California Privacy Policy

Applicability:

This Notice applies to the following California residents who provided us with PI in HR contexts:

• Job applicants who have applied for a position with S&B.
• Current/former employees of S&B.
• Independent contractors of S&B.

This Notice also applies to California residents whose family member or friend has provided PI about you to S&B in an HR context, such as if:

• You are listed as an emergency contact for one of the foregoing.
• You are a beneficiary or dependent of one of the foregoing.

The individuals referred to in the foregoing bullet points are collectively referred to as “Personnel” throughout this Notice. Section 1 of this Notice provides notice of our data practices, including our collection, use, retention, and disclosure of Personnel PI. Sections 2-5 of this Notice provide information regarding California Personnel rights under the CCPA and how you may exercise them.

Non-Applicability:

This Notice does not apply to our consumer facing website(s) or our data practices outside of the HR context, which are addressed in our general privacy notice available here.

1. NOTICE OF DATA PRACTICES

The description of our data practices in this Notice covers the twelve (12) months prior to the Effective Date and will be updated at least annually. Our data practices may differ between updates, however, if materially different from this Notice, we will provide supplemental pre-collection notice of the current practices, which may include references to other privacy policies, notices, or statements. Otherwise, this Notice serves as our notice at collection.

(a) PI Sources and Use

We may collect your PI directly from you, such as when you apply for a position or become employed or engaged by us (e.g., identification/identity data, contact details, educational and employment data), others through interactions in the course of employment or engagement, or third parties (e.g., references).

Generally we use Personnel PI for HR Business Purposes and as otherwise related to the operation of our business, including for: Performing Services; Managing Interactions and Transactions; Security; Debugging; Advertising & Marketing; Quality Assurance; Processing Interactions and Transactions; and Research and Development. For example, we use Personnel PI for the following purposes:

• Workforce Planning and Recruitment, for example business forecasting, employee assignment, planning and budgeting, job advertising, interviewing, selecting and hiring staff, assessing job candidacy and conducting background checks;
• General Human Resources Management and Administration, for example employee intake/onboarding/off-boarding, employee career development, performance management, training and education program, compensation and benefits management and benchmarking, administering payroll and benefit arrangements (including long-term incentive awards and bonus administration), obtaining management and employee satisfaction feedback, managing absences (e.g., sickness, parental leave and other family related and flexible working policies), health and safety, travel and expense management, and general headcount reporting;
• Performance of S&B’s Business Operations, for example carrying out S&B’s day to day business activities, allowing us to work together and collaborate, providing services to our customers and ensuring business continuity;
• Security Management, for example to ensure the security of S&B’s premises, assets, information, HR IT systems, and employees;
• Marketing, Advertising and Public Relations, for example displaying employees’ contact details and photographs on our website, or other professional social media websites and on other means of communication such as press releases;
• Legal and Regulatory Compliance, for example to ensure compliance with health and safety requirements and other legal or fiscal obligations, or in connection with litigation or an internal investigation or audit and to ensure compliance with our policies regarding anti-money laundering, bribery and corruption; and
• Ensuring compliance with our Code of Conduct, for example to ensure that we are living up to our values and, in particular for equal opportunities monitoring purposes.

We may also use PI for “Additional Business Purposes” in a context that is not a Sale or Share under the CCPA, such as:

• Disclosing it to S&B’s parent company which acts as our Service Provider pursuant to our intracompany data processing agreement;
• Disclosing it to our Service Providers or Contractors that perform services for us (“Vendors”);
• Disclosing it to you or to other parties at your direction or through your action (e.g., payroll processors, benefits providers, some software platform operators, etc.);
• For the additional purposes explained at the time of collection (such as in the applicable privacy policy or notice);
• As required or permitted by applicable law;
• To the government or private parties to comply with law or legal process or protect or enforce legal rights or obligations or prevent harm;
• Where we believe we need to in order to investigate, prevent or take action if we think someone might be using information for illegal activities, fraud, or in ways that may threaten someone’s safety or violate our policies or legal obligations; and
• To assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business (“Corporate Transaction”).

Subject to restrictions and obligations under the CCPA, our Vendors may also use your PI for Business Purposes and Additional Business Purposes, and may engage their own vendors to enable them to perform services for us.

(b) PI Collection, Disclosure, and Retention - By Category of PI

We collect, disclose, and retain PI as follows:

There may be additional information we collect that meets the definition of PI under the CCPA but is not reflected by a category above, in which case we will treat it as PI as required, but will not include it when we describe our practices by PI category.

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We will not attempt to reidentify data that we maintain as deidentified.

Because there are numerous types of PI in each category of PI, and various uses for each PI type, our retention periods vary for each of the categories of PI described above. The length of time for which we retain each category of PI depends on the purposes for our collection and use and requirements pursuant to applicable laws. In no event do we retain your PI for any longer than reasonably necessary to achieve the purposes for which it was collected or processed, or as required by applicable law. The criteria used to determine the retention period of PI includes the nature and sensitivity of the PI, the potential risk of harm from unauthorized use or disclosure of the PI, as well as applicable laws (such as applicable statutes of limitation).

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2. YOUR RIGHTS AND HOW TO EXERCISE THEM

California Personnel have the same rights to know/access, delete, correct, and opt-out as traditional Consumers and may learn more about these rights and how to exercise them in Section 2 of our California Privacy Notice here.

Right to Limit Use and Disclosure of Sensitive PI

We only Process Sensitive PI of Personnel for purposes that are exempt from choice under U.S. Privacy Laws.

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3. NON-DISCRIMINATION / NO RETALIATION

We will not discriminate or retaliate against you in a manner prohibited by the CCPA for your exercise of your privacy rights.

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4. NOTICE OF FINANCIAL INCENTIVE PROGRAMS

We do not currently offer discounts or rewards for providing us PI, or set price or service differences related to the collection, retention, Sale, or Sharing of PI. If we offer such programs in the future, we will update this Notice to describe such program(s), including how you may opt-in and how we value the PI required.

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5. OUR RIGHTS AND THE RIGHTS OF OTHERS

Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your rights under the CCPA. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.

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6. CONTACT US

If you have any questions, comments, or concerns about our HR privacy practices, please contact us by e-mail at privacypolicy@sbfoods.co.jp or by mail at S&B International Corporation, 21241 S. Western Ave., Suite 110, Torrance, CA 90501. Please note that e-mail communications will not necessarily be secure; accordingly, you should not include sensitive information in your e-mail correspondence with us.

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