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Human Resources Privacy Notice for California Residents at Collection

Effective Date: January 1, 2024
Last Updated: March 12, 2024

Gold Medal Products Co. (“Gold Medal” or the “Company”) has implemented this Human Resources Privacy Notice for California Residents at the time of personal information collection (“HR Privacy Notice”) to describe the types of personal information we collect about California residents who are (1) Company employees, owners, directors, and officers (collectively, “Gold Medal Personnel”), (2) emergency contacts of Gold Medal Personnel, (3) individuals related to Gold Medal Personnel for whom Gold Medal administers benefits (collectively with Gold Medal Personnel, “HR Covered Individuals”), and (4) Gold Medal job applicants. This HR Privacy Notice supplements any other privacy policy implemented by the Company.

Gold Medal Personnel are responsible for providing this HR Privacy Notice to any HR Covered Individual whose personal information is provided to Gold Medal by Gold Medal Personnel. Certain terms in this Notice have the meanings given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).

If HR Covered Individuals have a disability, please click here for additional support. If this HR Privacy Notice is provided offline, please ask Gold Medal Personnel to provide the HR Privacy Policy in an alternative format to accommodate your disability.

We may also collect, use and share aggregated or deidentified information. Aggregated information and deidentified information could be derived from your personal information but is not considered personal information as this data will not directly or indirectly reveal your identity. Please note that CCPA requirements do not apply to aggregated or deidentified information.

Categories of Personal Information Collected

Gold Medal may have collected during the 12-month period prior to the Last Updated date of this HR Privacy Notice the following categories of Personal Information about HR Covered Individuals.

Category Examples Collected
A. Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other contact information. YES
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Signature, physical characteristics or description, social security number, state identification card number, insurance policy number, education, bank account number and information; credit card number and debit card number; and other financial information, medical information and health insurance information.

Some personal information included in this category may overlap with other categories.		 YES
C. Protected classification characteristics under California or federal law. Race, ethnic origin, religion, age, sex, gender, gender identify, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status. YES
D. Commercial information. Purchasing or consuming histories or tendencies. YES
E. Biometric information. Biometric data such as the facial recognition data, Iris recognition data or fingerprint recognition data. NO
F. Internet or other similar network activity. Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites or applications. YES
G. Geolocation data. GPS or Physical location or movements data. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES
I. Professional or employment-related information. Professional or employment-related information, such as your position, title, job description, department, contract details (if any), resume, recruitment history, application form; compensation and benefits information (e.g., salary-related information, tax-related information, benefits elections, and details regarding leaves of absence), disciplinary information, such as employee misconduct or misbehavior, evaluation records, such as your performance assessments and performance reviews, academic background, such as education history, completed transcript, certificates, professional associations, historic compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information, emergency contact information, marital status, dependent information, and beneficiary information, and securities holding information. YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other Personal Information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO
L. Sensitive Personal Information. Social security number, driver’s license, state identification card, or passport number, biometric information to uniquely identify an employee, race, ethnic origin, religious beliefs, and sexual orientation, contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. YES

 

The Purpose for the Personal Information Collected and Used

Gold Medal may have collected or used Personal Information and Sensitive Personal Information during the 12-month period prior to the Last Updated date of this HR Privacy Notice for the purpose of carrying out and supporting HR functions and activities, including the uses described below. In addition to general HR purposes, we list below relevant “business purposes” as they are described in the CCPA.

•  Business Purpose

  • Accommodating disabilities or illnesses.
  • Administering payroll services, reimbursing expenses, and health, dental, or other benefits.
  • Allocating and managing Company assets and human resources for strategic planning and Project management.
  • Background screening for onboarding.
  • Carrying out obligations under employment contracts.
  • Compiling audit trails and other reporting tools for conducting audits.
  • Complying with legal requirements, such as tax, record keeping and reporting obligations.
  • Complying with requests from government or other public authorities.
  • Conducting investigations and complying with internal policies and procedures.
  • Creating staff directories.
  • Detecting or preventing theft fraud, or attempted theft or fraud; and facilitating communication with you and your designated contacts in an emergency.
  • Determining physical and or mental illness fitness for work.
  • Determining suitability for employment, promotion, or eligibility of salary increases and bonuses.
  • Developing and maintaining compensation and benefit programs.
  • Ensuring business continuity.
  • Facilitating, processing or fulfilling transactions, and processing payments of HR Covered Individuals.
  • Facilitating employee relocations and international assignments and arranging business travel.
  • Maintaining records relating to business activities, budgeting, and financial management.
  • Managing mergers, acquisitions, sales, reorganizations or disposals and integration with business partners.
  • Managing the onboarding of company personnel.
  • Managing work activities and personnel generally, including recruiting.
  • Performing services, including maintaining or servicing accounts, providing customer service.
  • Processing and assessing job applications.
  • Protecting and managing the health and safety and the rights of Gold Medal Personnel, HR Covered Individuals, and others.
  • Providing access to Gold Medal facilities and computer networks, employee profiles and internal intranet employee directories.
  • Pursuing legal rights and remedies and defending against litigation and managing internal complaints or claims.
  • Responding to legal process such as subpoenas and court orders.
  • Reviewing and evaluating performance.
  • Safeguarding, monitoring, improving and maintaining our IT infrastructure, communications infrastructure, office equipment, facilities, and other property and providing Technical Support.
  • Secured immigration statuses.
  • Training, talent development, performance appraisals and onboarding.
  • Work planning, managing communications, and relations with HR Covered Individuals.

 

•  Consent
We rely on your consent to disclose or transfer your Sensitive Personal Information for the following purposes:

  • Race and religious beliefs data and sexual orientation data
    • To provide equal opportunities and diversity.
    • For statistical purposes of improving our work force and employment practices.
  • Social security number, driver’s license state identification, and passport data
    • To verify the HR Covered Individual’s identity for employment opportunities.
    • To complying with legal requirements, such as tax, labor and employment law and regulations, and applicable regulations.
  • Biometrics data
    • To verify the HR Covered Individual’s identity for safeguarding, monitoring, and maintaining our IT infrastructure, information security, communications infrastructure, office equipment, and facilities.

 

The Company does not collect or process Personal Information or Sensitive Personal Information with the purpose of inferring characteristics about HR Covered Individuals.

The withdrawal of consent will not affect the lawfulness of the collection, use, and/or disclosure of your Sensitive Personal Information based on your consent before it was withdrawn. Further, the Company will not retaliate against any employees for the withdrawal of their consent.

Sources of Personal Information

During the 12-month period prior to the last updated date of this HR Privacy Notice, the Company may have obtained personal information about HR Covered Individuals from the following categories of sources:

  • Directly from you.
  • Your devices.
  • From your colleagues in the form of performance assessment and feedback.
  • Our affiliates and subsidiaries.
  • Service providers, contractors and other vendors who provide services on our behalf.
  • Customers or business partners who provide information about you in the form of feedback.
  • Operator systems and platforms.
  • Government entities.
  • Social media networks.

Disclosure of Personal Information

During the 12-month period prior to the last updated date of this HR Privacy Notice, the Company may have disclosed the following categories of personal information about you for a business purpose:

  • Category A: Identifiers
  • Category B: Personal Information categories listed in the California Customer Records statute
  • Category C: Protected classification characteristics under California or federal law
  • Category D: Commercial information

We may disclose the categories of personal information to our parent company or affiliates for business purposes. We may also disclose these categories to service providers and subcontractors who provide payment processing, shipping, information technology, software as a service, software, marketing, web design, cloud hosting, human resources, insurance, and payroll facilitation services on the Company’s behalf.

In addition to the categories of third parties identified above, during the 12-month period prior to the last updated date of this Privacy Notice, we may have disclosed personal information about HR Covered individuals to government entities and third parties in connection with corporate transactions, such as mergers acquisitions or divestitures.

The Company does not sell (as defined by the CCPA) or share for cross-context behavioral advertising purposes personal information about HR Covered Individuals. We do not share any information about Gold Medal Personnel or any other HR Covered Individuals with any other third parties other than as needed for the business purposes stated above.

Retention of Personal Information

We will retain your personal information as reasonably necessary for the disclosed purpose. The retention periods for each category of personal information, including sensitive information, vary depending on compliance with relevant laws, your request for deletion, and our retention policies. For example, we may need to retrain your personal information to comply with our legal or reporting obligations in accordance with the laws or to defend against claims. Consequently, it is not possible for us to provide a definitive length of time. Our retention periods are determined by using and balancing the following criteria:

  • The volume, nature, and sensitivity of your information;
  • The potential risk of unauthorized access, use or disclosure, or misappropriation;
  • The purposes for which we process your personal information; and
  • The retention obligations under applicable legal requirements.

Cookies and Automatic Data Collection Technologies

Our website may use automatic data collection technologies to distinguish you from other website users. This helps us deliver a better and more personalized experience when you browse our website. It also allows us to improve our website by enabling us to:

  • Estimate our visitor traffic and usage patterns.
  • Store your preferences, so we may customize our website according to your individual interests.
  • Recognize you when you return to our website.

For more information, please visit our Cookie Policy.

California Consumer Privacy Rights

If you are an HR Covered Individual, you have certain choices regarding your personal information as described below.

Right to know

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Once we verify your request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or shared your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that the recipient purchased; and disclosures for a business purpose, identifying the personal information categories that recipient obtained.
Right to obtain a copy of your personal information

You have a right to obtain a copy of the specific pieces of personal information we collected about you (also called a data portability request). Once we verify your request, we will provide you with a copy of your personal information that is responsive to your request.

Your right to correct inaccurate personal information

You have the right to request us to correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Once we receive a verifiable consumer request, we will process your request.

Right to deletion of your personal information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Your right to opt-out of Selling or Sharing your information

You have the right to opt-out from having your personal information sold or shared for targeted advertising purposes. However, we do not sell or share personal information for cross-context behavioral advertising purposes with third parties.

Right to Not be discriminated

Company will not discriminate against you for exercising any of your CCPA rights. You have a right not to receive discriminatory treatment by us for exercising your privacy rights. Discriminatory treatment under the CCPA includes but not limited to the Company (a) denying goods or services to you; (b) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing a different level or quality of goods or services; (d) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

We will not retaliate against an employee, applicant for employment, or independent contractor for exercising their CCPA rights.

Opt-out preference signals

Opt-out preference signals or Global Privacy Controls (GPC) provide consumers with a simple and easy-to-use method by which consumers interacting with us online can automatically exercise their opt-out of sale/sharing rights. Because we do not sell your personal information or share it for targeted advertising purposes, we are not required to implement an opt-out preference signal for Covered HR Individuals.

How to exercise your CCPA rights

To exercise your CCPA rights, please submit your request to us by contacting us at (800)-543-0862 or provide your request at Your Privacy Choices.

How Company verifies requests and respond to requests

Before fulfilling your request, we take steps to verify that you are who you say you are or you have the authority to act on someone else’s behalf. Therefore, upon receipt of your request, we may request additional information that we need to verify you and, if you are submitting a request on behalf of someone else, to verify that you are permitted to act on that person’s behalf.

When we contact you to request verification information, please respond and provide the information that we have requested. Depending on the nature of your request, we will verify your identity to either a reasonable or high degree of certainty. This may mean that we need to match two or three pieces of information that we hold about you with information that you provide to us.

In addition to providing the information we need to verify you or your authority, you must provide us with enough information so that we can understand, evaluate, and respond to your request. We cannot respond to your request or provide you with personal information if we cannot confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request and to locate relevant information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and to understand, evaluate, and respond to your request.

We cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.

Who may submit requests

You, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. You may designate an authorized agent to make a request on your behalf by registering such person or entity with the California Secretary of State.

How often can you submit requests

You may make a CCPA consumer request twice within a 12-month period.

Response timing and format

We will attempt to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require an additional forty-five (45) days to respond to your request. We will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. When you request a copy of your personal information, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity easily.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide a cost estimate before completing your request.

Notice of financial incentives

We do not offer financial incentives or pricing discounts for providing your personal information or registering an account with us.

Children’s information

Our website is not intended for children nor do we employ individuals under 16 years of age. We will not knowingly solicit or collect personal information from children under 16, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law. If we learn that we have received information directly from a child under 16 without his or her parent’s or legal guardian’s consent, we will make commercially reasonable efforts to delete such information.

Personal information security

The security of your personal information is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal information from loss, misuse and unauthorized access, use, alteration, or disclosure. We will only retain your personal information for as long as reasonably necessary to fulfill the purpose of collecting it.

We also require our service providers and business partners to whom we disclose the information to do the same. When you use certain types of information, for example, we encrypt the transmission of certain sensitive or financial information using secure socket layer technology (SSL). We will continue to improve our physical, electronic, and administrative safeguards. However, the Internet environment is not 100% secure, and we cannot guarantee that information we collect will never be accessed in an unauthorized way.

Contact Information

If you have any questions or feedback about our HR Privacy Notice or practices, your privacy choices, or wish to exercise your CCPA rights, please contact:

Attn: Human Resources Department
Gold Medal Products Co.
10700 Medallion Drive
Cincinnati, OH 45247

Toll Free: 1-800-543-0862
Email: [email protected]
Web Form: Click Your Privacy Choices to submit your CCPA consumer request.

Changes to this HR Privacy Notice

Nothing in this HR Privacy Notice alters your at-will employment relationship with the Company or forms a contract for employment. The Company may update this HR Privacy Notice from time to time. If there are material changes to how we collect, use, or disclose your personal information, we will notify you of the most recent version of the HR Privacy Notice. It is recommended that you periodically revisit this page for the latest version of the Privacy Policy.