Employee Privacy Policy

PRIMAL PET FOODS, INC., a California corporation

EMPLOYEE (AND APPLICANT) PRIVACY POLICY/NOTICE OF COLLECTION OF PERSONAL INFORMATION FOR EMPLOYMENT PURPOSES

Last updated:  February 23, 2022

SECTION 1 -- SCOPE OF THIS POLICY/NOTICE

This Employee (And Applicant) Privacy Policy/Notice of Collection of Personal Information for Employment Purposes (“Privacy Policy/Notice”) governs both existing and former California employees of Primal Pet Foods, Inc., a California corporation (“Primal”), as well as California applicants for employment.

This Privacy Policy/Notice is supplemented by Primal’s Employee Handbook, CA Hourly & Salaried Employees, January 2019 (“Employee Handbook”).  The Employee Handbook addresses, in addition to many other subjects, privacy-related issues such as employee access to personnel files, personnel information changes, employee reference checks, workplace monitoring, company property, employee property, technology systems policies and drug and alcohol use policies.  The Employee Handbook is an important document that may affect your legal rights.  Read it carefully and contact Primal with any questions.

Except as may be provided by applicable law, nothing in this Privacy Policy/Notice is intended to alter any rights or protections that any employee, former employee, or applicant may have under applicable law such as, in example, the California Labor Code.  Please also note that the laws that may govern a specific employment matter or situation may in some cases provide greater or lesser rights or protections than might otherwise appear to be provided by this Privacy Policy/Notice.  In such a case, your related rights or protections may be greater or lesser than as may appear from this Privacy Policy/Notice.

SECTION 2 -- WHAT CATEGORIES OF PERSONAL INFORMATION (INCLUDING SENSITIVE PERSONAL INFORMATION) DOES PRIMAL COLLECT AND WHAT CATEGORIES OF PERSONAL INFORMATION SOURCES ARE UTILIZED?

When you communicate with Primal regarding any aspect of your employment with Primal, your former employment with Primal, or prospective employment with Primal, whether through Primal’s website, app (if any), by email, text or other electronic means, or by phone or in person, Primal or a third-party (including third-party service providers) may collect personal information you provide such as your name, address, previous address information, phone number, email address, bank account information, social security number and information, tax information, employment, education and salary history, history of employment with Primal (and Primal affiliates), your relatives’ history of employment with Primal (and Primal affiliates), reference information, former name history such as a maiden name or a legal name that was changed, driver’s license information, employment identification documents for purposes of completing USCIS Form I-9 including but not limited to U.S. passport, employment authorization card, permanent resident card, and birth certificate information, medical and insurance information, physical and work abilities and traits information, gender, age, race and ethnicity information, veteran information including classifications, disability information, emergency contact information, biometric fingerprint and iris capture information, geo-tracking location information, and the like.

When you land on, browse or interact with Primal’s website or app (if any), or email or call Primal, Primal or a third-party (including third-party service providers) may also receive computer, mobile device, landline phone, internet, network or electronic information such as internet protocol (IP) addresses and operating system, web browser, and similar technical data, without limitation.  Primal or a third-party (including third-party service providers) may also collect other personal information from your devices including things such as your URL, referring URLs, browsing history (including dates), search terms used, the history and manner of your use of Primal’s website(s), data regarding your interactions with Primal emails, and geolocation data.  Finally, Primal or a third-party (including third-party service providers) may also collect personal information from public sources and personal information which you provide should you have any other employment-related communications with Primal, such as by email, by phone, or in person.  If Primal is acquired or merged with another company, your personal information may be transferred to the new company.

SECTION 3 -- WHAT IS PRIMAL’S PURPOSE IN COLLECTING YOUR PERSONAL INFORMATION (INCLUDING SENSITIVE PERSONAL INFORMATION), AND WHAT DOES PRIMAL DO WITH IT? 

Primal collects your personal information to use it for all aspects of your employment, former employment, or prospective employment with Primal.  That includes, without limitation, maintaining your employment file, tracking your hours, paying you, administering local, state and federal governmental entities’ information collection practices (including without limitation entities such as OSHA, Cal-OSHA, Cal-EDD, Cal-DFEH, Cal-FTB, the federal Department of Labor, the USCIS (e-verify), the Social Security Administration and the Internal Revenue Service), administering employment benefits, monitoring employee performance, making hiring, discipline and termination decisions, administering employment status changes such as promotions, demotions, and the like, auditing employment, employees, employment and USCIS I-9 practices, performance and costs, emergency medical purposes, applying for company credit cards, auditing motor vehicle usage, and the like.  Primal retains your personal information as required to accomplish such purposes.  Primal does not sell your personal information.

SECTION 4 -- WHAT CATEGORIES OF PERSONS OR ENTITIES DOES PRIMAL SHARE (DISCLOSE) YOUR PERSONAL INFORMATION (INCLUDING SENSITIVE PERSONAL INFORMATION) WITH?; THIRD-PARTY SERVICE PROVIDERS

In utilizing your personal information as described above, Primal may share it with (i.e., disclose it to) third-parties (including third-party service providers), including Primal affiliates, involved in employment administration, accounting, payments and similar employment-related activities such as employment job boards, Primal’s employee benefits providers and insurers, and local, state and federal governmental entities as indicated above and below.  Primal may also share your personal information with entities such as financial institutions including banks and business support providers (including third-party service providers) of things like Domain Name Service and website administration, support and security services, without limitation.  As explained below, some of these third-parties (and others) may use cookies in connection with Primal’s website, including on its Employment page.  Primal is not responsible for third-parties’ privacy practices.  Also, remember that third-parties, whether third-party service providers or not, may be located in or have facilities that are located in a different jurisdiction than either you or Primal.  So if you elect to proceed with a transaction that involves the services of a third-party, then your personal information may become subject to the laws of the jurisdiction(s) in which that party or its facilities are located or which govern their activities.  Also remember that if you leave Primal’s website or are redirected to a third-party website or application, you are no longer covered by this Privacy Policy/Notice.

As indicated above, Primal may also share your personal information with local, state and federal governmental entities that collect such information such as, without limitation, OSHA, Cal-OSHA, Cal-EDD, Cal-FTB, the federal Department of Labor, the Social Security Administration, the Internal Revenue Service, and the USCIS (e-verify).

SECTION 5 -- DISCLOSURES REQUIRED OR ALLOWED BY LAW

Primal may disclose your personal information (including sensitive personal information) as required or allowed by law.

SECTION 6 -- CONSENT & WITHDRAWAL OF CONSENT & USE LIMITATIONS; YOUR RIGHTS TO REQUEST PERSONAL INFORMATION (INCLUDING SENSITIVE PERSONAL INFORMATION) OR TO CHANGE, DELETE OR LIMIT DISCLOSURE OF SUCH PERSONAL INFORMATION; CONTACTING PRIMAL TO DO SO

When you provide Primal with personal information for employment, past employment, or prospective employment purposes, we infer that you consent to our collecting it and using it as described above.

Under California law, only to the extent that it may be applicable, you (or an authorized agent) may have the right to withdraw your consent (whether express or implied) or to limit Primal’s collection, use or disclosure of certain personal information.  Certain restrictions may apply to such requests.  Also under California law, only to the extent that it may be applicable, you (or an authorized agent) may also have the right to request that Primal change or delete certain personal information that it has collected or provide copies by category, by specific item, by source, by purpose, and by persons or entities with whom Primal has shared it.  Certain restrictions may apply to such requests.  Any such request must be verifiable as being made by the actual individual in question (or by an authorized agent).  Any such verified request shall also be shared with Primal’s applicable third-party service providers, if any.  To provide or withdraw consent to any service or action, to obtain copies of personal information, or to request that Primal change, delete or limit the sharing of personal information, please email your request to Primal Human Resources via email:  [email protected] or telephone (707) 398-6057.  Primal will respond within 10 days and strive to resolve all requests within 45 days.  To protect you and all Primal employees, former employees and applicants, Primal will have to verify your identity (and any agent’s identity and authority) before disclosing, changing, limiting the disclosure of or deleting any personal information.  Generally, Primal may do this from information Primal already has, from public information and/or by asking you for verifying information including unique identifiers and two-factor identifying information.  Primal may also require written and signed authorization or a legal power of attorney in the event of an agent request.  Also under California law, only to the extent that it may be applicable, you have the right not to be discriminated against based on the exercise of your privacy rights.

SECTION 7 -- SECURITY

Primal takes precautions to help protect personal information (including sensitive personal information) from inappropriate destruction, loss, access, disclosure or misuse.  Primal cautions that it does not believe that any method of transmission over the internet or of electronic storage is 100% secure, and so cautions you.

SECTION 8 -- COOKIES

Primal or third-parties (including third-party service providers) may use cookies in connection with Primal’s website, including its Employment page.  The cookies that Primal uses or understands are used in connection with Primal’s website are, generally, used for purposes such as:  user and session identification, session data storage (e.g., referrer, landing page), token identification, login, password security, payment security, website site security, number of visits, cart information, purchase transactions, website, session and purchase analytics, embedded video view tracking, ad tracking across time and platforms, and geolocation.  Primal discloses cookie use in connection with its website to help you choose if you want to block cookies or use similar “do not track” type settings, or not.  Again, Primal is not responsible for third-party privacy practices.

SECTION 9 -- AGE OF CONSENT 

By applying for or continuing employment with Primal, you represent that you are at least 18 years of age as of the date you submit your employment application.

SECTION 10 -- CHANGES TO THIS PRIVACY POLICY/NOTICE

Primal reserves the right to modify this Privacy Policy/Notice at any time, so please review it frequently.  Changes will take effect immediately upon their posting on Primal’s website.  Changes to the Policy/Notice Last Updated date typically mean that the Policy/Notice terms have changed.

SECTION 11 -- QUESTIONS AND CONTACT INFORMATION

If you have any questions about this Privacy Policy/Notice, please contact Human Resources at [email protected] or by telephone at (707) 398-6057.