PRIVACY POLICY FOR CALIFORNIA EMPLOYEES, FORMER EMPLOYEES & JOB APPLICANTS

Effective Date: April 25, 2023

Kolbe & Kolbe Millwork Co., Inc., and our subsidiaries, KK Way, Ltd., Kolbe Galleries, Inc., and Kolbe ServicePro, Inc. (collectively, “Kolbe,” “we,” “our,” or “us”) respect the privacy of our job applicants, employees, and contractors.  This Privacy Policy (“Privacy Policy”) describes the types of personal information that we collect, use, and disclose about California job applicants, employees, and interns (“Employee(s),” “you,” and “your”).
 
Please take the time to read this Notice carefully.  We will review and update this Privacy Policy periodically.  If we change this Privacy Policy, we will post it on this website. You may also contact us as described in the “HOW TO CONTACT US” section below to request a copy of this Privacy Policy.
 

TABLE OF CONTENTS

  1. SCOPE OF PRIVACY POLICY
  2. EXCLUSIONS
  3. NOTICE AT COLLECTION OF PERSONAL INFORMATION
  4. DISCLOSURE OF PERSONAL INFORMATION
  5. SALE OF PERSONAL INFORMATION
  6. RETENTION OF PERSONAL INFORMATION
  7. YOUR RIGHTS
  8. HOW TO EXERCISE YOUR RIGHTS
  9. OUR PROCESS FOR VERIFYING A REQUEST TO KNOW, DELETE, AND/OR CORRECT
  10. OTHER RELEVANT POLICIES, INCLUDING MONITORING
  11. ACCESSIBILITY
  12. HOW TO CONTACT US
  1. Scope of Privacy Policy. This Privacy Policy is intended solely for, and is applicable only to, current and former California employees, job applicants, interns, agency workers, contractors, consultants, and other individuals whose information we collect in connection with providing employment.
 
  1. Exclusions. This Privacy Policy does not apply to individuals who are not California residents. This Privacy Policy also does not apply to our collection and use of your personal information in a consumer or business-to-business capacity. For more information on our collection and use of your personal information in that capacity, including how we process opt-out preference signals, please see our online privacy policy available here.
 
  1. Notice at Collection of Personal Information.
  1. “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 California resident or household. Personal information does not include publicly available, deidentified, or aggregated information or lawfully obtained, truthful information that is a matter of public concern.
  1. Personal Information We Collect. We currently collect and, in the 12 months prior to the Effective Date of this Privacy Policy, have collected the following categories of Personal Information from Employees:
Categories of Personal Information Collected
Personal Identifiers Name, alias name, signature, Social Security number, passport number, driver’s license or state identification card number, account name, and online identifiers
Contact
Information		 Email address, telephone number, postal address, and contact information of referrals, references, and emergency contacts
Employment-Related
Information		 Background check, credit check, education verification, employment verification, drug testing information, timekeeping records, performance records, training records, work history, and prior employer information
Education Information Education history and records
Benefits Administration Information Insurance policy number, vacation/holiday and other paid time off or absence records, requests for leave, health related information, military or veteran status, marital status, and information about family members and dependents (for example, if you enroll them in our benefits plan or name them as a beneficiary)
Financial Information Company issued credit and debit card information, personal bank account information (for example, direct deposit for your pay)
Professional Information Resume/CV, employment history, education history, certifications, language proficiency
Classifications Sex, gender, age, race, national origin, disability, medical conditions and information, citizenship, immigration status, marital status, and military and veteran status
Internet Information Internet or network activity information, such as browsing history, search history, and interactions with our website, applications or systems, and IP address
Location Information Geolocation data, such as device location for Kolbe owned devices and vehicles
Audio and Visual Information Audio, electronic, visual, and similar information, such as images and audio, video recordings created in connection with our business activities
Emails and messages Contents of an employee’s mail, email, and text messages sent from a Kolbe work account.
 
Characteristics of protected classifications necessary to satisfy our obligations as an employer and your rights as an employee under applicable law Race, color, gender, age (40 and older), national or ethnic origin, disability, citizenship or immigration status, marital status, medical condition, military or veteran status, and requests for family care leave, for leave for an employee’s own serious health condition, or for pregnancy disability leave.
 
 
  1. Special Category or Sensitive Personal Information.  Subject to and in accordance with applicable regional law and this Privacy Policy, we collect and process special category or sensitive personal data such as race, ethnicity, disability, and, in appropriate circumstances due to the nature of the position, drug testing and criminal background information.
 
  1. Sources of Personal Information.  We collect Employee Personal Information directly from California residents and from references; former employers; educational institutions; online providers (such as through LinkedIn and similar providers); government entities; other employees; business partners; benefits providers; medical providers; background checks; claims handlers; authentication and single sign-on providers; advertising networks; internet service providers; data analytics providers; operating systems, platforms, or software; and social networks. We do not collect all categories of Personal Information from each source.
 
  1. Purposes for Collection.  We currently collect and have collected the above categories of Personal Information for all purposes of providing employment, including:
 
  • To comply with state and federal law and regulations;
  • To have you fill out applications and forms associated with your employment or prospective employment;
  • To verify your ability to work in this country;
  • To identify you as a veteran;
  • To have you acknowledge your agreement to certain company policies;
  • To process payroll;
  • To track time and attendance;
  • To manage workers’ compensation claims;
  • To enroll you in our wellness program;
  • To administer and maintain benefits, including group health insurance;
  • To administer and maintain a retirement savings plan;
  • To maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance;
  • To manage employee performance of their job duties, including promotions, discipline, and/or termination;
  • To conduct workplace investigations;
  • To obtain and verify background checks;
  • To grant and monitor your access to secure company facilities;
  • To implement, monitor, and manage electronic security measures on devices that are used to access networks and systems (e.g., incident management);
  • To engage in corporate transactions requiring review of employee records and information such as for evaluating potential mergers and acquisitions;
  • To review web traffic and events, monitor for virus attacks and web content, and determine bandwidth consumption;
  • To anonymize and/or aggregate data to perform workforce analytics, data analytics, and benchmarking; and
  • For emergency contact purposes.
 
  1. Legal Basis. We process your Personal Information in compliance with applicable law. In addition, and to the extent required by law, we will process your personal information with your consent, for our legitimate interest of considering your employment application, your employment with us, to enable us to comply with legal obligations, and as may be necessary to exercise or defend against any legal claims.
 
  1. Disclosure of Personal Information.  The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy and, for each category, categories of recipients to whom we disclosed Personal Information.
Categories of Personal Information Categories of Recipients
Personal identifiers and contact information Human resource/payroll information systems, operating systems and platforms, company-used software applications, customer relationship management systems, background check service providers, government or law enforcement entities, expense management service providers, enterprise travel providers, data analytics providers, company bankers, authentication and single sign-on providers, security providers, mobile device management providers, accountants, lawyers, benefits providers, social networks, company insurers, consultants and other professional advisors
Medical and insurance information Benefits providers and company insurers
 
Education, employment history, and related information Applicant software, background check service providers, benefits providers, lawyers
Characteristics of protected classifications under California or federal law Applicant software, human resource/payroll information systems, benefits providers, company insurers, background check service providers, lawyers
 
We disclose this information for the same purposes for which we collect it, which are described above in Section 3(e).
 
  1. Sale of Personal Information. We do not sell and have not sold Employee Personal Information in the twelve (12) months preceding the Effective Date of this Privacy Policy. We do not sell and have not sold the Personal Information of individuals under 16 years of age.
 
  1. Retention of Personal Information.  We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with employment and benefits you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. Please contact us via the contact methods described in the “How to Contact Us” section below for more information on our employee data retention schedule.
  2. Your Rights. If you are a California Employee, you have the following rights:
RIGHT TO KNOW You have the right to request that we disclose to you the Personal Information we collected about you in the 12-month period preceding your request.  This right includes the right to request: (1) specific pieces of Personal Information we have collected about you; (2) categories of Personal Information we have collected about you; (3) categories of sources from which the Personal Information was collected; (4) categories of Personal Information that we sold or disclosed for a business purpose about you (if applicable); (5) categories of third parties to whom your Personal Information was sold or disclosed for a business purpose (if applicable); and (6) the business or commercial purpose for collecting or, if applicable, selling your Personal Information.
RIGHT TO DELETE You have the right to request that we delete your Personal Information that we have collected from you, with some exceptions. 
RIGHT TO CORRECT You have the right to correct inaccurate Personal Information we maintain about you.
RIGHT TO OPT OUT OF SALE You have the right to say no to the sale of your Personal Information.  The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.  Kolbe does not sell or share Employee Personal Information with others for monetary or other valuable consideration.
RIGHT TO LIMIT PROCESSING OF SENSITIVE PERSONAL INFORMATION If we use or disclose Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use and disclosure.  Kolbe does not use or disclose Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.
RIGHT TO NON-DISCRIMINATON You have the right to non-discrimination for exercising your CCPA rights.  Kolbe will not and does not discriminate against you or other Employees for exercising any of your CCPA rights.
 
  1. How to Exercise Your Rights. If you have questions or would like to exercise your rights, you may email us at privacy@kolbewindows.com or you may contact us through our online form.  Please note that to protect your information, we may need additional information from you to verify your identity before processing your request.  Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We reserve the right to request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
 
  1. Our Process for Verifying a Request to Know, Delete, and/or Correct.

We will comply with your request upon verification of your identity and, where applicable, the identity of the California Employee on whose behalf your request is made.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.

For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and/or poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

If your request cannot be fulfilled due to an exception or our legal requirements, we will let you know.
 

  1. Other Relevant Policies, Including Monitoring.   When we hire you, we provide you with other policies and procedures that govern your use of our offices, networks, computers, and other devices. We have the right to monitor your use of our offices and electronic resources in accordance with those policies and procedures. For more information, please read our human resources policies and manuals. You may obtain copies of these policies by contacting your designated HR representative.
 
  1. ACCESSIBILITY. We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities.  If you wish to access this Privacy Policy in an alternate format, or would like to report an issue you are experiencing with respect to this Privacy Policy, please email us at privacy@kolbewindows.com.  You expressly agree to attempt to resolve any and all issues with accessibility directly with us and in good faith prior to instituting any legal action against us.
 
  1. How to Contact Us.  To contact us for questions or concerns about our privacy policies or practices please contact your designated HR representative.  If you are not a current employee, you may contact us at:
Kolbe & Kolbe Millwork Co., Inc.
Attn: Human Resources Department
1323 S. 11th Avenue
Wausau, WI 54401
800-955-8666 (select Human Resources)
privacy@kolbewindows.com
Contact Us – Privacy Request Webform