Privacy Notice for California Applicants

Last Updated: January 28, 2025

This Privacy Notice for California Applicants (the “California Applicant Privacy Notice” or “Notice”) applies solely to all job applicants of Sihl Inc. and Dietzgen Corporation (collectively, “Sihl,” or “we,” “us,” or “our”) who reside in the State of California (“Applicant,” “consumer,” “you,” or “your”). We adopt this California Applicant Privacy Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CPRA”), and any terms defined in the CPRA have the same meaning when used in this California Applicant Privacy Notice.

This California Applicant Privacy Notice applies to information that we collect about Applicants that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). Personal Information also includes “Sensitive Personal Information” (or “SPI”), as defined below. However, publicly available information lawfully made available to the general public from government records or widely distributed media or otherwise by you, as well as information that is deidentified or aggregated in accordance with the CPRA’s requirements, are not considered Personal Information and fall outside the scope of this California Applicant Privacy Notice.

This California Applicant Privacy Notice does not apply outside of the context of your role as a Sihl Applicant or to certain Personal Information that is excluded from the scope of the CPRA, such as Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act. Some of these exclusions may be applicable to the Personal Information we collect about you as part of background checks. If you have any questions on whether these exceptions apply to your Personal Information, please contact us through the Contact Information below.   

We collect and, over the prior twelve (12) months have collected, the following categories and corresponding pieces of Personal Information about our Applicants:

Category	Applicable Pieces of Personal Information Collected
Identifiers	A real name; alias; postal address; unique personal identifier; online identifier; email address; Social Security number; and other similar identifiers, including driver’s license, state identification card, and/or passport number(s) (if provided by you as proof of eligibility to work). We receive some of this information in truncated form from our background check providers.
Personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name; signature; Social Security number; address; telephone number; education and/or employment details (including job history); and other similar information, including driver’s license, state identification card, and/or passport number(s) (if provided by you as proof of eligibility to work). We receive some of this information in truncated form from our background check providers. NOTE: Some pieces of Personal Information included in this category may overlap with other categories of Personal Information collected by us.
Characteristics of protected classifications under California or federal law	Required: Age (40 years or older); national origin; or citizenship. NOTE: We require your age to verify your identity and run background checks. We require your national origin and citizenship to verify your eligibility to work in the US. You are not required to provide us with this information for any other uses. Optional: Race; color; ancestry; religion or creed; marital status; medical condition; physical or mental disability; sex (including gender; gender identity; gender expression; pregnancy or childbirth and related medical conditions); sexual orientation; and veteran or military status. NOTE: Providing this information is completely optional and at your discretion. We will collect this information only to the extent you choose to provide it in your resume or as otherwise may be provided by a reference or other third-party during reference or background checks.
Audio, visual, electronic, or similar information	Information collected during phone or video screenings or interviews in connection with the application and recruitment process. If you visit one of our facilities as part of this process, your entry, exit and actions in or around such facility may be monitored or recorded by security cameras.
Professional or employment-related information	Employment history; skills and qualifications; information related to previous applications to Sihl; details regarding the type of employment sought; willingness to relocate; job preferences; and other relevant experience including information contained in a resume, cover letter, or job application.
Sensitive Personal Information (SPI)	Government identifiers (Social Security, driver’s license, state identification card, and/or passport number(s)) (if provided by you as proof of eligibility to work); Racial or ethnic origin (*see note below); and Information about your health, sex life, or sexual orientation (*see note below). NOTE: Providing this information is completely optional and at your discretion. We will collect this information only to the extent you choose to provide it in your resume or as otherwise may be provided by a reference or other third-party during reference and background checks.

We will not collect additional categories of Personal Information without providing you notice. As further described below, we do not (i) “sell” any categories of Personal Information for monetary or other valuable consideration, or (ii) “share” any categories of Personal Information for cross-context behavioral advertising.

We collect Personal Information:

• Directly from you when you provide it to us during the application and recruitment process or when you otherwise contact us in your role as an Applicant.
• When you visit one of our facilities, such as for an in-person interview. We may collect your photograph in order to issue you a badge for entry. In addition, your entry, exit, and actions in or around our facility may be monitored or recorded by security cameras that are deployed at such facility.
• From third-party sources that assist us with our application and recruitment efforts, such as:
  • Recruiters or other third-party platforms (such as Indeed, LinkedIn, etc.), from which we collect information you submit in connection with your application for a position with Sihl (for example, through your formal submission of an application and related materials, including your resume and cover letter);
  • Pre-employment screening and background check providers, from which we collect information disclosed in your pre-employment screenings or background checks (which may include, among other information, certain redacted PI and SPI, criminal convictions, and/or drug test results);
  • Prior employers and other references you list on your application materials or that are referred to us; and
  • Temporary employment placement agencies.

We may use the Personal Information we collect for one or more of the following purposes:

• recruiting, including identifying and evaluating job applicants, and assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied;
• verifying your information and carrying out pre-employment, background, and reference checks, where applicable, subject to your consent where required by law, and maintaining records on such checks as required by law;
• communicating with you and our personnel about the recruitment process and your application (including scheduling and conducting interviews with you), and facilitating your communications with our personnel and other third parties involved in the application and recruitment process;
• analyzing and improving our application and recruitment process;
• complying with our applicable legal and regulatory requirements;
• responding to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• maintaining the security and safety of our facilities, personnel, and other assets, including to authenticate Applicants to access our facilities;
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and helping prosecute those responsible for that activity;
• evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Sihl’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Sihl about our Applicants is among the assets transferred; and
• as described to you when collecting your Personal Information or as otherwise permitted by applicable law.

We will not use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

We disclose and, in the preceding twelve (12) months, have disclosed the following categories of Personal Information about our Applicants to the following categories of third parties for one or more of the business purposes described below:

Category of Personal Information	Categories of Third-Party Recipients
Identifiers	Pre-employment screening services Background check providers Building or property management and security personnel
Personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Pre-employment screening services Background check providers Building or property management and security personnel
Characteristics of protected classifications under California or federal law	Pre-employment screening services Background check providers
Audio, electronic, visual, or similar information	Building or property management and security personnel Our parents, affiliates, and subsidiaries
Professional or employment-related information	Pre-employment screening services Background check providers

 

Category of Sensitive Personal Information	Categories of Third-Party Recipients
Government identifiers (i.e., Social Security, driver’s license, state ID card, and/or passport number(s))	We do not disclose this type of Sensitive Personal Information.
Racial or ethnic origin (if you choose to provide it to us)	We do not disclose this type of Sensitive Personal Information.
Information concerning health, sex life, and/or sexual orientation (if you choose to provide it to us)	We do not disclose this type of Sensitive Personal Information.

We disclose your Personal Information to the categories of third parties listed above for the following business purposes:

• Helping to ensure the security and integrity of our facilities and IT infrastructure, to the extent the use of such Personal Information is reasonably necessary and proportionate to achieve this purpose.
• Performing services on behalf of Sihl, such as administering the recruitment and application process, facilitating pre-employment screenings and background checks, verifying Applicant information, and providing other similar services on our behalf.

In addition to the above, we may disclose any or all categories of Personal Information to any third party (including government entities and/or law enforcement entities) as necessary to:

• comply with: (i) federal, state, or local laws, or to comply with a court order or subpoena to provide information; (ii) civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; and/or (iii) certain government agency requests for emergency access to your Personal Information if you are at risk or danger of death or serious physical injury;
• cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers) believe may violate federal, state, or local law;
• exercise or defend legal claims; and/or
• complete a transaction where a business transfer or change in ownership occurs as part of a merger, divestiture, restructuring, reorganization, dissolution, bankruptcy, liquidation, or similar proceeding.

We do not: (i) “sell” Personal Information for either monetary or other valuable consideration and have no actual knowledge of “selling” any Personal Information of Applicants under the age of sixteen (16) for monetary or other valuable consideration; or (ii) “share” any Personal Information of Applicants with third parties for cross-context behavioral advertising purposes and have no actual knowledge of “sharing” any Personal Information of Applicants under the age of sixteen (16) for such purpose.

The CPRA provides Applicants with specific rights regarding their Personal Information. This section describes these rights and explains how to exercise those rights. You may exercise these rights yourself or through your authorized representative (as defined below). For more information on how you or your authorized representative can exercise your rights, please see Exercising Your CPRA Privacy Rights.

• Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months (a “Right to Know” request). This includes: (i) the categories of Personal Information we have collected about you; (ii) the categories of sources from which that Personal Information was collected; (iii) our purposes for collecting this Personal Information; (iv) the categories of third parties to whom we have disclosed your Personal Information; and (v) if we have “sold” or “shared” or disclosed your Personal Information, a list of categories of third parties to whom we “sold” or “shared” your Personal Information, and a separate list of the categories of third parties to whom we disclosed your Personal Information. You must specifically describe if you are making a Right to Know request or a Data Portability request (defined below). If you would like to make both a Right to Know request and a Data Portability request, you must make both requests clear in your submission to us. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. You may make a Right to Know request a total of two (2) times within a twelve (12)-month period at no charge.
• Access to Specific Pieces of Information (Data Portability). You also have the right to request that we provide you with a copy of the specific pieces of Personal Information that we have collected about you, including any Personal Information that we have created or otherwise received from a third party about you (a “Data Portability” request). If you make a Data Portability request electronically, we will provide you with a copy of your Personal Information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the Personal Information to another third party. You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like to make a Right to Know request and a Data Portability request, you must make both requests clear in your submission to us. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. To the extent applicable, we will not disclose your Social Security number, driver’s license number, or other government-issued identification number in response to a Data Portability request. We will also not provide this information if the disclosure would create a substantial, articulable, and unreasonable risk to any of the following: (i) your Personal Information; (ii) your relationship to Sihl as an Applicant; or (iii) the security of our systems or networks. In addition, we will not disclose any Personal Information that may be subject to another exception under the CPRA. If we are unable to disclose certain pieces of your Personal Information, we will describe generally the types of Personal Information that we were unable to disclose and provide you a description of the reason we are unable to disclose it. You may make a Data Portability request up to two (2) times within a twelve (12)-month period at no charge, although you may have other rights to access certain pieces of your Personal Information under applicable labor and employment laws.
• Correction. You have the right to request that we correct any inaccurate Personal Information we maintain about you to ensure that it is complete, accurate, and as current as possible. You may request that we correct the Personal Information we have about you as described below (see Exercising Your CPRA Privacy Rights). In some cases, we may require you to provide reasonable documentation to show that the Personal Information we have about you is incorrect and what the correct Personal Information may be. We may also not be able to accommodate your request if (i) we believe it would violate any law or legal requirement or cause the information to be incorrect, or (ii) the Personal Information at issue is subject to another exception under the CPRA.
• Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request (see Exercising Your CPRA Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies under the CPRA. Some exceptions to your right to delete include, but are not limited to, if we are required to retain your Personal Information to complete the transaction for which we collected the Personal Information and to comply with our legal obligations (among others).
• Limiting our Uses and Disclosures of Your SPI. You have the right to request that we limit our uses and disclosures of your SPI to only those purposes specifically enumerated in the CPRA. Currently, we do not use or disclose your SPI for purposes other than those expressly permitted by the CPRA. Should this change in the future, we will update this Notice and provide you with methods to limit the use and disclosure of SPI.
• Non-Discrimination. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not do any of the following as a result of you exercising your CPRA rights: (i) deny you employment or other similar relationship with Sihl; (ii) offer you with different compensation, benefits, work hours, or terms of employment or other similar relationship with Sihl; or (iii) suggest that you may receive different compensation, benefits, work hours, or terms of employment or other similar relationship with Sihl.

Exercising Your CPRA Privacy Rights

To exercise the rights described above, please submit a request (an “Applicant Request”) to us by:

• Calling us at 1-800-854-2341; or
• Emailing us at HR.Payroll.US@SIHL.com.

If you fail to make your Applicant Request in accordance with the ways described above, we may either treat your request as if it had been submitted via the methods described above or provide you with information on how to submit the request or remedy any deficiencies with your request.

Only you, or someone that you have authorized to act on your behalf (an “authorized representative”), may make an Applicant Request related to your Personal Information. All Applicant Requests must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of such a person. This may include providing certain information about yourself, such as your home address, date of birth, and telephone number.
• Be described with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm which Personal Information relates to you or the individual for whom you are making the request as their authorized representative. We will only use Personal Information provided in an Applicant Request to verify the requestor’s identity or authority to make the request.

For all categories of Personal Information described above, we will retain your Personal Information for the duration of your relationship with us as an Applicant, or the length of time (i) required by applicable law or our contracts with service providers that we utilize to assist us with our application process, or (ii) our record retention practices for the type of document that contains your Personal Information. However, we may also retain any or all categories of Personal Information when your information is subject to one of the following exceptions:

• When stored in our backup and disaster recovery systems. Your Personal Information will be deleted when the backup media your information is stored on expires or when our disaster recovery systems are updated.
• When necessary for us to exercise or defend legal claims.
• When necessary to comply with a legal obligation.
• When necessary to help ensure the security and integrity of our IT systems and to protect the rights, property, or safety of Sihl, our facilities, our customers, or others.

Your Personal Information will be deleted when we no longer require it for any of the above purposes.

We reserve the right to amend this California Applicant Privacy Notice at our discretion and at any time. When we make changes to this Notice, we will notify you of the same through Sihl’s communication channels, including through paper or email (or other electronic) notices, and update the Notice’s effective date.

If you have any questions or comments about this California Applicant Privacy Notice, the ways in which Sihl collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at the contact information below:

Address: 121 Kelsey Lane, Suite G, Tampa, FL 33619
Toll-Free Telephone Number: 1-800-854-2341
Email: HR.Payroll.US@SIHL.com