Effective: April 1, 2024

About this statement

Monarch Landscape Companies and its subsidiaries, affiliates, and other Monarch companies, including but not limited to, Jensen Landscape, Northwest Landscape Services, Signature Landscape, Terracare Associates, Landsystems. Monarch Tree Service, Texscape Services, The Growing Company, Dynaserv, Environmental Designs, True North, and any affiliated company (“Monarch”, “we” or “us”) offer this Personnel Privacy Policy (“Policy”) to describe our practices for handling personal information associated with our former, current, and potential employees, contractors, temporary workers, interns, and their family members, and dependents (collectively, “Personnel”). This Policy describes the personal information that we collect and process about Personnel, our purposes for processing personal information, the ways in which we may disclose such information to third parties, and the rights that Personnel may have regarding the processing of their personal information.

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Types of personal information we collect

The types of personal information we process include, but are not limited to:

• Identifiers, such as your name, Social Security number, employee ID, home and business address, telephone number, email address, social media handle, device identifiers, user credentials, emergency contact details, passport number/national ID number, other government identifiers.
• Financial information, such as financial account details, tax and withholdings information, and details about compensation, benefits, and expenses.
• Demographics, such as gender, age (including date of birth), marital status, military service, and disability status.
• Work eligibility information, such as immigration and visa status.
• Device, internet, or other electronic network activity information associated with Monarch IT systems, networks, devices, applications, and resources, such as device ID, IP addresses, log files, unique pins, account log-in information, electronic communications and files, network connections, and login credentials.  
• Geolocation information, such as location of job sites on which you work and precise location information collected through the devices, equipment, or applications used in the course of employment including use of our mobile timekeeping application, where applicable.
• Video recordings in certain work areas and photographs for security, safety, and identification purposes.
• Recordings of communications for quality control, recordkeeping, and training purposes.
• Professional or employment-related information, such as job title/position, office or branch location, employment contract, dates/times of service, positions held, performance and disciplinary records, grievance procedures, travel and expenses, work location preferences, worksite team composition, timekeeping and related metrics (including time on site, breaks, meals, and drive time) and feedback (such as whether you agree or disagree with your timesheet), investigations, complaints, sickness/holiday records, academic/professional qualifications, CV/résumé, criminal records data (for vetting purposes, where permissible and in accordance with applicable law), reference information, and information relating to background checks.
• Education information, such as degrees or certifications held, trainings and development programs attended, and assessments.
• Biometrics, such as fingerprints or facial scans for purposes of facilitating access to facilities, devices, or applications, where permissible and in accordance with applicable law.
• Other information you may choose to provide to us (e.g., feedback on our operations).
• Inferences and analytics drawn from the above.
• Information that may be treated as sensitive under applicable laws, such as government identification numbers, login credentials, personal communications received or sent using our information resources, trade union membership, precise geolocation, biometrics, sexual orientation, and health information (e.g., for benefits or accommodations purposes).

Purposes for processing personal information

Recruitment

If you apply for or are recommended for a role at Monarch, we collect, use, and disclose to third parties personal information for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying our reference checks or background checks, checking visa status and/or eligibility to work (where applicable) and to generally manage the hiring process, and communicate with you about it.  

If you are accepted for a role at Monarch, the information collected during the recruitment process will form part of your ongoing record.

If you are not offered a position, we may retain personal information to allow us to consider you for other suitable openings within Monarch in the future.

Employment or work-related purposes

If you are employed by Monarch, we collect, use, and disclose to third parties personal information for the following purposes:

• Workforce management, including appraisals, promotions, succession planning and career development; administering payroll; providing other compensation; providing healthcare, life insurance, and other benefit administration; social security, pensions and savings plans; training (including distribution of policies and training materials to employees); maintaining leave; entering into and complying with employment agreements; maintaining directories; conducting investigations and resolving disciplinary or grievance issues; supporting work-related travel; asset allocation.
• Communications and emergencies, including facilitating communication with employees, providing references, protecting the health and safety of employees and others, facilitating communication in an emergency.
• Operating and managing the IT and communications systems, including for security and business continuity purposes.
• Maintaining the safety and security of our facilities, assets, customers, Personnel, and others.
• Budgeting, financial management and reporting.
• Managing mergers, acquisitions, and re-organizations.
• Responding to legal process such as subpoenas.
• Pursuing legal rights and remedies and addressing litigation and managing internal complaints or claims.
• Complying with legal and other requirements, such as tax, record-keeping, reporting, and audit obligations.
• Monitoring and addressing compliance with applicable laws and Monarch policies and procedures including Monarch’s social media policy and in connection with the protection of our trade secrets and confidential information.  
• Receiving and responding to inquiries, reports, or complaints.
• Conducting audits, compliance with government inspections and other requests from government or other public or regulatory authorities, and complying with internal policies and procedures

Monarch mobile timekeeping application

If you are employed by Monarch and download, access, use, or otherwise provide information to our mobile timekeeping application, we collect, use, and disclose to third parties personal information for the following purposes:

• Workforce management, including evaluating site crews, job performance, hours worked, and compensation.
• Monitoring and addressing compliance with applicable laws, customer instructions and requirements, worksite restrictions and boundaries, and Monarch policies and procedures.
• Maintaining the safety and security of our facilities, work sites, customers, Personnel, and others.
• Budgeting, financial management, and reporting.
• Operating and managing the mobile timekeeping application, including analytics.
• Evaluating and improving the mobile timekeeping application, related technologies, and workforce performance measures.

With your consent

In addition to the purposes described above, we may collect, use, or disclose to third parties personal information for specific purposes for which we seek your consent.

How long we keep your personal information

We retain the personal information we collect for as long as reasonably necessary to fulfill the purposes described above or as otherwise described at the time the information is collected, unless a shorter retention period is required by law. We may retain personal information after our relationship with you ends.  The length of retention may vary depending upon factors such as:

• The existence of an ongoing relationship between you and us;
• Recordkeeping or legal compliance requirements;
• The need to resolve inquiries or complaints;
• Operating, expanding, and improving our business;
• The need to exercise or defend legal claims;
• The need to prevent fraud, protect assets or individuals, and promote security;
• The operation of our mobile timekeeping application; and
• Protecting the rights or safety of you, us, or others.

Disclosures of personal information

We may disclose all of the categories of personal information listed above for our business purposes or as otherwise described in this Policy. The categories of recipients for each of the categories of personal information listed above include:

• Service providers: We engage service providers that perform services to help us administer human resources and staff member compensation and benefits, facilitate our recruiting efforts, assist us with facilitating our employment relationship with you, operate and maintain our IT resources, provide data or physical security, provide services to our customers, and otherwise operate our business. Unless otherwise specified, these companies will only use your personal information in the ways described in this Policy.
• Benefit providers: We arrange for you to receive certain benefits from third parties, such as insurance or financial benefit companies. We share information with those parties to facilitate the provision of those services.
• Consultants: We may provide personal information to consultants and advisors that help us operate and improve our business.  
• Solutions providers: We engage third-party solutions providers to provide backend support for some of our operations and services. This includes companies like Radar Labs, Inc. (Radar) and Industrial and Financial Systems (IFS), who provide geolocation infrastructure and enterprise service management support in connection with our mobile timekeeping application.
• Group companies and customers: Monarch has affiliate companies, partners, and customers around the country. We may disclose your personal information to affiliates, partners, or customers for employment, recruiting, diligence, security, and internal reporting purposes. For example, this information may be necessary for you to gain access to a secure worksite. Unless otherwise specified, Monarch affiliates, partners, and customers will only use your information in the ways described in this Policy.
• Recipients of legal disclosures: We may disclose your personal information to law enforcement agencies, courts, government authorities, or other third parties where we believe necessary to comply with a legal or regulatory obligation. We may disclose personal information as we deem reasonably necessary to support lawful investigations or requests, or as reasonably necessary to protect our rights or the rights of you or any other party.  
• In the context of a transaction: We may disclose personal information to potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we acquire, divest, are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business.
• Aggregate and de-identified information: We may disclose aggregate, anonymized, or de-identified information about you for any purpose permitted under applicable local law.
• Consent: We may also disclose your personal information with your consent.

We neither share personal information for targeted advertising nor sell personal information we collect regarding Personnel, including sensitive personal information and information associated with Personnel under 16 years of age. We do not permit individuals under 16 years of age to use our mobile timekeeping application.

Sources of personal information we collect

We collect and process Personnel personal information from variety of sources, including:

• Directly from you or the devices you use while on Monarch’s networks in association with your prospective, current, or former employment with us.
• From application materials and processes including from interviews and phone screenings.
• From certain third parties to: (i) verify information about your credentials, such as education and prior employment, (ii) follow-up references that you may provide, and (iii) conduct background investigations, where permitted or required by law.
• From the use of our CCTV cameras for certain premises or worksites where they are installed for security purposes.
• From publicly available sources.
• From our affiliated companies, business partners, recruitment agencies, benefit providers, service providers, and other Personnel.
• From the use of our mobile timekeeping application and other employee management tools.
• Information we automatically collect when you interact with our websites, applications, or Monarch information resources, databases, and systems (e.g., communications resources, internet, networks, and applications).

Additional Information for Californian Employees

This section of our Policy applies only to residents of the state of California and supplements the information above. All terms not otherwise defined in this section shall have the meanings as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, along with any implementing regulations (collectively the “CCPA”).

In the preceding twelve (12) months, Monarch has disclosed personal information for the business purposes described above to the following categories of recipients:

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Please note that we may also disclose any or all of the categories of information listed above in the event of a sale or transfer of all or part of our business, in response to legal process, or in the interests of protecting rights or safety, as described in more detail above.

CCPA Rights

We do not use or disclose sensitive personal information associated with Personnel for purposes other than those expressly permitted under California law.

If you are a California resident, you may have certain rights in relation to your personal information under California law:

• Right to Know: You have the right to know what personal information we have collected about you, 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 we disclose personal information, and the specific pieces of personal information that we have collected about you. We are not required to provide you with this information more than twice in a 12-month period.
• Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
• Right to Correct: You have the right request that we correct inaccurate personal information that we maintain about you.
• Right to Opt Out of Sales and Sharing: You have the right to opt out of sales of your personal information to third parties and to opt out of the disclosure of your personal information to third parties for cross-context behavioral advertising, if applicable.
• Right to Limit Use or Disclosure of Sensitive Personal Information: You have the right to limit the use and disclosure of your sensitive personal information to certain specific business purposes.
• Right to Non-discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.

Exercising your CCPA rights

If you are a California resident and want to exercise any of your CCPA rights described above or to have an authorized representative submit a request on your behalf, please contact us at (800) 613-0291 or email esc@monarchlandscape.com. Please note that we may require additional information from you to honor your request, and we may decline your request as permitted under applicable law.

Updates to this Policy

This Policy may be updated periodically to reflect any necessary changes in our privacy practices. We encourage you to check back at this Policy or with our Employee Solution Center periodically in order to be aware of the most recent version of this Policy.

Contact Details

Please address any questions or requests relating to this Policy to the Employee Solution Center at (800) 613-0291 or email esc@monarchlandscape.com.

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