JOB APPLICANT PRIVACY POLICY

LAST UPDATED: February 7, 2024

Thank you for your interest in a career with Red Wing Brands of America, Inc. (“Red Wing,” “we,” “us,” or “our”). This Job Applicant Privacy Policy (this “Privacy Policy”) describes how we collect, use, disclose, and protect the personal information of job applicants as part of our recruitment process.

In this Privacy Policy, “personal information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you.

This Privacy Policy does not apply to personal information collected online through the websites we own and operate or your interactions with us as a customer (collectively, the “Services”). For information regarding our privacy practices related to the Services and the personal information we collect from and about customers, please review our consumer-facing privacy policy, which is available here.

Please carefully review this Privacy Policy to learn more about our information handling and privacy practices.

NOTICE AT COLLECTION

We collect the categories of personal information (as defined in the California Consumer Privacy Act (CCPA)) listed in the table below.

Category of Personal Information Collected	Sold or Shared
Identifiers, including names, postal addresses, email addresses, online identifiers, IP addresses, and other similar identifiers.	No
Personal information categories listed in the California Customer Records statute, including names, postal addresses, telephone numbers, education and employment information, and financial information.	No
Protected classification characteristics under California law, including age (over 40), race, sex/gender, gender identity/gender expression, sexual orientation, military or veteran status, national origin, and disability status.	No
Internet or other electronic network activity information, including information regarding interactions with this Website (as defined in this Privacy Policy).	No
Geolocation data, such as IP location.	No
Education information subject to the federal Family Educational Rights and Privacy Act, such as phone call recordings (where permitted by law).	No
Inferences, meaning inferences drawn from any of the above-listed categories of information to create a summary about individuals’ abilities or aptitude.	No
Sensitive personal information, including information revealing or concerning racial or ethnic origin and personal information collected and analyzed concerning sexual orientation.	No

As further described in the “Information Use” section below, we generally collect and use the above-listed categories of personal information for our recruitment activities and as otherwise necessary or appropriate in connection with the fulfillment of other legitimate business purposes.

As noted in the table above, we do not “sell” or “share” (as these terms are defined in the CCPA) personal information.

We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in the Privacy Policy, including to satisfy legal or reporting requirements.

For additional information regarding our information handling practices and your legal rights, please review the “California Privacy Rights” section below.

INFORMATION COLLECTION

We (and our service providers) collect a variety of information from and about you during the job application and recruitment process. Additional details about our collection of personal information (including the sources of such information) can be found below.

Information you provide

The specific types of personal information that you may provide directly to us when you apply for employment with Red Wing and throughout the recruitment process are described below.

Contact information, such as your name, postal address, email address, and telephone number(s).

Application information and documentation, such as your completed job application, resume/CV, cover letter, and other supporting documentation.
Education and training information, such as your highest level of education; the school(s) you attended and your dates of attendance; the degree(s), certificate(s), or other educational qualification(s) you earned; and your transcript(s) or training records.
Professional history and qualifications, such as your current and previous employer(s), positon(s), and work experience; your skills, professional license(s), certification(s), and/or other qualifications; and your professional references (and information that your references provide about you).
Protected characteristics, such as your age, race, ethnicity, national origin, citizenship, sex, gender identity/gender expression, sexual orientation, military or veteran status, or disability status, if you choose to provide it (note that we will not use this information in hiring decisions unless specifically permitted by law).
Other information you provide, such as your social media account handle, employment preferences, current salary, and desired salary.

Information we collect automatically

Like most websites, when you visit the “Careers” section of our website (https://www.redwingshoes.com) to submit a job application or any other website where this Privacy Policy is posted or linked (collectively, this “Website”), we collect certain information automatically about your device, browser, and/or activity. This information may include your device’s Internet Protocol (IP) address, device operating system, browser type, browser settings, language preferences, the time and date of your visit to this Website, the website from which you linked to this Website (referring page), the name of the website you choose to visit immediately after leaving this Website (exit page), and information about your usage of this Website.

We (and our service providers) may use cookies (i.e., small text files placed on your browser or device when you visit a website) and other similar technologies to facilitate the collection of certain information. For additional information about our use of cookies, please review the Services Privacy Policy, which is available here.

Information we receive from third parties

We (and our service providers) may collect some of your personal information from other sources. For example, during the job application and recruitment process, we may collect information about you from employment agencies and recruiters, your current and former employer(s) and educational institution(s), your professional references, credit bureaus, and publicly-available sources (e.g., government records and social media sites/platforms).

The information that we receive from other sources may include identification information; education information; professional and employment-related information; credit reports and other credit information; background check information (including criminal conviction history and/or drug test information that may be relevant to the position that you apply for with us); and inferences drawn about your abilities, interests, or preferences.

We use the information that we receive from other sources to verify or supplement the information we collect and fulfill other purposes described in this Privacy Policy.

Combination of information

We may combine the personal information that we receive from and about you, including information you provide to us, information we automatically collect through this Website, and information we receive from third-party sources. Where applicable, we will use, disclose, and protect the combined information as described in this Privacy Policy.

INFORMATION USE

We use the personal information that we collect from and about you for our recruitment activities and as otherwise necessary or appropriate in connection with the fulfillment of other legitimate business purposes. The specific purposes for which we use your personal information are described below.

Facilitate the recruiting and interview process. We use your personal information in connection with our general recruitment activities, which may include identifying you as a potential candidate, reviewing your application for a position with us, verifying the information provided to us in connection with your application or received from other sources, determining your eligibility and suitability for a potential position or other opportunities with us, and communicating with you about the status of your application or other opportunities with us that may be of interest to you.

Analytics. We use your personal information to perform analytics and evaluate and improve our job application and recruitment activities.
Maintain security and prevent fraud. We use your personal information to help monitor and maintain the security and integrity of this Website as well as our business, network, and systems. We also use your personal information to detect, prevent, investigate, and protect you, our business, and others from fraud and other unlawful or unsafe activity.
Satisfy our legal obligations. We use your personal information to comply with applicable law and/or respond to requests and communications from law enforcement authorities or other government officials.
As otherwise necessary or appropriate. We use your personal information as otherwise described in this Privacy Policy or as explained to you at the point of information collection. We also use your personal information for other purposes at your direction or with your consent. Finally, we use your personal information as we believe necessary or appropriate to protect our rights, privacy, safety, property, and/or those of others.

We will also use your personal information as described to you at the point of information collection or, where appropriate, with your consent.

Please note that if you accept a job offer from us, we may transfer the personal information that we collected from and about you during the recruiting and interview process to your personnel file.

INFORMATION DISCLOSURE

In connection with one or more of the purposes outlined above, we may disclose your personal information to the categories of recipients listed below.

Our affiliates and subsidiaries. We disclose your personal information to our affiliates and subsidiaries for internal administrative purposes and uses that are consistent with this Privacy Policy and/or other business and operational purposes.

Our service providers. We disclose your personal information to third parties that provide business, professional, or technical support services to us (e.g., data hosting, analytics, etc.) or administer activities on our behalf. Our service providers may include job recruiters and professional advisors.
Our personnel. We disclose your personal information to Red Wing personnel who need it to perform their tasks and duties and as otherwise necessary or appropriate.
Government and public authorities. We disclose your personal information to government and public authorities as necessary or permitted by the laws of any jurisdiction in which we operate, including in response to a valid warrant or subpoena.
Third parties in connection with a sale or business transaction. We may sell or purchase assets during the normal course of business. If another entity acquires us or any of our assets, information that we have collected may be transferred to such entity and its advisors leading up to and/or following the transaction. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, information that we hold may be considered an asset of ours and may be sold or transferred to third parties.

Other third parties. We will disclose your personal information to other parties at your direction or with your consent. We will also disclose your personal information as we believe necessary or appropriate either: (a) under applicable law; (b) to protect our operations and those of any of our affiliates; (c) to protect our rights, privacy, safety, or property (and/or those of others); or (d) to allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your personal information for other reasons that we will describe at the time of information collection or prior to disclosing your information.

Additionally, we may de-identify, anonymize, or aggregate information and disclose such information to third parties for various purposes as permitted by law.

INFORMATION SECURITY

We employ and maintain reasonable administrative, physical, and technical measures designed to safeguard and protect the personal information under our control from unauthorized access, use, and disclosure.

INFORMATION RETENTION

We will keep your personal information for as long as necessary to fulfill the purposes for which we have collected it, including for the purposes of satisfying any legal or reporting requirements.

To determine the appropriate retention period for personal information, we consider: (i) the amount, nature, and sensitivity of the information; (ii) the potential risk of harm from unauthorized use or disclosure of the information; (iii) the purposes for which we use the information; (iv) whether we can achieve those purposes through other means; and (v) the applicable legal requirements.

Once retention of your personal information is no longer necessary for the purposes outlined in this Privacy Policy, we will either delete or de-identify it or, if this is not possible (for example, because the information has been stored in backup archives), we will securely store the personal information and isolate it from further processing until deletion or de-identification is possible.

If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law.

CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act, as amended by the California Privacy Rights Act and its implementing regulations (collectively, the “CCPA”) provides California residents with certain rights in relation to their personal information (as defined in the CCPA). Pursuant to the CCPA, this section provides additional details regarding our collection, use, and disclosure of personal information relating to job applicants residing in California. This section also describes the rights available to you as a California resident in relation to your personal information and how you can exercise your rights.

Personal information collection and disclosure

The following chart details which categories of personal information we have collected from and about job applicants residing in California in the past twelve (12) months, the source(s) of each category of information, and the categories of third parties to whom we have disclosed each category of information for a business purpose. Please note that the first column in the chart lists by category the types of information described in the “Information Collection” section above, as required by the CCPA.

Category of Personal Information Collected	Categories of Sources	Disclosures of Personal Information for a Business Purpose
Identifiers, including names, postal addresses, email addresses, online identifiers, IP addresses, and other similar identifiers.	Directly from individuals Through automated means	Red Wing has disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties: Our affiliates and subsidiaries Our service providers Our personnel
Personal information categories listed in the California Customer Records statute, including names, postal addresses, telephone numbers, education and employment information, and financial information.	Directly from individuals Third-party sources	Red Wing has disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties: Our affiliates and subsidiaries Our service providers Our personnel
Protected classification characteristics under California law, including age (over 40), race, sex/gender, gender identity/gender expression, sexual orientation, military or veteran status, national origin, and disability status.	Directly from individuals	Red Wing has disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties: Our affiliates and subsidiaries Our service providers Our personnel
Internet or other electronic network activity information, including information regarding interactions with this Website.	Through automated means	Red Wing has disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties: Our affiliates and subsidiaries Our service providers
Geolocation data, such as IP location.	Through automated means	Red Wing has disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties: Our affiliates and subsidiaries Our service providers Our personnel
Professional or employment-related information, including professional history and qualifications.	Directly from individuals Third-party sources	Red Wing has disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties: Our affiliates and subsidiaries Our service providers Our personnel
Inferences, meaning inferences drawn from any of the above-listed categories of information to create a summary about individuals’ abilities or aptitude.	Through automated means Third-party sources	Red Wing has disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties: Our affiliates and subsidiaries Our service providers Our personnel
Sensitive personal information, including information revealing or concerning racial or ethnic origin and personal information collected and analyzed concerning sexual orientation.	Directly from individuals	Red Wing has disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties: Our affiliates and subsidiaries Our service providers Our personnel

Purposes for collecting personal information

As described in more detail in the “Information Use” section above, we generally collect the above-listed categories of personal information for our recruitment activities and as otherwise necessary or appropriate in connection with the fulfillment of other legitimate business purposes.

Disclosures of personal information

As detailed in the “Information Disclosure” section above, we disclose personal information to fulfill specific processing purposes. We will also disclose certain categories of personal information to competent governmental and public authorities and other third parties as necessary to appropriate, including when we have a legal or contractual obligation to disclose the information.

Sale and sharing of personal information

We do not “sell” or “share” (as such terms are defined in the CCPA) personal information of any individuals (including individuals under 16 years of age) and have not “sold” or “shared” any personal information in the past twelve (12) months.

Use and disclosure of sensitive personal information

As detailed in the chart above, we collect certain “sensitive personal information” (as defined in the CCPA). However, we do not use or disclose sensitive personal information for the purpose of inferring characteristics about individuals or for any other purpose outside of the limited permissible purposes set forth in the regulations implementing the CCPA.

Your legal rights

You have the right to request that we:

Disclose to you the following information covering the twelve (12) months preceding your request:

the categories of personal information we have collected about you and the categories of sources from which we collected such information;
the specific pieces of personal information we have collected about you;

the business or commercial purposes for collecting, selling, or sharing your personal information (where applicable);
the categories of third parties to whom we disclosed such personal information; and
if we sold, shared, or disclosed your personal information for a business purpose, two separate lists disclosing:

sales and shares, identifying the personal information categories that each category of recipient received; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Delete the personal information that we have collected from you, subject to certain exceptions.
Correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing.

We will not discriminate against you if you decide to exercise your rights under the CCPA.

If you are interested in exercising any of the above-listed rights, you can do so by calling us at 1-800-261-0326, emailing us at dataprivacy@redwingshoes.com or submitting the request form at https://www.redwingshoes.com/opt-out-request-form.

To protect your privacy, we will require the matching of up to three pieces of personal information provided with your request with information we maintain to verify that it is you making the request. Where applicable, we will use the requested information for verification purposes only. Please note that we may decline a request where we are unable to verify your identity and confirm the personal information we maintain relates to you.

Authorized Agents
You may authorize someone to submit a privacy rights request on your behalf (an “authorized agent”). An authorized agent will need to demonstrate that you’ve authorized them to act on your behalf, unless you have provided the agent with power of attorney pursuant to applicable probate law. Depending on the evidence provided, we may also contact you to verify your identity with us or request confirmation from you that the agent is authorized to submit the request on your behalf.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our information handling and privacy practices and/or changes in applicable law. The “Last Updated” date at the top of this page indicates when this Privacy Policy was last revised. If we make changes, we will revise the date at the top of this page. We encourage you to review this Privacy Policy periodically to remain informed about our information handling and privacy practices.

HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy or our information handling and privacy practices, please contact us using the following contact details:

Calling us at 1-800-261-0326
Emailing us at dataprivacy@redwingshoes.com
Submitting Request Form https://www.redwingshoes.com/opt-out-request-form