PRIVACY NOTICE TO CALIFORNIA APPLICANTS AND EMPLOYEES

 

This Policy and PRIVACY NOTICE FOR CALIFORNIA APPLICANTS AND EMPLOYEES contains WASH DEPOT HOLDINGS, INC.’s policy and privacy notice and disclosure to employees who reside in the State of California (“you”). We adopt this policy and notice to comply with the California Consumer Privacy Act (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

 

Information We Collect

 

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we will collect or have collected categories of personal information from you as follows: 

 

·         Identifying information, such as your full name, gender, date of birth, and signature.

·         Demographic data, such as race, ethnic origin, marital status, disability, and veteran or military status.

·         Contact information, such as your home address, telephone numbers, email addresses, and emergency contact information.

·         Dependent's or other individual's information, such as their full name, address, date of birth, and Social Security numbers (SSN).

·         National identifiers, such as SSN, passport and visa information, and immigration status and documentation.

·         Educational and professional background, such as your work history, academic and professional qualifications, references, and interview notes.

·         Employment details, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.

·         Financial information, such as banking details, tax information, payroll information, and withholdings.

·         Health and Safety information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information.

·         Information Systems (IS) information, such as your search history, browsing history, login information, and IP addresses on the Company's information systems and networks.

·         Biometric information, such as, fingerprints, keystroke, or other physical patterns, and OTHER.

·         Geolocation data, such as time and physical location related to use of an internet website, application, device, or physical access to a Company office location.

·         Sensory or surveillance information, such as COVID-19 test results  and video surveillance.

·         Profile or summary about an [applicant/employee]'s preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.

 

 

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

 

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from documents beginning from the job application process, on-boarding documents, and documents necessary for eligibility and participation in employment benefits.
• Indirectly from our service providers or their agents. For example, through information we collect from our service providers in the course of receiving services to them – such as employment agencies, on-line job resources, or background check companies.
• Directly and indirectly from activity on our website (www.washdepot.com). For example, from submissions through our website portal or website usage details are collected automatically.

 

Use of Personal Information

 

We may use or disclose the personal information we collect for one or more of the following business purposes:

·         Comply with all applicable laws and regulations.

·         Recruit and evaluate job applicants and candidates for employment.

·         Manage your employment relationship with us, including for:

o   onboarding processes;

o   timekeeping, payroll, and expense report administration;

o   employee benefits administration;

o   employee training and development requirements;

o   the creation, maintenance, and security of your online employee accounts;

o   reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;

o   workers' compensation claims management;

o   employee job performance, including goals and performance reviews, promotions, discipline, and termination;

o   other human resources purposes; and

 

·         Manage and monitor employee access to company facilities, equipment, and systems.

·         Conduct internal audits and workplace investigations.

·         Investigate and enforce compliance with and potential breaches of Company policies and procedures.

·         Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company.

·         Maintain commercial insurance policies and coverages, including for workers' compensation and other liability insurance.

·         Perform workforce analytics, data analytics, and benchmarking.

·         Administer and maintain the Company's operations, including for safety purposes.

·         Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents.

 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sharing Personal Information

 

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

 

We may disclose the following categories of personal information for a business purpose:

Category A:             Identifiers.
Category B:             California Customer Records personal information categories.
Category C:             Protected classification characteristics under California or federal law.
Category I:              Professional or employment-related information.

 

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information.

 

Your Rights and Choices

 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

Access to Specific Information and Data Portability Rights

 

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

Deletion Request Rights

 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Comply with federal, state, or local law.
2. Maintain necessary information to continue your employment and benefits.
3. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
4. Debug products to identify and repair errors that impair existing intended functionality.
5. Protect the right of another employee to exercise their free speech rights, or exercise another right provided for by law.
6. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Data Portability, and Deletion Rights

 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable request to us by either :

• Calling Human Resources at (800) 339-3949
• Emailing Human Resources at HR@Washdepot.com
• Mailing Human Resources at 2400 East Commercial Blvd. Suite 901 Fort Lauderdale, FL 33308

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

 

Response Timing and Format

 

We endeavor to confirm receipt of a request to know or delete within ten business days.  We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Non-Discrimination

 

We will not discriminate against you because you exercise your rights under the CCPA.

 

Changes to Our Privacy Notice

 

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or U.S. Mail.

 

Contact Information

 

If you have any questions or comments about this notice, this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: (800) 339-3949