APPLICANT NOTICE ABOUT YOUR PERSONAL INFORMATION

1. Overview

This Notice explains your rights under the California Consumer Privacy Act (“CCPA”) (Cal. Civ. Code § 1798.100 et seq.) and helps you understand how Markstein Beverage Co. of Sacramento (“MBCS”) collects and uses your Personal Information in compliance with the CCPA. In this Notice, the terms “company,” ”us,” “we,” and “our” refer to MBCS and its affiliates and subsidiaries. “Applicant” or “you” refer to job applicants or candidates for employment with MBCS.

1. What Information We Collect

MBCS collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). The following discusses the categories of Personal Information we collected about our Applicants (from the application through date of hire, if applicable) in the last twelve (12) months. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different purposes without first providing you notice.

• Identifiers. We collect your name, driver’s license, signature, email address, phone number, and mailing address from you during our recruitment process. We may also collect personal identifiers about your emergency contacts, if you provide this information during the recruitment process.
• Audio, Visual, or Similar Information. We collect information from you that may be used to identify you to our employees, such as your photograph.
• Biometric Information. We collect biological characteristics about you during employment physical screenings. For individuals applying for driver positions, this information may include sleep, health, and exercise data as required by Department of Transportation regulations.
• Communication Data. We may collect text messages, phone calls, or audio messages, which may identify you, if you use these methods to contact us during the onboarding process.
• Characteristics of Protected Classifications Under California or Federal law. We may collect your date of birth, age, gender identity, racial or ethnic origin, veteran status, disability information, genetic information, or marital status if you include this information in your application. Additionally, we may collect other information voluntarily provided during the application process, including sexual orientation or pregnancy and related information.
• Professional or Employment-related Information. We collect information related to your employment history during the recruitment process. We will not request or collect your salary history information during the application process.
• Education Information. We collect your education history from you as part of your application.
• Medical Information. We may collect information about physical screenings or drug test results, if your position required such screenings or testing.

1. How We Use the Information We Collect

We use the Personal Information we collect for the following business and commercial purposes:

• Recruiting and Hiring. We use the Personal Information we collect from your application and through the interview process to evaluate your qualifications and eligibility for employment.
• Physical Screenings. Our Applicants are given an offer of employment contingent on the completion of a physical to ensure the Applicant’s functional capabilities meet the physical requirements of the job.
• Background Checks. After receiving a conditional offer of employment, we require our Applicants to complete a background check to verify your identity, check for criminal history, and confirm the validity of your application.

1. Additional Rights under California Law

At this time, the CCPA does not afford you the right to make requests regarding your Personal Information. MBCS will inform you about any policies and procedures related to such rights if they become available. This does not affect other rights you may have under the California Labor Code or similar laws.

1. How We Retain Your Personal Information

To the extent permitted by applicable law, MBCS will retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or other reporting requirements or obligations.

1. How You Are Protected Against Discrimination

MBCS will not unlawfully discriminate against you for exercising any of your rights under the CCPA. This commitment applies to all persons involved in our operations and prohibits unlawful discrimination by any employee of MBCS, including supervisors and coworkers.

1. Disclaimer

Nothing in this Notice restricts MBCS’s ability to:

• Comply with federal, state, or local laws;
• Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
• Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
• Exercise or defend legal claims;
• Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
• Transfer Personal Information as part of a merger or acquisition, dissolution or in the event of bankruptcy or any other transaction in which a third party assumes control of all or part of MBCS.

1. Changes to this Notice

This Notice is reviewed and updated annually to ensure it accurately captures our practices and procedures. The effective date of this version is posted below.

1. Resolving Concerns and How to Contact Us

If you have questions or concerns regarding this Notice or the handling of your Personal Information, please contact us at CCPA@marksteinbev.com or 916-920-9070.

EFFECTIVE DATE: February 17, 2021

APPLICANT NOTICE ABOUT YOUR PERSONAL INFORMATION

1. Overview

This Notice explains your rights under the California Consumer Privacy Act (“CCPA”) (Cal. Civ. Code § 1798.100 et seq.) and helps you understand how Markstein Beverage Co. of Sacramento (“MBCS”) collects and uses your Personal Information in compliance with the CCPA. In this Notice, the terms “company,” ”us,” “we,” and “our” refer to MBCS and its affiliates and subsidiaries. “Applicant” or “you” refer to job applicants or candidates for employment with MBCS.

1. What Information We Collect

MBCS collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). The following discusses the categories of Personal Information we collected about our Applicants (from the application through date of hire, if applicable) in the last twelve (12) months. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different purposes without first providing you notice.

• Identifiers. We collect your name, driver’s license, signature, email address, phone number, and mailing address from you during our recruitment process. We may also collect personal identifiers about your emergency contacts, if you provide this information during the recruitment process.
• Audio, Visual, or Similar Information. We collect information from you that may be used to identify you to our employees, such as your photograph.
• Biometric Information. We collect biological characteristics about you during employment physical screenings. For individuals applying for driver positions, this information may include sleep, health, and exercise data as required by Department of Transportation regulations.
• Communication Data. We may collect text messages, phone calls, or audio messages, which may identify you, if you use these methods to contact us during the onboarding process.
• Characteristics of Protected Classifications Under California or Federal law. We may collect your date of birth, age, gender identity, racial or ethnic origin, veteran status, disability information, genetic information, or marital status if you include this information in your application. Additionally, we may collect other information voluntarily provided during the application process, including sexual orientation or pregnancy and related information.
• Professional or Employment-related Information. We collect information related to your employment history during the recruitment process. We will not request or collect your salary history information during the application process.
• Education Information. We collect your education history from you as part of your application.
• Medical Information. We may collect information about physical screenings or drug test results, if your position required such screenings or testing.

1. How We Use the Information We Collect

We use the Personal Information we collect for the following business and commercial purposes:

• Recruiting and Hiring. We use the Personal Information we collect from your application and through the interview process to evaluate your qualifications and eligibility for employment.
• Physical Screenings. Our Applicants are given an offer of employment contingent on the completion of a physical to ensure the Applicant’s functional capabilities meet the physical requirements of the job.
• Background Checks. After receiving a conditional offer of employment, we require our Applicants to complete a background check to verify your identity, check for criminal history, and confirm the validity of your application.

1. Additional Rights under California Law

At this time, the CCPA does not afford you the right to make requests regarding your Personal Information. MBCS will inform you about any policies and procedures related to such rights if they become available. This does not affect other rights you may have under the California Labor Code or similar laws.

1. How We Retain Your Personal Information

To the extent permitted by applicable law, MBCS will retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or other reporting requirements or obligations.

1. How You Are Protected Against Discrimination

MBCS will not unlawfully discriminate against you for exercising any of your rights under the CCPA. This commitment applies to all persons involved in our operations and prohibits unlawful discrimination by any employee of MBCS, including supervisors and coworkers.

1. Disclaimer

Nothing in this Notice restricts MBCS’s ability to:

• Comply with federal, state, or local laws;
• Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
• Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
• Exercise or defend legal claims;
• Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
• Transfer Personal Information as part of a merger or acquisition, dissolution or in the event of bankruptcy or any other transaction in which a third party assumes control of all or part of MBCS.

1. Changes to this Notice

This Notice is reviewed and updated annually to ensure it accurately captures our practices and procedures. The effective date of this version is posted below.

1. Resolving Concerns and How to Contact Us

If you have questions or concerns regarding this Notice or the handling of your Personal Information, please contact us at CCPA@marksteinbev.com or 916-920-9070.

EFFECTIVE DATE: February 17, 2021