Last Updated: October 25, 2022

CCPA Notice at Collection for California EMPLOYEES, INDEPENDENT

MPL Brands NV, Inc. and/or MPL Brands, Inc. (collectively, “we” or “us”) provide the
following details regarding the Personal Information that we collect and use about
California residents in the context of their current, former, or potential role as our
employees, independent contractors, directors, or officers. This Privacy Notice also
applies to such individuals’ emergency contacts and benefits beneficiaries who are
residents of California.

Categories of Personal Information

We collect the following categories of Personal Information:
• Characteristics of protected classifications under California or federal law, such as
sex, age, race, religion, national origin, disability, medical conditions and
information, citizenship, immigration status and marital status
• Identifiers, such as name, signature, contact information, online identifiers, IP
address, and Social Security numbers and other government-issued ID numbers
• Demographic data, such as race, ethnic origin, marital status, disability, and
veteran or military status.
• Contact information, such as your home address, telephone numbers, email
addresses, and emergency contact information.
• Dependent’s or other individual’s information, such as their full name, address, date
of birth, and Social Security numbers (SSN).
• National identifiers, such as SSN, passport and visa information, and immigration
status and documentation.
• Educational and professional background, such as your work history, academic and
professional qualifications, educational records, references, and interview notes.
• Education information subject to the federal Family Educational Rights and Privacy
• Employment details, such as your job title, position, hire dates, compensation,
performance and disciplinary records, and vacation and sick leave records.
• Contract engagement details, such as your title, service dates, and amount of
contract or engagement.
• Financial information, such as banking details, tax information, payroll information, and withholdings.
• Health and Safety information, such as health conditions (if relevant to your
employment), job restrictions, workplace illness and injury information, and health
insurance policy information.
• Information Systems (IS) information, such as your search history, browsing
history, login information, and IP addresses on the Company’s information systems
and networks.
• Geolocation data, such as time and physical location related to use of an internet
website, application, device, or physical access to a Company office location.
• Sensory or surveillance information, such as COVID-19 related temperature checks
and call monitoring and video surveillance.
• Profile or summary about an applicant, employee, or independent contractor’s
preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.
• Audio, electronic, visual, and similar information, such as photographs or audio or
video recordings created in connection with our business activities.

Use of Personal Information
We use and disclose this Personal Information as appropriate to:
• Comply with all applicable laws and regulations.
• Recruit and evaluate job applicants and candidates for employment.
• Conduct background checks.
• Manage your employment relationship with us, including for onboarding processes;
timekeeping, payroll, and expense report administration; employee benefits
administration; employee training and development requirements; the creation,
maintenance, and security of your online employee accounts; reaching your
emergency contacts when needed, such as when you are not reachable or are
injured or ill; and/or workers’ compensation claims management.
• Evaluate independent contractors in deciding to engage in their services.
• Manage your contracting relationship with us, including for payment and benefits
administration, the creation, maintenance, and security of your online accounts,
reaching your emergency contacts when needed, such as when you are not
reachable or are injured or ill, employee job performance, including goals and
performance reviews, promotions, discipline, and termination, and/or other human
resources purposes.
• Manage and monitor employee and/or contractor access to company facilities, equipment, and systems.
• Conduct internal audits and workplace investigations.
• Investigate and enforce compliance with and potential breaches of Company
policies and procedures.
• Engage in corporate transactions requiring review of employee or independent
contractor records, such as for evaluating potential mergers and acquisitions of the
• Maintain commercial insurance policies and coverages, including for workers’
compensation and other liability insurance.
• Perform workforce analytics, data analytics, and benchmarking.
• Administer and maintain the Company’s operations, including for safety purposes.
• For client marketing purposes.
• Exercise or defend the legal rights of the Company and its employees, affiliates,
customers, contractors, and agents.
• Provide an efficient means for personnel to obtain the contact information of their
colleagues so they may contact them.
• Calculate insurance and other employee benefits.
• Maintain and secure our facilities, equipment, systems, and infrastructure.
• Undertake quality and safety assurance measures, protect the health and safety of
our workforce and others, and conduct risk and security control and monitoring.
• Conduct research, analytics, and data analysis to assist in planning succession and
to ensure business continuity, as well as to design employee retention programs
and diversity initiatives.
• Perform identity verification, accounting, audit, and other internal functions, such as
internal investigations.
• Monitor use of IT infrastructure, internet access, and electronic communication for
unauthorized, unlawful, or inappropriate use.
• Record phone calls for training, quality assurance, and legal compliance purposes.
• Operate and manage IT and communications systems and facilities, allocate
company assets and human resources, and undertake strategic planning and
project management.
• Obtain legal advice and establishing, exercising or defending legal rights, acting on
collection and discovery requests in the context of litigation, government
investigations or regulatory audits or inquiries.
• Comply with law, legal process, investigations, internal policies and other
requirements such as income tax deductions, monitoring, record-keeping and
reporting obligations.

Changes to this CCPA Notice
We may change or update this CCPA Notice from time to time. When we do, we will
post the revised Notice with a new “Last Updated” date.
If you have any questions about this Notice or need to access this Notice in an
alternative format due to having a disability, please contact [email protected] and