PRIVACY NOTICE TO CALIFORNIA APPLICANTS AND EMPLOYEES

LAST UPDATED: MARCH 11, 2024

 

This Policy and PRIVACY NOTICE FOR CALIFORNIA APPLICANTS AND EMPLOYEES contains WASH DEPOT HOLDINGS, INC.’s policy and privacy notice and disclosure to applicants and 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”). We collect, disclose or share personal information for human resources, employment, benefits administration, health and safety, and business-related purposes and to be in legal compliance. In particular, we will collect or have collected categories of personal information from you  for the following business purposes as follows: 

 

Personal Information Category	Business Purpose
Identifiers, such as your full name, contact information, gender, date of birth, signature, Social Security number, driver's license or state identification numbers, and similar information for your dependents and beneficiaries.	·         Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks ·         Conduct employee onboarding ·         Maintain and administer payroll and employee benefit plans, including enrollment and claims handling ·         Maintain personnel records and complying with record retention requirements ·         Provide employees with human resources management services and employee data maintenance and support services ·         Communicate with employees and their emergency contacts and plan beneficiaries ·         Comply with applicable state and federal labor, employment, tax benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws ·         Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data ·         Ensure employee productivity and adherence to Company policies ·         Conduct internal audits and investigate complaints, grievances, and suspected violations of Firm policy ·         Respond to law enforcement requests and as required by applicable law or court order ·         Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents
California Customer Records employment and personal information, such as your name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certifications, bank account number, credit card number, debit card number, or any other financial, medical or health insurance information].	·         Same purposes as for identifiers category
Protected classification characteristics under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information).	·         Comply with federal and state equal employment opportunity laws ·         Perform workforce analytics, data analytics, and benchmarking ·         Conduct internal audits, grievances, and suspected violations of Company policy ·         Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents
Biometric information, such as fingerprints, keystroke, or other physical patterns, and certain wellness metrics.	·         Possible fingerprinting for a criminal background check after an initial offer of employment is made. Criminal background checks protect the company, mitigate risk, and avoid potential negligent hiring lawsuits ·         Administer and design health wellness programs ·         Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents
Internet or other similar network activity information, including 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 (such as phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee's use of company-issued devices).	·         Facilitate the efficient and secure use of Company information systems ·         Ensure compliance with Company information systems policies and procedures. ·         Comply with applicable state and federal laws ·         Prevent unauthorized access to, use, or disclosure or removal of the Company's property, records, data, and information ·         Enhance employee productivity ·         Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy ·         Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents
Geolocation data, such as the time and physical location related to use of an internet website, application, or device, and GPS location data from mobile devices of employees who participate in our vehicle reimbursement program.	·         Improve safety of employees, customers, and the public regarding use of the Company property and equipment ·         Prevent unauthorized access, use, or loss of the Company property ·         Improve efficiency, logistics, and supply chain management ·         Ensure employee productivity and adherence to the Company's policies ·         Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company's policy
Sensory and surveillance data, such as COVID-19 related temperature checks and call monitoring and video surveillance.	·         Comply with applicable state and federal laws, including on workplace health and safety ·         Prevent unauthorized access, use, or loss of the Company property ·         Improve customer service ·         Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents
Professional or employment-related information, such as employment application information (work history, academic and professional qualifications, educational records, references, and interview notes, background check, drug testing results, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, leave of absence information including religious, military and family obligations, health data concerning employee and their family members.	·         Recruit and process employment applications, including verifying eligibility for employment, background checks, and onboarding ·         Design and administer employee benefit plans and programs, including for leaves of absence. ·         Maintain personnel records and comply with record retention requirements. ·         Communicate with employees and their emergency contacts and plan beneficiaries. ·         Comply with applicable state and federal labor, employment, tax, benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws. ·         Prevent unauthorized access to or use of the Company's property, including its information systems, electronic devices, network, and data. ·         Ensure employee productivity and adherence to the Company policies. ·         Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company policy. ·         Evaluate and provide useful feedback about job performance, facilitate better working relationships, and for employee professional development ·         Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents
Non-public education information, such as education records, degrees and vocational certifications obtained, report cards, and transcripts.	·         Evaluate an individual's appropriateness for hire, or promotion or transfer to a new position at the Company
Inferences drawn from other personal information to create a profile or summary, for example, an individual's preferences, abilities, aptitudes, and characteristics	·         Engage in human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity, and analyze employee preferences to inform human resources policies and procedures ·         Conduct applicant reference checks to assist in hiring decisions

 

 

We retain the above information for at least four years post termination of the applicant or employment relationship.

 

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

 

In addition to the specific business purposes above, we may use, disclose, or share 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 that purpose.

 

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

·         Identifiers.

·         California Customer Records personal information categories.

·         Protected classification characteristics under California or federal law.

·         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.

 

We will not knowingly sell (as defined by CCPA) the personal information, including any sensitive personal information, we collect about our employees or applicants for employment or share it with third parties for cross-context behavioral advertising.  We do not knowingly sell or share personal information about consumers under age 16.

 

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 sharing 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 Policy and Notice

 

This policy was last updated on March 11, 2024.  We reserve the right to amend this privacy policy and notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email,  U.S. Mail, providing a hyperlink, or posting.

 

To view our full privacy policy to consumers, visit https://washdepot.com/privacy.html. To view our applicant/employee privacy policy and notice, visit https://washdepot.com/CCPA.html

 

 

Contact Information

 

If you have any questions or comments about this policy, 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, of if you need to access this Policy and Notice in an alternative format due to having a disability, please do not hesitate to contact us at:

 

• 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