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 Employee/Applicant 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 Employee/Applicant Privacy Notice Applies To:

This Employee/Applicant 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 Employee/Applicant 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, aggregated, or other 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. Some information requested from you as part of your application process is required to verify your identity and assess your qualifications for the position in which you are applying for. Schwan’s collects information consistent with what is allowed by law in your state or country of residence. Certain information, such as gender, race, and religion, may only be collected where legally permissible in your jurisdiction.

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.

Some personal information included here is considered “Sensitive Personal Information” under certain data privacy regulations. Where required by law, your explicit consent to collection, processing, or transferring of such Sensitive Personal Information will be obtained. If such Sensitive Personal Information is collected as a part of the application process, you are deemed to have consented to such collection and/or you consent may not be required where the collection is mandated by US federal or other laws. Appropriate security and protection measures will be provided that will be congruent with the nature and risks associated with the data and processing activities.

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
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
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

If you are using a third-party job search engine, a social media platform (E.g., LinkedIn), or other third-party recruiter that is not affiliated with Schwan’s, please be advised that this Notice does not apply to such third parties and Schwan’s has no control over the privacy practices of such third parties. For more information on a particular third-party’s practices, please review the privacy practices of the particular website, entity, or individual by contacting them directly or reviewing information available on their websites.

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
Business partners, contractors, channel partners, or other affiliated entities
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
Government agencies or other parties in response to legal process or other requests, where such disclosure is permitted and or required by law.

Schwan’s will not share your personal information with other, third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you have the ability to opt-in or opt-out.

If you are located outside of the United States, processing your information may require your information be transferred outside your country of residence. If transferred outside your country of residence. Please note the below section on “International Data Transfer” if you are located outside the United States. In any circumstance, we require that any party receiving your personal information agree to protect the confidentiality of such information consistent with the terms of this Notice any internal privacy compliance standards.

In addition, we may release personal information: (i) to the extent we have a good-faith belief that such action is necessary to comply with any applicable law; (ii) to enforce our rights and/or make or defend claims related to your employment with Schwan’s, protect ourselves against any liability, defend ourselves against any claims, protect the rights, property and personal safety of any user, or protect the public welfare; (iii) when disclosure is required to protect the security of other persons, consistent with applicable laws (iv) to respond to a court order, subpoena, search warrant, or other legal process, to the extent permitted and as restricted by law; (v) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of our assets; or (vi) is for an additional purpose that is directly related to the original purpose for which the personal information was collected.

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

Opt-Out Procedures

You may request that Schwan’s stops sharing your personal information (“opt-out”) for certain advertising or marketing purposes. You may submit a request to opt-out by calling 1-866-255-4350 or scanning the QR code below

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.

International Data Transfer

Schwan’s is a US based company. If you are located outside the United States, in particular if you are located in Canada, Brazil, the European Union (“EU”), the European Economic Area (“EEA”), New Zealand, the Republic of South Africa, Switzerland, the United Kingdom, or other countries with similar data privacy laws, please note that we and our servers are located in the United States. Any information that you provide to us may be transferred to and processed in the United States or other countries around the world where we do business. While we make efforts to respond to all privacy inquiries from Individuals, Schwan’s does not actively solicit employees or contractors from outside the US; therefore, Individuals should not expect to avail themselves of the rights provided under the EU’s General Data Protection Regulation (“GDPR”) or similar laws. By providing your information, you unambiguously consent to transfer of your personal information and other information to the US and elsewhere for the purposes and uses described in this Notice. Further, you acknowledge that Schwan’s is not subject to the GDPR or similar international privacy laws, and, therefore, you may be unable to claim the privacy rights provided in those laws.

California Privacy Rights

If you are a California resident, California law may provide you with certain rights with regard to your personal information under the California Consumer Privacy Act (“CCPA”), and as amended by the California Privacy Rights Act ("CPRA"). Throughout this Employee/Applicant Privacy Notice you will find information required by CCPA regarding the categories of personal information collected from you; the purposes for which we use personal information, and the categories of third parties your data may be shared with. This information is current as of the date of this Employee/Applicant Privacy Notice and is applicable in the 12 months preceding the effective date of this notice.

As a California resident, the CCPA provides you the ability to make inquiries regarding to your personal information. Specifically, the degree to which the information is not already provided in this Employee/Applicant Privacy Notice, you have the right to request disclosure about the collection and use of your personal information over the past 12 months, including:

The categories of personal information collected about you.
The categories of sources for the personal information collected about you.
The business or commercial purpose for collecting your personal information.
The categories of third parties with whom your personal information was shared.
The specific pieces of personal information collected about you.
If your personal information was disclosed for a business purpose, the personal information categories disclosed and the categories of third parties to which the information was disclosed.
If your personal information was sold in the past 12 months, the personal information categories sold and the categories of third parties to which the information was sold.

Schwan’s does not sell, re-sell, distribute for re-sale, or otherwise “share” your personal information.

Please note that you may only make the above requests twice in a 12-month period. You also have the right to request that any of your personal information collected and retained be deleted, subject to certain exceptions. Finally, you have the right to not receive discriminatory treatment by Schwan’s or any business for exercising any of the rights provided under CCPA.

You may submit a request regarding your rights under CCPA by calling 1-866-255-4350 or scanning the QR code below

If we receive a CCPA request from you, we will first make a determination regarding the applicability of the law, and we will then take steps to verify your identity prior to responding. The steps to verify your identity may vary based on our relationship with you, but, at a minimum, it will take the form of confirming and matching the information submitted in the request with information already held by Schwan’s and/or contacting you through previously used channels to confirm that you submitted the request (i.e. confirming identity through contact information that we have on file, not the contact information submitted to make the request).

Your rights as stated here can also be exercised by an authorized agent on your behalf. Schwan’s will follow the standards set by the Attorney General of California regarding designation of an authorized agent to exercise rights under CCPA. You may review information available through from the Attorney General regarding how an individual can be designated as an authorized agent under CCPA.

Browser Settings and Universal Opt-Out

At this time, Schwan’s websites are not able to recognize and or respond to certain browser preference signals or opt-out settings such as Global Privacy Control (“GPC”) or Do Not Track. GPC and “Do Not Track” are browser settings that notify websites of an individual’s privacy preferences. For example, “Do Not Track” is a preference you can set in your web browser to inform websites you visit that you do not wish to be tracked via certain technology like cookies and pixels. Such browser settings must be supported by the website you are visiting to be effective. Schwan’s is not currently able to support such browser codes, so Schwan’s will not automatically acknowledge and or respond to your particular settings when you access our websites. However, you may make a request to opt-out of or limit any processing activities as described herein or through the links available on our websites.

Information Security and Data Integrity

Schwan’s will take reasonable steps to protect your personal information in Schwan’s possession and secure against risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction. We employ industry-standard security measures designed to protect the security of all information collected prior to and during the employment relationship. Schwan’s periodically reviews its security measures in an effort to ensure the privacy of personal information. However, the security of information transmitted through the internet or via a mobile device can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data.

You are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected areas of Schwan’s systems, such as Schwan’s job portal. In order to protect you and your information, we may suspend your access to any Schwan’s systems, without notice, pending an investigation, if any breach of security is suspected.

Schwan’s will take reasonable precautions to ensure that your personal information is only used for the purposes for which it was collected as described in this Employee/Applicant Privacy Notice. Schwan’s will take steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. However, Schwan’s relies upon you to assist in providing accurate updates to your personal information.

Changes to this Employee/Applicant Privacy Notice:

Schwan’s may from time to time make changes to this Employee/Applicant 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 to the Employee/Applicant Privacy Notice will be effective from the time they are communicated. This Employee/Applicant Privacy Notice was last updated in January 2023.

Contact Information

If you have any questions or concerns about the contents of this Employee/Applicant Privacy Notice, please contact us at the following:

Schwan’s Shared Services

ATTN: Legal Department

115 West College Drive

Marshall, MN 56258

1-866-255-4350

If you believe our Employee/Applicant Privacy Notice or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with Schwan's using the contact information listed above, and we will respond to let you know who will handle your concern and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.

Privacy Notice – Employees/ Applicants