NOTICE TO EMPLOYEES, JOB APPLICANTS, AND CONTRACTORS RE: COLLECTION OF PERSONAL INFORMATION

Effective Date: March 1, 2025

At Irene Neuwirth, Inc. and our operating groups, subsidiaries, and affiliates, (“Irene Neuwirth,” the “Company,” “we” “our,” or “us”), we are committed to the proper handling of the Personal Information collected or processed in connection with your employment with us. We provide the following notice to all Irene Neuwirth employees, job applicants, and independent contractors. Although this notice is required only for residents of California, we want all of our employees and job applicants nationwide to understand the Personal Information we collect and rights they may have relating to that information. 

As a preliminary matter, we do not sell or otherwise disclose our employee or applicant Personal Information for monetary or other consideration to third parties. We may provide your Personal Information to those providing services for us, such as our benefits administrators or other entities that need the information to provide a business function for us, or to government agencies (such as taxing authorities and the social security administration). 

This disclosure describes the categories of Personal Information we collect and the purposes for which we process that information in accordance with California Civil Code § 1798.100(a) of the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”). The CCPA defines “Personal Information” as categories of information that identify, relate to, describe, or are reasonably capable of being associated with, or can reasonably be linked, directly or indirectly, to a particular individual or household. 

Please note that the CCPA’s definition of Personal Information does not include the following:

• Publicly available information lawfully made available to the general public from federal, state, or local government records (information is not publicly available if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained);

• De-identified or aggregated consumer information;

• Personal Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accessibility Act of 1966, the California Medical Information Act or clinical trial data; or 

• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver's Privacy Protection Act of 1994.

1. Sources of Personal Information 

Our sources of Personal Information can be directly from you, or we may also combine Personal Information collected from other sources with the Personal Information you provide to us. In some instances, Personal Information may be collected automatically, such as in connection with your use of the internet on Company-issued or Company-controlled devices, or via keycard or key fob access. 

The sources of your Personal Information may include: 

• You 

• Recruiters

• Prior employers (e.g., for references) 

• Professional references you provide to us

• Educational institutions

• Pre-employment screening services

• Job posting and talent acquisition sites or services (e.g., LinkedIn, Indeed, Monster, etc.)

• Credentialing and licensing organizations (if applicable) 

• Publicly available resources including your social media profile (e.g., LinkedIn, Twitter, Instagram, or Facebook) or your current employer’s website

• Third parties, as necessary for providing you with benefits and ancillary services

• Your Company-issued or Company-controlled device (such as computers and phones)

• Other sources as directed by you.

2. Personal Information Collected

This section describes what information we collect from you. We may receive information (including Personal Information) as follows:

Information That You Provide to Us

During your application or employment with us, we may collect the following Personal Information via webforms, forms, or through telephone calls, letters, emails and other communications with you:

• Contact and account information. We may collect information such as your first and last name, email address, home address, telephone numbers, mobile numbers, emergency contact information and password;

• Sensitive Personal Information. We may collect sensitive Personal Information as follows:

• Social security number, passport number, driver’s license number or other government-issued identification;

• Citizenship status;

• Background checks or drug/substance tests;

• Health information such as disability status or medical conditions (for accommodations);

• Financial information. We may collect information such as bank account information and information about your compensation, including salary, bonus and benefits; 

• Social media information. We may collect information such as social media handles, content and other data that you share with us. Please note that your social media activity can be public;

• Employment information. We may collect information such as your current or past employment or educational information, as well as references and referrals provided to us in connection with your employment applications; and/or

• Other information. We may collect other information that could reasonably be used to identify you personally.

Information That Is Automatically Collected

Like many businesses, we and/or our service providers may automatically collect and/or store certain information during the course of your employment with us, such as information collected about your internet usage or use of Company-owned or -controlled devices (including in-store tablets). Please note that you should not expect privacy with regard to this Personal Information, as further explained in our Employee Handbook. 

This information includes:

• Usage Information. We may collect the following information from a Company-issued or Company-controlled computer, laptop, tablet, mobile phone or other device (a “Device”):

• Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;

• Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);

• Referring and exit web pages and URLs; 

• The areas within the Site and App that you visit and your activities there, including remembering you and your preferences;

• Your Device location or other location information, including the zip code, state or country from which you accessed the Services;

• Your Device characteristics; 

• Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;

• Information about your engagement with our emails; 

• Statistical information about how both unregistered and registered users, collectively, use the Site and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser; and

• Information about the applications or programs you are using.

• Sensory information. We may collect sensory information such as audio and visual information from the audiovisual surveillance on our premises; or from software on a Company-issued or Company-controlled Device (which could include a “Face-ID” type of login on an in-store tablet).

• Precise geolocation. If you use a Company-issued or controlled Device or enter a facility owned or used by Irene Neuwirth (“Premises”) with a keycard/key fob, we may collect precise geolocation information, which includes information about your whereabouts and the time.

Information Collected from Third Parties

We may collect Personal Information from third parties. For example, we might run a background check on you prior to your employment with us with your express consent; or we might obtain information from a prior employer or a reference.  If applicable, we encourage you to review the privacy statements of these third parties to understand their privacy practices.

3. How We Share Personal Data

Services Providers

We share your Personal Information with our third-party service providers who provide services such as payroll and benefits processing, surveys, information technology, customer service, email delivery, auditing, event planning or other services. 

Other

Aside from the instances described above, we may share your Personal Information: 

• to comply with the law; 

• to respond to claims or comply with legal process served on the Company (e.g., a lawful subpoena, warrant, or court order);

• to enforce or apply our policies or agreements; 

• to protect and defend our rights or property or that of our customers, employees, visitors, or the public; 

• in connection with a business transfer, sale, liquidation, or merger; 

• if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and

• to other parties only with your consent.

4. Use of Your Personal Information 

We use the information collected for the purposes stated below:

For Job Applicants:

• To recruit employees, including evaluation of marketing and job offering services, website traffic, and referral sources; 

• To process your application for employment;

• To conduct employment-related background screening and/or reference checks; 

• To send you correspondence and information relating to your application or your employment with Irene Neuwirth; 

• To verify your identity, citizenship, or legal right to work for Irene Neuwirth, or to assist or cooperate with obtaining relevant immigration documents;

• To verify your educational background and/or degrees, certifications, or qualifications for the position you apply for; 

• To verify your prior employment; 

• To offer you employment with the Company; 

• For testing, evaluation and/or reporting metrics, including but not limited to aggregating or anonymizing such information for workforce analytics, data analytics, and benchmarking; 

• To comply with applicable law or regulatory requirements, including legal requirements under state and federal law, law enforcement investigations or inquiries, as well as internal Company reporting obligations, such as diversity, equity and inclusion initiatives and/or Equal Employment Opportunity Act reporting obligations; 

• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for such activity;

• For quality assurance purposes, including call monitoring or customer service, and debugging to identify and repair errors that impair existing intended functionality; 

• For auditing related to a current interaction with the applicant or employee and concurrent transactions, including, but not limited to, counting impressions to unique visitors, verifying positioning and quality of impressions, and auditing compliance with this and other standards; 

• To analyze the effectiveness of placement of job listings and job descriptions; 

• For fraud prevention; and

• For internal research for technological development and demonstration.

For Past and Current Employees and Independent Contractors:

All of the above, plus: 

• To track time and attendance; 

• To administer employee benefits, such as medical, dental, commuter and retirement benefits, including the recording and processing of eligibility of dependents and beneficiaries, absence and leave monitoring, insurance and accident management, and rewards or discount programs offered to employees; 

• To provide healthcare-related services, such as accommodations and/or services based on eligibility (e.g., disability, worker’s compensation, medical condition); 

• To provide payroll, invoice, and tax services, including reimbursement for expenses, salary administration, payroll management, payment of expenses, payment of state and/or federal income taxes (if applicable), social security and unemployment taxes, and to administer other compensation-related payments, including bonuses and equity, if applicable; 

• To conduct performance-related reviews, including performance appraisals, professional development, career planning, skills monitoring, job moves, promotions and staff re-structuring; 

• To monitor work-related licenses and credentials and ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies or governing agencies; 

• To provide employees with other employment-related services, such as handling of employees’ claims, travel for Irene Neuwirth, moving or relocation services, or administration of separation from employment; 

• To assist you in case of an emergency, including maintaining contact information for you, your partner or spouse, and/or your dependents in case of personal or business emergency; 

• To maintain the safety and security of our employees, residents, tenants, contractors, visitors and others, including maintenance of security on Irene Neuwirth websites, apps, intranets and/or extranets (such as monitoring email and internet access, and ensuring secure network access and data integrity), maintenance of physical security (including controlled entry to Irene Neuwirth worksites and/or real estate assets), monitoring of worksite locations and/or real estate assets, including using biometrics or location monitoring for keys, key fob or key card entry to Irene Neuwirth property, ensuring that employees, contractors and visitors comply with all applicable safety regulations; 

• In connection with audiovisual surveillance of public spaces; 

• For internal Irene Neuwirth directories; 

• For video presentations, interviews, training materials, and/or web conferences within the scope of your employment or contract;

• For the tracking of Irene Neuwirth-owned or Irene Neuwirth-leased vehicles, computers, equipment, and devices, including, but not limited to, remote deletion of Irene Neuwirth data on business or personal devices; 

• For verification of proper use of Irene Neuwirth resources;

• To facilitate a better working environment; 

• To maintain commercial insurance policies and overages, including for workers’ compensation and other liability insurance; and 

• For other purposes stated at or before the time of the collection of the information. 

Further, please note that under the CPRA, we may use your Personal Information for Irene Neuwirth business or other notified purposes, provided that the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or processed. 

5. Collection and Use of Sensitive Personal Information:

We only collect your Sensitive Personal Information in order to enroll and administer benefits to you, to fulfill our contract with you, and for general human resource purposes. We do not collect your Sensitive Personal Information for the purpose of inferring characteristics about you.

6. Retention Schedule

We retain information related to applications for employment until the job is filled or as required by applicable law. 

We retain information related to your employment for the term of your employment and for 7 years thereafter. Some information, such as contact information, tax information, or historical information about your employment with Irene Neuwirth, may be retained indefinitely for the integrity of our databases and our reporting requirements.

Third Parties with whom you have directly shared information during the term of your employment (e.g., benefits organizations) may have a different retention schedule for the information you have provided to them. 

7. Your Privacy Rights

Based on the applicable law where you live, you may have certain rights with respect to Personal Information about you. Upon receipt of a verifiable employee request, we will use commercially reasonable efforts to honor your exercise the rights below, unless there is a business reason exception, or if your exercise of the rights is impossible or otherwise involves a disproportionate effort. We will let you know in writing if we are unable to process your request. 

Please note that if we collect information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

Depending on where you live, you may have the following rights:

• To know the categories of Personal Information being collected about you, the purposes for which the categories of information are collected or used, and whether that information is sold or shared;

• To know if sensitive Personal Information is being collected about you, the categories of sensitive Personal Information being collected, the purposes for which the categories of sensitive Personal Information are collected or used, and whether the sensitive Personal Information is sold or shared; 

• To know the length of time we intend to retain each category of Personal Information; 

• To know whether your Personal Information is sold or disclosed and to whom;

• To access your Personal Information;

• To delete the Personal Information you have provided to us, with certain exceptions; 

• To correct your Personal Information if it is inaccurate;

• To limit the use of your sensitive Personal Information;

• To reject automated decision making and profiling;

• To access information about automated decision making;

• To opt out of the sale or sharing of your Personal Information; and

• Not to be discriminated against, even if you exercise your privacy rights.

In an effort to ensure that the Personal Information we have about you is accurate and that you are able to have access to and correct it, we give you the ability to access and update Personal Information that we have about you by logging into Gusto or the applicable software that contains your Personal Information, by contacting your manager, or by using the information in the Contact Us section below.

In addition to the above rights, you also may have the right to withdraw consent at any time with respect to ways that we process Personal Information about you based on your consent.

We will honor requests to the extent and within the timeframes required by applicable law. There may be exceptions to our obligation to comply with your request, such as if we have a legal obligation or legitimate business reason to keep your Personal Information, and we will advise you if there is an exception to your request.

8. Your California Privacy Rights

The information in this section is intended to supplement and not replace the information provided in other sections of this Notice; in the case of any conflict, the information in this section will apply for individuals residing in California.

Any capitalized terms used in this section and not otherwise defined in this section or elsewhere in this Privacy Notice will have the meaning given in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). 

Under the CCPA, we are considered the “business” with respect to the Personal Information we handle under this Notice. In other words, we are responsible for deciding how to collect, use, and disclose Personal Information, subject to applicable law. 

Personal Information Collected

In connection with your application for employment or your employment with Irene Neuwirth, we have collected the following categories of Personal Information from employees and job applicants within the last twelve (12) months:

Information related to how long we retain Personal Information is included in the Retention Schedule section above. 

Personal Information Sold or Shared

We do not sell or otherwise disclose your Personal Information for monetary or other consideration to third parties.

Personal Information Disclosed for a Business Purpose

Please see the How We Share Personal Information section above for a description of how we disclose your Personal Information for a business purpose.

9. Contact Us

If you are a current employee, you are required to keep your Personal Information updated. To update your Personal Information or if you have any questions regarding this Notice or the collection and processing of your Personal Information, please update your information in Gusto or the applicable software and contact your manager or the Human Resources team to ensure that the information has been received.  You can also send an email to hello@ireneneuwirth.com if you have additional privacy requests.  Please state whether you are an employee, former employee, job applicant or contractor in the subject line.