Privacy Policy - Michels Corporation

R1VER building on a partly cloudy winter day.

Notice at Collection and Privacy Policy

Michels and its subsidiaries and affiliated companies (“Company”, “Michels”, or “we”) take your privacy seriously. We want you to know how we collect, use, and disclose your personal information. The Michels legal entity that you are directly interacting with is the data controller and is responsible for ensuring that your personal information is processed in accordance with applicable laws and this policy. As the parent company of the local Michels entity, Michels Corporation also undertakes certain processing activities that we can confirm to you should you request such information.

This Privacy Policy explains:

The categories of personal information we collect about you.
The categories of sources from which we collect your personal information.
The purposes for which we use your personal information.
How we may disclose your personal information.
How long we keep your personal information.
Your privacy rights and how to exercise them.
International transfers of information.
Changes to this Privacy Policy.

Scope:

This Privacy Policy applies to the personal information of Michels (a) employees, (b) independent contractors, interns, volunteers, owners, board members, and other individuals who perform work for Company (collectively “Contractors”), (c) employees’ and Contractors’ dependents, emergency contacts, and beneficiaries (“Related Contacts”), and (d) users of our website and the employees of our customers, prospective customers, and vendors whose information we collect (“Business Contacts”) (all collectively, “Covered Individuals”). This Privacy Policy informs Covered Individuals about the categories of personal information Company has collected about them in the preceding twelve months as well as the categories of personal information that the Company will collect about them in the future. Except where the Privacy Policy refers only to a specific category of Covered Individuals, e.g., employees, this Privacy Policy refers to all categories of Covered Individuals collectively.

“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 Covered Individual or household.

1. THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT

A. Employees & Contractors

As applicable, we may collect the below information about Employees and Contractors.

Identifiers, including: real name, alias, telephone number, postal address, e-mail address, signature, bank account name and number for direct deposits, government identification numbers, date of birth, driver’s license number and photographs, and passports.

Identifiers, including: real name, alias, telephone number, postal address, e-mail address, signature, bank account name and number for direct deposits, government identification numbers, date of birth, driver’s license number and photographs, and passports.
Professional or Employment-Related Information, including: educational institutions attended, degrees and certifications, licenses, work experience and previous employers, professional memberships and affiliations, union representation, seniority, training, employment start and ending dates, employer’s name, and job title.

Compensation and Benefits Information for Employees, including: salary, bonus and commission, hours and overtime, pay for services rendered, attendance records, leave information, bank details (for payroll and reimbursement purposes only), benefits in which you may be enrolled, and identifying information for dependents and beneficiaries.

Non-public Educational Information, including: academic transcripts.

Commercial Information, including: business travel and expense records.

Internet Activity Information, including: internet browsing and search history while using Company’s network, log in/out and activity on Company’s electronic resources, interactions with Company’s Internet website, application, or advertisement, and publicly available social media activity. For more on how the Company collects and uses cookies and other similar technologies, please see our Cookie Policy.

Sensory or Surveillance Data, including: voicemails, recordings of meetings or videoconferences, and footage from video surveillance cameras.

Health information, including: information about an on-the-job injury collected for workers’ compensation purposes, disability, medical condition, pregnancy, childbirth, breastfeeding, and related medical conditions, as necessary to comply with applicable law related to leaves of absence and accommodation.

Characteristics of Protected Classifications Under Applicable Law for Employees and Suppliers, including (where legally permitted): race, age, national origin, disability, sex, gender identity, and veteran status as necessary to comply with legal obligations and to support diversity and inclusion programs and marital and familial status as necessary to provide benefits to employees and for tax purposes.

Geolocation Data, including: GPS tracking on Company vehicles.

Communications, including: e-mails, correspondence, and other communications that you send to Michels.

B. Related Contacts

Company only collects contact information about emergency contacts. Company may collect the following categories of personal information about spouses or domestic partners, dependents, and beneficiaries: (a) Identifiers; (b) Commercial Information if, for example, Company arranges travel for a dependent to attend a Company event; (c) Sensory or Surveillance Data if the individual enters Company facilities; (d) health information, such as insurance policy numbers if the individual is covered by Company insurance or health information, infectious disease testing when a Related Contact attends a Company event, and childbirth to administer parental leave; and (e) Protected Categories of Personal Information, for example, marital status to pay taxes, and familial status to administer benefits.

C. Business Contacts

Company collects the following categories of personal information from Business Contacts: (a) Identifiers; (b) Professional or Employment-Related Information; (c) Commercial Information if, for example, Company arranges travel for you to attend a Company event; (d) Internet Activity Information; (e) Sensory or Surveillance Data if the individual enters Company facilities; and (f) Communications.

Note on inferring characteristics: Company does not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about the Covered Individual.

2. THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION

Depending on your relationship with Michels, we may collect personal information from the below sources.

You, for example, in your application, forms you fill out for us, assessments you complete, surveys you submit, and any information you provide during the course of your relationship with us.

Your spouse or dependent with respect to their own personal information.

Vendors and service providers, for example, software vendors and payroll.

Affiliated companies, for example, when an employee works on a cross-enterprise team.

Third parties, for example, job references, business partners, professional employer organizations or staffing agencies, insurance companies.

Public internet sources, for example, social media, job boards, public profiles, and other public online sources

Public records, for example, court records, and credentialing and licensing organizations.

Automated technologies on Company’s electronic resources, for example, to track logins and activity across Company network.

Surveillance/recording technologies installed by Company, for example, video surveillance in common areas of Company facilities, global positioning system (“GPS”) technologies, voicemail technologies, webcams, audio recording technologies, and blue-tooth technologies, any of these with consent to the extent required by law.

Labor processes, including collective bargaining processes, National Labor Relations Board processes to determine union representation, and grievance and arbitration processes.

Union agreements, including collective bargaining agreements and other agreements between Company and a union.

Government or administrative agencies, for example, law enforcement, public health authorities, California Department of Industrial Relations, Employment Development Department, or any applicable European government labor, employment, or tax agencies.

Government or administrative agencies, for example, law enforcement, public health authorities, California Department of Industrial Relations, Employment Development Department, or any applicable European government labor, employment, or tax agencies.

Acquired company, if Company acquired your employer, Company might collect personal information from that employer.

Your employer, for our Business Contacts, Company may collect information directly from your employer.

Note: This Privacy Policy does not cover background screening conducted collected by third-party background check vendors subject to applicable local laws. Company provides separate notices for such screening as required by applicable laws.

3. THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

A. All Covered Individuals

Managing Personnel, including:

(Not applicable to Related Contacts or Business Contacts)

Administration, including:
- To manage personnel and workforce matters
- To communicate with the workforce
- To plan and arrange work supplies and workspaces
- To fulfill recordkeeping and reporting responsibilities
- For recruitment of new Covered Individuals
- To resolve internal grievances and disciplinary issues
- To make business travel arrangements
- To manage workforce-related emergencies, including health emergencies

Workforce development, including:
- To screen workforce for risks to Company and continued suitability in their positions
- To conduct surveys

Team building, including:
- To maintain an internal workforce directory and for purposes of identification
- To facilitate communication, interaction, and collaboration among Covered Individuals
- To arrange meetings and manage Company-sponsored events and public service activities
- To promote Company as a place to work
- Workforce reporting and data analytics/trend analysis
- For workforce satisfaction

Monitoring, Security, and Compliance, including:

To monitor access to, and use of, Company facilities and information systems
To ensure compliance Company policies
To conduct internal audits and investigations
To administer Company’s whistleblower hotline
To protect the safety and security of Company’s facilities, including preventing illicit activity
To report suspected criminal conduct to law enforcement and cooperate in investigations
To exercise Company’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel

Conducting Our Business, including:

(Not applicable to Related Contacts)

To engage in marketing, advertising, and promotion
For communications with prospective, current, and former customers
To provide a directory and contact information for prospective and current customers and business partners
For customer service purposes and to provide customers with our products
To manage business expenses and reimbursements
To engage in project management
To conduct product and service training
To conduct research and development
To conduct quality assurance and improvement
For event planning
To engage in crisis management

Miscellaneous Other Purposes, including:

To efficiently manage and operate administrative, information technology, and communications systems, risk management and insurance functions, budgeting, financial management and reporting, and strategic planning;
To manage litigation involving Company, and other legal disputes and inquiries and to meet legal and regulatory requirements;
In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Company or any of its subsidiaries or affiliates;
To manage licenses, permits, and authorizations applicable to Company’s business operations;
To protect the rights, property, or safety of Company, Covered Individuals, customers, or others; and
To exercise the Company’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitrator, or mediation panel.

B. Employees

Generally Applicable Purposes

Unless stated otherwise in section 3.B.2, below, we may use employees’ personal information for the following purposes:

Managing Employees, including:

Administration, including:
- To set up and manage a personnel file
- To manage performance
- To administer compensation, bonuses, equity grants, other forms of compensation, and benefits (as permitted by law)
- To manage vacation, sick leave, and other leaves of absence
- To track hours and attendance
Employee development, including:
- To provide, evaluate, and manage training and career development
- To evaluate job performance and consider employees for other internal positions or promotions
- To assist with professional licensing
- To develop a talent pool and plan for succession
Team building, including:
- For diversity and inclusion programs or affirmative action compliance
- To arrange team building and other morale-related activities
- To design employee retention programs

2. Purposes Specific to Certain Special or Sensitive Categories of Employees’ Personal Information

Where permitted by applicable law, we may use the categories of employees’ personal information listed in this Section 3.B.2 for the purposes stated below. This information may be considered sensitive or special personal information under certain privacy laws. In certain countries, we may legally use special or sensitive categories of personal information without consent to fulfill our legal obligations and in the substantial public interest.

Purposes For Using Employees’ Geolocation Data:

Company will issue employees an RFID-enabled security badge that tracks employee location within Company’s facilities.
Company places tracking software on certain field service employee vehicles to allow the Company or customers to see these employees’ location and for fleet management.

Purposes For Using Employees’ Health Information:

To the extent necessary to comply with Company’s legal obligations, such as to accommodate disabilities
To conduct a direct threat analysis in accordance with applicable law
For workers’ compensation purposes
For occupational health surveillance
For occupational health and safety compliance and record-keeping
To conduct fitness-for-duty examinations (where permitted by applicable law)
To administer leaves of absence and sick time
To provide a wellness program
To respond to an employee’s medical emergency
For reasons of substantial public interest, on the basis of local laws

Note: This Privacy Policy does not cover health information collected by the Company pursuant to any separate health-specific notice as required by the Health Insurance Portability and Accountability Act (HIPPA), the Health Information Technology for Economic and Clinical Health Act (HITECH Act), California’s Confidentiality of Medical Information Act (CMIA), or any other applicable laws.

Purposes For Using Employees’ Protected Categories of Information:

Company collects information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of applicable governmental bodies, such as the Federal Equal Employment Opportunity Act, the Federal Office of Contracting Compliance Programs (applicable to government contractors), California’s Fair Employment and Housing Act, and applicable European regulations. Company also collects information about disability status to the extent an employee may need special assistance during emergencies from Company or from first responders.

Where permitted by applicable law, Company also collects the following characteristics (in addition to those listed above) for its diversity and inclusion programs (including analytics): (a) religion, (b) sex, (c) gender, (d) pregnancy, (e) childbirth, (f) breastfeeding, or related medical conditions, (g) sexual orientation, (h) disability, (i) gender identity, (j) gender expression, (k) marital status, (l) age, (m) familial status, or (n) ancestry.

Where permitted by applicable law, Company also uses this personal information for purposes including:

with respect to disability, medical condition, familial status, marital status, and pregnancy, childbirth, breastfeeding, and related medical conditions: as necessary to comply with applicable law related to leaves of absence and accommodation;
with respect to military and veteran status: as necessary to comply with leave requirements under applicable law and for tax purposes;
with respect to age: incidentally to the use of birth date for birthday celebrations and identity verification;
with respect to religion and pregnancy, childbirth, breastfeeding, and related medical conditions: as necessary for accommodations under applicable law;
with respect to protected classifications, such as national origin: to the extent this information is contained in documents that you provide in employment documentation; and
with respect to marital status and familial status: for Company events and as necessary to provide benefits and for tax purposes.

Company collects personal information about membership in protected categories on a purely voluntary basis, except where required by law, and uses the information only in compliance with applicable laws and regulations.

C. Contingent Workforce

Managing Contingent Workforce, including:

To evaluate the individual’s qualifications for engagements, including licensure and certifications
To negotiate and execute the agreement with the individual
To provide orientation and familiarization with Company’s working environment
To administer the contractual relationship, including payments
To manage absences

E. Related Contacts

Spouse and Dependents/Beneficiaries

To manage and administer benefits
To communicate with the individual and manage the relationship
To arrange travel to, and manage participation in, Company events

Emergency Contacts

To communicate in the event of an emergency involving the individual who provided the emergency contact’s information

F. Deidentified Information

At times, Company converts personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”). Company maintains Deidentified Information in a deidentified form and does not attempt to reidentify it, except that Company may attempt to reidentify the information solely for the purpose of determining whether its deidentification processes ensure that the information cannot be associated with the individual.

G. Legal Basis of Processing

In some jurisdictions, we are required to identify our legal grounds for processing your personal information. Not providing your personal information may result in disadvantages for you. For example, you may not be able to register an account on our website, purchase or use our products and services, or receive marketing information. If you do not provide the Company with personal information necessary to fulfill an applicable contract of employment or to fulfill the Company’s obligations as an employer, the Company may not be able to fulfill its obligations to you as your employer. However, unless otherwise specified, not providing your personal information will not result in legal consequences for you. The principal grounds that justify our use of your personal information are as follows:

Contract performance: where your personal information is necessary to enter into or perform a contract with you, if applicable.
Protection of vital interests: where processing is necessary to protect the vital interests of you or of another natural person where you are physically or legally incapable of giving consent, such as in a medical emergency.
Legal obligation: where we need to use your personal information to comply with our legal obligations.
Legitimate interests: where we use your personal information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights. In addition to the purposes listed in Section 3(A) – (C) above, our legitimate interests include enabling us to conduct our business by providing customers with services and products; allowing us to communicate with you; cooperating with law enforcement and regulatory authorities and protecting our rights; allowing us to change and improve our business, services, and products; and preventing or detecting crime or fraud.
Legal claims: where your personal information is necessary for us to defend, prosecute, or make a claim against you, us, or a third party.
Consent: where you have consented to the processing of personal information for one or more specified purposes. You are free to withdraw your consent by contacting us in accordance with Section 6 of this
Policy. Where you do so, we may be unable to fulfill the request that requires the use of such information.

4. HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

Company generally maintains information related to its personnel and customers as confidential. However, from time to time, Company may have a legitimate business need to disclose personnel information for one of the purposes listed in Section 2, above, to one or more of the categories of recipients listed below. In that event, Company discloses your personal information only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by applicable laws.

Service providers and contractors: Company discloses your personal information to service providers and contractors to assist us in meeting our business needs and contractual and legal obligations.
- Company discloses your personal information to service providers and contractors only subject to written contracts in compliance with applicable law.
- Service providers and contractors include payroll providers, HR management systems and software, auditors, administrative service providers, law firms, travel agencies, benefits providers, and any other entity providing services to Company.
Affiliated companies: Other companies within the Michels family of companies.
Clients and customers: This may include, for example, disclosing an employee’s qualifications for a job (for instance, to meet an owner or client’s requirements) and to provide services and products to our customers.
Business partners: For example, Company might disclose your business contact information to a business partner for purposes of implementing the relationship.
Government or administrative agencies: These may include, for example:
- Internal Revenue Service to pay taxes;
- Employment Development Department as required for state payroll taxes and to respond to unemployment or state disability insurance claims;
- OSHA/CalOSHA as required to report work-related death or serious injury or illness;
- Law enforcement in the event of criminal investigations;
- Department of Fair Employment and Housing as required to respond to employment charges;
- California Department of Industrial Relations as required to resolve workers’ compensation claims’
- Other applicable regulators, supervisory authorities, or government agencies.
Public: Company may disclose your personal information to the public as part of a press release, for example, to announce promotions or awards. If you do not want your personal information in press releases, please contact Michels Corporation Marketing Team at Marketing@michels.us. Company does not disclose sensitive personal information to the public.
Labor union: Company may disclose workers’ personal information to a union if it represents the worker or with worker consent.
Required Disclosures: We may be required to disclose personal information (a) in a court proceeding, (b) in response to a court order, subpoena, civil discovery request, other legal process, or (c) 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.
Corporate Transactions: We may disclose your personal information in connection with a corporate merger, consolidation, bankruptcy, the sale of all, or substantially all, of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

No sales and no “sharing,” i.e., disclosure for cross-context behavioral advertising:

Company does not sell the personal information of any Covered Individuals nor disclose their personal information for cross-context behavioral advertising (as defined under applicable law).

5. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Company keeps your personal information no longer than necessary for the purposes described in Section 2 above, unless the Company is required to retain your personal information longer by applicable law or regulation, by legal process, or to exercise or defend legal claims. For Employees and Contractors, the Company shall maintain personal information in accordance with the Company’s Data Retention Policy. For all other personal information, the standards the Company uses to determine the retention period are as follows: the time required to retain personal information to fulfill business purposes, including providing products and services; maintaining business records; controlling and improving the performance and quality of the websites; handling possible customer queries or conducting assessments of customer complaints; whether you agree to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention. For further details regarding how long Company retains personal data, please request to see Company’s Data Retention Policy.

6. YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM

A. Your Privacy Rights

You may have certain rights relating to your personal information, subject to local privacy laws. These rights are subject to certain exemptions, including without limitation to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege).

Depending on the applicable laws and under certain conditions, Covered Individuals may have the following rights:

Right to Know: You have the right to submit a request for copies of specific pieces of your personal information obtained from you and for information about the Company’s collection, use, and disclosure of your personal information. Please note that this right to obtain copies does not grant a right to the whole of any document that contains personal information, but only to copies of “specific pieces” of personal information. Moreover, Covered Individuals have a right to know categories of sources of personal information and categories of third parties to which personal information is disclosed.

Right to Delete: You have the right to submit a request for the deletion of personal information that you have provided to Company.

Right to Correct: You have the right to submit a 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.

Right to Portability: You have the right to request we transmit the personal information you have provided to us to a third party.

Right to Restrict Use: You have the right to restrict how we process your personal information while we consider a request you have raised.

Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw the consent—some countries may require a written withdrawal request. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

Right to Object or Make a Complaint: You have the right to object to any processing of personal information that we process on the “legitimate interests” or “public interests” grounds, unless our reasons for the underlying processing outweighs your interests, rights, and freedoms. You also have the right to lodge a complaint with your local government agency or supervisory authority.

B. How to Exercise Your Rights

Company will respond to requests 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:

If residing in the United States:

Call Michels Corporation Human Resources Team at (920)924-8755 or email at HR@michels.us; or
Call the Michels Compliance Hotline at 888-310-7732.

If residing outside of the United States:

Email Michels Canada Human Resources Team at hrcompliance@michelscanada.com.

Once your request is received, you will be provided a request form to complete, and your request will be responded to in a timely manner.

C. How We Will Verify Your Request

The processes that we follow to verify your identity when you make a request are described below. The relevant process depends on how and why the request is submitted.

If you submit a request by any means other than through a password-protected account that you created before the date of your request, the verification process that we follow will depend on the nature of your request as described below:

Requests To Know Categories or Purposes: We will match at least two data points that you provide with your request, or in response to your verification request, against information about you that we already have in our records and that we have determined to be reliable for purposes of verifying your identity. Examples of relevant data points include your mobile phone number, your zip code, or your employee identification number.
Requests To Know Specific Pieces of Personal Information: We will match at least three data points that you provide with your request, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we may require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request.
Requests To Correct or Delete Personal Information: Our process for verifying your identity will depend on the risk level (as determined by Company) associated with the personal information that you ask us to correct or delete. For low-risk personal information, we will require a match of two data points as described in Point No. 1, above. For higher risk personal information, we will require a match of three data points and a signed declaration as described in Point No. 2, above.

We have implemented the following additional procedures when verifying the identity of requestors:

If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will not use that information for any purpose other than verification.
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.

D. Authorized Agents

If an authorized agent submits a request on your behalf, the authorized agent must submit with the request another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may 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 HR@michels.us.

E. Company’s Non-Discrimination and Non-Retaliation Policy

Company will not unlawfully discriminate or retaliate against you for exercising your rights under applicable privacy laws.

7. INTERNATIONAL TRANSFERS OF INFORMATION

We may hold your personal information in the country of the Michels legal entity that you have a relationship with. We may also transfer your personal information to Canada or the United States. Other countries may not have the same protections for personal information as the country where you have applied for employment. If we transfer your personal information outside of the country where you are located, we will do so in accordance with applicable law and ensure that such transfers have an appropriate level of protection given the personal information. For personal information originating in the European Economic Area (EEA) that is transferred to other countries without an adequacy decision (such as the United States), we generally use either the Standard Contractual Clauses or require your consent. In situations where personal data is transferred internationally to a country without an adequacy decision (such as the United States) and for where we do not use the Standard Contractual Clauses, we will ask for your consent and take reasonable steps to ensure an adequate level of protection for such personal data; however, there may not be the same or any supervisory authority, data processing principles, and/or data subject rights provided to you in such country. You have the right to withdraw your consent at any time. If you would like to see a copy of the safeguards we apply in relation to the export of your personal information, please contact us at HR@michels.us or hrcompliance@michelscanada.com.

8. CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal information, we will provide a prominent notice of such changes and the effective date of the changes before making them.

For More Information

For questions or concerns about Company’s privacy policies and practices, please contact us at HR@michels.us.

Date Created: November 20, 2023 – Last modified: December 14, 2023

Notice at Collection and Privacy Policy for Job Applicants

Michels and its subsidiaries and affiliated companies (“Company”, Michels”, or “we”) take your privacy seriously. We want you to know how we collect, use, and disclose, your personal information. The Michels legal entity that you are applying for employment with is the data controller and is responsible for ensuring that your personal information is processed in accordance with applicable laws and this policy. As the parent company of the local Michels entity, Michels Corporation also undertakes certain processing activities that we can confirm to you should you request such information.

Non-Discrimination Statement:

Company is an equal employment opportunity employer. The Company’s policy is not to unlawfully discriminate against any applicant or employee on the basis of race, color, sex, gender identity, religion, national origin, age, disability, or any other consideration made unlawful by applicable laws. The Company also prohibits harassment of applicants and employees based on any protected category, characteristic or status. It is also the Company’s policy to comply with all applicable laws respecting consideration of unemployment status in making hiring decisions.

Company complies with the ADA, the ADAAA, and applicable disability-related law and considers reasonable accommodation measures that may be necessary for qualified applicants/employees to perform the essential functions of the job. Hire may be contingent upon a post-offer medical examination, and to skill and agility tests, as appropriate for the position.

This Privacy Policy explains:

The categories of personal information we collect about you
The categories of sources from which we collect your personal information
The purposes for which we use your personal information
How we may disclose your personal information
How long we keep your personal information
Your rights and how to exercise them
International transfers of information
Changes to this Privacy Policy

Scope:

This Privacy Policy applies to the personal information of job applicants to Company (“Applicants”).

1. THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU

Identifiers, including: real name, nickname, telephone number, postal address, e-mail address, and signature.
Professional or Employment-Related Information, including: educational institutions attended, degrees and certifications, licenses, work experience and previous employers, and professional memberships and affiliations.
Non-public educational information, including: academic transcripts.
Commercial Information, including: travel expense records for an interview.
Internet Activity Information, including: interactions with Company’s Internet web site, job application, or job advertisement, and publicly available social media activity.
Sensory or Surveillance Data, including: voice-mails and footage from video surveillance cameras.
Other details, including: hobbies and leisure activities or membership in voluntary/charitable/public organizations, for example, as stated on the Applicant’s resume.
Characteristics of Protected Classifications Under Applicable Law for Applicants, 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. Where legally permitted, these classifications include race, age, national origin, disability, sex, and veteran status.
Geolocation data, including: through a radio frequency identification (RFID) chip in a security badge to determine an Applicant’s physical location.
Health Information, including: information that you may provide to request an accommodation or during a pre-employment medical examination (to the extent such examinations are permitted under applicable law).
Communications, including: e-mails, correspondence, and other communications that you send to Michels.

2. THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION

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 the course of your application and interview process.
Vendors and service providers, for example, recruiters.
Third parties, for example, job references, affiliated companies, professional employer organizations or staffing agencies.
Public internet sources, for example, social media, job boards, public profiles, and other public online sources.
Public records, for example, court records, and credentialing and licensing organizations.
Automated technologies on Company’s electronic resources, for example, to track logins and activity on Company’s careers page.
Surveillance/recording technologies installed by Company, for example, video surveillance in common areas of Company facilities, voicemail technologies, webcams, and audio/video recording technologies with consent to the extent required by law.
Government or administrative agencies, for example, law enforcement or public health authorities.
Acquired company, if Company acquired your employer, Company might collect personal information from that employer.

Note: This Privacy Policy does not cover background screening conducted by third-party background check vendors subject to applicable local laws. Company provides a separate disclosure for such screening as required by applicable laws.

3. THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

A. Generally Applicable Purposes:

Unless stated otherwise in section 3.B, below, we may use Applicants’ personal information for the following purposes:

Recruiting, including:

To evaluate Applicants’ qualifications or suitability for employment with Company
To communicate with Applicants
To conduct a pre-employment or criminal history background check (where permitted by applicable law)
For identification purposes
For diversity and inclusion purposes (where permitted by applicable law)
To arrange and manage Company-sponsored events
To create a talent pool for future job openings
For recordkeeping purposes
To demonstrate Applicants’ agreement to, or acceptance of, documents presented to them, e.g., pre-employment arbitration agreement, acknowledgment of employment application, offer letter
To evaluate and improve the recruiting process
To promote Company as a place to work

Monitoring, Security, and Compliance, including:

To monitor use of Company facilities and information systems
To ensure compliance with applicable laws and Company policies
To conduct internal audits and investigations
To protect the safety and security of Company’s facilities
To administer Company’s compliance hotline
To report suspected criminal conduct to law enforcement and cooperate in investigations
To exercise Company’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel

Conducting Our Business, including:

For training purposes or quality assurance with respect to Company employees conducting the interviews or otherwise assisting with the recruiting and hiring process
For travel and event planning
To manage travel reimbursements

Miscellaneous Other Purposes:

To manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning;
To manage litigation involving Company, and other legal disputes and inquiries and to meet legal and regulatory requirements;
In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Company or any of its subsidiaries or affiliates; and
To protect the rights, property, or safety of Company, HR Individuals, customers or others.

B. Purposes Specific to Certain Special or Sensitive Categories of Personal Information:

Where permitted by applicable law, we may use the categories of Applicants’ personal information listed in this Section 3.B for the purposes stated below. This information may be considered sensitive or special personal information under certain privacy laws.

Purposes For Using Applicant Health Information:

To the extent necessary to comply with Company’s legal obligations, such as to accommodate disabilities
To protect the health and safety of Company’s employees and facilities, for example, to take the Applicant’s temperature
For occupational health and safety compliance and record-keeping
To conduct pre-employment medical examinations (where permitted by applicable law)
To respond to an Applicant’s medical emergency
For reasons of substantial public interest, on the basis of local laws

Purposes For Using Applicants’ Protected Categories of Information:

Company collects information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of applicable governmental bodies, such as the federal Equal Employment Opportunity Act, the federal Office of Contracting Compliance Programs (applicable to government contractors), and California’s Fair Employment and Housing Act, and for purposes of diversity analytics.

Company also uses this personal information for purposes including: (a) with respect to disability and/or medical condition, as necessary, to comply with applicable laws related to accommodation; and (b) with respect to age, incidentally to the use of birth date for identity verification.

Company collects protected categories of Personal Information on a purely voluntary basis, except where required by law, and uses the information only in compliance with applicable laws and regulations.

C. Deidentified Information

D. Legal Basis of Processing:

In some jurisdictions, we are required to identify our legal grounds for processing your personal information. These are the principal grounds that justify our use of your personal information:

Legal obligation: where we need to use your personal information to comply with our legal obligations.
Legitimate interests: where we use your personal information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights. In addition to the purposes listed in Section 3(A) and (B) above, our legitimate interests include enabling us to effectively recruit staff; evaluating your application for employment; cooperating with law enforcement and regulatory authorities and protecting our rights; allowing us to change our business; and preventing or detecting crime or fraud.
Legal claims: where your personal information is necessary for us to defend, prosecute, or make a claim against you, us, or a third party.
Consent: where you have consented to the processing of personal information for one or more specified purposes. You are free to withdraw your consent by contacting us in accordance with Section 6 of this Policy. Where you do so, we may be unable to fulfill the request that requires the use of such information.

4. HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

Company generally maintains information related to Applicants as confidential. However, from time to time, Company may have a legitimate business need to disclose Applicants’ personal information for one of the purposes listed in Section 2, above, to one or more of the categories of external recipients listed below. In that event, Company discloses your personal information only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by applicable laws.

Service providers and contractors: Company discloses your personal information to service providers and contractors for the purposes above to assist us in our recruiting efforts and in meeting our business needs and legal obligations.
- Company only discloses your personal information to service providers and contractors subject to written contracts as required by applicable law.
- Service providers and contractors include recruiters, law firms, travel agencies, and any other entity providing services to Company.
Affiliated companies: Other companies within the Michels family of companies.
Government or administrative agencies: These may include, for example:
- Equal Employment Opportunity Commission as required for reporting.
- California Department of Fair Employment and Housing as required to respond to employment claims and charges.
- Law enforcement in the event of criminal investigations.
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.
Corporate Transactions: We may disclose your personal information in connection with a corporate merger, consolidation, bankruptcy, the sale of all, or substantially all, of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

No sales and no “sharing”, i.e., disclosure for cross-context behavioral advertising:

Company does not sell the personal information of any Applicants nor share their personal information for cross-context behavioral advertising (as defined under applicable law).

5. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

If Company hires you, the information collected about you during the job application process may become part of your personnel file and may be used to administer the employment relationship and for related reporting and recordkeeping purposes. Company will retain this application information for the entire duration of your employment relationship with Company and for as long thereafter as permitted or required by applicable law. Company makes its document retention schedule available to employees for review.

Unless otherwise required by applicable laws, Company will retain information of Applicants who are not hired for the time period detailed in Company’s Data Retention Policy. These records will be retained for our internal recordkeeping and reporting purposes in compliance with applicable laws. During that time, we may use your information to consider you for positions in addition to the position(s) for which you initially applied.

6. YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM

A. Your Privacy Rights:

Right to Know: You have the right to submit a request for copies of specific pieces of your personal information obtained from you and for information about the Company’s collection, use, and disclosure of your personal information. Please note that this right to obtain copies may not grant a right to the whole of any document that contains personal information, but only to copies of “specific pieces” of personal information. You have a right to know categories of sources of personal information and categories of external recipients to which personal information is disclosed.
Right to Delete: You have the right to submit a request for the deletion of personal information that you have provided to Company.
Right to Correct: You have the right to submit a 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.
Right to Portability: You have the right to request we transmit the personal information you have provided to us to a third party.
Right to Restrict Use: You have the right to restrict how we process your personal information while we consider a request you have raised.
Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw the consent—some countries may require a written withdrawal request. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
Right to Object or Make a Complaint: You have the right to object to any processing of personal information that we process on the “legitimate interests” or “public interests” grounds, unless our reasons for the underlying processing outweighs your interests, rights, and freedoms. You also have the right to lodge a complaint with your local government agency or supervisory authority.

B. How to Exercise Your Rights:

Company will respond to requests 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:

If residing in the United States:

Call Michels Corporation Human Resources Team at (920)924-8755 or email at HR@michels.us; or
Call the Michels Compliance Hotline at 888-310-7732.

If residing outside of the United States:

Email Michels Canada Human Resources Team at hrcompliance@michelscanada.com.

Once your request is received, you will be provided a request form to complete, and your request will be responded to in a timely manner.

C. How We Will Verify Your Request:

The processes that we follow to verify your identity when you make a request are described below. The relevant process depends on how and why the request is submitted.

Requests To Know Categories or Purposes: If you request to know how we collect and handle your personal information, we will match at least two data points that you provide with your request, or in response to your verification request, against information about you that we already have in our records and that we have determined to be reliable for purposes of verifying your identity. Examples of relevant data points include your mobile phone number, your zip code, and the month and year you submitted a job application to us.
Requests To Know Specific Pieces of Personal Information: We will match at least three data points that you provide with your request to know, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we may require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request.
Requests To Correct or Delete Personal Information: Our process for verifying your identity will depend on the risk level (as determined by Company) associated with the personal information that you ask us to correct or delete. For low-risk personal information, we will require a match of two data points as described in Point No. 1, above. For higher risk personal information, we will require a match of three data points and a signed declaration as described in Point No. 2, above.

We have implemented the following additional procedures when verifying the identity of requestors:

If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will not use that information for any purpose other than verification.
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.

D. Authorized Agents:

If an authorized agent submits a request 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 may 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 HR@michels.us.

E. Company’s Non-Discrimination and Non-Retaliation Policy:

Company will not unlawfully discriminate or retaliate against you for exercising your privacy rights under applicable privacy laws.

7. INTERNATIONAL TRANSFERS OF INFORMATION

We may hold your personal information in the country where you have applied for employment. We may also transfer your personal information to Canada or the United States. Other countries may not have the same protections for personal information as the country where you have applied for employment. If we transfer your personal information outside of the country where you applied for employment, we will do so in accordance with applicable law and ensure that such transfers have an appropriate level of protection given the personal information. For personal information originating in the European Economic Area (EEA) and that is transferred to other countries without an adequacy decision (such as the United States), we generally use either the Standard Contractual Clauses or require your consent. In situations where personal data is transferred internationally to a country without an adequacy decision (such as the United States) and for where we do not use the Standard Contractual Clauses, we will ask for your consent and take reasonable steps to ensure an adequate level of protection for such personal data; however, there may not be the same or any supervisory authority, data processing principles, and/or data subject rights provided to you in such country. You have the right to withdraw your consent at any time. If you would like to see a copy of the safeguards we apply in relation to the export of your personal information, please contact us HR@michels.us or hrcompliance@michelscanada.com.

8. CHANGES TO THIS PRIVACY POLICY

For More Information

For questions or concerns about Company’s privacy policies and practices, please contact us at HR@michels.us.

Date Created: November 20, 2023 – Last modified: December 14, 2023

Michels and its subsidiaries and affiliated companies (“Company”, Michels”, or “we”) take your privacy seriously. We want you to know how we collect and use your personal information via cookies. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with an enhanced web-browsing experience and allows us to improve our site. Further information regarding how Michels protects your privacy can be found in our Privacy Policy.

Types of Cookies We Use

We may use the following types of cookies:

Strictly Necessary Cookies. Our website requires the use of these cookies to properly operate or provide necessary functions relating to the services you request. They include, for example, cookies enabling you to securely log into our website or adjusting your consent preferences. These cookies do not store any personally identifiable information. These are persistent cookies that generally last one (1) year.
Functionality Cookies. These cookies enable helpful but non-essential website functions that improve your website experience. By recognizing you when you return to our website, they may, for example, allow us to personalize our content for you, greet you by name, or remember your preferences (for example, your choice of language or region). These cookies may enable visitor identification over time, but not across different websites. These are persistent cookies that generally last up to one (1) year.
Analytical Cookies. These cookies allow us and our third-party service providers to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve how our website works by, for example, ensuring that users can easily find what they need on our website. These cookies may generate aggregate statistics that are not associated with an individualized profile and are persistent cookies that generally last up to two (2) years.
Performance Cookies. These cookies allow us and our third-party service providers to understand and analyze key performance indexes of the website. This helps us deliver a better experience for users on the website. These cookies may generate aggregate statistics that are not associated with an individualized profile and are persistent cookies that generally last up to two (2) years.
Advertisement Cookies. These cookies enable different advertising related functions. They may allow us or our third-party services providers to record information about your visit to our website, such as pages visited, links followed, and videos viewed so we can make our website and the advertising displayed on it more relevant to your interests. These cookies also may allow us and our third-party service providers to analyze the effectiveness of ad campaigns. Finally, these cookies may enable visitor identification across websites and over time. We may also share the information with third parties for similar purposes. These are persistent cookies that generally last three (3) months.

Except for strictly necessary cookies, all first-party cookies set by this site will expire no later than two (2) years after your last website visit. Third-party cookie expiration periods are set by their respective owners.

Please see our Cookie Table [please link Cookie Table] for a list of the individual first party and third-party cookies potentially used on this site and their specific purposes.

Your Cookie Choices

Please visit our consent manager tool to make or manage your cookie use preferences. You may withdraw your consent for our cookie uses that are not strictly necessary at any time by re-engaging the consent manager tool:

Most web browsers allow you to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation.

Cross-Border Data Transfers

The cookies we use may process, store, or transfer personal data in and to a country outside your own, with privacy laws that provide different, possibly lower, protections. You consent to this transfer, storing, or processing when you consent to our cookie use. We are based in United States. Please review our Privacy Policy and each third-party cookie provider’s policy to learn more about its location.

Changes to the Policy

If we change this Cookie Policy, we will post those changes on this page and update the Cookie Policy modification date below. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal information, we will provide a prominent notice of such changes and the effective date of the changes before making them.

For More Information

For questions or concerns about Michels’ cookie policy or any of our privacy policies or practices, please contact us at HR@michels.us.

Cookie Table

Cookies Used on Michels Website

The following table lists all cookies potentially in use on the Michels.us website. We will update this table as our website changes and evolves, so please check back frequently to review any new cookie uses.

Necessary

Name	Description	Source	Duration	Privacy Policy
_GRECAPTCHA	This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks.	google.com	5 months 27 days	https://policies.google.com/privacy
cookieyes-consent	CookieYes sets this cookie to remember users’ consent preferences so that their preferences are respected on their subsequent visits to this site. It does not collect or store any personal information of the site visitors.	michels.us	1 year	https://www.cookieyes.com/privacy-policy/

Functional

Name	Description	Source	Duration	Privacy Policy
UserMatchHistory	LinkedIn sets this cookie for LinkedIn Ads ID syncing.	linkedin.com	1 month	https://www.linkedin.com/legal/privacy-policy
bcookie	LinkedIn sets this cookie from LinkedIn share buttons and ad tags to recognize browser ID.	linkedin.com	1 year	https://www.linkedin.com/legal/privacy-policy
lidc	LinkedIn sets the lidc cookie to facilitate data center selection.	linkedin.com	1 day	https://policies.google.com/technologies/partner-sites?hl=en
bscookie	LinkedIn sets this cookie to store performed actions on the website.	linkedin.com	1 year	https://www.linkedin.com/legal/privacy-policy
li_gc	Linkedin set this cookie for storing visitor’s consent regarding using cookies for non-essential purposes.	linkedin.com	5 months 27 days	https://www.linkedin.com/legal/privacy-policy

Analytics

Name	Description	Source	Duration	Privacy Policy
_ga	The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data, and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.	michels.us	1 year 1 month 4 days	https://policies.google.com/privacy
_gid	Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.	michels.us	1 day	https://policies.google.com/privacy?hl=en-US
CONSENT	YouTube sets this cookie via embedded youtube-videos and registers anonymous statistical data.	googleapis.com	2 years	https://support.google.com/youtube/answer/7671399?hl=en&p=privacy_guidelines
_gat_UA-*	Google Analytics sets this cookie for user behaviour tracking.	michels.us	1 minute	https://policies.google.com/privacy
AnalyticsSyncHistory	Linkedin set this cookie to store information about the time a sync took place with the lms_analytics cookie.	linkedin.com	1 month	https://www.linkedin.com/legal/privacy-policy
_ga_*	Google Analytics sets this cookie to store and count page views.	michels.us	1 year 1 month 4 days	https://policies.google.com/privacy

Name	Description	Source	Duration	Privacy Policy
_fbp	This cookie is set by Facebook to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website.	michels.us	3 months	https://www.facebook.com/privacy/explanation
fr	Facebook sets this cookie to show relevant advertisements to users by tracking user behaviour across the web, on sites that have Facebook pixel or Facebook social plugin.	facebook.com	3 months	https://www.facebook.com/privacy/explanation
li_sugr	LinkedIn sets this cookie to collect user behaviour data to optimise the website and make advertisements on the website more relevant.	linkedin.com	3 months	https://www.linkedin.com/legal/privacy-policy

Other

Name	Description	Source	Duration	Privacy Policy
ENTERPRISE_SESSION	No description	bluedoorconsulting.jotform.com	1 month	https://www.jotform.com/privacy/
userReferer	The page the JotForm is submitted on.	bluedoorconsulting.jotform.com	1 month 1 hour	https://www.jotform.com/privacy/
guest	Guest user id for identifying the user on next visit to Jotform	bluedoorconsulting.jotform.com	1 month 1 hour	https://www.jotform.com/privacy/
jcmc_ent	No description	bluedoorconsulting.jotform.com	past	https://www.jotform.com/privacy/
jcm_ent	No description	bluedoorconsulting.jotform.com	past	https://www.jotform.com/privacy/

Date Created: November 20, 2023 – Last modified: November 20, 2023

Notice at Collection and Privacy Policy

Notice at Collection and Privacy Policy for Job Applicants

Michels’ Cookie Policy

Cookie Table

Necessary

Functional

Analytics

Advertisement

Other