party. Where permitted by law, NCR Atleos may charge a reasonable fee if we are required to provide information about you. You may have the right to request information about public and private entities with which the NCR Atleos has shared data.
Request rectification correction of your Personal Data where it is inaccurate or incomplete. In some cases, NCR Atleos may provide self- service tools that enable you to update Personal Data about you or refer you to the Controller of your Personal Data who is able to make the correction.
Request deletion or erasure of your Personal Data where required by law, subject to certain exceptions prescribed by law.
Request restriction of or object to Processing of your Personal Data, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law. You may request restriction of the Processing of your Personal Data while NCR Atleos undertakes to verify the accuracy of your data where you have contested its accuracy; where NCR Atleos’s Processing is unlawful and you have the right to erasure, but request that we restrict Processing instead; where the data are no longer needed for the purposes of the Processing by us, but they may be required by you for the pursuit or defense of a legal claim, or by NCR Atleos where its legitimate interests override your request for restriction. NCR Atleos will notify you before we begin to Process any information about you that was restricted just prior to Processing.

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You may log into your account or use the contact mechanisms specified below to make your request, or, if you do not have an account, please visit our access request portal. We will process such requests in accordance with applicable laws. Where necessary to protect your privacy, NCR Atleos may take reasonable steps to verify your identity before acting on a request.

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Consent Exceptions. Where you have previously provided your consent, you may withdrawal your consent at any time; however, doing so will not affect the lawfulness of NCR Atleos’s processing before your withdrawal of consent. Once you withdraw consent, we will no longer Process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further Processing which override your interests, rights, and freedoms or if Processing is necessary for the establishment, exercise, or defense of legal claims.

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Denying a Request. In certain circumstances applicable law may permit NCR Atleos to deny such requests, for example, where an access, rectification, or erasure request is manifestly unfounded or excessive, in particular where it is repetitive, where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where the rights of other persons would be violated. You may appeal a denial by contacting NCR Atleos in the manner set forth in the Contact Us section of this Privacy Policy.

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Use of Automated Individual Decision Making Including Statistical Analysis and Profiling

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NCR Atleos may use statistical and analytic techniques to support automated individual decision-making including profiling for the purpose of improving the quality, performance or efficiency of our products, services or processes or to screen applicants for employment, to facilitate compliance with law or policy, or to protect our information technology infrastructure.

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Protection of Your Personal Data
‍NCR Atleos aims to provide leading data security protections to safeguard Personal Data. We prioritize safety across our business and commit to operating in accordance with the laws applicable to the countries in which we conduct business and with our contractual requirements.
Furthermore, NCR Atleos takes reasonable and appropriate steps designed to safeguard Personal Data in accordance with these laws and requirements.

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Retention of Personal Data
‍NCR Atleos retains Personal Data only for so long as it is necessary to support the overall purpose(s) for which NCR Atleos collected such information. We will retain and use your personal information as necessary to comply with our business and legal obligations, resolve disputes, protect our assets, and enforce our rights and agreements. We take steps to minimize access, use and retention of Personal Data to what is reasonably necessary.

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Children's Information‍
NCR Atleos’s applications and websites are not directed to children under the age of 16. By your use of our applications and websites, you affirm that you are at least 16 years of age. If you are a parent or a guardian, and you believe your child has provided NCR Atleos with Personal Data without your consent, please contact us as described below.

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Changes to This Privacy Policy
‍We reserve the right to update this Privacy Policy at any time, and we will make an updated copy of such privacy Policy available on our website. When we make any revisions that materially change the ways in which we use or share the Personal Data previously collected from you, we will give you the opportunity to consent to or opt-out of such changes before applying them to that Personal Data in accordance with applicable law.

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Changing Your Preferences and Contacting Us
‍You may change your marketing preferences by clicking here.

We want to address any concerns you may have. You may send any comments or questions regarding this Privacy Policy or NCR Atleos’s handling of your Personal Data by email to office.privacy@ncratleos.com, or by mail to:

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NCR Atleos Corporation
Privacy Office
864 Spring Street NW
Atlanta, GA 30308

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US Toll-free: 1-833-627-2853

Global: 1-832-308-4998

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We will respond to your request within 30 days of submission.

If NCR Atleos does not satisfactorily address your concerns, you may have the right to lodge a complaint with any national data protection authority of competent jurisdiction.

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THIRD PARTY CODE OF CONDUCT

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INTRODUCTION/EXPLANATION

This NCR Atleos Third Party Code of Conduct (the “Code”) sets forth the minimum standards NCR Atleos Corporation and its affiliates (collectively “NCR Atleos” or the “Company”) expect from everyone with whom we do business, including without limitation our vendors, service providers, and channel partners(each a “Third Party”).

Each Third Party must adhere to the minimum requirements set forth in this Code. Third Parties must also require third parties with whom they do business to adopt similar minimum requirements for their workforce.

If applicable laws conflict with the provisions of this Code, Third Parties must follow applicable law and advise NCR Atleos immediately about the conflict.

NCR Atleos reserves the right to terminate its relationship with Third Parties who do not follow this Code.

All Third Parties are required to report to NCR Atleos instances of suspected violations of this Code, NCR Atleos policy, and applicable law that relate in any way to the Third Party’s dealings with NCR Atleos.Third Parties must promptly respond to requests from NCR Atleos for information or documentation to verify their adherence to this Code and promptly remediate any failures.

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WORKPLACE MATTERS

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Workplace Violence

Each Third Party will provide a safe and secure work environment for their employees and visitors. ThirdParties shall require all individuals on their premises be treated with respect and courtesy. Acts or threats of violence must be strictly prohibited. Each Third Party must maintain a mechanism to address acts or threats of violence that occur on their premises.

Third Parties shall not bring any weapons to any NCR Atleos facility or to any facility that they visit when engaged in business related to its dealings with NCR Atleos.

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‍Non-Discrimination

Third Parties must comply with all applicable employment and labor laws and provide equal employment opportunity to all of their employees and applicants. Third Parties must provide a work environment free from any discrimination. While NCR Atleos respects local customs, norms and cultural expectations, Third Parties must, at minimum, prohibit discrimination based on race, color, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ethnicity, national origin, caste, disability, genetic information, medical condition, pregnancy, religion, political affiliation, union membership, covered veteran status or any unlawful factor to the fullest extent permitted by applicable law. This prohibition shall apply to decisions concerning recruiting, hiring, performance appraisals, compensation promotions, termination and all other aspects of employment. Third Parties must make reasonable accommodations to their employees to accommodate personnel needs consistent with applicable law.

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Harassment

Third Parties must provide a working environment that is free from harassment based on personal characteristics, including race, color, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ethnicity, national origin, caste, disability, genetic information, medical condition, pregnancy, religion, political affiliation, union membership, covered veteran status and any other characteristic protected by applicable law. Third Parties must strictly prohibit conduct that creates an intimidating or offensive work environment.

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Human Trafficking, Child and Forced Labor

Third Parties must strictly prohibit human trafficking or forced labor of any type, including but not limited to sex trafficking, debt bondage, forced prison labor, and child labor. Third Parties must set minimum working standards for all personnel, including:

• prohibiting the hiring of individuals below the legal working age, and legal workers under 18 years of age may not perform dangerous work.
• prohibiting corporal punishment and the threat of corporal punishment
• prohibiting requirements for worker deposits, retaining employee identity or immigration documentation and any other action that could restrict employees from freely terminating their employment
• providing fair compensation to all employees that meets minimum wage standards set by applicable law, including the payment of overtime wages
• capping daily and weekly working hours at or below limits set by applicable law, ensuring that all overtime is voluntary and providing no less than one rest day per week and permitting no more than 60 hours of work per week
• where the Third Party is providing housing for workers, such housing should be clean, safe, and provide reasonable living space
• respecting employees’ rights to freedom of association and collective bargaining to the full extent provided by applicable law

Third Parties may only use internal and external recruiters with sufficient training to support compliance with these minimum requirements.

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Drug-Free Workplace‍

NCR Atleos Third Parties must maintain drug-free workplaces. Third Parties must prohibit the use, possession,
distribution, or sale of illegal drugs while conducting work for or on behalf of NCR Atleos, whether or not on Third Party premises. Third Party personnel must not perform work on or behalf of NCR Atleos while under the influence of alcohol.

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Acceptable Use of Information Technology Resources

NCR Atleos’s electronic information technology (IT) infrastructure is to be used by Third Parties for NCR Atleos business purposes only and may not be used to espouse personal, political, or religious views or to solicit support for any non-business cause or event. Third Party personnel must use NCR Atleos’s IT infrastructure resources in a responsible, ethical, and lawful manner and are prohibited from using NCR Atleos e-mail or other NCR Atleos-provided electronic messaging or communication tools, among other things, to create or exchange offensive, harassing, obscene or threatening messages or to create or exchange chain letters and other unsolicited non-business-related e-mail. Except where prohibited by applicable law, NCR Atleos reserves all rights to search and review any information sent, received, or stored using its IT infrastructure.

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CONDUCT IN THE MARKETPLACE

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Interactions with Competitors
Third Parties must at all times comply with all applicable anti-trust and competition laws.
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Intellectual Property
Third Parties shall respect NCR Atleos’s and others’ trademarks, software, trade secrets and other confidential and proprietary information, inventions, works of other authorship, technology, data, documentation and other materials and intellectual property, including intellectual property rights (including patent, copyright, trade secret and trademark rights). Third Parties shall not use any NCR Atleos intellectual property, or others’ intellectual property in or in conjunction with NCR Atleos or any NCR Atleos related activity, project or engagement, without the right(s) to do so, and then only to the extent of such right(s).

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Anti-Bribery / Anti-Corruption Laws
Third Parties must at all times comply with the the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and all other anti-bribery and anti- corruption laws (collectively, “Anti-corruption Laws”). Third Parties may not provide or promise or receive or accept a promise to receive anything of value, directly or indirectly, to any third party to induce them to take or not take any action or for the purpose of obtaining or retaining a business advantage. Third Parties must maintain complete and accurate books and records and have in place adequate internal accounting controls designed to prevent and detect improper payments.

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Gifts & Hospitality
Gift-giving practices vary around the world. Third Parties shall use good judgment when giving or receiving gifts, in each case consistent with the following minimum requirements:

• All gifts must comply with Anti-corruption Laws.
• Third Parties must avoid actual or apparent conflicts of interest.
• Third Parties must accurately record the details of its transactions in all documents submitted to NCR Atleos, including contracts, order forms, and invoices.
• Never offer or provide payments, loans, favors, bribes, kickbacks, special privileges, or services to or from anyone in return for doing business with the Third Party or receiving any other favorable treatment from NCR Atleos.

Gifts given to or received from NCR Atleos personnel must be infrequent and modest in nature.

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GLOBAL COMMERCE
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Exports, Imports and Trade Control

Third Parties should not directly or indirectly provide to NCR Atleos any material or service from a country, person or entity that is subject to U.S. Export control laws and other regional, unilateral, and multilateral regulations that restrict transactions with specific foreign entities, persons or countries (often referred to as denied, debarred, embargoed and/or restricted parties). Third Parties shall comply with applicable laws and regulations governing (a) the export, re-export and transfer of goods, technical data, software and services; (b) import of goods and obligations with respect to sourcing materials; (c) economic sanctions and embargoes; and (d) U.S. antiboycott requirements.

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ENVIRONMENT/OCCUPATIONAL HEALTH & SAFETY

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Environment
Third Parties must comply with applicable environmental protection laws and endeavor to minimize undesirable environmental impacts from its business operations. Third Parties shall endeavor to reduce consumption of resources and creation of waste of all types and promote recycling efforts.

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Conflict Minerals
NCR Atleos expects Third Parties to take steps to determine if their products contain tin, tantalum, gold, or tungsten (“conflict minerals”) and if so, that they will:

• implement supply chain due diligence processes to identify sources of Conflict Minerals
• support efforts to proactively eradicate the use of Conflict Minerals which directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries.

Third Parties shall, promptly upon request by NCR Atleos, provide such information, certifications, and documentation as NCR Atleos deems necessary to monitor or assess compliance with this provision.

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Occupational Safety & Health
Third Parties must comply with applicable health and safety laws related to protecting human health and providing working conditions that are free from recognized hazards that may cause death, physical harm, or illness.
Third Parties must provide all personnel with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage, and eating facilities. If Third Party provides personnel with residential facilities, such facilities must meet local housing and safety standards, including maintenance and upkeep requirements.

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MAINTAINING COMPLIANCE/REPORTING CONCERNS
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Maintaining Compliance
Third Parties must establish training and communications programs to ensure that their personnel understand their rights and obligations under this Code.

Reporting Concerns
Third Parties must promptly report any known or suspected violations of this Code to NCR Atleos’s Ethics & Compliance Office Ethics (by e-mail: ComplianceOffice.Ethics@ncratleos.com or NCR Atleos’s AlertLine).

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