Privacy Notice to California Personnel, Candidates and Contractors

Effective Date: January 1, 2023

EG America, LLC and its affiliates and subsidiaries (“EG America,” “we,” “us,” or “our”) is committed to the responsible management, use, and protection of personal information. We do not sell to third parties the personal information we collect about you in the HR contexts described below. This Privacy Notice to California Personnel, Candidates and Contractors (this “Notice”) describes our processing of California residents’ personal information in various human resources (“HR”) contexts over the prior 12 months, as required under the California Consumer Privacy Act (as amended by the California Privacy Rights Act and otherwise, the “CCPA”). 

If you are a California resident and have interacted with us or otherwise provided us with personal information in the following HR contexts in the bulleted lists below, please read this Notice carefully as it describes how we collect, use, retain, disclose, and otherwise process your personal information, and the rights you have under California law as to your personal information. 

  • Current/Former Employee: (you are a current or former employee of EG America). 
  • Independent Contractor: (you are a current or former independent contractor of EG America).
  • Job Applicant: (you have applied for employment with EG America previously, such as on https://nowhiring.com/ega/).

This Notice also applies to California residents whose family member or friend has provided their information to EG America in an HR context, such as if:

  • they are listed as an emergency contact for a EG America employee or former employee.
  • they are a beneficiary or dependent of a EG America employee or former employee.

Collection of Personal Information

We may collect the following categories of personal information from you or about you from third party vendors (for example, background check providers): 

Categories of Personal Information we may collect:

Categories of Third Parties with Whom We Disclosed Personal Information for a Business Purpose

Professional/Employment-related data (e.g., if you are an applicant, your current and prior jobs and education. If you are an employee, examples include your status of employment, office location, company email or telephone number, start date, etc.)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Educational records (e.g., official grades, transcripts, class lists, or disciplinary records from your educational institution )

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Financial Information (Examples include your bank account number, credit card number, debit card number, government-issued Tax ID, and any other financial information.)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Identifiers (e.g., a real name, alias, postal address, online identifiers, and other similar identifiers)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Internet/Electronic network activity (e.g., browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Geolocation data (e.g., approximate location of a device or equipment based on geographical coordinates and measurements)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Characteristic of protected classifications under California or federal law (e.g., In some circumstances, we may collect PI that is considered protected under U.S. or California law, such as age, gender, nationality, race or information related to medical conditions[, but only when that information is relevant for our business purposes (which, include legal obligations).])

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Audio, electronic, visual, thermal, olfactory, or similar information (e.g. security video footage and HR hotline recordings)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Inferences (we may draw inferences from other information we collect about you. [For example, based on your performance or other information we may recommend skills training that may benefit you. Additionally, based on information you voluntarily provide during onboarding, we may infer your interest in diversity, equity, and inclusion  programs and create internal email lists to communicate with you about relevant DEI programs.])  

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Commercial information (e.g., records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Sensitive Personal Information

Social Security, driver’s license, state identification card, or passport number (For example, we collect certain government ID numbers when you apply for jobs with us or when we onboard you as an employee.)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account (For example, we may collect account logins in combination with passwords for some of our IT systems.)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Racial or ethnic origin, religious or philosophical beliefs, or union membership ([For example, as part of our diversity, equity, and inclusion efforts, we may use information you voluntary provide to perform internal research, monitor our progress, and develop DEI initiatives and programs that we operate internally for employee participation.])

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

The contents of mail, email and text messages, unless Company is the intended recipient of the communication (Like all employers, if you utilize our email or other communications systems, we may review and monitor your communications.)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

PI collected and analyzed concerning health (For example, we may receive information about your health in relation to health insurance and other benefits.)

  • General IT, software, and other business vendors
  • HR system and software vendors
  • Non-software HR vendors, such as background check vendors
  • Payroll and benefits vendors and providers
  • Insurance providers and brokers
  • Affiliates and related entities
  • Governmental entities (for example, in relation to our obligations to determine employment eligibility and responding to requests pursuant to legal or regulatory process)

Sale/Share: N/A

Retention of Personal Information: For current or former employees and contractors and their emergency contacts or dependents: generally, the last date of employment or engagement, plus seven years. For job applicants: seven years.

Use of Personal Information

The following are the business purposes for which we may use the personal information described above:

  1. Human resources administration, including facilitation of applications and background checks, where appropriate, internal employee management, corporate travel and other reimbursable expenses, development and training, absence monitoring, timekeeping, performance appraisal, disciplinary and grievance processes, administration of termination of employment, reporting, career planning, talent management, relocation, learning management, promotion of EG America’s values, succession planning and other general administrative and human resource related processes; 
  2. Payroll and benefits, including incentives and coordination of compensation, keeping beneficiary details;
  3. Recordkeeping, including accounting, commercial, procurement, document management and other similar services; reporting financial information and financial background checks, consultancy and advisory services, and corporate credit cards;
  4. Administrating external workforce and independent contractors, planning and allocation of resources; 
  5. Production of products, integrated supply-chain, logistics, plant design, documentation tools, engineering drawings, enterprise resource planning and analytics, log book for facilities, task list for operators, event and associated action items, handling of maintenance, requisitions workflow, product quality, plant visitor administration, development of products, technologies and services, research;
  6. Administrating and enhancing customer relationships, customer data trending and analysis; 
  7. Environmental, health and safety, including security of the working environment,  maintenance of medical and sickness records and occupational health programs, keeping emergency contacts, environmental protection and sustainability management, labor tracking for billing, behavioral safety, statutory reporting obligations;
  8. IT services, providing the IT infrastructure including hardware and software, enabling telecoms and electronic communications and organization, including the Internet, mobile applications, remote access, online meetings, collaboration tools and other resources, storage for electronic records, license allocation, allocation of user rights, debugging and troubleshooting, firewall and intrusion prevention, URL and malware filtering and reporting, tracking of files copied to removable media, ticket systems for requests; 
  9. IT security management, monitoring and forensic tasks to protect the safety and security of employees, customers and property, including controlling and facilitating access to and monitoring activity in secured premises and activity using computers; and 
  10. Corporate policy, corporate compliance, regulatory, export compliance and legal subject matter training; fulfillment of legal tasks including investigating and responding to claims against the company and its customers and employees, handling complaints, electronic signatures, internal audits, third party due diligence systems, including anticorruption screening, operation of whistle blowing hotlines, and other such purposes in relation to the above-mentioned services.

For a description of your rights under the CCPA and other applicable laws, and how you may exercise them, please refer to our Privacy Policy.

Contact. Please contact our Privacy Team with any questions regarding use of your personal information. You may do so by emailing privacy@eg-america.com.