DG Premium Brands LLC California Employee Privacy Notice

This California Employee Privacy Notice (the “California Employee Privacy Notice”) supplements the 7 For All Mankind Privacy Policy, Splendid Privacy Policy Privacy Policy and applies to the personal information of California employees, interns, contractors, volunteers, and applicants (collectively, “Workforce Members”) collected by DG Premium Brands, LLC (“DGPB,” the “Company,” “us,” or “we”). This California Employee Privacy Notice also applies to information provided to us about employees’ relatives or others used for emergency contact or benefits administration purposes.

Please read this California Employee Privacy Notice to learn how we collect and process your personal information when you are employed by DGPB, engaged to provide services to DGPB, or apply for a job with DGPB. Under the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), as modified by the California Privacy Rights Act (the “CPRA”), you have the right to know and understand the categories of personal information we collect about you and the purposes for which we use such personal information. Certain terms used in this California Privacy Notice have the meaning given to them in the CCPA or CPRA and their implementing regulations. This California Employee Privacy Notice only applies to Workforce Members who are residents of the State of California. The Company does not sell or otherwise disclose Workforce Member personal information for monetary or other consideration to any third parties.

Categories of Personal Information We Collect

In each case as permitted by applicable law, we collect the following categories of personal information for the purposes described below:

Sensitive Personal Information

Government-issued identifiers, such as Social Security number, driver’s license number, passport number, or state identification card number.
Financial information, such financial account combined with any required security or access code, password, or credentials allowing access to an account, or debit card or credit card number combined with any required security or access code, password, or credentials.
Private communications, including mail, email, or text message content unless in the information was intentionally sent to the Company.
Personal characteristics such as racial or ethnic origin, religious or philosophical beliefs, or union membership.
Personal information concerning health or sexual orientation.
Biometric information that may uniquely identify an employee.
Geolocation data that indicates your precise location, such as address, ZIP code, and city.
Additional sensitive personal information as defined in the CPRA.

Additional Personal Information

Personal identifiers, such as your name, preferred name, signature, date of birth, physical characteristics or description, education, postal address, unique personal identifiers (such as device identifiers, cookies, beacons, pixel tags, mobile ad identifiers and similar technology), telephone number, online identifier, Internet Protocol address, or email address, or insurance policy number.
Characteristics of protected classifications, such as race, color, national origin, age, sex, gender, gender identity, sexual orientation, marital status, medical condition, disability, citizenship status and military or veteran status. We only collect this information if you voluntarily disclose it and as permitted by applicable law, and we will not use this information to make hiring decisions.
Online activity, such as your browsing history, search history and information regarding your interaction with a website, application or advertisement.
Sensory data, such as audio and visual information that we may obtain if you use video interviewing as part of the application process. If you visit, work or perform services in our facilities or facilities in which we operate, your entry, exit and actions in or around those facilities may be monitored by CCTV.
Professional or employment-related information, such as your employment history, job application or resume, employment contract, references, information about skills and abilities, accomplishments and awards, training and development information, performance evaluation information and employment termination information.
Non-public education information, such as your education history, education records (such as grades, transcripts and class lists) and other information included in your resume or cover letter.
Inferences drawn from other personal information, including any information referenced above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

We also may collect personal information included in job interview notes, responses to screening questions, assessment results and any other information you provide or that is provided at your request or with your permission, such as references, in connection with the recruitment process.

Sources of Personal Information

We collect personal information you voluntarily provide to us during the application process or when you otherwise contact us. We may also automatically collect certain information, such as IP addresses and device identifiers.

We may combine personal information you voluntarily provide to us with information we collect from other sources, such as:

Recruiters;
Prior employers and professional references;
Educational institutions;
Pre-employment screening and background check services;
Credentialing and licensing organizations;
Publicly available sources, such as public social media profiles on LinkedIn, Twitter or Facebook; and
Other sources as directed by you

Business Purposes for Collecting Personal Information

We use the categories of personal information above for the following business purposes:

Recruitment of Employees and other staff and Processing and Managing Job Applications: We use your personal information to process your job application, create an applicant profile, evaluate your qualifications, schedule and conduct interviews, and communicate with you.
Conducting Pre-Employment Screening and Background Checks: In accordance with applicable law, we use your personal information to conduct employment screening and background checks.
Compensation and Expense Management: We use your personal information to conduct payroll processing, salary administration, expense reimbursement, manage the Company’s corporate credit card program, and other compensation purposes such as determining bonuses, equity and other forms of employee compensation.
Benefits Administration: We use your personal information we collect to administer benefits we provide, such as medical, dental, vision, disability insurance, retirement benefits, and other employee benefit programs.
General Human Resources Management: We use your personal information we collect to provide general HR management services, including managing employee on-boarding, termination and separation, travel administration, workplace accommodations and safety, and return-to-work screening (including any medical screening as required or permitted by applicable law).
Training and Professional Development: We use your personal information to provide employment-related training, and assist with professional licensing and development.
Internal Employment Purposes: We use your personal information to conduct internal investigations, conduct surveys, resolve disputes, prevent or detect fraud or security incidents, conduct employee performance reviews, enforce our policies and code of conduct, protect the rights and safety of employees or others, and manage whistleblower programs.
Compliance with Legal Requirements and Enforcement of Our Legal Rights: We use your personal information to comply with applicable laws, regulations and legal processes (such as responding to subpoenas or court orders), and to respond to legal claims, resolve disputes, enforce our legal rights contained in employment or other contracts and those of our staff, customers and others, and comply with legal or regulatory recordkeeping requirements.

Disclosure of Personal Information

We may share your personal information for the business purposes described in this California Employee Privacy Notice with the following parties:

Affiliates and Subsidiaries: We may share your personal information with our affiliates and subsidiaries.
Service Providers: We may share your personal information with service providers, such as recruiters, pre-employment screening services, third-party benefits administrators, payroll processors, background check providers, and others.
Governmental Authorities: As required by law or legal process, we may share your personal information with federal or state regulatory agencies, law enforcement, courts, and other governmental authorities.
Professional Advisors: We may share your personal information with our professional advisors, such as auditors and law firms.
Parties Involved with Business Transfers: We may share your personal information to third parties in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

Retention

The chart below describes how long we retain records for each category of your employment information:

Retention Category	Retention Period
Documentation of human resources operations related to personnel management, staffing, and payroll administration, including time tracking, drug testing records, equal employment opportunity, recruitment, and employee relocation	8 years
Documentation of each individual’s employment history, including leaves of absences, immigration and naturalization, and records of payroll elections	8 years
Records documenting the development, design, management and administration of company-sponsored benefit and incentive plans (e.g., health and welfare, pension and savings, etc.)	8 years
Records of employee eligibility and participation in company-sponsored benefit plans	8 years

Your Rights

The CPRA grants you certain rights in connection with the Personal Information which we collect. These rights do not always apply, and cannot be exercised in violation of our rights or those of our staff or of third parties.

Right to Notice. Before or at the time we collect Personal Information from you, you have the right to receive notice of the Personal Information to be collected and the purposes for which we use it. This Notice is intended to satisfy this requirement.
Right of Access. You also have the right to request that we disclose to you the personal information we have collected about you in the 12 months preceding your request, along with (i) the categories of sources from which that personal information was collected, (ii) the purposes for collecting or selling that personal information, (iii) the categories of third parties with whom we shared that personal information, and (iv) the categories of third parties to whom we sold or transferred that personal information.
Right to Deletion. You have the right to request that we delete the Personal Information we collect from you. DGPB thoroughly reviews each deletion request and determines its approval or denial status on a case-by-case basis in accordance with California law.
Right to Limit the Use of Sensitive Personal Information. You may request that we limit the use of your personal information to only fulfill specific necessary purposes.
Right to Correct Inaccuracies. You have the right to request that we update your personal information to correct any inaccuracies.
Right to Opt Out of the Sale or Sharing of Personal Information. We only share your information within DGPB and with trusted partners of DGPB for the purposes outlined above.

You can exercise any of these rights by calling 213-488-4208 or sending an email to DGPB.HumanResources@dgpb.com.

If you are exercising your right to know, correct, and delete, we reserve the right to verify your identity to protect our employee data from unauthorized access.

In accordance with our policies and procedures, we will not discriminate or retaliate against you if you choose to exercise any of your rights under the CCPA or CPRA.

Contact

If you have any questions about this Notice or need to access this Notice in an alternative format due to having a disability, please contact DGPB.HumanResources@dgpb.com or 213-488-4208.