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CCPA Privacy Notice

CCPA/CPRA Privacy Notice

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Dreisbach Enterprises, Inc. and Coolport Management LLC (“Company” or “we” or “us”) take your privacy seriously.  We want you to know how we collect, use, and disclose, your personal information.

This Privacy Policy and Notice applies to the personal information of California residents in their role as (a) job applicants (“Applicants”), (b) employees, (c) independent contractors, interns, volunteers, owners, board members, and other individuals who perform work for Company (collectively, “Non-Employees”), and (d) employees’ and Non-Employees’ dependents, emergency contacts, and beneficiaries (“Related Contacts”), (all collectively, “HR Individuals”).

“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 HR Individual. Personal information does not include information publicly available from government records or made publicly available by you or with your permission, deidentified or aggregated information, and information excluded from the CPRA’s scope (such as protected health information, consumer credit reports and background checks).

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We may collect the following categories of personal information.  Not all categories may be collected about every individual.

  • Identifiers, for example: real name, contact information, and social security number.
  • Additional Data Subject to § 1798.80: such as a state identification card, photograph or health information (this category may overlap other categories)
  • Characteristics of Protected Classifications Under California or Federal Law, collected on a purely voluntary basis, except where collection is required by law, and used only in compliance with applicable laws and regulations, for diversity and inclusion reporting, and related purposes.
  • Commercial Information, for example: travel expense records.
  • Biometric information, for example: a fingerprint might be scanned to obtain numerical template.
  • Internet Activity Information, for example: electronic network activity information, including, but not limited to, browsing history, online behavior, access logs, and interactions with websites, applications, and systems.
  • Geolocation data, for example: dashcam, mobile devices.
  • Audio, Visual, and Sensory Information, for example: CCTV footage, dashcam and photographs.
  • Professional or Employment-Related Information, for example: educational institutions attended, degrees and certifications, licenses, work experience and previous employers, and professional memberships and affiliations.
  • Inferences, for example, Company might infer characteristics from a personality assessment completed by you.
  • Compensation and benefits information for employees, for example, salary, hours and overtime, leave information, and identifying information for dependents and beneficiaries.
  • Other details, for example, work preferences.

We do not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about the HR Individual.

SOURCES OF PERSONAL INFORMATION

We collect personal information from the following categories of sources.  Not all categories apply to every HR Individual.

  • You, for example, in your job application, forms you fill out for us, assessments you complete, surveys you complete, and any information you provide us during your relationship with us.
  • Your spouse or dependent with respect to their own personal information.
  • Vendors and service providers, for example, recruiters or law firms we have hired to provide services for us.
  • Third parties, for example, job references or affiliated companies.
  • Automated technologies on Company’s electronic resources, for example, to track logins and activity on Company’s careers page or network, voicemail technologies.
  • Government or administrative agencies, for example, law enforcement or public health authorities.

 HOW WE USE YOUR PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job or become an employee, we will use that personal information in connection with your employment or potential employment.
  • To manage pre-employment matters including identifying you, communicating with you, evaluating your application, background checks, emergency contact information, staffing, eligibility to work, promoting Company as a place to work, and other Applicant-related activities.
  • Administering the employment relationship including, but not limited to, human resources administration, payroll processing, benefit administration, leave programs, sicknesses, holidays, vacations, corporate travel and other business expenses, development and training, absence monitoring, timekeeping, ELD data, government / regulatory programs, grievance or disciplinary matters, diversity and inclusion, ascertaining your fitness to work, dispute resolution, drug screening, worker’s compensation administration, and facilitating employee communication and collaboration.
  • Managing and/or analyzing all aspects of employee performance including but not limited to talent management, periodic reviews, performance tracking, promotions, retention, discipline, education, training and development requirements and data analytics.
  • Administering the relationship with Non-Employees, including, but not limited to, evaluating the Non-Employee’s qualifications for engagement, managing workforce matters, facilitating communications, negotiating, executing, and monitoring the performance of work contracts, payments, and workforce satisfaction.
  • To reduce the risk of exposure to, and the spread of infectious disease, in the workplace, to comply with local, state, and federal law, regulations, ordinances, guidelines, and orders, to identify potential symptoms linked to COVID-19 (including through temperature checks, screening questionnaires, or testing), to assist with contact tracing relating to potential exposure, to communicate regarding potential exposure to COVID-19, and to help prevent further spread of the virus.
  • To manage health, safety and security in our workplace and investigate and report on accidents and incidents in accordance with our policy and applicable laws.
  • To provide, support, personalize, and develop our website and services relating to your employment or potential employment.
  • To detect and prevent fraud or other types of wrongdoing.
  • To monitor your use of our information and communication systems to ensure compliance with our IT policies.
  • To ensure and enhance the security of our electronic systems, corporate network, Website, and managed devices including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution, disaster recovery, business continuity, record keeping obligations and cyber security.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To manage licenses, permits, and authorizations applicable to Company’s business operations.
  • Equal opportunities monitoring.
  • To protect the rights, property, or safety of Company, HR Individuals, customers, or others.

We may also use this personal information to operate, manage, and maintain our business, for our employment purposes, and to otherwise accomplish our business purposes and objectives including developing and improving our services and programs for our employees; conducting research, analytics, and data analysis; maintaining our facilities and infrastructure; undertaking quality and safety assurance measures; conducting risk and security controls and monitoring; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies; maintaining records; exercising and defending legal claims; and in connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or our financial status or any of related subsidiaries or affiliates.

HOW WE MAY SHARE YOUR PERSONAL INFORMATION

We generally maintain personal information related to HR Individuals as confidential.  However, from time to time, we may have a legitimate business need to disclose personal information to one or more of the categories of external recipients listed below:

  • Your direction: We may disclose your personal information to third parties at your direction.
  • Service providers and contractors: Company discloses your personal information to service providers and contractors for the purposes above to assist us in meeting our business needs and contractual and legal obligations.
  • Affiliated companies: Other companies affiliated with Company.
  • Customers: For example, Company might disclose your business contact information to a customer for purposes of facilitating a delivery.
  • Government or administrative agencies: These may include, for example: regulators, courts or law enforcement
  • Required Disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
  • Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, our users, or others.

No sales and no “sharing”, i.e., disclosure for cross-context behavioral advertising: Company does not sell the personal information of any HR Individuals nor share their personal information for cross-context behavioral advertising.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this Privacy Notice or any other notice provided at the time of data collection. Retention is based on several factors, including legal requirements, statutes of limitation, and business needs.

YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM

Your California Privacy Rights

Subject to applicable law, HR Individuals have the following rights:

  • Right to Know: You have the right to submit a verifiable request, twice in a 12-month period, for copies of specific pieces of your personal information obtained from you and for information about Company’s collection, use, and disclosure of your personal information. Please note that CPRA’s right to obtain copies does not grant a right to the whole of any document that contains personal information, but only to “specific pieces” of personal information.  Moreover, HR Individuals have a right to know categories of sources of personal information and categories of external recipients to which personal information is disclosed, but not the individual sources or recipients.
  • Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Company.
  • Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Company, taking into account the nature of the personal information and the purposes of processing the personal information.

It is important to note that the above rights are not absolute, so while you may request to know, delete, or correct your personal information, we may not be legally required to comply with your request. We will evaluate any request to exercise the above rights on a case-by-case basis and will respond to that request as required by applicable law.

 How to Exercise Your Rights

Company will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:

How We Verify Your Request:

The law requires that we validate the identity and legal authority associated with any personal information request for an HR Individual. If you make a request, we will send a message to the email address you provided in your request and you must follow the instructions in that email for us to verify your request. We will begin processing your request once you have completed the verification process. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.

If an authorized agent submits a request to know, correct, or delete on your behalf, the authorized agent must submit with the request a document signed by you that authorizes the authorized agent to submit the request on your behalf.  In addition, we will ask you or your authorized agent to follow the applicable process described above for verifying your identity. You can obtain the “Authorized Agent Designation” form by contacting us at by phone or email as outlined above.

Company’s Non-Discrimination and Non-Retaliation Policy

Company will not unlawfully discriminate or retaliate against you for exercising your privacy rights under the California Privacy Rights Act.

UPDATES TO PRIVACY POLICY

We may update or make changes to this Privacy Policy and Notice from time to time and may apply any changes to information previously collected, as permitted by law. When we make changes to this Policy, we will post those changes on this page and update the effective date.

For More Information

For questions or concerns, please contact us at CPRAPrivacyRequest@dreisbach.com.

Effective Date: January 1, 2023