Imperial Bag & Paper Co. LLC, Dade Paper & Bag LLC, and their respective subsidiaries (collectively, “Imperial Dade”) are committed to privacy and to transparency in our information practices. In this Privacy Notice (“Notice”), we describe our collection, use, disclosure and processing of personal information that we collect relating to our employees and their beneficiaries and dependents, nonemployee workers, and job applicants and candidates.

1. Scope of this Notice

This privacy notice describes, generally, how Imperial Dade handles and processes personal information related to our employees and their beneficiaries and dependents, non-employee workers, and job applicants and candidates who apply for employment with us. This Notice does not apply to the personal information we process relating to our former, current and prospective customers, partners, and vendors, the use of our websites and associated services (collectively, the “Website”), other individuals who communicate with us and/or who use our products and services and individuals whose personal information we receive in providing the services, and whose personal information is subject to different privacy notices. In this Notice, our use of the term “personal information” includes other similar terms under applicable privacy laws—such as “personal data” and “personally identifiable information.” In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked, or linkable with a particular individual.

2. What Personal Information we Collect

We may collect and process the following categories of personal information:

- Identifiers such as a real name, alias, postal address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, date of birth, gender, marital status, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, driving/motor vehicle qualifications, training, and history, background check information criminal history information, beneficiary/dependents information, or any other financial information, medical information, or health insurance information;
- Characteristics of protected classifications under state or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information;
- Biometric information;
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding an individual’s interaction with an internet website application, or advertisement;
- Geolocation data;
- Audio, electronic, visual, or similar information;
- Professional or employment-related information, including job application materials, hire state, job responsibilities, salary and employment history, disciplinary or other related human resources records, performance evaluations, job end or termination date;
- Education information, including educational history, academic status, achievements, or discipline;
- Inferences drawn from any of the information identified in this subdivision to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
- Sensitive personal information, including information concerning racial or ethnic origin, union membership, and health.

Categories of sources of personal information: We may collect personal information directly from you, as well as automatically related to your use of our Website and other services, as well as from third parties. For example, we collect personal information:

- from you, either directly (i.e., through information you submit to us) or indirectly (i.e., by observing your actions);
- from data analytics providers;
- from government entities;
- from service providers (i.e., companies who are assisting us in fulfilling our contracts and carrying out our business); and
- from other sources, such as public databases, social media platforms (including from people with whom you are friends or otherwise connected), job boards, and from other third parties.

3. What We Do with Your Personal information

We may process your personal information for the following purposes:

- Performing and managing the contract we have with you or the company you are associated with;
- Providing training;
- Registering you for and communicating with you about events;
- Managing our relationship with you;
- Communicating with you;
- Investigating and handling reports to our hotline;
- Managing rebates;
- Analyzing and improving our business;
- Tracking accidents and incidents;
- Training and analyzing driving ability;
- Making deliveries of our products;
- Conducting sales through our company store;
- Increasing employee engagement;
- Protecting the health and safety of our people and property;
- Providing and administering payroll and benefits;
- Managing our talent, including coaching and evaluating performance;
- Evaluating job applicants and candidates;
- Providing disability accommodations;
- Defending our legal rights;
- Auditing, reporting, corporate governance, and internal operations, including relating to audits, accounting, and legal functions, and relating to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business; and
- Complying with our legal obligations.

We do not use your personal information for profiling or for any other automated decision making purposes, and we do not sell your personal information.

4. Information Sharing

Imperial Dade will process some of your personal information locally. As a large organization, however, many of our business activities can also be carried out by processing or consolidating information about you in specific or centralized databases and systems located at our different facilities and companies. As a result, your information may be shared with other entities within or affiliates of Imperial Dade in accordance with applicable laws, this Privacy Notice, any applicable specific local policy, and to support our business purposes. We also may share your personal information with our equity partners for corporate governance purposes.

As a general rule, we do not share your personal information with anyone outside Imperial Dade. However, we may share your personal information with certain third parties that perform business functions or provide services to us, including with the following categories of recipients: service providers and data processing vendors.

Your personal information may also be shared for legal reasons (e.g., to prevent crime or fraud, or to comply with a court order or legislation), in connection with any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business, or with your consent.

We do not “sell” your personal information or “share” your personal information with third parties for cross-context behavioral advertising.

5. Data Retention

We store personal information as needed to accomplish the purposes identified in this Notice and to meet legal requirements, including legal and compliance requirements regarding records retention, resolving disputes, and enforcing our agreements. This means that we may be required to maintain your personal information, for example, to: (1) comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us); (2) to exercise, establish or defend legal claims; and/or (3) to protect against fraudulent or abusive activity on our services and systems. For these and possibly other reasons, we may be unable to delete personal information upon request of an individual in certain cases.

We may retain different categories of information for different periods of time for the instances stated above. However, it our policy as an organization that when personal information is no longer needed or after legal authority to retain it has expired, personal information will be destroyed in accordance with applicable law and pursuant to procedures established in relation to the relevant services, systems, or processes. Retention periods for records maintained by us, including those containing personal data are established based upon business need, statutory and regulatory record keeping requirements in the geographies where we do business, and legal obligations. If you have any further questions about our handling of personal information, please contact us using the contact details below.

6. Additional Information for California Residents

If you are a resident of California, the California Consumer Privacy Act of 2018 (CCPA) permits you to request the following from us:

(1) disclosure of information about the collection, use, disclosure, and sale of your personal information;
(2) a list of categories of personal information collected about you in the preceding 12 months, including (a) categories of personal information collected about you, (b) categories of sources from which the personal information is collected, (c) the business or commercial purpose for collecting or selling personal information, (d) categories of third parties to whom we disclose, share, or sell personal information, and (e) specific pieces of information that we have collected about you;
(3) deletion of any personal information about you that we have collected from you;
(4) correction of inaccurate personal information about you.

These rights are subject to certain limitations. You have the right not to face discrimination for exercising any of your rights under the CCPA. As stated above, we do not sell your personal information.

When you would like to exercise your rights, please send your request to the contact details below. Please note that we may need you to provide additional information to confirm your identity.

We will use the following process to verify requests: We will acknowledge receipt of your request, verify it using processes required by law, then process and respond to your request as required by law. To verify such requests, we may ask you to provide the following information:

- For a request to know categories of personal information which we collect, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you against information in our systems which are considered reasonably reliable for the purposes of verifying a consumer’s identity.
- For a request to know specific pieces of personal information or for requests to delete, we will verify your identity to a high degree of certainty by matching at least three pieces of personal information provided by you to personal information maintained in our systems and also by obtaining a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request.

Authorized agent requests: An authorized agent can make a request on a California residents’ behalf by providing a power of attorney valid under California law, or providing: (1) proof that the consumer authorized the agent to do so; (2) verification of their own identity with respect to a Right to Know categories, Right to Know specific pieces of personal information, or Requests to Delete which are outlined above; and (3) direct confirmation that the consumer provided the authorized agent permission to submit the request.

We will respond to verifiable requests as required by law. You can also contact us if you have any questions, remarks, or complaints in relation to this Notice.

7. How We Manage this Notice

We have most recently updated this Notice on January 1, 2023 and it replaces earlier versions. We will update this Notice from time to time and notify you of any changes by posting a revised version on Imperial Dade’s employee portal as well as recruitment portal.

8. Contact Us

833-419-4567 privacy@imperialdade.com