California Employee Privacy Policy (supplements)

Last Revised on: March 16, 2023

This California Employee Privacy Policy and Notice (“this Policy”) applies only to information collected about applicants, current employees, and past employees residing in California (“employee(s),” “you,” “your”) and supplements the information contained in our primary Privacy Policy, and our employee handbook. It provides information required under the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), and related regulations.

This Policy describes the practices of Win-Dor, LLC. and its subsidiaries (“Win-Dor,” “we,” “us,” or “our”) regarding the collection, use, and disclosure of personal information and provides instructions for submitting data subject requests.

If you are unable to review or access this Policy due to a disability, you may contact Win-Dor at [email protected], or +1-866-457-2826 to access this Policy in an alternative format.

Definitions Specific to this Policy

• “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information also includes “Sensitive Personal Information,” as defined below.
• “Sensitive Personal Information” means Personal Information that reveals an individual’s: 1) Social security, driver’s license, state identification card, or passport number; 2) Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; 3) Precise geolocation; 4) Racial or ethnic origin; 5) Religious beliefs; 6) Union membership; 7) Contents of email or text messages, unless we are the intended recipient; 8) Genetic data; 9) Biometric information used to uniquely identify the individual, and 10) Health, sex life, or sexual orientation.
• “Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s Personal Information to a Third Party for money or other valuable consideration.
• “Share,” “Shared,” or “Sharing” means transferring an individual’s Personal Information to a Third Party for behavioral advertising purposes, whether or not for money or other valuable consideration.
• “Third Party” means a person or organization which is not a consumer, applicant, employee, former employee, Vendor, or an entity owned or controlled by us and as defined by the CCPA.
• “Vendor” means a “service provider,” or “contractor,” which collects, stores, or otherwise handles data for us, as those terms are defined in the CCPA.

These definitions apply, whether terms are capitalized or not. Other terms used in this Policy may be defined under the CCPA, and they shall have the meanings described therein.

The Personal Information We Collect and Disclose

The chart below shows the categories of personal information we may collect; examples of personal information in each category; types of sources from which each category of personal information is collected; the business purposes for which each category of personal information is collected; and the types of Vendors or Third parties with whom that category of personal information is shared. As this chart shows, we may share your personal information with Third Parties or disclose certain personal information to Vendors for business purposes.

 

Category of Personal Information	Examples	Sources from Which This Personal Information is Collected	Business Purposes for Collection	Types of Vendors or Third Parties with Whom This Personal Information is Shared, Sold or Disclosed
Unique Identifiers	Name, signature, address, telephone email, account name, SSN, driver’s license number, passport number, online identifier, IP address	·    Collected for purposes of payroll, benefits, and beneficiary benefits.	·   To evaluate job applicants and candidates for employment ·   To set up benefits upon starting employment.	Disclosed ·   Provided to Benefits Provider, Payroll Vendor, and Tax Reporting Agencies.
Contact and Financial Information	Name, address, telephone, email, credit card number, debit card number, or any other financial information	·    Collected when you complete an application. ·    Collected for purposes of payroll, benefits, and beneficiary benefits.	·   To evaluate job applicants and candidates for employment ·   To set up benefits upon starting employment.	Disclosed ·   Provided to Benefits Provider, Payroll Vendor, and Tax Reporting Agencies.
Medical Information or Health Insurance Information	Medical information or health insurance information	· Requested during application process for Diversity and Inclusion · Requested during application process for hiring certain manufacturing roles	· To complete your hiring process · To complete and finalize your employment contract	Disclosed ·   Provided to Benefits Provider, a hiring manager to obtain necessary safety equipment
Characteristics of Protected Classifications	Age, gender, race, physical or mental health conditions, marital status	·    Collected for Diversity and Inclusion	·   To evaluate job applicants and candidates for employment ·   To comply with state and federal law and regulations	Disclosed ·  Provided to government agencies as required by law
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	·    Employee purchase program, auction, logo store purchase history	· Tracked to meet auction rules and payroll requirements.	Disclosed ·   Provided to Payroll Provider
Biometric Information	Fingerprint scan for employee log in	·    Collected to process claim and benefits	·   Tracked for the purposes of tracking time and issuing paychecks.	Disclosed: ·   Provided to Payroll Vendor and kept by security vendor.
Internet or Other Electronic Activity	Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement	·    Collected while using a company device	·   Tracked for ensuring company policies and issuing paychecks.	N/A
Geolocation Data	Device location	·  IP Address, location from where an employee logs into a Win-Dor owned device or application ·  Corporate Travel through travel agency and corporate credit card paid by company	·   Data Security and Integrity of Systems. ·   Knowledge of where employee is located when accessing company information. ·   The company authorizes and pays for corporate travel and has a right to review and approve travel by its employees.	Disclosed ·   For Data Security and Privacy Laws governing Win-Dor information and employment laws. ·   For Federal and State Compliance with financial and tax laws.
Audio, Electronic, Visual, Thermal, Olfactory, Or Similar Information	Call and video recordings	·    Collected while using a company device or while on company property	·   Tracked for the purposes of tracking security	N/A
Professional or Employment-Related Information	Work history, prior employer	·  Collected for the purposes of Application, Employment Opportunities, and Continued Training.	· To evaluate job applicants and candidates for employment · Additional Opportunities within Company	Disclosed ·   Service provider holding applications
Education Information	Student records, directory information	·  Collected for the purposes of Application, Employment Opportunities, and Continued Training.	· To evaluate job applicants and candidates for employment · Additional Opportunities within Company	Disclosed ·   Service provider holding applications
Inferences Drawn from Other Categories to Create a Profile	Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	·    Collected from employee purchase program, auction, logo store purchase history	·   Tracked to meet auction rules and payroll requirements.	Disclosed: ·   Payroll vendor

 

Sensitive Personal Information We Collect and Disclose

 

Category of Sensitive Personal Information	Sources From Which This Sensitive Personal Information is Collected	Business Purposes for Collection	Types of Vendors or Third Parties with Whom This Sensitive Personal Information is Shared, Sold or Disclosed
Social security, driver’s license, state identification card, or passport number	· Collected when you complete an application. · Collected during onboarding · Collected from you directly	·   Perform background checks ·   Set up direct deposit ·   confirm citizenship	Disclosed: ·   Background checkers ·   Payment processor
Account log-in, financial account, debit card number, plus an access code	· Collected directly from you  you via during employee onboarding	·   Enable payroll ·   Assist with account unlock	Disclosed: ·  Payment processors ·  IT providers
Precise Geolocation	· Collected from your Win-Dor-owned digital device when you sign in	·   Network Security ·   Knowledge of employee location when accessing Win-Dor information	Disclosed: ·  IT providers ·  Security providers
Racial or Ethnic Origin, Religious or Philosophical Beliefs, or Union Membership	· Collected directly from you on an employment application	·   Comply with legal requirements ·   Accommodate special needs (e.g. religious dietary restrictions) ·   Diversity, Equity and Inclusion programming	Disclosed: ·  HR consultants ·  Diversity consultants ·  Government agencies
Biometric Data if processed for identification purposes	· Collected directly from you at login or when you start your shift	·   Network security ·   Time keeping	Disclosed: ·  Security providers ·  Timekeeping services
Health Information	· Requested during application process for Diversity and Inclusion · Requested during application process for hiring certain manufacturing roles	· To complete your hiring process ·   To complete and finalize your employment contract	Disclosed ·  Benefits Provider
Information on Sex Life or Sexual Orientation	· Directly from you on an employment application if you elect to provide it	·   Diversity, Equity and Inclusion programming	Disclosed: ·   Diversity consultants ·  HR training firms ·  EEOC, State and federal employment agencies.

 

Retention of Data

We intend to retain each category of personal information described above only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average person’s expectation, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain personal information: why we collected the personal information; the nature of the personal information; the sensitivity of the personal information; our legal obligations related to the personal information, and risks associated with retaining the personal information.

Your Rights to Your Personal Information

Subject to certain limitations, if you are a California resident, you have the right to submit requests related to the personal information we have collected about you. You may make such a request twice in a 12- month span. Please note, there are circumstances when we may not be able to comply with your request. For example, we may not be able to verify your request, or we may find that providing a full response conflicts with other legal obligations or regulatory requirements. We will notify you if this is the case.

Right to Receive Information on Privacy Practices. You have the right to receive the following information at or before the point of collection:

• The categories of personal information to be collected;
• The purposes for which the categories of personal information are collected or used;
• Whether or not that personal information is sold or shared with Third Parties or disclosed to Vendors;
• If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is Sold or Shared; and
• The length of time the business intends to retain each category of personal information, or if that is not possible, the criteria used to determine that period.

We have provided such information in this Policy, and you may request further information about our privacy practices by using the contact information provided below.

Right Know and Right to Access. You have the right to request certain information we have collected about you. You have the right to request:

• Specific pieces and categories of personal information we collected about you;
• The categories of sources from which personal information was collected;
• The purposes for which personal information was collected, shared, sold, or processed;
• The categories of personal information we shared, sold or disclosed; and
• The categories of Vendors or Third Parties with whom we shared, sold or disclosed personal information.

Right to Delete. You have the right to request that we delete certain personal information that we have collected.

Right to Correct. You have a right to request that we correct any inaccurate personal information we may retain about you.

Right to Opt-Out of the Sale and Sharing of Your Personal Information. You have the right to opt-out of the sharing of your personal information with Third Parties.

We Share personal information or process personal information for targeted advertising purposes. In the past 12 months, we have Shared the categories of personal information as listed in this this Policy. If you are a California resident, you have the right to opt-out of the Sharing of personal information for the purpose of targeted advertising. To submit an opt-out request, please access the below link or follow the “Do Not Share My Personal Information,” below. We do not knowingly sell or share personal information of any individuals under 16 years of age.

Do Not Share My Personal Information

If you opt-out of the sale of your personal information, we will wait at least 12 months before asking you if we may sell or share your personal information.

You have the right to opt-in to the sale of your personal information after you have opted out. If you would like to opt-in to the sale or sharing of your personal information, please email us at [email protected] or call us at +1-866-457-2826. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.

Right to Limit the Use of Your Sensitive Personal Information. You have the right to instruct us to limit the use and disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by average consumers, or for specific business purposes defined by applicable law.

You have the right to limit the use of your Sensitive Personal Information to the purposes authorized by the CCPA. To submit a request to limit the use of your Sensitive Personal Information, please click here to request the removal of your information.

Right to Non-discrimination. You have a right to exercise the above rights and we will not discriminate against you for exercising these rights. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests.

Instructions to Exercise your Rights. If you would like to make any of the data requests listed above, please click here to submit your request or call us at +1-866-457-2826. If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request, and the level of verification will depend on the request being submitted. You may also submit a request by emailing us at [email protected].

You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Such individual must have power of attorney, or be an authorized agent registered with the relevant Secretary of State.

Right to Appeal.

Verification Process

When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity.

If you designate an authorized agent to exercise your rights on your behalf, we may require that you or the authorized agent do the following:

• Verify your identity with us directly.
• Provide proof of your signed written permission for the authorized agent to submit a request on your behalf.

We may deny a request from an agent purportedly acting on your behalf if we request, and the agent does not submit, proof that he, she, or it has been authorized by you to act on your behalf.

Personal Information of Minors

We are proud of our online information, and we strive not to offend people of any age. We may store information from minors under the age of sixteen years only as required by applicable law for beneficiary reasons. If you believe that a child has submitted personal information to us outside of this narrow use, please contact us at [email protected], or +1-866-457-2826, and we will delete the information.

Additional California Privacy Rights

Shine the Light Request. California Civil Code Section § 1798.83 permits users of our website who are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to [email protected], or +1-866-457-2826 with the subject “Shine the Light Request.”

California Data Subject Request Metrics. In compliance with 11 C.C.R. § 999.317(g), we provide the following metrics regarding data subject requests received from California consumers during the prior calendar year:

Type of Request	Number Received	Number Complied With (in whole or in part)	Number Denied (in whole or in part)	[Median/Mean] Number of Days to Provide a Substantive Response
Request to Know
Request to Delete
Request to Opt-Out

 

Financial Incentives for California Consumers. Under California law, we may provide financial incentives to California applicants or employees who allow us to collect, retain, sell, or share their personal information. These incentives may include payments to applicants or employees, a lower price for goods or services, and/or a higher level of goods or services.

Changes to Our California Employee Privacy Policy

Win-Dor reserves the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post an updated policy on our website at www.windorsystems.com/privacy-employee with the effective date.

Additional Information

If you would like additional information regarding this Policy, please contact us at [email protected], +1-866-457-2826, or

Attn: Human Resources
Win-Dor, LLC
450 Delta Avenue
Brea, CA 92821

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