LAST UPDATED: December 31, 2025

CALIFORNIA EMPLOYEE / CONTRACTOR / APPLICANT PRIVACY POLICY

Ventura Foods, LLC, and its affiliates (collectively, “Company,” “we,” or “us”) value the trust of our employees, contractors and applicants and endeavor to protect the privacy of their personal information. The purpose of this California Employee/Contractor/Applicant Privacy Policy (the “Policy”) is to notify California residents (“you”) of the processing of information that can reasonably be linked with them and that we collect, use, retain, and disclose in the context of their current, former or potential role as our employees, contractors or applicants (“Personal Information”).

If you are an employee, the Policy also applies to the beneficiaries of your employment benefits, such as the individuals who are on your health plan and the beneficiaries of your retirement accounts, as well as your emergency contacts. It is your responsibility to inform any such individuals about this Policy and ensure that you have the right to provide their Personal Information to us.

NOTICE AT COLLECTION

Collection and Disclosure of Personal Information

The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business and employment purposes, including within the 12 months preceding the date this Policy was last updated.

Categories of Personal Information Disclosed to Which Categories of Third Parties
for Operational Business Purposes
Identifiers, such as name, alias, postal address, unique personal identifiers, IP address that can reasonably be linked or associated with a particular California resident or household, email address, account name, online identifiers, photo badges, beneficiary designations and government-issued identifiers (e.g., Social Security number, driver’s license number, passport number) Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Personal information as defined in the California customer records law, such as name, contact information, signature, Social Security number, passport number; medical, insurance, financial, education and employment information, physical characteristics or description Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Protected Class Information, such as characteristics of protected classifications under California or federal law, such as sex, age, gender, race, disability, medical conditions, citizenship, military/veteran status, gender identity and expression, primary language, political affiliation/activities, immigration status, marital status, and requests for leave Our affiliates; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Commercial Information, such as transaction information and purchase history, such as travel expenses, including information about corporate credit card purchases, frequent flyer rewards, and other travel-related programs and expenses Our affiliates; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Biometric Information, such as fingerprints, voiceprints, faceprints, and iris or retina scans Our affiliates; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Internet or network activity information, such as access and usage information regarding websites, applications and systems, information about online communications, including browsing and search history, timestamp information, and access and activity logs Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Geolocation Data, such as device location, Company-owned vehicle location, and approximate location derived from IP address, or GPS, Wi-Fi or BLE (Bluetooth Low Energy) tracking Our affiliates; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Audio/Video Data. Audio, electronic, visual and similar business related information, such as call and video recordings, including voicemail and security camera footage, information about the use of electronic devices and systems, key card usage, and photos on websites or in personnel directories Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Education Information subject to the federal Family Educational Rights and Privacy Act such as student transcripts, grade point average, grades, academic standing and disciplinary records, confirmation of graduation Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Employment Information. Professional or employment-related information, such as work history and prior employer, information from reference checks, background screening information, employment application, membership in professional organizations, personnel files, personal qualifications and training, eligibility for promotions and other career-related information, work preferences, business expenses, wage and payroll information, benefit information, information on leaves of absence or PTO, performance reviews, information on internal investigations or disciplinary actions Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, characteristics, predispositions, and abilities Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Sensitive Personal Information.

  • Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, or union membership; the contents of mail, email, and text messages unless Company is the intended recipient of the communication; genetic data;
  • The processing of biometric information for the purpose of uniquely identifying an individual;
  • Personal Information collected and analyzed concerning an individual’s health;
  • Personal Information collected and analyzed concerning an individual’s sex life or sexual orientation;
  • Personal Information collected from a known child.
 Our affiliates; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other similar business related services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners

We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Without limiting the foregoing, we do not “sell” or “share” the Personal Information, including the Sensitive Personal Information, of minors under 16 years of age. Without limiting the foregoing, we do not collect any consumer neural data.

Purposes for the Collection, Use, and Disclosure of Personal Information

We collect, use, and disclose Personal Information for the purposes of operating, managing, and maintaining our business, managing our workforce and other employment purposes, and accomplishing our business purposes and objectives, including, for example, using Personal Information to:

  • Plan and manage workforce activities and personnel generally, including for recruitment, onboarding, appropriate staffing, performance management, training and career development, payments and benefit administration, training, leaves and promotions;
  • Conduct workforce assessments, including determining physical or mental fitness for work and evaluating work performance;
  • Process payroll, manage wages and other awards such as stock options, stock grants and bonuses, reimburse expenses and provide healthcare, pensions, savings plans and other benefits;
  • Operate, maintain, monitor and secure our facilities, equipment, systems, networks, applications and infrastructure;
  • Manage attendance, time keeping, leaves of absence and vacation;
  • Facilitate communication and workforce travel;
  • Disclose Personal Information to our service providers and providers of the benefits we offer to our employees to enable them to provide services to us and to provide benefits to our employees and their beneficiaries;
  • Disclose Personal Information at the request of our personnel and former personnel to provide employment verification to third parties;
  • 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, such as to assist in succession planning and to ensure business continuity, as well as to design retention programs and diversity initiatives;
  • Perform identity verification, accounting, budgeting, audit, and other internal functions, such as internal investigations, disciplinary matters and handling grievances and terminations;
  • Operate and manage IT and communications systems and facilities, allocate Company assets and human resources, and undertake strategic planning and project management;
  • Receive and process job applications;
  • Manage the candidate selection process;
  • Evaluate your suitability for the position(s) you are applying for;
  • Communicate with you about your application, respond to your inquiries, and notify you of applicable terms and policies;
  • Conduct reference checks;
  • Conduct background checks, consistent with applicable law;
  • Disclose Personal Information to our service providers to enable them to provide services to us such as information technology and related infrastructure provision, email delivery, auditing, and other services;
  • Analyze and monitor the diversity of job applicants, in accordance with applicable law;
  • Subject to our discretion, make an offer to enter into an employment contract;
  • Contact you about future career opportunities;
  • Fulfill administrative functions, such as aggregate management reporting, statistical analyses, internal training, and as generally required to conduct our business; and
  • Comply with law, legal process, requests from governmental or regulatory authorities, internal policies and other requirements such as income tax deductions, record-keeping, work permit, equal employment opportunity laws, and immigration regulations and reporting obligations, and the exercise or defense of legal claims.

Purposes for the Collection, Use, and Disclosure of Sensitive Personal Information

We collect, use, and disclose Sensitive Personal Information for purposes of: performing services on behalf of our business; performing services and providing goods as requested by you; ensuring the quality or safety of services we control or improving those services; ensuring the security and integrity of our infrastructure and the individuals we interact with; receiving and processing your job application, evaluating your suitability for the position(s) you are applying for, making an offer (subject to our discretion), establishing and maintaining your employment relationship with us; managing payroll and corporate credit card use; administering and providing benefits; short-term transient use; securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure; preventing, detecting, and investigating security incidents; resisting and responding to fraud or illegal activities; and other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use or disclose Sensitive Personal Information for additional purposes.

Retention Period

We retain each category of Personal Information including, without limitation, Sensitive Personal Information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

  • The duration of the job application process;
  • Whether your job application is successful and you become an employee;
  • Whether, if your application is not successful, you would like to be notified of future job opportunities with us or our affiliates;
  • The duration of your employment or your contract with us;
  • The length of time we have an ongoing relationship with you or your dependents/beneficiaries and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
  • Whether there is a legal obligation to which we are subject (for example, certain laws may require us to keep your records for a certain period of time); and
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Sources of Personal Information

We collect this Personal Information from you and from our affiliates, your colleagues and managers, references you provide, prior employers or schools, clients, background check providers, providers of benefits, social media networks, publicly available databases, and cooperative databases.

Individual Rights and Requests

You may, subject to applicable law, make the following requests:

  1. You may request that we disclose to you the following information:
    1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
    2. The business or commercial purpose for collecting Personal Information about you; and
    3. The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).
  2. You may request to correct inaccuracies in your Personal Information.
  3. You may request to have your Personal Information deleted.
  4. You may request to receive the specific pieces of your Personal Information, including a copy of the Personal Information you provided to us in a portable format.
  5. You may request that we limit the use and disclosure of your Sensitive Personal Information.

We will not unlawfully retaliate against you for making an individual request. To make a request, please complete the CPRA Rights Request Intake Form or contact us at [email protected] or 1-877- VENTURA (1-877-836-8872). We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as California drivers’ license in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Individual Rights and Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Rights and Requests” or confirm that you provided the agent permission to submit the request.

Diversity

In certain cases we will ask questions about race/ethnic origin, gender, and disability of our job applicants, to comply with equal opportunity laws and reporting requirements. We may also inquire about criminal records, where permitted by applicable law. Otherwise, we ask that you avoid submitting information that may qualify as sensitive information under applicable law, except where such information is legally required. We are an equal opportunity employer, which means we offer equal treatment to all job applicants consistent with applicable law. We do not unlawfully discriminate, either directly or indirectly, based on characteristics protected by applicable law, such as: race, ethnicity, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status or genetic information in any area of recruitment.

Applicant Obligations

Any information you submit to us must be true, complete and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your job application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights. If you provide us with Personal Information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

Changes to this Policy

We may change or update this Policy from time to time. When we do, we will communicate changes and updates to this Policy by sending an updated Policy to you via email or posting the updated Policy on the website with a new “Last Updated” date.

Contact Us

Please contact us at [email protected] or your local HR representative if you have any questions regarding this Policy.