Effective date: January 1, 2023
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Under the California Consumer Privacy Act (“CCPA”), Fortune Brands Innovations, Inc. (“FBIN”) or the FBIN operating company you are applying to work for (hereinafter, “we”, “our”, or “us”) may collect personal information and use it for certain business purposes as described below in this Job Applicant and Employee Privacy Notice. We are required to disclose the following information to California “consumers” regarding our collection of their personal information. Under the CCPA, “consumers” means California residents, including job applicants, employees, or contractors of a business.
Categories of Personal Information We Collect
We may collect one or more pieces of personal information from the following categories of personal information, as pre-defined by the CCPA:
- A. Identifiers: 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, or passport number, other similar identifier, information necessary to provide job apparel or safety equipment.
- B. Sensitive Personal Information: A social security number, driver’s license information, state identification card, passport information, or racial or ethnic origin.
- C. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, medical information, or information necessary to provide health insurance and other benefits, including dependents, and emergency contact information.
- D. Protected classification characteristics under California or federal law: Age, race, color, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.
- E. Commercial Information: Products or services purchased in connection with an employee discount program.
- F. Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application.
- G. Geolocation data: Coarse physical location.
- H. Sensory data: Audio.
- I. Professional or employment-related information: Current or past job history or performance evaluations, future potential.
Business or Commercial Purpose for Using or Disclosing the Personal Information We Collect
We may use or disclose the categories of personal information described above for the following business and commercial purposes:
- Complete the transaction for which your personal information is collected and as necessary to enter into or perform a contract to which you are a party;
- Detect, protect against and prevent security incidents and illegal or unauthorized activities, investigate complaints and claims, and provide other security protections;
- Train, develop, assess, and promote our employees;
- Administer diversity, equity, inclusion and engagement initiatives;
- Cooperate with law enforcement and protect our rights, interests, safety or property or those of our customers, service providers and other third parties;
- Comply with and enforce applicable legal and regulatory obligations, and respond to governmental requests;
- Enforce our policies, terms and conditions, or other agreements;
- Defend against or pursue claims, disputes, or litigation – in court or elsewhere;
- Provide technical and operational support by debugging to identify and repair errors that impair existing intended functionality;
- Evaluate applications for transfers to new positions, verify your information and complete reference checks (where applicable and pursuant to applicable law), and determine the terms of an employment offer or promotion;
- Carry out reasonable internal purposes based on your employment with us, such as communicating with you, giving assignments, providing reviews and evaluations, administering payroll and benefits, providing reimbursement of authorized expenses, arranging business travel and relocation and providing apparel or safety equipment;
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA or subsequently agreed to by you;
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Consumers is among the assets transferred, and
- Other uses which you might reasonably expect us to collect information.
Sales of Personal Information or Sensitive Personal Information
In the preceding twelve (12) months, FBIN has not sold Personal Information or Sensitive Personal Information.
Retention of Personal Information or Sensitive Personal Information
We will not retain your Personal Information or Sensitive Personal Information for longer than is reasonably necessary to carry out the purposes we disclose in this policy.
Your Consumer Rights and Choices
Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of Personal Information we collect, use, disclose, and to access your information, (2) request deletion of your Personal Information, (3) request correction of your Personal Information, (4) not be discriminated against for exercising these rights, and (5) limit processing of Sensitive Personal Information.
Access Request Rights
You have the right to request that FBIN disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we disclose that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we disclosed your Personal Information for a business purpose, a list identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that FBIN delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will delete your Personal Information from our records, unless an exception applies.
We may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
Right to Correction
You have the right to correct inaccurate Personal Information maintained by us. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will correct (and direct our service providers to correct) your inaccurate Personal Information from our records, unless an exception applies.
Right to Limit Processing of Sensitive Personal Information
You have the right to limit our processing of Sensitive Personal Information to that use which is necessary to perform services reasonably expected by an average consumer who requests such services, including processing applications for employment purposes and administering the employment relationship with you. When we collect your Sensitive Personal Information, we collect and use that information in order to perform the services for which that information is necessary and as reasonably expected by you.
Exercising Your Rights
To exercise the access, data portability, correction, and deletion rights described above, as well as to request that we limit our processing of your sensitive personal information, please submit a verifiable consumer request to us by either:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) business days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing (electronically).
We will deliver our written response electronically to the email address provided.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Changes To Our Job Applicant and Employee Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website. If you have any questions or would like to access this policy in an alternative format, please contact Human Resources at AskHR@moen.com.
Feel free to contact us if you have more questions.
If you have any questions about this Notice, please email us at AskHR@moen.com to submit your question — this is for questions only, all requests must be submitted as noted above.
You can also write to us or call at:
Fortune Brands Innovations, Inc.
520 Lake Cook Road, Suite 300
Deerfield, Illinois 60015