California Applicant Privacy Notice 2023
Effective Date: January 1, 2023
The purpose of this California Workforce Privacy Notice (“Workforce Privacy Notice”) is to inform Black Rifle Coffee Company (“BRCC,” “Company,” “us,” “we,” or “our”) California Workforce Members of our practices regarding the collection, use, and disclosure of their personal information (“Workforce Member Personal Information”), and the rights they have under the California Consumer Privacy Act, as amended (the “CCPA”). “Workforce Member” means all employment relationships, including current and former BRCC: full-time employees, part-time employees, temporary employees, interns, and contractors.
Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.
- How and Why We Collect, Use, and Disclose Your Workforce Member Personal Information
As used in this Workforce Privacy Notice, the term “Workforce Member 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 BRCC Workforce Members. Workforce Member Personal Information does not include information that is publicly available, de-identified, or aggregated, and the CCPA exempts certain additional categories of information from its purview, such as information subject to other laws and regulations. This Notice applies only to information governed by the CCPA.
BRCC may collect, use, and disclose Workforce Member Personal Information for business purposes consistent with applicable laws as identified below. Where BRCC discloses applicable Workforce Member Personal Information to recipients, such as our service providers, it does so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
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Category of Workforce Member Personal Information |
Business Purposes for Collection, Use, or Disclosure |
Categories of Recipients to whom Workforce Member Personal Information is Disclosed for a Business Purpose |
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Identifiers including real name, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, or other similar identifiers |
• To communicate with you • To assess your eligibility to work with us • To onboard and enroll you • To provide compensation and benefits • To comply with applicable laws and regulations • To manage the security of our premises and systems • To detect and prevent fraud against you and/or us |
• Data analytics providers • Benefits providers • 401(k) providers • Security providers • Background check vendors • Information technology vendors • Service providers • Affiliates |
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Personal Information described in Cal. Civ. Code § 1798.80(e), including your name, signature, social security number, 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, or other financial information, or health insurance information |
• To communicate with you • To assess your eligibility to work with us • To onboard and enroll you • To provide compensation and benefits • To comply with applicable laws and regulations • To manage the security of our premises and systems • To detect and prevent fraud against you and/or us |
• Data analytics providers • Benefits providers • 401(k) providers • Security providers • Background check vendors • Information technology vendors • Service providers • Affiliates |
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Characteristics of protected classifications under California or federal law, including age and date of birth, marital status, citizenship, race, ethnic origin, sex, gender, military or veteran status, medical condition, disability status |
• To comply with applicable laws and regulations • To onboard and enroll you
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• Benefits providers • Background check vendors • Service providers
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Internet or other electronic network activity information, including browsing and usage history, search history, and information regarding your interactions with our websites |
• To manage corporate information technology • To manage security • To detect and prevent fraud against you and/or us |
• Data analytics providers • Security providers • Information technology vendors • Service providers
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Commercial information, such as purchase history |
• To manage reimbursements |
• Service providers • Benefits providers |
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Geolocation data, including GPS data collected from your vehicle and location data inferred from your device IP address |
• To manage corporate information technology • To manage job duties, evaluate performance, and operate our business • To manage security • To detect and prevent fraud against you and/or us |
• Data analytics providers • Payroll and timekeeping providers • Information technology vendors • Service providers |
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Sensory information, including closed-circuit images, photographs and video of you (for ID badges, marketing materials, etc.) |
• To manage safety and security • To manage job duties, evaluate performance, and operate our business • To detect and prevent fraud against you and/or us |
• Data analytics providers • Security providers • Information technology vendors • Service providers |
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Professional or employment-related information, including: Recruitment information (such as skills, qualifications, references, recommendations, and other information included in a resume, application form, or cover letter) Background information commonly used for onboarding and security screenings Employment information (employee status, organization information, performance and talent information, employment background, functional experience, leadership experience, honors or awards, education, training, professional certifications, evaluations, developmental planning, career interests and development information, and other talent management and team-based assessments) Compensation, payroll, and benefits information Medical, parental, family, vacation, and other leave and associated records, including details of the types of and reasons for leave being taken, duration of leave, and leave-related correspondence Any termination of employment documentation, including resignation letters, dismissal letters, minutes of meetings, settlement agreements and related correspondence |
• To assess your eligibility to work with us • To onboard and enroll you • To manage job duties, evaluate performance, and operate our business • To provide compensation and benefits • To comply with applicable laws and regulations • To manage the security of our premises and systems • To detect and prevent fraud against you and/or us |
• Data analytics providers • Benefits providers • 401(k) providers • Security providers • Background check vendors • Information technology vendors • Service providers • Affiliates |
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Non-public education information, including school(s) attended, degrees obtained, and other information relating to your education |
• To assess your eligibility to work with us • To onboard and enroll you |
• Background check vendors • Service providers |
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Sensitive Workforce Member Personal Information, including social security, driver’s license, or state identification card number; precise geolocation (e.g., when using company vehicles); information that reveals racial or ethnic origin; and information collected and analyzed concerning your health (e.g., for insurance purposes) |
• To manage corporate information technology • To manage job duties, evaluate performance, and operate our business • To manage safety and security • To detect and prevent fraud against you and/or us • To onboard and enroll you • To provide compensation and benefits • To comply with applicable laws and regulations • To manage the security of our premises and systems |
• Benefits providers • Payroll and timekeeping providers • Security providers • Information technology vendors • Service providers • Background check vendors |
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Personal Information that does not directly fall within the categories listed in the CCPA, including immigration, visa status, and work authorization information, emergency contacts, languages spoken, criminal records information, withholdings and tax information, information about births, adoptions, deaths, child medical support orders, loss of eligibility for medical coverage, and other life events that may trigger an opportunity to modify your benefits elections, information about your health, sickness, and absences, and vehicle information for parking assignments. |
• To assess your eligibility to work with us • To onboard and enroll you • To manage job duties and operate our business • To provide compensation and benefits • To comply with applicable laws and regulations • To manage safety and security • To detect and prevent fraud against you and/or us |
• Benefits providers • Payroll and timekeeping providers • Security providers • Information technology vendors • Service providers |
In addition to the categories of Workforce Member personal Information above, we may also collect personal information that you submit to us on a voluntary basis which we would not otherwise request. For example, information on your CV or information you provide to us via email or other communications.
- Disclosing Your Workforce Member Personal Information
We may disclose each of the categories of Workforce Member Personal Information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the Workforce Member Personal Information was collected including, but not limited to:
- Helping to ensure security and integrity;
- Debugging, repairing, and improving functionality;
- Short-term, transient use;
- Performing services on our behalf;
- Internal research for technological development; and
- Verifying quality and/or safety.
In addition to the other purposes for collection, use, and disclosure of Workforce Member Personal Information described in this Workforce Member Notice, we may collect, use, and disclose Workforce Member Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose Workforce Member Personal Information to other parties in connection with a sale, assignment, merger, reorganization, or other transfer of our Company.
- Sources of Workforce Member Personal Information
We may collect the Workforce Member Personal Information identified above from the following sources:
- Directly from you. For example, during the onboarding process and throughout your interactions with us, including through our IT systems, company forms, human resources, and other processes where you submit information to us.
- Automatically when using our electronic systems. For example, we may collect your usage history when you use our websites, systems, and applications.
- Automatically when you visit our facilities. For example, security camera footage.
- From service providers that help us run our business. For example, from human resources and information technology vendors, background check agencies, benefits providers, and other service providers.
We may also collect publicly available information about you, including information that is lawfully made available to the general public from federal, state, or local government records.
- Selling or Sharing Your Workforce Member Personal Information
- We do not sell Workforce Member Personal Information or share it for cross-context behavioral advertising. If you also interact with us as a consumer, please review our California Consumer Privacy Notice here for more information about our practices in that context. We do not have actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age.
- How Long We Keep Your Workforce Member Personal Information
We generally maintain Workforce Member Personal Information according to our retention obligations and policies, operational business purposes, and other legal and regulatory requirements. We discard this Workforce Member Personal Information when reasonably practicable.
We keep the categories of Workforce Member Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
- Your Workforce Member Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected it;
- Your Workforce Member Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which it was collected;
- Your Workforce Member Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case);
- We are otherwise required or permitted to keep your Workforce Member Personal Information by applicable laws or regulations.
Where your Workforce Member Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires.
- Submitting Requests Relating to Your Workforce Member Personal Information
If you are a resident of California, you have the right to submit certain requests relating to your Workforce Member Personal Information as described below. To exercise any of these rights, please submit a request to customerservice@blackriflecoffee.com or call us toll free at 385-262-7184. Please note that if you submit a request to know, request to delete, or request to correct, you will be asked to provide two-to-three (2-3) pieces of Workforce Member Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.
Right to Know. You have the right to know what Workforce Member Personal Information we have collected about you, which includes:
- The categories of Workforce Member Personal Information we have collected about you, including:
- The categories of sources from which the Workforce Member Personal Information was collected;
- Our business purposes for collecting Workforce Member Personal Information;
- The categories of recipients to which we disclose Workforce Member Personal Information;
- The categories of Workforce Member Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Workforce Member Personal Information.
- The specific pieces of Workforce Member Personal Information we have collected about you.
Right to Delete Your Personal Information. You have the right to request that we delete Workforce Member Personal Information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe that Workforce Member Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Opt-Out of Sales and Sharing of Personal Information. We do not sell Workforce Member Personal Information or share it for cross-context behavioral advertising.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive Workforce Member Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us, including retaliation against you as an employee, job applicant, or independent contractor.
- How to Contact Us
If you have any questions about how BRCC handles your Workforce Member Personal Information or if you need to access this notice in an alternative format or language, please contact us at:
Email: customerservice@blackriflecoffee.com
Toll-free phone: 385-262-7184
