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Applicant Privacy Notice

PRIVACY POLICY FOR JOB APPLICANTS

Effective Date: September 26, 2025

  1. PURPOSE AND INTENT

SRS Distribution Inc. / Heritage Family of Companies and its operating groups, parent(s), subsidiaries and affiliates (collectively, “the Company”) are committed to protecting the privacy and security of personal information of its job applicants. This privacy policy describes how we collect, use, retain, secure, and disclose personal information about job applicants.

This privacy policy is intended to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act and its implementing regulations (collectively, the “CCPA”). It does not apply to information we collect from visitors to our corporate website: https://www.srsdistribution.com/en/.  This privacy policy does not form part of any contract of employment or other contract to provide services.  We may update this policy at any time in accordance with Section 6, below.

If you wish to access this privacy policy in an alternate format or require an accommodation to access this privacy policy, please contact us at: HR@help.srsdistribution.com.

  1. PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT, USE, AND SHARE IT.

We collect, use, receive, and share, and may have done so during the 12-month period prior to the effective date of this privacy policy, the following categories of personal information relating to our job applicants from the following sources for the purposes of carrying out and supporting HR functions and activities, including for the business purposes described in the below table.

Depending on your interactions with us, we may not have collected each of these categories of personal information. We do not:

  • Sell job applicants’ personal information;
  • Share or disclose job applicants’ personal information for cross-contextual behavioral advertising;
  • Use job applicants’ sensitive information to third parties for purposes other than those allowed by the CCPA as set out in Cal. Code. Regs. tit. 11 § 7027(m); or
  • Sell or share the personal information of consumers under 16 years of age.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

SOURCES OF THE PERSONAL INFORMATION

BUSINESS AND COMMERCIAL PURPOSES FOR COLLECTING, USING, AND DISCLOSING THE PERSONAL INFORMATION

CATEGORIES OF ENTITIES TO WHOM WE DISCLOSE PERSONAL INFORMATION

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
  • You, including automatically and indirectly through logging and analytics tools, cookies, pixel tags, and other similar technologies on our information technology systems and equipment,
  • Our service providers, such as recruitment and human resources service providers and background check companies, and
  • Other third parties, including your emergency contacts, references, beneficiaries, healthcare providers, and publicly available sites and sources.

 
  • Recruitment,  
  • Establishing and managing our relationship with you, including HR functions such as ensuring compliance with our policies,
  • Business continuity and security purposes, including general business operations like strategic planning and project management, and safeguarding, monitoring, operating and maintaining our IT infrastructure, IT systems, and communications systems,
  • Contacting your designated emergency contact persons in the event of an emergency, and
  • Complying with our legal and contractual requirements, and to establish and exercise our legal and contractual rights.
  • Company personnel at our subsidiaries and affiliates, including those involved with hiring, human resources, management, financial, and purchasing functions, as well as IT personnel,
  • Our service providers, including recruitment, background check, and human resources service providers such as benefits administrators and insurance companies, and
  • Other third parties, such as former employers, references, applicable law enforcement and government agencies, shareholders, the public, healthcare professionals, and drug testing laboratory personnel.

Demographic data, including protected classifications such as race, color, national origin, religion, sex, disability, age, citizenship status, genetic information, ancestry, marital status, sexual orientation, gender identity and gender expression, AIDS/HIV status, medical condition, and military or veteran status.

 

 
  • You, and
  • Our service providers, such as recruitment and human resources service providers like benefits administrators and insurance companies,

 
  • Recruitment,
  • Establishing and managing our relationship with you, including HR functions such as administering our diversity, equality and inclusion programs and initiatives, and ensuring compliance with our policies, and
  • Complying with our legal and contractual requirements, and to establish and exercise our legal and contractual rights.

 
  • Company personnel at our subsidiaries and affiliates, including those involved with hiring, human resources, management, and IT personnel,
  • Our service providers, including recruitment and human resources service providers, like benefits administrators and insurance companies, and
  • Other third parties, such as applicable government agencies. 

Categories of personal information described in California Civil Code § 1798.80, such as name, signature, Social Security number, physical characteristics or description, telephone number, passport number, state identification card number, driver’s license number, insurance policy number, education information, bank account number, credit card number or debit card number, other financial information, medical information, and health insurance information.
  • You, and
  • Our service providers, such as recruitment and human resources service providers like benefits administrators and insurance companies,
  • Recruitment,
  • Establishing and managing our relationship with you, including HR functions such as administering our diversity, equality and inclusion programs and initiatives, and ensuring compliance with our policies,
  • Complying with our legal and contractual requirements, and to establish and exercise our legal and contractual rights.
  • Company personnel at our subsidiaries and affiliates, including those involved with hiring, human resources, management, and IT personnel,
  • Our service providers, including recruitment and human resources service providers, like benefits administrators and insurance companies, and
  • Other third parties, such as applicable government agencies. 

Internet or other electronic network activity information, such as browsing history, search history, and information regarding your interaction with an internet website, social media site or application.
  • You, including automatically and indirectly through logging and analytics tools, cookies, pixel tags, and other similar technologies on our information technology systems and equipment, and
  • Our service providers, such as our IT service providers.
  • Recruitment,
  • Establishing and managing our relationship with you, ensuring compliance with our policies,
  • Business continuity and security, including general business operations like strategic planning and project management, protecting Company and customer information and Company equipment, safeguarding, monitoring, operating and maintaining our IT infrastructure, IT systems, and communications systems, and
  • Complying with our legal and contractual requirements, and to establish and exercise our legal and contractual rights.
  • Company personnel at our subsidiaries and affiliates, including those involved with human resources, financial, purchasing, and management functions, and IT personnel,
  • Our service providers, including IT service providers, and
  • Other third parties, such as applicable government agencies.

Geolocation information, such as time and physical location related to use of an internet website, application, device, or physical access to an office location.

You, including automatically and indirectly through logging and analytics tools, cookies, pixel tags, and other similar technologies on our information technology systems and equipment.
  • Establishing and managing our relationship with you, including ensuring compliance with our policies,
  • Business continuity and security, including general business operations like strategic planning and project management, identification verification and verifying access rights, and safeguarding, monitoring, operating and maintaining our IT infrastructure, IT systems, and communications systems, and
  • Complying with our legal and contractual requirements, and to establish and exercise our legal and contractual rights.
  • Company personnel at our subsidiaries and affiliates, including those involved with hiring, human resources, and management functions, and IT personnel,
  • Our service providers, including our IT and human resources service providers, and
  • Other third parties, such as applicable government agencies.

Sensory or surveillance information, such as health related temperature checks, call monitoring and video surveillance.
  • You, including automatically and indirectly through logging and analytics tools, cookies, pixel tags, and other similar technologies on our information technology systems and equipment.

 
  • Establishing and managing our relationship with you, including HR functions such as ensuring compliance with our policies,
  • Business continuity and security, including general business operations like strategic planning and project management, identification verification and verifying access rights, and safeguarding, monitoring, operating and maintaining our IT infrastructure, IT systems, and communications systems, and
  • Complying with our legal and contractual requirements, and to establish and exercise our legal and contractual rights.
  • Company personnel, including those involved with hiring, human resources, and management functions, and IT personnel,
  • Our service providers, including our IT service providers and human resources service providers,
  • Other third parties, such as applicable government agencies.

Professional or employment-related information, such as compensation, benefits and payroll information (e.g., salary-related information, bonus-related information, tax-related information, benefits elections and details regarding leaves of absence), information relating to your position (e.g., job title, job description, department, terms of employment, business travel details), performance-related information (e.g., evaluations, training, promotions, disciplinary records), talent management information (e.g., résumé information, professional qualifications, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information), emergency contact information, dependent information, compliance information and other reporting channels, and the evidence gathered in the course of an investigation (including the report of the investigation and the outcome of the report).  
  • You,
  • Our service providers, such as our recruitment service providers, human resources service providers such as benefits administrators and insurance companies, and our background check service providers, and
  • Third parties, including applicable law enforcement and governmental agencies, your former employers, references you provide, other references, background check companies, your beneficiaries and their employers, healthcare providers, and publicly available sites and sources.
  • Recruitment,
  • Establishing and managing our relationship with you, including HR functions such as ensuring compliance with our policies,
  • Business continuity and security, including general business operations like strategic planning and project management, identification verification, safeguarding, monitoring, operating and maintaining our IT infrastructure, IT systems, and communications systems, and
  • Complying with our legal and contractual requirements, and to establish and exercise our legal and contractual rights.
  • Company personnel at our affiliates and subsidiaries, including those involved with hiring, human resources, management, purchasing, and financial functions, and IT personnel,
  • Our service providers, including our recruitment, background check, and human resources service providers like benefits administrators and insurance companies, and
  • Other third parties, such as our customers, shareholders, the public, applicable law enforcement and governmental agencies, your former employers, and references you provide.

Education information relevant to the job, such as student records or other education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
  • You,
  • Our service providers, including recruitment and background check service providers, and
  • Other third parties, such as, your former employers, references you provide, other references, and publicly available sites and sources.
  • Recruitment,
  • Establishing and managing our relationship with you, including HR functions and ensuring compliance with our policies, and
  • Complying with our legal and contractual requirements, and to establish and exercise our legal and contractual rights.
  • Company personnel at our affiliates and service providers, including those involved with human resources, management, and financial functions, and IT personnel,
  • Our service providers, including our recruitment and background check service providers, and
  • Other third parties, including customers, shareholders, the public, applicable law enforcement and governmental agencies, your former employers, and references you provide.

Inferences drawn from the personal information collected to determine your abilities and aptitude.
  • You,
  • Your references and former employers, and
  • Our service providers, including recruitment, employment, and retention service providers.
  • Recruitment,
  • Managing our relationship with you, including HR functions, and
  • Complying with our legal and contractual requirements, and to establish and exercise our legal and contractual rights.
  • Company personnel at our subsidiaries and affiliates, including those involved with hiring, human resources, financial, purchasing, and management functions, and IT personnel,
  • Our service providers, including our recruitment and human resources service providers, and
  • Other third parties.

Other information you choose to provide, such as career planning, hobbies and interests.
  • You, and
  • Our service providers, including recruitment, employment, and retention service providers.
  • Recruitment, and
  • Establishing and managing our relationship with you, including HR functions.
  • Company personnel at our affiliates and subsidiaries, including those involved with hiring, human resources, financial, purchasing, and management functions, and IT personnel,
  • Our service providers, including our recruitment and human resources service providers, and
  • Other third parties including customers, shareholders, the public, and government agencies.

 

We do not process “sensitive personal information,” as that term is defined by the CCPA, for the purpose of inferring characteristics about job applicants.

By providing us with any personal information, you agree that you are authorized to provide us with such information. Where the information you are providing pertains to someone else (e.g., a family member, agent, or other job applicant), you acknowledge that you are required to inform them of the contents of this privacy policy.

  1. CALIFORNIA CONSUMER PRIVACY RIGHTS AND CHOICES

The CCPA provides California job applicants with the following privacy rights regarding their personal information. The following section applies only to job applicants who are residents of the state of California:

  • The right to know and right to access: Job applicants have the right to request, twice in a 12-month period, that we disclose the personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information we have collected about them;
  • The right to delete: Job applicants have the right to request that we delete certain personal information that we have collected about them, subject to certain exceptions;
  • The right to correct: Job applicants have the right to request that we correct inaccurate personal information that we maintain about them;
  • The right of portability: Job applicants have the right of portability, or the right to have us transfer their personal information to other persons or entities upon their request;
  • Rights related to Automated Decisionmaking: In the event we do this, you may ask us to ensure that, when we are evaluating you (for example evaluating your conduct or your performance), where prohibited by law we will not base any decisions solely on an automated process, and we will provide any legally required information to you regarding the role of automated decision making in the process. You may obtain information regarding this process by contacting us in writing as set forth herein.
  • Non-Discrimination: job applicants have the right not to be discriminated against for exercising their privacy

How to Submit a Request

Job applicants can exercise their privacy rights by submitting a request to us by emailing us at HR@help.srsdistribution.com, calling us at: 855.556.3221; or asking our Human Resources department for a written request form. 

Verifying Requests

To help protect the security of job applicants’ personal information and maintain security, we will take steps to verify the job applicant’s identity before granting access to their personal information or complying with their request. If a job applicant asks us to provide them with specific pieces of personal information, we will require them to provide us with identifying information, which may include but is not limited to personal email address, personal telephone number, and/or other information that we can match with the personal information we have collected about the job applicant to verify their identity.

For requests to know or delete information about a child under the age of 13, we accept requests for information regarding minors under the age of 13 if we can determine that such requests were submitted by a parent or guardian.

Job applicants may use an authorized agent to initiate a request on their behalf as described above. We will require the authorized agent to provide us with either (1) a power of attorney authorizing the authorized agent to act on the job applicant’s behalf or (2) the job applicant’s written authorization permitting the authorized agent to act on their behalf.  Further, we will require the job applicant or their authorized agent to provide us with identifying information to verify their identity.  We may also require the job applicant to either verify their own identity directly with us or directly confirm with us that they provided the authorized agent permission to submit the request.

Responding to Requests

Within 10 days of receiving a request to know, to correct, or to delete, we will confirm receipt of the request and provide information about how we will process the request.  Generally, we will respond to a verifiable request within 45 days.  If we need more time to respond, we will provide the requestor with notice and an explanation of the reason we need more time to respond.  We may deny the request if we cannot verify the data subject’s identity or are legally permitted to deny the request, such as if doing so proves impossible or would involve disproportionate effort. 

If we deny the request, we will explain the basis for the denial, provide or delete any personal information that is not subject to the denial, and refrain from using the personal information retained for any purpose other than permitted by the denial. We will maintain a record of the request and our response for 24 months. To the extent permitted by applicable law, we may charge a reasonable fee to comply with a request if the request is manifestly unfounded, excessive, or repetitive.

  1. DATA SECURITY

While no data security system can fully protect personal information and the transmission of information over the internet is never completely secure, the Company has implemented physical, technical, and organizational safeguards and controls, designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. 

  1. DATA RETENTION

We retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of administering the recruitment and employment relationship, compliance with applicable laws, regulations, rules and relevant law enforcement requests, satisfying any legal, accounting, or reporting requirements, and to protect our, our employees’, and our business partners’ and clients’ rights, property, or safety and the rights, property and safety of others. To determine the appropriate retention period for personal information, we consider the certain criteria, including the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we retain personal information for the duration of our relationship with you plus any legally required record or data retention period and/or any period of time necessary to exercise our legal rights. In specific circumstances, we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges. 

  1. CHANGES TO THIS PRIVACY POLICY

As we strive to improve our practices, we may revise the Company’s privacy policy from time to time. This privacy policy is not a contract and we reserve the right to change this policy at any time and to notify you of those changes by posting an updated version of this policy. It is your responsibility to check this policy from time to time for any changes.

  1. QUESTIONS AND FURTHER INFORMATION

If you have any questions or would like further information regarding this privacy policy or our privacy practices, please contact us at: HR@help.srsdistribution.com.

 

 

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