California Consumer Privacy Act Notice

This notice describes the categories of personal information collected by C&S Wholesale Grocers, Inc. or one of its subsidiaries (including but not limited to Tracy Logistics LLC and Sacramento Logistics LLC) (collectively, the “Company”) and the purposes for which such information may be collected and used. For additional information about the Company’s data privacy practices, please review our Privacy Policy.

Categories of Personal
Information Collected

Identifiers and Contact information. This category includes names, postal addresses, telephone numbers (including mobile numbers), email addresses, signatures, account names, dates of birth, photographs, social security numbers, bank account information, driver’s license numbers/information, other state and federal identification numbers/information, on-line identifiers, Internet Protocol addresses, and other similar contact information and identifiers.

Protected Classification Information. This category includes characteristics of protected classifications under California or federal law.

Internet or Other Electronic Network Activity Information. This category includes, without limitation:

  • all activity on the Company’s information systems, such as interactions with a website, internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames and passwords
  • all activity on communications systems, including phone calls, call logs, voice mails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee’s use of Company systems and networks, and Company-issued/sanctioned devices.

Geolocation Data. This category includes, without limitation, GPS location data from company-owned, leased, operated, or issued mobile devices, applications, or vehicles.

Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information. This category includes, without limitation, information collected from cameras, thermometers, voicemail messages, recorded telephone conversations, and other recording devices.

Biometric Information. This category includes, without limitation, an individual’s physiological, biological, or behavioral characteristics. It includes, for example, fingerprint scans and related information, and certain wellness information, possibly including symptom and temperature checks and vaccination status. It includes the use of biometric equipment, devices, or software to record your time worked, to enter or exit facilities or rooms, to access or use equipment, or for other business purposes related to establishing individual identity.

Professional and Employment-Related Information. This category includes, without limitation:

  • data submitted with employment applications, including salary history, employment history, employment recommendations, etc.
  • background check and criminal history
  • work authorization information, including state and federal identification numbers/information
  • fitness for duty data and reports
  • performance and disciplinary records
  • salary and bonus data
  • benefit plan enrollment, participation, and claims information
  • leave of absence information, including religious and family obligations, and physical and mental health data, concerning employees and their family members

Education Information. This category includes, without limitation, education history and information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).

Sensitive Personal Information. This category includes sensitive information such as:

  • social security, driver’s license, state identification card, or passport number
  • financial account information that allows access to an account, including log-in credentials, financial account numbers, passwords, etc.
  • precise geolocation
  • racial or ethnic origin, religious or philosophical beliefs, or union membership
  • content of mail, email, and text messages (unless the Company is the intended recipient of the communication)
  • genetic data
  • biometric information
  • health information
  • information concerning sex life or sexual orientation

Inferences Drawn from the Personal Information in the Categories Above. This category includes engaging in human capital analytics, including, without limitation, identifying correlations between certain characteristics and job success, analyzing data to improve retention, and analyzing employee preferences to inform HR policies, programs, and procedures.

Purposes Personal Information, Including Sensitive Personal Information, Is Used

  • Collecting and processing employment applications, including confirming eligibility for employment, background and related checks, onboarding, and related recruiting efforts.
  • Processing payroll, other forms of compensation, and employee benefit plan and program design and administration including enrollment and claims handling and leave of absence administration.
  • Maintaining physician records and occupational health programs.
  • Making Company and third-party programs and benefits available to employees, and informing employees and applicants of those programs and benefits.
  • Maintaining personnel records and complying with record retention requirements.
  • Communicating with employees and/or employees’ emergency contacts and plan beneficiaries.
  • Complying with applicable state and federal health, labor, employment, tax, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws, guidance, or recommendations.
  • Preventing unauthorized access to, use, or disclosure/removal of the Company’s property, including the Company’s information systems, electronic devices, network, and data.
  • Ensuring and enhancing employee productivity and adherence to the Company’s policies.
  • Providing training and development opportunities.
  • Investigating complaints, grievances, and suspected violations of Company policy.
  • Designing, implementing, and promoting the Company’s diversity, equity, and inclusion programs.
  • Facilitating the efficient and secure use of the Company’s information systems.
  • Ensuring compliance with the Company information systems policies and procedures.
  • Improving safety of employees, customers and the public with regard to use of Company-owned, leased, operated, or issued property and equipment.
  • Improving efficiency, logistics, and supply chain management.
  • Improving accuracy of time management systems and attendance, including vacation, sick leave, and other leave of absence monitoring.
  • Evaluating an individual’s appropriateness for a particular position at the Company, or promotion to a new position.
  • Managing customer engagement and other legitimate business purposes.
  • Responding to and managing legal claims against the Company and/or its personnel, including civil discovery in litigation.
  • Facilitating other business administrative functions and strategic activities, such as risk management, information technology and communications, financial management and reporting, workforce and succession planning, merger and acquisition activities, and maintenance of licenses, permits and authorization applicable to Company operations.

Retention. We retain your personal information for as long as is necessary to satisfy the purpose (see above) for which it was collected (for example, processing your application for employment, processing your pay, administering your benefits, complying with the law, etc.) and in accordance with the Company’s data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal or reporting obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, address other legitimate business needs, or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements. Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.

Disclosure. To carry out the purposes outlined above, the Company may disclose personal information to service providers or other third parties, such as background check vendors, third-party human resources and staffing vendors, information technology vendors, outside legal counsel, and state or federal governmental agencies. The Company does not sell or share, as those terms are defined under applicable law, the above categories of personal information. The Company may add to the categories of personal information it collects and the purposes for which it uses that information. The Company will inform you in the event it does so.

California Resident Individual Rights Requests. Individuals who are residents of the State of California have certain individual rights. Information about these rights and how to exercise them is available in the Company’s Privacy Policy (see hyperlink at the top of this Notice).

Please also see the Company’s Privacy Policy to learn about the categories of sources from which the Company obtains personal information, which categories of personal information are disclosed to third parties, and the categories of third parties to which personal information is disclosed.

We reserve the right to amend this notice at any time without advance notice. Please direct questions about this notice to the Employee Resource Center at (800) 833-7701 or employeeresourcecenter@cswg.com.

DirectEmployers