CCPA Notice at Collection for Employees and Applicants

FOR CALIFORNIA RESIDENTS

CCPA Notice at Collection for Employees and Applicants

Last Updated: June 14, 2023

This notice describes the categories of personal information collected by Kenco PPC Buyer LLC and subsidiaries (the “Company”) and the purposes for which such information may be collected and used. It also provides information concerning the Company’s record retention practices and rights you may have under the CCPA. For more complete information about the Company’s Privacy Policy, please see https://kencogroup.com/privacy-policy/.

We retain your personal information for as long as necessary to process your application for employment, and in accordance with the Company’s data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, such as to resolve disputes or if requested by a lawful order from court, or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements. Personal Information does not include certain categories of information, such as publicly available information from government records, deidentified or aggregated consumer information, and information subject to HIPAA or the California Confidential Medical Information Act.

Categories of Personal Information Collected

Identifiers and Contact information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, signature, account name, dates of birth, bank account information, and other similar contact information and identifiers.

Protected classification information. This category includes characteristics of protected classifications under California or federal law.

Internet or other electronic network activity information. This category includes without limitation:

all activity on the Company’s information systems, such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames and passwords, and

all activity on communications systems including phone calls, call logs, voice mails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an applicant or employee’s use of company-issued systems or devices.

Geolocation data. This category includes GPS location data from the Company’s information systems.

Audio, electronic, visual, thermal, olfactory, or similar information. This category includes, for example, information collected from camera, microphones, and similar devices. Biometric information. This category includes information such as an individual’s physiological, biological, or behavioral characteristics used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. For example, this category might include the use of biometric equipment, devices, or software to record your time worked, to enter or exit facilities or rooms, to access or use equipment, or for other business purposes.

Biometric information. This category includes information such as an individual’s physiological, biological, or behavioral characteristics used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. For example, this category might include the use of biometric equipment, devices, or software to record your time worked, to enter or exit facilities or rooms, to access or use equipment, or for other business purposes.

Professional and employment-related information. This category includes without limitation:

data submitted with employment applications including salary history, employment history, employment recommendations, etc.,

background check and criminal history,

work authorization,

fitness for duty data and reports,

performance and disciplinary records,

salary and bonus data,

benefit plan enrollment, participation, and claims information, and

leave of absence information including religious and family obligations, physical and mental health data concerning employee and his or her family members.

Education information. This category includes education history.

Limited medical information. This category includes without limitation:

symptoms, test results, and other indicators of exposure to the coronavirus (COVID-19) and related vaccination status information

fitness for duty data and reports,

leave of absence information including family obligations, physical and mental health data concerning employee and his or her family members, and

travel information and information regarding close contacts.

Sensitive Personal Information. This category includes sensitive information such as

social security, driver’s license, state identification card, or passport number,

financial account information that allows access to an account, including log-in credentials, financial account numbers, passwords, etc.,

precise geolocation,

racial or ethnic origin, religious or philosophical beliefs, or union membership,

content of mail, email, and text messages unless the Company is the intended recipient of the communication,

genetic data,

biometric information for the purpose of uniquely identifying a consumer, and

information concerning health and sex life or sexual orientation.

Inferences drawn from the Applicant Personal Information in the categories above. This category includes engaging in human capital analytics, including but not limited to, identifying certain correlations about individuals and success on their jobs, analyzing data to improve retention, and analyzing employee preferences to inform HR Policies, Programs and Procedures.

Google Analytics and Other Third Parties. We use cookies provided by Google Analytics, a third-party service provider, to assist us in better understanding visitors to the Website. These cookies collect data tied to a user’s IP address such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting https://kencogroup.com. Based on this information, Google Analytics compiles aggregate data about Website traffic and Website interactions, which we use to offer you a better experience when you visit https://kencogroup.com. Other Google advertising features we use include Dynamic Remarketing, DoubleClick, and AdWords Conversion.

You can obtain more information about Google Analytics here: https://www.google.com/analytics/learn/privacy.html?hl=en-GB.

For information about how to prevent your data from being used by Google Analytics, visit https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631.

This section does not apply to existing employees.

Purposes For Which Personal Information, Including Sensitive Personal Information, is Used

Collect and process employment applications, including confirming eligibility for employment, background and related checks, onboarding, and related recruiting efforts.

Processing payroll, other forms of compensation, and employee benefit plan and program design and administration including enrollment and claims handling, and leave of absence administration.

To maintain physician records and occupational health programs.

Maintaining personnel records and record retention requirements.

Communicating with employees and/or employees’ emergency contacts and plan beneficiaries.

Complying with applicable state and federal health, labor, employment, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws, guidance, or recommendations.

Preventing unauthorized access to, use, or disclosure/removal of the Company’s property, including the Company’s information systems, electronic devices, network, and data.

Protect the legal rights, privacy, safety or property of Company or its employees, agents, contractors, customers or the public.

Protect against fraud or other illegal activity or for risk management purposes.

Ensuring and enhancing employee productivity and adherence to the Company’s policies.

Enforce the Company’s website’s terms of use.

To provide training and development opportunities.

Investigating complaints, grievances, and suspected violations of Company policy.

Design, implement, and promote the Company’s diversity and inclusion programs.

Facilitate the efficient and secure use of the Company’s information systems.

Ensure compliance with Company information systems policies and procedures.

Improve safety of employees, customers and the public with regard to use of Company property and equipment.

Improve efficiency, logistics, and supply chain management.

Improve accuracy of time management systems, attendance, including vacations, sick leave and other absence monitoring.

Evaluate an individual’s appropriateness for a participation position at the Company, or promotion to a new position.

Client engagement and other legitimate business purposes.

To respond to and manage any legal claims against the Company and/or its personnel, including civil discovery in litigation.

To facilitate other business administrative functions and strategic activities, such as risk management, information technology and communications, financial management and reporting, workforce and succession planning, mergers and acquisition activities; and maintenance of licenses, permits and authorization applicable to Company operations.

Sources and Disclosures of Personal Information

For information on the sources of personal information we collect and the categories of third parties to whom we may disclose personal information, please see the Company’s Privacy Policy by visiting https://kencogroup.com/privacy-policy/.

The Company does not sell or share, as those terms are defined under applicable law, the above categories of Personal Information. We also do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary to maintain the employment relationship as reasonably expected by an average employee. The Company may add to the categories of personal information it collects and the purposes it uses personal information. In that case, the Company will inform you.

California Resident Individual Rights Requests. Individuals who are residents of the State of California have certain individual rights as outlined below.

These rights and how to exercise them are described more fully in the Company’s Privacy Policy by visiting https://kencogroup.com/privacy-policy/.

Upon receipt of a verifiable consumer request (see below), and as required by applicable law, we will provide a response to such requests.

Right To Know About Personal Information Collected or Disclosed. In addition to what is described above, as a California resident, you also have the right to request more information regarding the following topics, to the extent applicable:

the categories of personal information,

the categories of sources from which the personal information is collected,

the business or commercial purpose for collecting, selling, or sharing personal information, if applicable,

the categories of third parties to whom the business discloses personal information, and

the specific pieces of personal information the business has collected about you.

Right To Request Deletion Of Your Personal Information. You have the right to request that we delete the personal information we collected or maintained about you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers and contractors with whom we disclosed your personal information to also delete your personal information from their records.

There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Such instances include, but are not limited to, enabling solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which you provided the information or to comply with a legal obligation.

Right to Request Correction. You have the right to request that the Company correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate or retaliate against you for exercising any of your rights as described above.

Submitting Consumer Rights Requests. To submit a California Consumer Rights request as outlined above, please contact the Company’s Human Resources Department by calling us at 1-800-758-3289 or emailing us at privacy@KencoGroup.com. We reserve the right to only respond to verifiable consumer requests to know, delete, or correct.

We reserve the right to amend this Notice at any time without advance notice.

If you have questions about this notice, you may call 1-800-758-3289.