Kleinfelder Employment and Applicant Privacy Notice

Latest Revision Date: 2/11/2025

Kleinfelder Inc., its affiliates and /subsidiaries (“Kleinfelder,” “we,” “us,” or “our“) are providing the following details regarding the Personal Information that we collect and use in the /context of current, former or potential role as our employees, contractors, owners, directors, officers, interns, or job applicants (collectively, “covered individuals“). We may not collect each category of Personal Information identified below about all covered individuals.

Kleinfelder respects the privacy rights of individuals and is committed to handling Personal Information responsibly and in accordance with applicable law. This Privacy Notice sets out the Personal Information that we may collect and process about you, the purposes of the processing, and the rights that you have in connection with it.

This Privacy Notice sets forth Kleinfelder’s standard on how it protects Personal Information. In some cases, the jurisdiction where you reside may require different levels of protection, and in such an instance we will handle your Personal Information in accordance with applicable laws and regulations at the location where the information is collected and processed. Where applicable local law provides a lower level of protection than that established by this Privacy Notice, we will still strive to meet the standard of this Privacy Notice.

Please take the time to thoroughly review this Privacy Notice, which should be read in conjunction with our other corporate policies and procedures. When appropriate, we will provide a “just in time” notice to cover any additional processing activities not mentioned in this document.

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

Categories of Personal Information We Collect

The Personal Information that we collect about covered individuals will depend on, for example, our relationship or interaction with that individual. Personal Information is information that identifies, relates to, or could reasonably be linked with you or your household.

During the past 12 months, we have collected the following categories of Personal Information:

Personal Identifiers — Personal unique identifiers, such as full name and federal or state issued identification numbers including Social Security number, driver’s license number, and/or passport number.

Personal Data — Personal information, including contact details (e.g., telephone number and address), financial information (e.g., account number), payment card details (e.g., credit and debit card numbers), and medical and health insurance information.

Characteristics of Protected Classes — Information concerning protected classes or groups as defined by state or federal law, such as sex, disability, citizenship, primary language, immigration status, and marital status.

Commercial information — Information such as transaction and purchase history, including travel expenses and information about corporate credit card purchases.

Biometric Information — Information, such as fingerprints and voiceprint.

Internet or Online Information — Information concerning internet browsing history and information regarding interaction with Kleinfelder’s websites, applications, or advertisements.

Geolocation Data — Geographic information, such as device location.

Audio and Visual Information — Audio, electronic, visual, thermal, or similar information, such as call and video recording.

Professional or employment information — Information including work history, education information subject to the federal Family Educational Rights and Privacy Act, student records, confirmation of graduation, prior employer, references, background checks, resumes, details of qualifications, safety record, agility, skills, experience, human resources data,  data necessary for benefits, and related administration services.

Inferences — Information about an individual, which is used to create a summary about, for example, an individual’s preferences and characteristics.

Sensitive Personal Information — A subtype of personal information, which may include:

• 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, or immigration status.
• The contents of mail, email, and text messages unless we are the intended recipient of the communication.
• Biometric information processed to uniquely identify an individual.
• Health information or sexual orientation.

Certain types of information may be subject to additional requirements under applicable laws. Data protection laws around the world may use varying terminology in naming these categories of sensitive data (such as “Special Categories of Personal Data” or “Sensitive Personal Information”), and also set requirements for companies to follow in their processing of such sensitive data. We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes, without providing appropriate and advance notice to you.

Our Sources of Personal Information

We collect Personal Information directly from you and from our affiliates, your colleagues and managers, references you provide, recruiting firms, prior employers or schools, clients, private and government screening, background check providers, results of screening or random substance testing, providers of employee benefits, social networks, publicly available databases, court orders, government inquiries or communications, and cooperative databases.

Our Purposes for Collection and Use of Personal Information

We will collect, use, and process your Personal Information in connection with conducting our application, recruitment, employment, termination, and on-boarding processes (as applicable), including to:

• Process and review your job application, including any cover letter, resume, and/or references.
• Consider you for employment opportunities and assess your skills, qualifications, and interests for a particular position.
• Contact you if we need more information related to your application or respond to questions from you.
• Schedule and/or conduct an interview with you.
• Facilitate or reimburse you for any travel.
• Provide you with compensation and benefits.
• Manage and develop your performance.
• Verify your information and conduct employment, background, and reference checks, where applicable and/or where required or permitted by applicable law.
• Communicate with you about the recruitment process and your application.
• Manage any on-boarding process or procedures.
• Analyze and assess the effectiveness of our recruiting processes.
• Create and submit reports, as required by applicable laws or regulations.
• Comply with legal, compliance, regulatory, and/or other corporate governance requirements (including, for example, to ensure compliance with applicable non-discrimination laws).
• Protect and defend the rights and property of Kleinfelder, other job applicants, our employees, or the public.
• Detect and protect against security incidents and malicious, deceptive, fraudulent, or illegal activity, or violations of Kleinfelder’s policies or the law, for fraud and crime prevention, and for information protection and cybersecurity.
• Collect information for internal business, product, strategy, and technological development.
• Comply with our disaster recovery, business continuity, and record keeping obligations.

How We Disclose Your Personal Information

Kleinfelder discloses your Personal Information as needed to fulfill the purposes described in this Privacy Notice and as permitted by applicable law, regulation, or contract. The circumstances for which we may disclose your information include the following:

When We Work Together – We may share information between and among Kleinfelder for purposes of management and analysis, decision making, and other human resources and employment-related business purposes.

When We Work with Service Providers & Other Third Parties – We may share identifiers, commercial information, Internet or online information, geolocation and precise geolocation information, audio and visual information, professional or employment information, and inferences, for a variety of business purposes, such as payroll services and administration, IT services and website hosting, health and safety compliance, benefits, facilities management, email, and postal delivery. Service providers and other third-parties will not use, retain, or share your Personal Information beyond the defined purposes in fulfilling the services.

When We Work on Business Transactions – If we become involved with a merger, reorganization, corporate transaction, or another situation involving the transfer of some or all our business assets, we may share your Personal Information with business entities or people involved in the negotiation or transfer.

When Sharing Helps Us Protect Safety and Lawful Interests – We may disclose your Personal Information if we believe that the disclosure is required by law or regulations, if we believe that the disclosure is necessary to enforce our agreements or policies, if we believe it will assist in the investigation of suspected or actual illegal activity, or if we believe that the disclosure will help us protect the rights, property, or safety of Kleinfelder, our customers, or our partners.

When You Give Consent – We may share Personal Information about you with other companies if you give us permission or direct us to share the information, in accordance with applicable law.

Kleinfelder has not sold and will not sell any covered individual’s Personal Information or share any covered individual’s Personal Information for purposes of cross-contextual behavioral advertising.

Data Transfer and Storage

Kleinfelder is a global business, headquartered in the United States, which operates in the United States, Canada, and Australia. Kleinfelder and its service providers may collect, use, process, store or disclose your Personal Information outside your home country or jurisdiction, including in the United States and elsewhere, that may have different data protection laws than the laws where you reside or work.

As a result, your Personal Information may be subject to data protection and other laws that may differ from your country of residence. Your Personal Information may be disclosed in response to inquiries or requests from governmental or regulatory authorities in the countries in which we and/or our service providers operate.

Data Security

We have implemented reasonable and appropriate safeguards to prevent Personal Information from being lost, misused, damaged, destroyed, accessed, altered, or disclosed by unauthorized parties. Personal Information is encrypted and secured throughout its transmission. We seek to use reasonable technical, organizational, and administrative measures to protect user information within our organization against unauthorized or unlawful access or processing. In addition, we protect Personal Information by protecting the ongoing confidentiality, integrity, availability, and resilience of our processing systems and services and to regularly test, assess, and evaluate the effectiveness of our technical and organizational security measures.

Data Retention

We retain Personal Information, including Sensitive Personal Information, for as long as needed or permitted considering the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

• The duration of your employment or contract with us.
• The duration of the job application process, whether your job application is approved, and whether you want to be notified of future job opportunities.
• 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 application or employment records for a certain period of time.
• Whether retention is advisable considering our legal position, such as regarding applicable statutes of limitations, litigation, or regulatory investigations.

Your Personal Information Rights

We aim to maintain data that is accurate and up to date. Generally, our job application portal and self-service tools allow you to view and update your Personal Information. Please notify us if any of your Personal Information changes. For your protection, we may need to verify your identity or if you have authority (acting as an agent) before acting on your request. We will process your request as soon as it is reasonably practical and according to applicable laws.

In certain instances, like you are a California resident, you have the right to:

• Request all Personal Information we have collected about you.
• Request to correct the Personal Information we have collected about you.
• Request to delete or remove Personal Information when there is no legitimate need for us to continue processing it.
• Object to the processing of Personal Information.
• Request to transfer your Personal Information.
• Opt-out of contacting you at any time.
• Limit the use of or disclosure of sensitive personal information (SPI), if we are using your SPI beyond what is reasonable and proportionate within the context of your relationship with us as an employee or job applicant.
• Express any concern about any Personal Information we have collected about you.

To exercise these rights, please contact us via the email, mail, or phone information provided in the Our Contact Information section below.

You may submit a data subject request and we may process it, as described in this Privacy Notice, even though your jurisdiction law or regulations does not require us to do so. In accepting, processing, and responding to data subject requests by individuals whose jurisdictions do not require us to do so, we will apply all the same limitations and exceptions under this Privacy Notice. We reserve the right to change or stop the practice of accepting requests from covered individuals whose jurisdiction, law, or regulations do not require us to do so.

Our Contact Information

For any questions, concerns, or requests to exercise your rights outlined in this Privacy Notice, please contact us via email at privacy@kleinfelder.com, phone at (619) 831-4757, or mail at:

Kleinfelder
Attn: Privacy Officer
770 First Avenue, Suite 400
San Diego, CA 92101

Changes to this Privacy Notice

We may update this Privacy Notice from time to time. When we make material changes to this Privacy Notice, we will notify you and will update the last revised date on this Privacy Notice. We encourage you to look for updates and changes to this Privacy Notice on the site from which you accessed it to learn about any updates to this Privacy Notice.