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:
- Comply with federal, state, or local
law.
- Maintain necessary information to
continue your employment and benefits.
- Detect security incidents, protect
against malicious, deceptive, fraudulent, or illegal activity, or
prosecute those responsible for such activities.
- Debug products to identify and
repair errors that impair existing intended functionality.
- Protect the right of another
employee to exercise their free speech rights, or exercise another right provided
for by law.
- 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