Lineage Logistics Holdings, LLC (“Company,” “we,” “our” or “us”) California Employee Privacy Notice

PURPOSE OF THIS NOTICE: This California Employee Privacy Notice (the “Notice”) describes our collection and use of certain personal information relating to our current and former full-time, part- time and temporary employees and staff, as well as Company officers, directors and owners who are California residents (each an “Employee”). This Notice describes our collection and use of personal information about Employees and is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”). We may provide Employees additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check or collect health information).

SCOPE OF THIS NOTICE: This Notice applies to personal information that we collect and use to manage the employment relationship (including emergency contact information) and other personal information related to our administration of benefits to Employees.

What is personal information? In this Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

What isn’t covered by this notice? This Notice does not address or apply to our collection of personal information that is not subject to the CCPA, such as protected health information (or “PHI”), consumer credit reports and background checks, publicly available data lawfully made available from state or federal government records, or other information that is exempt under the CCPA. This Notice also does not apply to the personal information we collect from contractors or job applicants, or from customers or end users of our products and services, including Employees in the context of their personal use of our products and services (which is subject to our Global Privacy Notice which you can access at https://www.lineagelogistics.com/privacy-policy).

Are our practices the same for all Employees? The categories of personal information we collect and our use of personal information may vary depending on the circumstances, such as an Employee’s role and responsibilities with the Company. The information in this Notice is intended to provide an overall description of our collection and use of personal information about Employees.

CATEGORIES OF PERSONAL INFORMATION COLLECTED: Generally, we may collect the below categories of personal information about Employees, where appropriate and to the extent permitted under applicable law:

Name, Contact Info, and other Identifiers. Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, and other government identifiers.

Protected Classifications. Characteristics of protected classifications under California or federal law such as race/ethnicity, sex, sexual orientation, gender identity, age, religion, national origin, disability, citizenship status, military/veteran status, marital status, medical condition and pregnancy. Note: Generally, this information is only collected on a voluntary basis, and it is used in support of our equal opportunity and diversity and inclusion efforts and reporting obligations, or where otherwise required by law.

Biometric Information. Physiological, biological, or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including imagery of the fingerprint, hand, palm, voice recordings and health data that contain identifying information.

Usage Data. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding an Employee’s interaction with an internet website, application or advertisement, as well as physical and network access logs and other network activity information related to your use of any Company device, network, or other information resource.

Geolocation Data. Precise geographic location information about a particular individual or device.

Audio, Video, and other Electronic Data. Audio, electronic, visual, thermal, olfactory, or similar information such as CCTV footage, photographs and call recordings and other audio recordings (e.g., recorded meetings and webinars).

Employment History. Professional or employment-related information.

Education Information. Information about education history or background that is not publicly available personally identifiable information as defined in the Federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

Profiles and Inferences. Inferences drawn from any of the information identified above to create a profile about an Employee reflecting the Employee’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION: Generally, we may use the above categories of personal information for the following purposes:

Compensation and Benefits. For purposes relating to our administration of compensation and benefits, including:

  • Administering Employee payroll, salary, and compensation
  • Administering any Employee benefits, including any employee pension or welfare benefit plans (which may include the collection of personal information about others such as beneficiaries, where necessary to administer such benefits)
  • Calculating withholdings or other lawful deductions, issuing tax return-related documents and forms to Employees
  • Reviewing timecards and reported time worked
  • Monitoring and managing PTO, holiday, FMLA and other leaves of absence

Management of Employment Relationship. To manage our relationship with Employees, including:

  • Hiring, terminations, relocation, transfers, promotions and disciplinary actions
  • Reviewing performance
  • Conducting Employee performance reviews, compensation and bonus reviews, and headcount and salary reviews
  • Administering and monitoring compliance with our policies and procedures
  • Maintaining records of emergency contact information for use in the event of an emergency
  • Administering or performing employment contracts where applicable
  • Conducting pre-employment and employment screening (where relevant and pursuant to applicable laws)
  • Professional development and training purposes
  • Verification and management of applicable Employee credentials, licensing and other qualifications
  • Facilitating Employee communication and collaboration, such as through the corporate directory and through Employee bios
  • Supporting our equal opportunity employment policy and diversity and inclusion programs

Business Operations and Client Services. For purposes relating to the organization and operation of our business and our performance of services to clients, including:

  • Operating our business by developing, producing, marketing, selling and providing goods and services
  • Providing after-sales services to clients
  • Auditing and assessing performance of business operations, including client services and associated activities
  • Training and quality control
  • Satisfying client reporting and auditing obligations
  • Facilitating business development opportunities, as relevant
  • Facilitating communications in furtherance of the foregoing

Security and Monitoring. To monitor and secure our resources, network, premises, and assets, including:

  • Monitoring for, preventing, and investigating suspected or alleged misconduct or violations of work rules
  • Monitoring for, preventing, investigating, and responding to security and privacy incidents
  • Providing and managing access to physical and technical access controls
  • Monitoring activities, access, and use to ensure the security and functioning of our systems and assets
  • Securing our offices, premises, and physical assets, including through the use of electronic access systems and video monitoring.

Auditing, Accounting, and Corporate Governance. For purposes relating to financial, tax, and accounting audits, and audits and assessments of our business operations, security controls, financial controls or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.

M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions (e.g., mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization, or other similar business transactions).

Defending and Protecting Rights. To protect and defend our rights and interests and those of third parties, including to manage and respond to legal claims or disputes, and to otherwise establish, defend, or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.

Compliance with Applicable Legal Obligations. For purposes relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders), as well as assessments, reviews, and reporting relating to such legal obligations, including under employment and labor laws and regulations, social security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions, and guidance.

CONTACTING US ABOUT THIS NOTICE: If you have any questions or concerns regarding our use of personal information as described in this Notice, please contact us at privacy@lineagelogistics.com.