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J&B Materials, Inc.

APPLICANT PRIVACY POLICY

1. What is this document and why should you read it?

J&B Materials, Inc. ("J&B", "we", "us", or "our") collects and uses personal information about the individuals who work for us. This Privacy Policy describes how we collect and use personal information about you in your capacity as an applicant of J&B.

We collect and process personal information about you in order to hire you. We do not sell your personal information, and we do not intend to do so in the future.

Personal information means information that identifies you (such as your name, Social Security Number and/or Employee ID number).

2. What types of personal information do we collect and where do we get it from?

We collect your personal information from you directly when you apply for your job with and through your interaction with our information technology resources.

We also collect personal information about you from third parties (that is, individuals and organizations that are not part of, or affiliates of, J&B). These third parties will include government agencies, third parties to whom we provide services which involve you, and third parties who provide services to you or to us in connection with your relationship with us (such as benefits providers).

We create records of personal information about you as part of your relationship with us. In all cases, we will collect personal information about you in accordance with the principles outlined in this Privacy Policy. The personal information about you that we collect includes the following categories of data:

  • Personal and Family Information: information such as name(s) (and any former name(s)), home address, home telephone number, personal e-mail address, date of birth, place of birth, nationality, gender, governmental number, social security number, insurance number, passport number, photograph(s), family status (including marital status and number of dependents), family member details (including name, date of birth, relationship to employee, nationality and marital status) and emergency contact details (including name, address and telephone number).
  • Administration Information: information such as job application details (including education history and certificates, notes of candidate interviews, decisions to offer employment, background information and third-party references); immigration-related details; employment or service contract details (such as start date of employment); job descriptions (including business unit, grade, function, job family, code and type, and status (full-time or part-time)); work location (including area, department, cost center, desk location, shift and hours) and contact details; employment and career history (including job titles, transfers, promotions, managers or supervisors, and reporting structure); termination details (such as end date of employment); working time and work schedule records, absence records, leave or vacation records; images/photographs you provide to us; your performance information (including any appraisals or other internal communication regarding performance), disciplinary or grievance procedures, skills records, training records, driving records, including motor vehicle accident reports and driving history, records of projects you have worked on, professional memberships; salary and pay records (such as frequency and pay) and any deductions, bonus, health insurance, pension arrangements, benefits provided to you (such as gym membership, health and life insurance); bank account details, including payroll information, tax codes, expense information; and IT-related information, such as usernames, passwords, access codes for company computer networks or systems, and use of communications and IT systems.
  • Other Information: other information collected for reasons related to your relationship with us.

If any of the personal information you have given to us changes, such as your contact details, please inform us without delay by contacting Human Resources.

The table at Schedule 1 provides more information about the categories of information we collect.

3. Why do we process personal information about you?

We process personal information about you, in accordance with applicable law and this Privacy Policy, because it is necessary for one or more of the following reasons:

  • to hire you;
  • compliance with a legal obligation which applies to us;
  • for our legitimate interests (in general, our legitimate interests for processing personal information about you include ensuring the efficient administration of your relationship with us, the efficient management of our business, and to protect the rights and interests of J&B). We only collect information that is necessary for us to employ, pay and administer the employment or other service relationship with you;
  • to protect your interests (or those of another person); and
  • where you have otherwise consented to the processing.

In general terms, we process personal information about you in order to administer your relationship with us, administer our workforce generally and run our business operations. Some of the specific ways we use your personal information are:

  • communication with you;
  • payroll, compensation and benefits administration;
  • J&B facility, security, and health and safety management;
  • recruitment;
  • backgrounds checks to the extent permitted by applicable law;
  • employee identification;
  • compliance and risk management;
  • investigations and audits by J&B or government or regulatory authorities;
  • internal technical and operational support; or
  • compliance with law.

The table at Schedule 2 sets out more detail on the different purposes for which we process personal information about you.

4. Who do we share personal information about you with, and why?

We transfer information relating to our operations, including personal information about you, to affiliates of J&B. We do this in order to streamline and improve human resources administration and our overall business operations. All J&B affiliated companies, including its parent company, Gypsum Management & Supply, Inc., are subject to the Privacy Policy in relation to any personal information about you that we transfer to them.

We may transfer personal data about you to third parties in accordance with this Privacy Policy. Some third parties (our service providers) will be processing that personal data on our behalf. Other third parties will be processing personal data independently, for their own behalf. In those cases, we will ensure that they do not sell any of our employee data to this parties. For those companies (indicated with an * below), their privacy policy will also govern. Please see Schedule 1 for more details.

The third parties to which we may transfer personal data about you include:

  • our payroll provider;
  • administrators of benefits that you receive in connection with your employment, including our employee stock purchase plan administrator, and insurance companies and their agents*; administrators of background checks;
  • immigration* and travel agents*;
  • relocation consultants;
  • companies that we provide services to*, in circumstances where you are involved in such services;
  • financial services providers who provide a financial service to you*;
  • accountants* and lawyers*;
  • human resources, benefits and compensation consultants, and other third-party service providers who provide goods and services to us in connection with your employment generally or your relationship with us specifically;
  • claims administrator and providers of risk management services;
  • consumer reporting agencies; and
  • governmental authorities (including tax authorities)* where required by, or in order to comply with, law.

5. Where do we keep personal information about you and how long do we keep it for?

We store personal information about you on computer systems operated by or under the instruction of J&B and/or at our premises. We will maintain personal information about you for as long as necessary in connection with both our and your legal rights and obligations and in accordance with our Records Retention Schedule, both during and following the period of your relationship with us. Such personal information will be maintained (i) for the purposes for which it was collected; (ii) to defend or advance legal claims; or (iii) as otherwise required by applicable law. We and other GMS companies will delete personal information about you in accordance with our Records Retention Schedule.

Unless we explain otherwise to you, we will hold your personal information for the following periods:

  • Retention in case of inquiries. We will retain this personal data in case of inquiries from you. We will keep this personal data as part of your human resources record for the length of your employment or other service arrangements with us. We may have to keep it for a longer period (see below).
  • Retention in case of claims. We will retain certain of your personal information for the period in which you might legally bring claims against us. This means your personal information will usually be held by us for a period of at least 6 years after the end of the employment or other relationship with us. We may have to keep it for a longer period (see below).
  • Retention in accordance with legal and regulatory requirements. We will retain your personal information for longer than 6 years where we are required to do so by law or regulations (such as health, employment and safety laws).
  • Retention of closed-circuit television (“CCTV”) images. We apply a separate criteria to the retention of these records, as follows. We retain CCTV images for up to one month (unless they are needed because of a dispute between us or because of a police investigation) and after that they will be erased because we will not need to retain them for any security of premises reason.
  • Retention of vehicle camera video recordings. We retain vehicle camera video recordings for 1 month (after that time they are erased) unless they are needed because of a related accident, dispute between us, or because of a police investigation. Information retained as the result of a related accident, dispute between us, or because of a police investigation will be kept indefinitely for legal purposes and training purposes.

In addition, any personal information contained in any work-related correspondence (such as emails and text messages) or other records may be retained for longer periods dependent on the retention period of the file in which your personal data is held.

6. How do we keep personal information about you secure?

We have reasonable and appropriate measures in place to prevent personal information from being accidentally lost, used, or accessed in an unauthorized way. We limit access to personal information to those who have a business need for such access. Those individuals who process personal information on our or our affiliates’ behalf may do so only in an authorized manner. They are also subject to a duty of confidentiality. We have policies in place that regulate how employees within J&B must handle data, including personal information about you. We and our affiliates limit access to our premises and to our computer networks, and we take reasonable and appropriate steps to safeguard against unauthorized access to such premises and networks. We have procedures in place to manage any suspected data security breach and will notify you, and any applicable regulator, of a suspected data security breach consistent with legal requirements.

7. What are your rights in relation to personal information about you and how can you exercise them?

When making employment decisions, we may, after receiving your consent, obtain a consumer report from one or more consumer reporting agencies (such as credit bureaus, private investigators, collection agencies, detective agencies, and background screening service providers). If we decide to take an action that adversely affects your employment (such as terminating your employment) and that decision is based in whole or in part on information obtained from a consumer report, then you will be provided with a copy of the consumer report and a written summary of your consumer rights. You will be given at least 5 business days to respond to the report’s contents before we proceed with the adverse employment action.

In the event that an adverse employment action is taken, you will receive a notice concerning the adverse action and contact information for the consumer reporting agency that provided the consumer report that was a basis for our decision to take the adverse employment action. For any consumer report that was a basis for a decision to take an adverse employment action, you have the right to request and acquire another copy of the report from the consumer reporting agency at no charge and to contest the contents of the consumer report with the consumer reporting agency.

If your credit score was a basis for taking the adverse employment action, you will also receive a notice of your credit score, along with the range of credit scores under the credit reporting system used, the key factors that adversely affected your credit score, the date the credit score was created, and the name of the consumer reporting agency that provided the credit score.

If you wish to exercise any of your rights, please contact the Privacy Department at 1-855-275-5787.

8. Where can you find out more?

If you have any questions or concerns you wish to raise about our use of personal information about you, please contact the Privacy Department at 1-855-275-5787.

9. Do Not Track Signals

Various third parties are developing ways for consumers to express their choice about the collection of the individual consumer’s online activities over time and across third-party websites or online services. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

10. Changes to this privacy policy

We reserve the right to change this privacy policy at any time. If we make a material change to this privacy policy, we will post the revised privacy policy to this website as of the effective date of such changes.

Effective Date: January 1, 2020

SCHEDULE 1

Categories of personal information we collect

The personal information that we collect about our employees may include the categories of data below. These categories also represent the categories of personal information that we have collected over the past 12 months.

Category of Information Collected Source Purpose of Collection
Personal Identifiers: your name, alias, postal address, email address, unique personal identifier, online identifier, account name, internet protocol (IP) address, social security number, driver’s license number, passport number, employee identification number or other similar identifiers

We may collect similar information about your spouse, children and beneficiaries.
- directly from you
- consumer reporting agencies
- our service providers
- our affiliates
- government agencies
- public records
- publicly available job, professional networking, or social media sites on which you post this information
We may use this data to enter into and perform on the contract governing your relationship with us, if applicable; to administer your relationship with us, including meeting our legal and compliance obligations; to pursue the efficient management of our business; and/or to provide you with benefits and services, as applicable.

See all purposes for which we use your data in Schedule 2.
Additional personal identifiers: your signature, physical characteristics or description, telephone number, insurance policy number, bank account, credit card number, debit card number, or any other financial information, medical information, and health, life or other insurance information, including your claims history - directly from you
- consumer reporting agencies
- our service providers
- our affiliates
- government agencies
- public records
- publicly available job, professional networking or social media sites on which you post this information
We may use this data to enter into and perform on the contract governing your relationship with us, if applicable; to administer your relationship with us, including meeting our legal and compliance obligations; to pursue the efficient management of our business; and/or to provide you with benefits and services, as applicable.

See all purposes for which we use your data in Schedule 2.
Sensitive information protected by federal or state law: your age, date of birth, gender, familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, and genetic information - directly from you
- consumer reporting agencies
- our service providers
- our affiliates
- government agencies
- public records
- publicly available job, professional networking or social media sites on which you post this information
We may use this data to enter into and perform on the contract .governing your relationship with us, if applicable; to administer your relationship with us, including meeting our legal and compliance obligations; to pursue the efficient management of our business; and/or to provide you with benefits and services, as applicable.

See all purposes for which we use your data in Schedule 2
Biometric information: physiological, biological or behavioral characteristics that can be used to identify you, such as fingerprints - directly from you
- our service providers
- through the use of cookies and similar technologies
We may use this data to enter into and perform on the contract governing your relationship with us, if applicable; to administer your relationship with us, including meeting our legal and compliance obligations; to pursue the efficient management of our business; and/or to provide you with benefits and services, as applicable.

See all purposes for which we use your data in Schedule 2.
Internet or other electronic network activity information: browsing history, search history, and information about your logins and interaction with a website, including online application and advertisements, text messages and email communications - directly from you
- our service providers
- through the use of cookies and similar technologies
We may use this data to enter into and perform on the contract governing your relationship with us, if applicable; to administer your relationship with us, including meeting our legal and compliance obligations; to pursue the efficient management of our business; and/or to provide you with benefits and services, as applicable.

See all purposes for which we use your data in Schedule 2.
Sensory information: Audio, electronic, visual, olfactory, or similar information - directly from you
- our affiliates
- our service providers
We may use this data to enter into and perform on the contract governing your relationship with us, if applicable; to administer your relationship with us, including meeting our legal and compliance obligations; to pursue the efficient management of our business; and/or to provide you with benefits and services, as applicable.

See all purposes for which we use your data in Schedule 2.
Professional or employment-related information: such as your former job titles, current job information and compensation, timekeeping and workers compensation records, employee stock purchases, background checks, ethics hotline and employee directories, driving and governmental records related to your job - directly from you
- our affiliates
- our service providers
- consumer reporting agencies
- governmental agencies
We may use this data to enter into and perform on the contract governing your relationship with us, if applicable; to administer your relationship with us, including meeting our legal and compliance obligations; to pursue the efficient management of our business; and/or to provide you with benefits and services, as applicable.

See all purposes for which we use your data in Schedule 2.
Educational information not publicly available: your level of education, schools attended, your degrees and disciplinary history - directly from you
- our affiliates
- our service providers
We may use this data to enter into and perform on the contract governing your relationship with us, if applicable; to administer your relationship with us, including meeting our legal and compliance obligations; to pursue the efficient management of our business; and/or to provide you with benefits and services, as applicable.

See all purposes for which we use your data in Schedule 2.
Inferences drawn from any of the above categories of information to create a profile about you: Information about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes - directly from you
- our affiliates
- our service providers
- consumer reporting agencies
We may use this data to enter into and perform on the contract governing your relationship with us, if applicable; to administer your relationship with us, including meeting our legal and compliance obligations; to pursue the efficient management of our business; and/or to provide you with benefits and services, as applicable.

See all purposes for which we use your data in Schedule 2.

SCHEDULE 2

Purposes of processing personal information

We use your personal information for the following purposes:
  1. Communicating with you and providing you with information in connection with your employment or engagement with us from time to time
  2. Administering your travel and accommodation arrangements
  3. Considering your continuous suitability for your role and determining whether any adjustments are necessary to enable you to carry out your role
  4. General staff administration, including allocating and assigning responsibilities as necessary for workload management purposes, measuring staff utilization, and evaluating facilities operations
  5. Implementing, adapting and enhancing systems and processes to develop or improve our business and/or make your job easier or more enjoyable
  6. Identifying and assessing our strategic business direction and resourcing needs, current employees and areas for development
  7. Managing, planning and delivering our global business, sales and marketing strategies
  8. Supporting the sale, transfer or merging of part or all of our business or assets, or in connection with the acquisition of another business
  9. Publishing external facing materials for marketing and public relations purposes such as where we mention you in the context of our projects and initiatives in our marketing materials, social media posts and press releases
  10. Analyzing recruitment and retention objectives, processes and employee turnover rates
  11. Developing, operating and collecting feedback on recruitment activities and employee selection processes
  12. Investigating, evaluating, demonstrating, monitoring, improving, reporting on and meeting our compliance responsibilities, including compliance with:
    • relevant legal and regulatory requirements;
    • health and safety obligations;
    • our policies and procedures; and
    • best practice and good governance responsibilities
  13. Managing and administering our equal opportunities and affirmative action reporting
  14. Responding to binding and non-binding requests or search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities
  15. Complying with disclosure orders arising in civil proceedings
  16. Handling grievance and disciplinary matters, including investigating issues, considering appropriate resolution and mitigating actions and reviewing outcomes
  17. Responding to employment and industrial relations matters where permitted by applicable law, including criminal investigations, grievances, arbitrations, and negotiations
  18. Preparing risk assessments to prevent future injuries in the workplace
  19. Conducting verification and vetting, including criminal background checks and credit checks where required by law
  20. Identifying, investigating and mitigating suspected misuse of our assets, systems and platforms
  21. Identifying and authenticating employees and other individuals
  22. Monitoring the security of our physical premises and systems, networks and applications
  23. Supporting and maintaining our technology infrastructure

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