Privacy Notice – Employees/ Applicants

Schwan’s Company and its subsidiaries (collectively, “Schwan’s” or “the Company”) are committed to protecting the privacy and security of all personal information. If you are a current or former Schwan’s employee, job applicant, contractor, or similar individual, this Privacy Notice describes the personal information that Schwan’s collects from or about you, and how the Company uses and to whom the Company discloses that information.

Who This Privacy Notice Applies To:

This Privacy Notice applies only to the personal information of individuals who seek to be, are, or were employed by, or a contractor for, the employing subsidiaries of Schwan’s Company (each, an “Individual”).

Personal Information Defined:

For the purpose of this Privacy Notice, personal information is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an Individual. Personal information does not include anonymous or non-personal information.

Personal Information Collected:

Listed below are the categories of personal information that Schwan’s may process about Individuals depending on the particular business purpose and the Individual’s role and/or relationship with Schwan’s:

• Identifiers, including real name, alias, postal address, unique personal identifiers, email, social security number, driver’s license number, account number, passport number or other similar identifiers. In this context, a “unique personal identifier” means a persistent identifier that can be used to recognize an Individual, or a device that is linked to an Individual, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, or similar technology; unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers.
• Characteristics of Protected Classifications, including the following: age, race, skin color, national origin, citizenship, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition, disability, military or veteran status, request for family care leave, request for leave for an Individual’s own serious health condition, and requests for pregnancy disability leave.
• Internet or Other Electronic Network Activity Information, including browsing history, search history, application access location and information regarding an Individual’s interaction with an internet website, application or advertisement, time and geolocation data related to use of an internet website, application or physical access to a Schwan office location.
• Professional or Employment-related Information (as applicable), including job related data, maintained as part of the employment relationship (if any) that is present in: job applications or resumes; background screening information; drug test results; references and interview notes; employment contracts; contractor agreements; policy acknowledgments and training records; performance reviews; disciplinary records; photos; information from expense reports; payroll and benefits related data; medical information, internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance.
• Education Information, including information about an Individual’s educational background, such as education records, report cards, and transcripts that is not publicly available.
• Inferences, including any information drawn from any of the personal information categories referenced above to create a profile about an Individual reflecting the Individual’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Purpose for Collecting Personal Information:

Schwan’s collects the personal information identified above for one or more of the reasons listed below (as applicable to the Individual and in the context of the Individual’s role and/or relationship with Schwan’s):

To fulfill or meet the purpose for which the Individual provided the information. For example, if an Individual shares their name and contact information to apply for a job or become an employed, Schwan’s will use that personal information in connection with such Individual’s employment or potential employment.

To recruit Individuals, including to conduct employment related background screening and checks.

To administer benefits, such as medical, dental, visual, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.

To pay and reimburse for expenses, including salary administration, payroll management, payment of expenses, and to administer other compensation related payments, including assigning amounts of bonus payments to Individuals.

To conduct performance-related reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring.

To monitor work-related licenses and credentials, including provisioning software licenses for use in the course of an Individual’s work-related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.

To provide applicable Individuals with Human Resources management services, including providing Individual data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.

To administer international assignments, including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration and filing obligations, and addressing health requirements.

To maintain Individual contact information, including altering Individual details across relevant entities within Schwan (for example personal, other employment and transferring roles).

To assist in case of emergency, including maintenance of contact details, and dependents in case of personal or business emergency.

To monitor eligibility to work in the U.S., which means monitoring and ensuring compliance of Individuals’ ability to work in the U.S.

To conduct healthcare-related services, including conducting pre-employment and employment-related medical screenings for return to work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of Individuals to plan and provide appropriate services, and including operation of sickness policies and procedures.

To facilitate a better working environment, which includes conducting staff surveys, providing senior management information about Individuals, and conducting training.

To ensure a safe and efficient working environment, which includes Schwan actions relating to disciplinary actions, and code of conduct processes and investigations.

To maintain security on Schwan websites and internet connected assets, which includes hosting and maintenance of computer systems and infrastructure; management of Schwan’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.

To comply with applicable law or regulatory requirements, such as legal (state and federal) and internal Company reporting obligations, including headcount, management information, demographic and Health, Safety, Security and Environmental reporting.

To evaluate or conduct a merger, divestiture, reorganization, dissolution, or other sale or transfer of some or all of Schwan’s assets.

Source of Personal Information:

Schwan’s obtains the categories of personal information listed above from the following sources:

Directly from the Individual. For example, from forms the Individual completes

Indirectly from the Individual. For example, from observing the Individual’s actions on our server

From third parties. For example, from recruiters who submit information about the Individual for an employment position and consumer reporting agencies for employment background checks

How Personal Information is Shared:

Schwan’s may disclose the personal information collected to a third party for a business purpose. Schwan’s discloses and shares personal information with the following categories of third parties:

Service providers

Third parties with whom the Individual directs Schwan’s to share the personal information

Third parties utilized as part of Schwan’s employment process, such as consumer reporting agencies for employment background checks

Disclosure of Personal Information for Business Purpose:

In the preceding twelve (12) months, Schwan’s has disclosed the following categories of Personal Information for a business purpose:

Identifiers

Characteristics of protected classes

Internet or other similar network activity

Professional or employment – related information

Education information

Inferences

Personal Information Retention Periods:

Except as otherwise permitted or required by applicable law or regulatory requirements, Schwan’s endeavors to retain personal information only for as long as it believes is necessary to fulfill the purpose for which the personal information was collected. Schwan’s may, instead of destroying or erasing personal information, make it anonymous such that it cannot be associated with or tracked back to the specific Individual.

Changes to this Privacy Notice:

Schwan’s may from time to time make changes to this Privacy Notice to reflect changes in its legal or regulatory obligations or in the manner in which Schwan’s deals with personal information. Any changes effective from the time they are communicated.