CPRA Privacy Policy

PREGIS LLC CPRA PRIVACY POLICY FOR WORK-RELATED INDIVIDUALS

PURPOSE AND INTENT

Pregis LLC and its operating groups, parent(s), subsidiaries and affiliates (collectively, “the Company”) are committed to protecting the privacy and security of the personal information of our job applicants, employees and their emergency contacts and beneficiaries, independent contractors, board of directors, medical personnel, and corporate officers who are residents of California (“Work-Related Individuals”). This privacy policy describes how we collect, use, retain, secure and disclose personal information about you (our “Information Practices”). The Company is responsible for deciding how it collects, uses, retains, secures, and discloses your personal information.

This privacy policy is intended to comply with the California Consumer Privacy Act (“CCPA”), California Privacy Rights Act (“CPRA”), applicable regulations, and other applicable data privacy laws. This Privacy Policy does not form part of any contract of employment or other contract to provide services. We may update this policy at any time.

It is important that you understand this privacy policy, together with any other privacy notices we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. If you have any questions about this privacy policy or how we handle your personal information, please contact us at: humanresources@pregis.com.

If you wish to access this privacy policy in an alternate format or require an accommodation to access this privacy policy, please contact us at: humanresources@pregis.com.

DATA PROTECTION PRINCIPLES

We collect, use, retain, and share your personal information in accordance with certain data privacy and data protection principles. Specifically, the personal information we collect about you is: (i) used lawfully, fairly and in a transparent way; (ii) collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes; (iii) reasonably necessary and proportionate to achieve these purposes; (iv) accurate and kept up to date; (v) kept only as long as necessary for these purposes; and (vi) kept securely. If we intend to collect, use, retain, or share your personal information for any purpose that is incompatible with the purposes for which your personal information was collected, we will obtain your consent to do so.

For the purposes of this privacy policy, “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 consumer or household. “Sensitive personal information” is a subcategory of personal information and means personal information that reveals: (a) an individual’s social security, driver’s license, state identification card, or passport number; (b) an individual’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) an individual’s precise geolocation; (d) an individual’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of an individual’s mail, email, and text messages unless the Company is the intended recipient of the communication; (f) an individual’s genetic data; (g) an individual’s biometric information used to uniquely identify the individual; (h) personal information collected and analyzed regarding an individual’s health; and (i) personal information collected and analyzed regarding an individual’s sex life or sexual orientation.

PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT, USE IT, AND SHARE IT

We collect, receive, use and share personal information for the following work-related individuals. We do not:

sell your personal information;
share or disclose your personal information to third parties other than the entities or service providers listed below;
share or disclose your sensitive information to third parties for purposes other than those listed below or otherwise permitted by the CPRA;
sell or share the personal information of consumers under 16 years of age; or
permit third parties to collect your personal information on our behalf other than our service providers listed below.

A. Job Applicants

CATEGORIES OF PERSONAL INFORMATION WE COLLECT	SOURCES OF THE PERSONAL INFORMATION	PURPOSES FOR COLLECTING THE PERSONAL INFORMATION	CATEGORIES OF ENTITIES WITH WHOM WE SHARE THE PERSONAL INFORMATION
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.	You, recruitment service providers, and publicly available sites and sources	Hire the best-qualified applicants, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company personnel involved with hiring, recruitment service providers, background check service providers, former employers, references you provide, applicable law enforcement and government agencies, healthcare professionals, legal, human resources and IT service providers, and drug testing laboratory personnel
Protected categories such as race, color, national origin, religion, sex (including pregnancy, childbirth, and related medical conditions), disability, age, citizenship status, genetic information, ancestry, marital status, sexual orientation, gender identity and gender expression, AIDS/HIV status, medical condition, political activities or affiliations, military or veteran status, and status as a victim of domestic violence, assault, or stalking.	You and our recruitment service providers	Hire the best-qualified applicants; comply with our legal and contractual requirements; administer our diversity, equality and inclusion initiatives; and to establish, exercise our legal and contractual rights	Company personnel involved with hiring, our recruitment service providers, background check service providers, former employers, applicant references, healthcare professionals, legal, human resources and IT service providers, drug testing laboratory personnel and applicable law enforcement and government agencies
Sensitive Personal Information, such as social security number; driver’s license number; state identification card number; passport number; account log-in; financial account; debit card number, credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; contents of an individual’s mail, email, and text messages unless the Company is the intended recipient of the communication; an individual’s biometric information used to uniquely identify the individual; personal information collected and analyzed regarding an individual’s health.	You and our recruitment service providers	Hire the best-qualified applicants; verify your identity; comply with our legal and contractual requirements; administer our diversity, equality and inclusion initiatives; and to establish, exercise our legal and contractual rights. We do not collect or process sensitive personal information for purposes of inferring characteristics about you.	Company personnel involved with hiring, recruitment service providers, healthcare professionals, legal, human resources and IT service providers, and drug testing laboratory personnel and applicable law enforcement and government agencies
Biometric Information, such as fingerprints, voice prints, retinal scans, facial recognition, hand geometry, and the like.	You and our recruitment service providers	Hire the best-qualified applicants, verify your identity, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company personnel involved with hiring, our recruitment service providers, and our biometric information service providers.
Internet or other electronic network activity information, such as social media site or application	You, our electronic communications equipment, Company human resources, marketing, management, and IT personnel; our IT service providers	Hire the best-qualified applicants, protect Company and customer information and Company equipment and systems, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company personnel involved with hiring and IT; and our legal and IT service providers; applicable law enforcement agencies
Geolocation information	You, and our electronic communications equipment; IT personnel; our IT service providers	Hire the best-qualified applicants, identification verification, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company personnel involved with hiring and IT; our legal and IT service providers
Audio, electronic, visual, or similar information	You, and our electronic communications equipment; IT personnel; our IT service providers	Hire the best-qualified applicants, identification verification, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company personnel involved with hiring and IT; and our legal and IT services providers
Professional or employment-related information such as job preference and work availability; qualifications; employment history and experience; compensation; military service; reference and background check information, including relevant criminal history and credit history; pre-employment test results; post-offer medical and medical examination information and results, including drug test results; immigration and work eligibility; and information provided by you during the interview and hiring process	You, our recruitment service providers, our background check service providers, applicable law enforcement and governmental agencies, your former employers, references you provide, and publicly available sites and sources	Hire the best-qualified applicants, identification verification, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company personnel involved with hiring, our legal and recruitment service providers, our background check service providers, applicable law enforcement and governmental agencies, references you provide
Education information relevant to the job	You, our recruitment service providers, our background check service providers, applicable law enforcement and governmental agencies, your former employers, references you provide, and publicly available sites and sources	Hire the best-qualified applicants, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	You, our recruitment service providers, our background check service providers, applicable law enforcement and governmental agencies, healthcare professionals and drug testing laboratory personnel, and references you provide
Inferences drawn from the personal information collected to determine your abilities and aptitude	Personal information collected about you	Hire the best-qualified applicants, identification verification, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company personnel involved with hiring and our recruitment service providers; our background check service providers, applicable law enforcement and governmental agencies, healthcare professionals and drug testing laboratory personnel, and references you provide.

B. Employees:

CATEGORIES OF PERSONAL INFORMATION WE COLLECT	SOURCES OF THE PERSONAL INFORMATION	PURPOSES FOR COLLECTING THE PERSONAL INFORMATION	CATEGORIES OF ENTITIES WITH WHOM WE SHARE THE PERSONAL INFORMATION
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, passport number, or other similar identifiers.	You; background check service provider	Manage our employment relationship with you, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; applicable government agencies; and our legal and human resources service providers.
Protected categories such as race, color, national origin, religion, sex (including pregnancy, childbirth, and related medical conditions), disability, age, citizenship status, genetic information, ancestry, marital status, sexual orientation, gender identity and gender expression, AIDS/HIV status, medical condition, political activities or affiliations, military or veteran status, and status as a victim of domestic violence, assault, or stalking.	You; Company human resources and DE&I personnel; background check and human resource service providers	Manage our employment relationship with you, comply with our legal and contractual requirements; establish, exercise our legal and contractual rights; and implement the Company’s diversity, equality, and inclusion programs.	Company human resources, management, and IT personnel; applicable government agencies; and our legal and human resources service providers.
Sensitive Personal Information, such as social security number; driver’s license number; state identification card number; passport number; account log-in; financial account; debit card number, precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; contents of an individual’s mail, email, and text messages unless the Company is the intended recipient of the communication; genetic data; an individual’s biometric information used to uniquely identify the individual; personal information collected and analyzed regarding an individual’s health; and personal information collected and analyzed regarding an individual’s sex life or sexual orientation.	You; background check service provider	Manage our employment relationship with you, verify your identity; comply with our legal and contractual requirements; establish, exercise our legal and contractual rights; and implement the Company’s diversity, equality, and inclusion programs.	Company human resources, management, and IT personnel; applicable government agencies; and our legal and human resources service providers.
Biometric Information, such as fingerprints, voice prints, facial recognition, and the like.	You, Company human resources and management personnel, and biometric information service providers	Manage our employment relationship with you, verify your identity and access rights; comply with our legal and contractual requirements; establish, exercise our legal and contractual rights;	Company human resources, management, and IT personnel; applicable law enforcement agencies; and our legal and human resources service providers.
Internet or other electronic network activity information, such as browsing history, search history, and information regarding your interaction with an internet website, social media site or application	You, our electronic communications equipment, Company human resources, management, marketing, and IT personnel; and our IT service providers; social media sites	Manage our employment relationship with you, protect Company and customer information and Company equipment and systems; comply with our legal and contractual requirements; establish, exercise our legal and contractual rights;	Company human resources, management, safety, and IT personnel; applicable government and law enforcement agencies; and our legal and human resources service providers.
Geolocation information	You, and our electronic communications equipment; marketing and IT personnel; and our IT service providers	Manage our employment relationship with you, verify access rights; comply with our legal and contractual requirements; establish, exercise our legal and contractual rights;	Company human resources, management, safety, and IT personnel; applicable government agencies; and our legal and human resources service providers.
Audio, electronic, visual, or similar information	You, and our electronic communications equipment	Manage our employment relationship with you, verify access rights; comply with our legal and contractual requirements; establish, exercise our legal and contractual rights;	Company human resources, management, and IT personnel; applicable government and law enforcement agencies; and our legal and human resources service providers.
Professional or employment-related information such as immigration and work eligibility; and information provided by you during the interview and hiring process performance management information, such as employment status (full-time or part-time, regular or temporary); work schedule; job assignments; hours worked; business travel information; expatriate and secondment assignments; accomplishments and awards; training and development information; performance evaluation information; workplace safety information; medical or health conditions, job restrictions, drug testing information, workplace accident and illness information, and health insurance information; complaint resolution information; discipline and counseling information; and employment termination information.	You and Company management and human resources personnel; legal and human resources service providers	Manage our employment relationship with you, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; applicable government and law enforcement agencies; and our legal and human resources service providers.
Education information relevant to the job	You and Company management and human resources personnel; legal and human resources service providers	Manage our employment relationship with you, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; and legal and human resources service providers.
Inferences drawn from the personal information collected to determine your abilities and aptitude	Personal information collected	Manage our employment relationship with you, comply with our legal and contractual requirements, and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; applicable government and law enforcement agencies; and our legal and human resources service providers.

C. Our Employees’ Emergency Contacts

CATEGORIES OF PERSONAL INFORMATION WE COLLECT	SOURCES OF THE PERSONAL INFORMATION	PURPOSES FOR COLLECTING THE PERSONAL INFORMATION	CATEGORIES OF ENTITIES WITH WHOM WE SHARE THE PERSONAL INFORMATION
Identifiers such as a name, alias, postal address, telephone number, and email address,	You and your emergency contacts	Manage our employment relationship with you; contact your designated emergency contact persons in the event of an emergency; comply with our legal and contractual requirements; and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; and our legal and human resources service providers.
Protected categories such as marital status or other family status.	You and your emergency contacts	Manage our employment relationship with you; contact your designated emergency contact persons in the event of an emergency; comply with our legal and contractual requirements; and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; and our legal and human resources service providers.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

SOURCES OF THE PERSONAL INFORMATION

PURPOSES FOR COLLECTING THE PERSONAL INFORMATION

CATEGORIES OF ENTITIES WITH WHOM WE SHARE THE PERSONAL INFORMATION

Identifiers such as a name, alias, postal address, telephone number, and email address,

You and your emergency contacts

Manage our employment relationship with you; contact your designated emergency contact persons in the event of an emergency; comply with our legal and contractual requirements; and to establish, exercise our legal and contractual rights

Company human resources, management, and IT personnel; and our legal and human resources service providers.

Protected categories such as marital status or other family status.

You and your emergency contacts

Company human resources, management, and IT personnel; and our legal and human resources service providers.

D. Our Employees’ Beneficiaries

CATEGORIES OF PERSONAL INFORMATION WE COLLECT	SOURCES OF THE PERSONAL INFORMATION	PURPOSES FOR COLLECTING THE PERSONAL INFORMATION	CATEGORIES OF ENTITIES WITH WHOM WE SHARE THE PERSONAL INFORMATION
Identifiers such as a real name, alias, postal address, telephone number email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	You, your beneficiaries, healthcare providers, and our human resources service providers such as benefits administrators and insurance companies.	Manage our employment relationship with you; administer benefits programs for beneficiaries of our employees. comply with our legal and contractual requirements; and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; healthcare providers, and our legal and human resources service providers such as benefits administrators and insurance companies.
Protected categories such as race, color, national origin, religion, sex (including pregnancy, childbirth, and related medical conditions), disability, age, citizenship status, genetic information, ancestry, marital status, sexual orientation, gender identity and gender expression, AIDS/HIV status, medical condition, political activities or affiliations, military or veteran status, and status as a victim of domestic violence, assault, or stalking.	You, your beneficiaries, healthcare providers, and human resources service providers such as benefits administrators and insurance companies.	Manage our employment relationship with you; administer benefits programs for beneficiaries of our employees; comply with our legal and contractual requirements; and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; healthcare providers, and our legal and human resources service providers such as benefits administrators and insurance companies.
Sensitive Personal Information, such as social security number; driver’s license number; state identification card number; passport number; account log-in; financial account; debit card number, credit card number in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin; religious or philosophical beliefs; union membership; contents of an individual’s mail, email, and text messages unless the Company is the intended recipient of the communication; genetic data; an individual’s biometric information used to uniquely identify the individual; personal information collected and analyzed regarding an individual’s health; and personal information collected and analyzed regarding an individual’s sex life or sexual orientation.	You, your beneficiaries, healthcare providers, and human resources service providers such as benefits administrators and insurance companies.	Manage our employment relationship with you; administer benefits programs for beneficiaries of our employees; comply with our legal and contractual requirements; and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; healthcare providers, and our legal and human resources service providers such as benefits administrators and insurance companies
Professional or employment-related information such as employer name and contact information and employment health insurance information.	You, your beneficiaries, your beneficiaries’ employers, healthcare providers, and human resources service providers such as benefits administrators and insurance companies.	Manage our employment relationship with you; administer benefits programs for beneficiaries of our employees; comply with our legal and contractual requirements; and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; healthcare providers, and our legal and human resources service providers such as benefits administrators and insurance companies
Information necessary to process benefits claims including health and financial information	You, your beneficiaries, your beneficiaries’ employers, healthcare providers, and human resources service providers such as benefits administrators and insurance companies.	Manage our employment relationship with you; administer benefits programs for beneficiaries of our employees; comply with our legal and contractual requirements; and to establish, exercise our legal and contractual rights	Company human resources, management, and IT personnel; healthcare providers, and our legal and human resources service providers such as benefits administrators and insurance companies

E. Corporate Officers:

To the extent that our Corporate Officers are employees of the Company, we collect the personal information listed above for employees and use the information for the same purposes.

Privacy Rights

As a California resident, you have the following privacy rights regarding your personal information:

The right to know and right to access the personal information we have collected about you, including the categories of personal information; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom the business discloses personal information; and the specific pieces of personal information the business has collected about the consumer;
The right to delete personal information that we have collected from you, subject to certain exceptions.
The right to correct inaccurate personal information that we maintain about you.
The right of portability, or right to have us transfer your personal information to other persons or entities upon your request.
The right to limit the use of your sensitive information if we decide in the future to use such information for purposes other than the purposes listed above; and
The right not to be discriminated or retaliated against for exercising your of privacy rights.

You can exercise your privacy rights by submitting a request to us by emailing us at: humanresources@pregis.com calling us at: (877) 692-6163; or asking our Human Resources department for a written request form. To protect the security of your personal information, we will require you to provide us with identifying information for you such as personal email address, personal telephone number, employee identification number, and/or other information that we can match with the personal information we have collected about you to verify your identity.

You may use an authorized agent to request access to or deletion of your personal information. We will require your authorized agent to provide us with either (1) a power of attorney authorizing the authorized agent to act on your behalf or (2) your written authorization permitting the authorized agent to request access to your personal information on your behalf. Further, we will require you or your authorized agent to provide us with identifying information to verify your identity. We may also require you to either verify your own identity directly with us or directly confirm with us that you provided the authorized agent permission to submit the request.

Within 10 days of receiving your request to know, we will confirm receipt of your request and provide information about how we will process your request. Generally, we will respond to your request within 45 days. If we need more time to respond, we will provide you with notice and an explanation of the reason we need more time to respond. We may deny your request if we cannot verify your identity or are legally permitted to deny your request. If we deny your request, we will explain the basis for the denial, provide or delete any personal information that is not subject to the denial, and refrain from using the personal information retained for any purpose other than permitted by the denial. We will maintain a record of your request and our response for 24 months.

DATA SECURITY

While no data security system can fully protect personal information from unauthorized data breaches, The Company has implemented reasonable safeguards and controls, consistent with its legal obligations under California and other local, state and federal laws. The Company is committed to: (i) seeking to safeguard all personal information that you provide to us; (ii) seeking to ensure that it remains confidential and secure; and (iii) taking all reasonable steps to ensure that personal privacy is respected. All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorized access or disclosure and loss or corruption by computer viruses and other sources of harm. We restrict access to personal information to those staff members of the Company and our services providers who need to know that information for the purposes identified in our privacy policy and privacy notices.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we retain personal information for the duration of our relationship with you plus any legally required record or data retention period and/or any period of time necessary to exercise our legal rights. Thereafter, we will securely destroy your personal information in accordance with the Company’s record retention policies.

In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

PERSONAL INFORMATION OF MINORS

The Company does not sell or share personal information for individuals under the age of 16.

CHANGES TO THIS PRIVACY POLICY

As we strive to improve our practices, we may revise the Company’s privacy policy from time to time. This privacy policy is not a contract, and we reserve the right to change this policy at any time and to notify you of those changes by posting an updated version of this policy. It is your responsibility to check this policy from time to time for any changes.

This privacy policy was last updated on September 14, 2023.

QUESTIONS AND FURTHER INFORMATION

If you have any questions or would like further information regarding this privacy policy or our privacy practices, please contact us at: humanresources@pregis.com.