This policy explains:

• What information we collect during our application and recruitment process and why we collect it;
• How we use that information; and
• How to access and update that information.

Types of information we collect

This policy covers the information you share with us and/or which may be acquired or produced by Cheney Bros., Inc., its subsidiaries and its affiliates (the “Company”) during the application or recruitment process including:

• Your name, address, email address, telephone number and other contact information;
• Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process;
• Information from interviews and phone-screenings you may have, if any;
• Details of the type of employment for which you may be looking, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
• Details of how you heard about the position for which you are applying;
• Any sensitive and/or demographic information obtained during the application or recruitment process such as gender, information about your citizenship and/or nationality, medical or health information and/or your racial or ethnic origin;
• Reference information and/or information received from background checks (where applicable), including information provided by third parties;
• Information relating to any previous applications you may have made to the Company and/or any previous employment history with the Company;
• Information about your educational and professional background from publicly available sources, including, but not limited to, online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile); and/or
• Information related to any assessment you may take as part of the interview screening process.

How we use information we collect

Your information will be used by the Company for the purposes of carrying out its application and recruitment process which includes:

• Assessing your skills, qualifications and interests against our career opportunities;
• Verifying your information and carrying out reference checks and/or conducting background checks;
• Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at the Company;
• Creating and/or submitting reports as required under any local laws and/or regulations, where applicable;
• Where requested by you and deemed appropriate by the Company, assisting you with obtaining an immigration visa or work permit where required;
• Making improvements to the Company’s application and/or recruitment process;
• Complying with applicable laws, regulations, legal processes or enforceable governmental requests; and/or
• Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us.

We will also use your information to protect the rights and property of the Company, our customers, applicants, candidates, employees or the public as required or permitted by law.

If you are offered and accept employment with the Company, the information collected during the application and recruitment process may become part of your employment record.

We may also seek your consent to process your personal information in specific circumstances, or process it where necessary to comply with a legal obligation or for purposes connected to legal claims. If we use your information to improve our application or recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates.

Who may have access to your information

• Your information may be shared with our affiliates, subsidiaries or joint venturers in the US and in other jurisdictions, in relation to the purposes described above. If you have been referred for a job at the Company by a current Company employee, we may inform that employee about the progress of your application and let the Company employee know the outcome of the process. In some cases, if it is identified that you have attended the same university/school or shared the same previous employer during the same period as a current Company employee we may consult with that employee for feedback on you.
• The Company may also use service providers acting on the Company’s behalf to perform some of the services described above including for the purposes of the verification / background checks. These service providers may be located outside the country in which you live or the country where the position you have applied for is located.
• The Company may sometimes be required to disclose your information to external third parties such as to local labor authorities, courts and tribunals, regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.
• We will also share your personal information with other third parties if we have your consent, or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of the Company, customers, vendors, applicants, candidates, employees or the public or as otherwise required by law.
• It is your responsibility to obtain consent from those whom you refer to the Company before providing their personal information to the Company.

The Company takes appropriate steps to protect information about you that is collected, processed, and stored as part of the application and recruitment process.

Our retention of your information

If you apply for a job at the Company and your application is unsuccessful (or you withdraw from the process or decline our offer), the Company will retain your information for a period after your application. We retain this information for various reasons, including to comply with legal mandates or other legal matters, to consider you for other current or future jobs at the Company and to help us better understand, analyze and improve our recruitment processes.

If you do not want us to retain your information for consideration for other roles, or want us to update it, please contact Legal@CheneyBrothers.com.   Please note, however, that we may retain some information if required by law or as otherwise needed.

Your rights in respect of your information

In certain countries, you may have certain rights under data protection law. This may include the right to request access or to update or review your information, request that it be deleted or anonymized, or object to or restrict the Company using it for certain purposes.

If you wish to exercise a right of access please contact Legal@CheneyBrothers.com.  We will respond to any requests in accordance with applicable law, and so there may be circumstances where we are not able to comply with your request.

1. WHICH CATEGORIES OF PERSONAL INFORMATION DO WE PROCESS AND FROM WHICH SOURCES?

We process personal information that you provide directly to us, such as when you submit a job application online or at a recruiting event, or when we conduct a phone or in-person interview. We may also receive personal information about you from other sources, such as from persons you indicate as a reference, persons who referred you for a position, in connection with background or employment checks, and from third party recruitment sources, including, without limitation, social sites where you have created a public page or profile or otherwise given permission so that recruiters can access your information on these sites. They also can include vendor sites where you have been invited to participate in assessments, evaluations or online interviews.

2. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?

We use personal information for the following purposes:

• to communicate with you and respond to your requests or application
• for recruitment, evaluation, background screening and hiring purposes
• to analyze, develop and improve our recruiting activities and related products and services
• to maintain the security of our sites, systems and networks
• to comply with applicable laws and regulations and to operate our business

3. FOR HOW LONG DO WE RETAIN PERSONAL INFORMATION?

We generally maintain your personal information for the following retention periods:

• If you are hired as an employee of the Company, your information will be retained for as long as you remain an active employee and for a period of at least three (3) years thereafter. Some of your personal information may be deleted prior to three (3) years and some may be retained longer than three (3) years.
• If you have submitted an application but were not ultimately hired or withdrew your application from consideration, your personal information related to your application will generally be retained for up to one (1) year from the date you applied (unless a longer or shorter period is required by applicable law or Company policy).

To the extent permitted or required by law, or as requested by you, the Company may delete your personal information at any time. As a result, you should retain your own copy of any information you submit to us.

4. HOW IS YOUR PERSONAL INFORMATION SECURED?

The Company has implemented appropriate technical, physical and organizational measures designed to protect your personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.

5. WHAT ARE YOUR CHOICES?

Depending on your country or State of residence, you may have certain choices and rights in relation to our use of information about you, such as the right to access, correct and update, erase or delete, and obtain a copy of your personal information. Unless otherwise required by law, the Company may or may not accommodate such requests in its sole discretion.

6. DO WE COLLECT SENSITIVE PERSONAL INFORMATION?

We do not request or require and ask that you do not send us any sensitive personal information, such as details concerning racial or ethnic origin, religion or philosophical beliefs, health (except as permitted by law post job offer), sexual orientation, or political affiliation in connection with your job application and our recruiting efforts. To the extent information you do provide to us contains sensitive information, for example details of your racial or ethnic origin, political opinions or beliefs, religious beliefs, membership in a trade union or political party, physical or mental health or condition, sexual orientation, commission or alleged commission of an offense or related proceedings, job evaluations or educational records, you explicitly authorize us to process this personal information as described in this Privacy Policy.

If you have a disability or other situation for which you would like the Company to consider an accommodation, you should provide relevant information to the Human Resources Department during the recruiting/hiring process.

7. WHAT ARE YOUR RESPONSIBILITIES?

You are responsible for the personal information that you provide or make available to the Company, and you must ensure it is relevant, truthful, accurate, complete and not misleading in any way. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable. Further, if you provide any personal information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for the Company to collect and use that information as described in this Privacy Policy.