Effective Date: January 1, 2023
Last Updated: January 1, 2023

Red Ventures California Employee Privacy Notice

This Notice at Collection and Privacy Policy (“Privacy Notice”) explains how Red Ventures, LLC and our Subsidiaries and Affiliates (“Red Ventures”, “us”, “our”, or “we”) collect, use, disclose, and/or retain Personal Information subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). This Notice applies solely to California residents who interact with us, or whose information is provided to us through our interactions with, a job applicant, employee, contractor, or other role within our Company.

For purposes of this notice:

The term “California Employee” refers to all current and former employees, directors, officers, Board members, job applicants, temporary staff, interns, independent contractors, consultants, and benefits recipients of Red Ventures that reside in California.
The term “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 consumer or household.
The term “Sensitive Personal Information” means information revealing racial or ethnic origin, religious or philosophical beliefs, union membership, biometrics, health, sex life or sexual orientation.

What Personal Information Do We Collect About You?

Most often, the Personal Information, including Sensitive Personal Information, we collect from California Employees is collected directly from you. In some cases, it is collected from third parties, for example, when we perform background checks. In most circumstances, we get your consent before we collect Personal Information about you from a third party. The table below includes each of the categories and types of Personal Information we collect from and about you, and whether we disclose that Personal Information to third parties.

Categories of Personal Information	Examples	Categories of Entities We Disclose To
Identifiers	Your name and the names of your spouse, partner, beneficiaries, and dependents. Contact details such as home address, telephone number, email addresses, social media handles, and emergency contact details. Employee identification number, photo, and Internet Protocol address. State and national identifiers such as social security number, driver's license number, passport number, visa, and immigration status and documentation.	Affiliates, Service Providers, and Third Parties
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Your name and the names of your spouse, partner, beneficiaries, and dependents. Any of the following numbers: telephone, social security, passport, driver's license or state identification card, insurance policy, bank account. Signature, address, education, employment, employment history, other financial information, medical information, or health insurance information.	Affiliates, Service Providers, and Third Parties
Protected classification characteristics under California or federal law	Age (40 years or older), race, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran, or military status. This information is generally collected on a voluntary consensual basis.	Affiliates, Service Providers, and Third Parties
Internet or other similar network activity	Email sent or received on our network or on our computer, browsing history, search history, and information on your interaction with a website, or application while operating on our network.	Affiliates, Service Providers, and Third Parties
Geolocation data	Internet protocol address and Multi-Factor Authentication, for security purposes, which may indicate general location.	Affiliates, Service Providers, and Third Parties
Sensory data	Photos, videos, voicemail, meeting recordings, or security cameras.	Affiliates, Service Providers, and Third Parties
Biometric data	Fingerprint for access to Red Ventures laptops (optional and collected with your consent)	None
Professional or employment-related information	Job application details such as academic and professional qualifications, education, CV/resume, and certifications. Employment details such as job title, work location, supervisor, work schedule and status, compensation information, benefit information, training and development information, employment duration, current or past job history, and performance evaluations.	Affiliates, Service Providers, and Third Parties
Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, and aptitudes.	Affiliates and Third Parties
Sensitive Personal Information	Social Security number, driver's license number, state identification card number, and passport number. Health information such as short/long-term disabilities, particularly in relation to a leave of absence. Demographic information such as race, ethnicity, religious or philosophical beliefs, sex life or sexual orientation. This information is generally collected on a voluntary consensual basis.	Affiliates, Service Providers, and Third Parties

We do not use or disclose the above Sensitive Personal Information for purposes other than those business purposes specifically enumerated under CCPA. As a result, we do not offer a right to limit our use or disclosure of these categories.

What Do We Use Your Personal Information For?

We use your Personal Information, including Sensitive Personal Information, primarily for the purposes of managing our employment relationship with you, and for other business purposes such as:

Applicant recruiting, conducting background and reference checks, and employee on-boarding;
Administering payroll and independent contractor payment processing;
Benefit administration, including equity-related plans and benefits;
Time entry and leave management;
Expense reimbursement and management;
Establishing emergency contacts and responding to emergencies;
Establishing internal directories, such as employee directories and facilitating; communication between and among the company workforce;
Protecting our business through security and entry to premises, systems, and processes;
Training, appraisal, development, performance, and disciplinary records;
Employee and staff surveys;
Equal opportunity and diversity monitoring;
To comply with applicable laws and legal obligations such as employment, tax, and anti-discrimination laws.

With Whom Do We Disclose Your Personal Information?

Your Personal Information may be provided to the following categories of persons who are engaged by us that need it to provide the services for which they have been engaged.

Our Affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).
Service providers and contractors that process your Personal Information on our behalf to establish, manage, or terminate your employment or services.
Third parties at your direction to fulfill requests by you with your consent such as benefit and payroll providers.
Third parties in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition.
Law enforcement and other third parties to address legal obligations.

We do not sell, nor do we share with third parties for purposes of cross-context behavioral advertising, your Personal Information, including Sensitive Personal Information, including that of individuals under age 16.

How Long Do We Retain Your Personal Information?

We retain your Personal Information so long as it is reasonably necessary for the purpose for which it was collected, compliance with our legal obligations, resolution of disputes, fraud prevention, and enforcement of our agreements.

To determine the appropriate retention period for your Personal Information, we consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it; whether we can achieve those purposes through other means; and the applicable legal requirements.

In some circumstances we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information.

Upon expiration of the applicable retention period, we will securely destroy your Personal Information in accordance with applicable laws and regulations.

Your Personal Information Rights

This section describes your rights under CCPA regarding your Personal Information. We do not discriminate against California Employees who exercise their rights described in this Privacy Notice.

Request to Access Your Personal Information (Right to Know)
You have the right to request that we provide you with the following information:

The specific pieces of your Personal Information that we have collected about you;
The categories of your Personal Information we have collected about you;
The categories of sources from which your Personal Information is collected;
The business or commercial purpose for collecting, disclosing, or selling your Personal Information; and
The categories of third parties to whom the Personal Information was disclosed or sold for a business purpose.

Our responses to a request to know will provide Personal Information collected and maintained about you since January 1, 2022, unless doing so proves impossible or would involve a disproportionate effort. There may be scenarios where we deny your request. If that occurs, we will provide you with an explanation as to why we could not provide you with all or some of your Personal Information. Please note that we are not required to provide Personal Information to you more than twice in a 12-month period.

Request to Delete Your Personal Information (Right to Request Deletion)
You have the right to request that we delete your Personal Information, under certain circumstances, subject to several exceptions. There may be scenarios where we deny your deletion request. If that occurs, we will provide you with an explanation as to why we could not delete all or some of your Personal Information.

Request to Correct Your Personal Information (Right to Request Correction)
You have the right to request correction of inaccurate Personal Information maintained by us. If you have an active account, you may make the corrections yourself. Otherwise, when we receive and confirm your request, we will correct, and direct our service providers to correct, your Personal Information in our records. As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under law, or if we determine that the contested information is more likely than not accurate, based on the totality of circumstances.

How to Submit a Request
You may submit an email to employeerights@redventures.com or call our Privacy Team at 1-877-435-6495.

What to Expect When you Submit a Request
We use reasonable measures to detect fraudulent requests and prevent unauthorized access to your Personal Information. To meet our obligations, we are required to verify your identity. We may need to contact you about your request, and you can choose the contact method you would like us to use.

You may designate, in writing or through a power of attorney an authorized agent to make requests on your behalf related to your Personal Information. If you use an authorized agent to submit a request, we require the agent to provide proof they are authorized to act on your behalf by submitting their registration with the California Secretary of State as well as proof that you gave the authorized agent written permission.

We will process your request within 45 days or notify you if we require additional information, require an extension, or if the request will be denied. If we require additional time beyond 45 days, we will inform you of the reason and the extension period.

Changes to this 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 post the updated notice on this page and update the Notice’s effective date. Your continued use of our Redventures.com website to apply for a job and your Red Ventures accounts following the posting of changes constitutes your acceptance of such changes.

Questions

Questions about this Privacy Notice can be directed to employeerights@redventures.com. Alternatively, you may raise any questions or concerns to your manager, HR Business Partner, or through the Privacy Team.