Applicant CCPA Notice

This notice describes the categories of personal information collected by ECCO USA, Inc. and ECCO Retail, L.L.C. (referred to herein as “ECCO,” “we,” “us” and “our” or the “Company”) and the purposes for which such information may be collected and used. It also provides information concerning the Company’s record retention practices and rights you may have under the CCPA. For more complete information about the Company’s Privacy Policy, please see https://us.ecco.com/legal-pages/legal-privacy-policy.html.

We retain your personal information for as long as necessary to process your application for employment, etc. and in accordance with the Company’s data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolving disputes or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements. Personal Information does not include certain categories of information, such as publicly available information from government records, deidentified or aggregated consumer information, and information subject to HIPAA or the California Confidential Medical Information Act. 

Categories of Personal Information Collected

Identifiers and Contact information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, signature, account name, dates of birth, bank account information, and other similar contact information and identifiers.

Protected classification information. This category includes characteristics of protected classifications under California or federal law.

Internet or other electronic network activity information. This category includes without limitation:

· all activity on the Company’s information systems, such as internet browsing history, search history, email communications, usernames and passwords, and

· all activity on communications systems including phone calls, call logs, voice mails, text messages, chat logs, and app use. 

Audio, electronic, visual, thermal, olfactory, or similar information. This category includes, for example, information collected from camera, thermometers, and similar devices.

Biometric information. This category includes information such as an individual’s physiological, biological, or behavioral characteristics used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity.

Professional and employment-related information. This category includes without limitation:

· data submitted with employment applications including employment history, recommendations, etc.,

· background check and criminal history,

· work authorization, and

· fitness for duty data and reports.

Education information. This category includes education history.

Limited medical information. This category includes without limitation:

· fitness for duty data and reports, and

· leave of absence information (including information related to family obligations), and physical and mental health data concerning applicant and his or her family members.

Sensitive Personal Information. This category includes sensitive information such as

· social security, driver’s license, state identification card, or passport number,

· precise geolocation,

· racial or ethnic origin, religious or philosophical beliefs, or union membership,

· biometric information for the purpose of uniquely identifying a consumer, and

· information concerning health and sex life or sexual orientation.

Inferences drawn from the Applicant Personal Information in the categories above. This category includes engaging in human capital analytics, including but not limited to, identifying certain correlations about individuals and success on their jobs, analyzing data to improve retention, and analyzing preferences to inform HR Policies, Programs and Procedures.

Purposes Personal Information, Including Sensitive Personal Information, is Used

· Collect and process employment applications, including confirming eligibility for employment, background and related checks, onboarding, and related recruiting efforts.

· To maintain physician records and occupational health programs.

· Maintaining personnel records and record retention requirements.

· Communicate with you about your application.

· Complying with applicable state and federal health, labor, employment, disability, equal employment opportunity, and related laws, guidance, or recommendations.

· Preventing unauthorized access to, use, or disclosure/removal of the Company’s property, including the Company’s information systems, electronic devices, network, and data.

· Investigating complaints, grievances, and suspected violations of Company policy.

· Protect the legal rights, privacy, safety or property of Company or its employees, agents, contractors, customers or the public.

· Protect against fraud or other illegal activity or for risk management purposes.

· Enforce the Company’s website’s terms of use.

· Design, implement, and promote the Company’s diversity and inclusion programs.

· Facilitate the efficient and secure use of the Company’s information systems.

· Improve safety of employees, customers and the public with regard to use of Company property and equipment.

· Evaluate an individual’s appropriateness for a participation position at the Company, or promotion to a new position.

· To respond to and manage any legal claims against the Company and/or its personnel, including civil discovery in litigation.

· To facilitate other business administrative functions and strategic activities, such as risk management, information technology and communications, financial management and reporting, workforce and succession planning, mergers and acquisition activities; and maintenance of licenses, permits and authorization applicable to Company operations.

Sources and Disclosures of Personal Information

For information on the sources of personal information we collect and the categories of third parties to whom we may disclose personal information, please see the Company’s Privacy Policy at https://us.ecco.com/legal-pages/legal-privacy-policy.html.

To carry out the purposes outlined above, the Company may disclose information with third parties or service providers, such as background check vendors, third-party staffing vendors and information technology vendors, outside legal counsel, and state or federal governmental agencies. Each party has agreed to safeguard any Personal Information to at least the same standards as the Company and to comply with the Company’s direction regarding consumer individual rights requests.

The Company does not sell or share, as those terms are defined under applicable law, the above categories of Personal Information from applicants. The Company may add to the categories of personal information it collects and the purposes it uses personal information. In that case, the Company will inform you.

California Resident Individual Rights Requests. Individuals who are residents of the State of California have certain individual rights. These rights and how to exercise them are described more fully in the Company’s Privacy Policy at https://us.ecco.com/legal-pages/legal-privacy-policy.html.

Upon receipt of a verifiable consumer request (see below), and as required by applicable law, we will provide a response to such requests.

Submitting Consumer Rights Requests. If you wish to exercise your right to request access to your Personal Information; deletion of your Personal Information or correction of your Personal Information, please submit your request through our toll-free number: 877-240-2365 or by email: ECCOUSA.Privacy@ecco.com. To ensure we can verify your identity and help us respond to your request please provide us with your full name, email, and home address, and clearly indicate which of the rights you wish to exercise.

We reserve the right to amend this Notice at any time without advance notice.

If you have questions about this Notice, please call us at 877-240-2365 or email us at ECCOUSA.Privacy@ecco.com.