Privacy information Notice for the Ethics Hotline 
(the “Privacy Notice”)

Date: January 27, 2025

Version: 1.0

This Privacy Notice aims to inform you on the personal data processing we (STMicroelectronics International N.V.) carry out and on your rights, when you use the Ethics Hotline (the “Hotline”) which access is operated on our behalf by the company EQS Group AG located in Switzerland at Talacker 418001 Zürich, Switzerland.

We may amend this Privacy Notice at any time. The version in force when you use the Hotline is the applicable version. 

#1. Who we are

STMicroelectronics International N.V. is the entity controlling the processing of your personal data in accordance with this Privacy Notice.

Should you have any questions in connection with the processing of your personal data, please contact directly the Head of Global Privacy by email at privacy@ST.com or by postal letter at STMicroelectronics International N.V., Head of Global Privacy, 39, Chemin du Champs des Filles 1228 Plan Les Ouates, Switzerland. 

#2. What types of personal data do we process?

In principle, the Hotline can be used – to the extent permitted by law – without providing your personal data. You may, however, voluntarily disclose your personal data as part of the reporting process, in particular information about your identity: your first and last name, your telephone number, and your email address.

Your report may also contain personal data of third parties, which you refer to: first and last name and title.

#3. Purposes of and legal grounds for processing your personal data

We process your personal data to check the report you have made through the Hotline and undertake the associated investigation and its conclusion.

We process your personal data insofar as this is necessary for the fulfilment of our legal obligations within the scope of the report you make as part of our speak-up policy. Your personal data will also be processed if this is necessary to safeguard our legitimate interests or of a third party. We do not use your personal data for purposes other than those listed above. Otherwise, your prior consent will be requested. 

#4. Technical implementation and security of your data

We maintain appropriate technical and organizational measures to ensure data protection and confidentiality and we continually adapt these measures to ongoing technological developments.

Moreover, the data you provide us with will be stored in a specially secured environment. 

#5. Disclosure of personal data 

Your personal data will only be made available to those persons who have a need to know, to comply with the law or when an important public interest is at stake. All persons to review your report are expressly obliged to maintain confidentiality.

To fulfil the purpose, it may also be necessary for us to transfer your personal data to external bodies such as law firms, criminal or competition authorities, within or outside your jurisdiction. If we pass on your personal data within the group or externally, a uniform level of data protection is ensured by means of internal data protection regulations and/or corresponding contractual agreements. In all cases, the responsibility for data processing remains with us. 

#6. Retention Period

We store personal data only as long as it is necessary for the processing of your report, or we have a legitimate interest in the storage of your personal data. Storage can also take place if this has been provided for by national legislation to fulfil legal obligations, such as storage obligations. At the end of the retention period, your personal data will be deleted, blocked, or anonymized. 

#7. Your rights

Unless this would seriously hinder the investigation and, as a result, the enforcement of rights in the framework of legal proceedings and to the extent that the personal data processed appears to be relevant and necessary for this purpose, you can request access to, rectification or erasure of personal data, or restriction of processing concerning your data or, where applicable, the right to data portability.

You can make your request by sending an email to privacy@st.com

#8. Questions

If you have a question regarding the Privacy Notice, please send your message to e-mail: privacy@st.com