California Privacy Policy

Knowles Corporation Privacy Notice for California Personnel

Updated on February 21, 2023

1.                   Introduction

This Privacy Notice for California Personnel (the “California Personnel Privacy Notice”) applies solely to all current or former employees, owners, directors, officers, and independent contractors of Knowles Corporation and its subsidiaries and affiliates (collectively, “Knowles Corporation,” or “we,” “us,” or “our”) who reside in the State of California (“Personnel,” “you,” or “your”). We adopt this California Personnel Privacy Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CPRA”), and any terms defined in the CPRA have the same meaning when used in this California Personnel Privacy Notice.

2.                   Scope of this California Personnel Privacy Notice

This California Personnel Privacy Notice applies to information that we collect about Knowles Corporation Personnel that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“ Personal Information”). “Personal Information” includes all “Sensitive Personal Information” as defined below. However, publicly available information lawfully made available to the general public from government records or widely distributed media or otherwise by you, as well as information that is deidentified or aggregated in accordance with the CPRA’s requirements, are not considered Personal Information and fall outside the scope of this California Personnel Privacy Notice.

This California Personnel Privacy Notice does not apply outside of the context of your relationship with us as Knowles Corporation Personnel or to certain Personal Information that is excluded from the scope of the CPRA, such as: (a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA); and (b) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA). Some of these exclusions may be applicable to the Personal Information we collect about you as part of background checks. If you have any questions on whether one of these exceptions apply to your Personal Information, please contact your local Human Resources personnel.

3.                   Types of Personal Information We Collect About You

Knowles Corporation collects and, over the prior twelve (12) months has collected, the following categories and corresponding pieces of Personal Information about our Personnel:

Category

Applicable Pieces of Personal Information Collected

1.      Identifiers

A real name; alias; postal address; unique personal identifier; online identifier; Internet Protocol address (when you access our network resources); account name; email address; username; Social Security number; and other similar identifiers, including driver’s license, state identification card, and/or passport number(s) (if provided by you as proof of eligibility to work)

2.      Personal information described 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; education and/or employment details (including job history); bank account number, or other financial information; medical information; health insurance information; and other similar details, such as driver’s license, state identification card, and/or passport number(s) (if provided by you as proof of eligibility to work).

NOTE: Some pieces of Personal Information included in this category may overlap with other categories of Personal Information collected by Knowles Corporation.

3.      Characteristics of protected classifications under California or federal law

Required: Age (40 years or older); national origin; or citizenship.

NOTE: We require your age to verify your identity and to provide you with health and retirement benefits. We require your national origin and citizenship to verify your eligibility to work in the United States. You are not required to provide us with this information for any other uses.

Optional: Race; color; ancestry; marital status; medical condition; physical or mental disability; sex; pregnancy or childbirth and related medical conditions; and veteran or military status.

NOTE: Providing this information is completely optional and at your discretion. We will collect this information only to the extent you choose to provide it in your resume, as part of the equal opportunity forms you fill out when you are hired; to comply with federal and state laws regarding leaves of absence and reasonable accommodations for disabilities; or for tax purposes.   

4.      Internet or other electronic network activity information

Browsing history; search history; file access history; and information on your (i) use of our computers and other information technology (IT) systems and assets, and (ii) interaction with a website or application that occurs on our networks (including via VPN).

5.      Geolocation data

Physical location or movements. We collect (i) information recorded by electronic card access systems, which may reveal your general location, and (ii) IP-based geolocation data, which may be used to locate the city and state that you are in when you access our network. This information cannot be used to precisely locate you.

6.      Audio, visual, electronic, or similar information

Security camera footage of our facilities; your photograph(s); video and call recordings or other audio recordings, such as of meetings and webinars that you attend.

7.      Professional or employment-related information

Current job history or current performance evaluations; employment contract; information about skills and abilities; accomplishments and awards; training and development data; performance evaluation data; and employment termination details.

8.      Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades or transcripts

9.      Inferences drawn from other Personal Information

Inferences drawn from any of the other Personal Information listed above to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and/or aptitudes.

NOTE: We use these inferences to help manage your career and for other similar purposes described below. We do not use these inferences for any discriminatory purpose protected by law.

10.  Sensitive Personal Information

(or “SPI”)

·      Government identifiers (Social Security, driver’s license, state identification card, and/or passport number(s)) (if provided by you as proof of eligibility to work or as part of your travel profile);

·      Complete account access credentials (usernames, account numbers, or card numbers combined with any required access/security code or password);

·      Contents of mail, email, or text messages not directed to us;

·      Racial or ethnic origin (*see note below);

Information concerning your health (*see note below). NOTE: Providing this information is completely optional and at your discretion. We will collect this information only to the extent you choose to provide it as part of the equal opportunity forms you fill out when you are hired; or for purposes of complying with state or federal laws regarding disabilities or medical-related leaves of absence.

We will not collect additional categories of Personal Information without providing you notice. As further described in To Whom Do We Sell or Share Your Personal Information, we do not (i) “sell” any categories of Personal Information for monetary or other valuable consideration, or (ii) “share” any categories of Personal Information for cross-context behavioral advertising.

4.                   Retention of Personal Information

For all categories of Personal Information described above, we will retain your Personal Information for the duration of your relationship with us as Knowles Corporation Personnel, or the length of time required by applicable law or our record retention guidelines for the type of document that contains your Personal Information.

However, we may also retain any or all categories of Personal Information when your information is subject to one of the following exceptions:

·         When stored in our backup and disaster recovery systems. Your Personal Information will be deleted when the backup media your Personal Information is stored on expires or when our disaster recovery systems are updated.

·         When necessary for us to exercise or defend legal claims.

·         When necessary to comply with a legal obligation.

·         When necessary to help ensure the security and integrity of our websites and IT systems.

5.                   Sources of Personal Information

We collect this Personal Information:

·           Directly from you when you provide it to us;

·           From third parties who help us manage our business and Knowles Corporation Personnel;

·           When you use our IT systems or access our facilities; and

·           We also create this information during the course of your employment relationship with Knowles Corporation.

6.                   How We Use Your Personal Information

Depending on your role or relationship with Knowles Corporation, we may use the Personal Information we collect for one or more of the following purposes:

·         managing our contractual and/or employment relationship with you as would reasonably be expected by an average consumer who wishes to have a Knowles Corporation Personnel relationship with us;

·         if you are an employee of Knowles Corporation, delivering or administering your salary and benefits, including insurance benefits;

·         if you are an independent contractor of Knowles Corporation, providing you with your agreed upon compensation;

·         managing our workforce and, if you are an employee of Knowles Corporation, your career;

·         delivering training programs, and measuring and recording the results of training;

·         communicating with you and for you to communicate with other Knowles Corporation Personnel and other third parties;

·         collecting and maintaining information about your work history and work performance;

·         investigating accidents and claims of wrongdoing, including to collect evidence for possible grievance or disciplinary actions or legal disputes;

·         to run and manage business operations, including to schedule work, manage the business organization, business assets, travel and expense reimbursement, maintaining corporate contact directories and organizational charts, managing and storing records;

·         processing IT infrastructure, including email, internet, and file shares;

·         maintaining the security and safety of our facilities, Personnel, and other assets, including to authenticate Personnel to access Knowles Corporation’s IT resources and facilities, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

·         to conduct compliance checks during your employment with Knowles Corporation and maintaining records on such screening and checks;

·         if you are an employee, providing employee programs such as on-site health services, company cars, pension schemes, stock options, and other similar benefits;

·         to comply with legal requirements, including to withhold taxes, and to report accidents, salary, and tax information to regulatory authorities;

·         to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;

·         to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Knowles Corporation’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Knowles Corporation about its Personnel is among the assets transferred;

·         in order to publish your name, picture, and contact information in our internal employee directory and, for leadership positions, to publish your online biography and for similar marketing efforts in accordance with Knowles Corporation’s policies; and

·         as described to you when collecting your Personal Information or as otherwise permitted by applicable law.

Knowles Corporation will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

7.                   Third Parties to Whom Do We Disclose Your Personal Information for Business Purposes

Knowles Corporation may disclose your Personal Information to third parties for one or more business purposes related to your role as Knowles Corporation Personnel. When we disclose Personal Information to non-affiliated third parties for a business purpose, we enter a contract that describes the purpose, requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes for which the Personal Information was disclosed and requires the recipient to otherwise comply with the requirements of the CPRA.

Knowles Corporation discloses and, in the preceding twelve (12) months, Knowles Corporation has disclosed the following categories of Personal Information of its Knowles Corporation Personnel to the following categories of third parties for one or more of the business purposes described below:

Category of

Personal Information

Categories of Third-Party Recipients

1.   Identifiers

·      Vendors who manage Personnel data, such as our enterprise resource planning systems, travel service providers, benefits providers, and other resources that we use to manage our workforce

·      Building or property management and security personnel

·      Our parents, affiliates, and subsidiaries

·      Business partners

·      Professional service providers, such as auditors, lawyers, consultants, and other similar parties

·      Government entities (for tax reporting and other similar purposes that require us to provide Personal Information to such entities)

2.   Personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

·      Vendors who manage Personnel data, such as our enterprise resource planning systems, travel service providers, benefits providers, and other resources that we use to manage our workforce

·      Building or property management and security personnel

·      Our parents, affiliates, and subsidiaries

·      Business partners

·      Professional service providers, such as auditors, lawyers, consultants, and other similar parties

·      Government entities (for tax reporting and other similar purposes that require us to provide Personal Information to such entities)

3.   Characteristics of protected classifications under California or federal law

·      Vendors who manage Personnel data, such as our enterprise resource planning systems, benefits providers, and other resources that we use to manage our workforce

·      Our parents, affiliates, and subsidiaries

·      Professional service providers, such as auditors, lawyers, consultants, and other similar parties

·      Government entities (for tax reporting and other similar purposes that require us to provide Personal Information to such entities)

4.   Internet or other similar network activity

·       

·      Professional service providers, such as auditors, lawyers, consultants, and other similar parties

·      Our parents, affiliates, and subsidiaries

5.   Audio, electronic, visual, or similar information

·      Vendors who manage Personnel data, such as our enterprise resource planning systems, and other resources that we use to manage our workforce

·      Professional service providers, such as auditors, lawyers, consultants, and other similar parties

·      Our parents, affiliates, and subsidiaries

6.   Professional or employment-related information

·      Vendors who manage Personnel data, such as our enterprise resource planning systems and other resources that we use to manage our workforce

·      Professional service providers, such as auditors, lawyers, consultants, and other similar parties

·      Our parents, affiliates, and subsidiaries

7.   Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).

·      We do not disclose this type of information to third parties.

8.   Inferences drawn from other Personal Information

·      Vendors who manage Personnel data, such as our enterprise resource planning systems and other systems that we use to manage our workforce

·      Professional service providers, such as auditors, lawyers, consultants, and other similar parties

·      Our parents, affiliates, and subsidiaries

 

Category of Sensitive Personal Information

Categories of Third-Party Recipients

1.   Government identifiers

(i.e., Social Security, driver’s license, state ID card, and/or passport number(s))

·      Vendors who manage Personnel data, such as our enterprise resource planning systems, benefits providers, and other resources that we use to manage our workforce

·      Building or property management and security personnel

·      Professional service providers, such as auditors, lawyers, consultants, and other similar parties

·      Our parents, affiliates, and subsidiaries

·      Government authorities or administrative agencies, such as: (i) the Equal Employment Opportunity Commission, as required for reporting; (ii) the California Department of Fair Employment and Housing as required to respond to employment claims and charges; and (iii) law enforcement in the event of civil or criminal investigations

2.   Complete account access credentials

(i.e., usernames, account numbers, or card numbers combined with any required access/security code or password)

·      Vendors who manage Personnel data, such as our enterprise resource planning systems, and other resources that we use to manage our workforce

 

3.   Contents of mail, email, or text messages not directed to us

 

We generally do not know of the existence of any such mail, email, or text messages. However, there should be no expectation of privacy in any such messages received or transmitted using Knowles Corporation’s IT systems and network. Such messages may be disclosed to third parties, such as:

·         Our parents, affiliates, and subsidiaries

·         Government authorities or administrative agencies, such as law enforcement authorities (if appropriate)

4.   Racial or ethnic origin

(if you choose to provide it to us)

·      Our parents, affiliates, and subsidiaries

·      Government authorities or administrative agencies, such as: (i) the Equal Employment Opportunity Commission, as required for reporting; (ii) the California Department of Fair Employment and Housing as required to respond to employment claims and charges; and (iii) law enforcement in the event of civil or criminal investigations

We disclose your Personal Information to the categories of third parties listed above for the following business purposes:

·         Helping to ensure the security and integrity of our facilities and IT infrastructure, to the extent the use of such Personal Information is reasonably necessary and proportionate to achieve this purpose.

·         Performing services on behalf of Knowles Corporation, including maintaining or servicing accounts; providing Human Resources services; processing or fulfilling payroll, benefits, and other similar transactions; verifying Knowles Corporation Personnel information; providing analytic services; providing storage; or providing similar services on our behalf.

In addition to the above, we may disclose any or all categories of Personal Information to any third party (including government entities and/or law enforcement entities) as necessary to:

·         comply with federal, state, or local laws, or to comply with a court order or subpoena to provide information;

·         comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;

·         cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers) believe may violate federal, state, or local law;

·         comply with certain government agency requests for emergency access to your Personal Information if you are at risk or danger of death or serious physical injury;

·         complete a transaction where a business transfer or change in ownership occurs as part of a merger, divestiture, restructuring, reorganization, dissolution, bankruptcy, liquidation, or similar proceeding; or

·         exercise or defend legal claims.

8.                   To Whom Do We Sell or Share Your Personal Information

“Sale” of Your Personal Information

Knowles Corporation has not “sold” any Personal Information for either monetary or other valuable consideration in the preceding twelve (12) months, and it has no actual knowledge of “selling” any Personal Information of minors under the age of 16.

“Sharing” of Your Personal Information for Cross-Context Behavioral Advertising

Knowles Corporation has not “shared” any Personal Information for the purpose of cross-context behavioral advertising in the preceding twelve (12) months, and it has no actual knowledge of “sharing” any Personal Information about minors under the age of 16.

9.                   Personnel Data Requests

The CPRA provides Knowles Corporation Personnel with specific rights regarding their Personal Information. This section describes these rights and explains how to exercise those rights. You may exercise these rights yourself or through your Authorized Agent (as defined below). For more information on how you or your Authorized Agent can exercise your rights, please see the section Exercising Your CPRA Privacy Rights.

·         Right to Know. You have the right to request that Knowles Corporation disclose certain information to you about our collection and use of your Personal Information over the past 12 months (a “Right to Know” request). This includes: (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which that Personal Information was collected; (c) our purposes for collecting this Personal Information; (d) the categories of third parties to whom we have disclosed your Personal Information; and (e) if we have “sold” or “shared” your Personal Information, a list of categories of third parties to whom we “sold” or “shared” your Personal Information, and a separate list of the categories of third parties to whom we disclosed your Personal Information to. You must specifically describe if you are making a Right to Know request or a Data Portability Request. If you would like to make both a Right to Know Personnel Request and a Data Portability Personnel Request, you must make both requests clear in your submission to Knowles Corporation. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. You may make a Right to Know or a Data Portability Personnel Request a total of two (2) times within a 12-month period at no charge.

·         Access to Specific Pieces of Information (Data Portability). You also have the right to request that Knowles Corporation provide you with a copy of the specific pieces of Personal Information that we have collected about you, including any Personal Information that we have created or otherwise received from a third party about you (a “Data Portability” request). If you make a Data Portability Personnel Request electronically, we will provide you with a copy of your Personal Information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the Personal Information to another third party. You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like to make both a Right to Know Personnel Request and a Data Portability Personnel Request, you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. We will not disclose your social security number, driver’s license number or other government-issued identification number, financial account number, health insurance or medical identification number, or your account password or security question or answers in response to a Data Portability Personnel Request. We will also not provide this information if the disclosure would create a substantial, articulable, and unreasonable risk to any of the following: (a) your Personal Information, (b) your Personnel relationship with Knowles Corporation, or (c) the security of our systems or networks. We will also not disclose any Personal Information that may be subject to another exception under the CPRA. If we are unable to disclose certain pieces of your Personal Information, we will describe generally the types of Personal Information that we were unable to disclose and provide you a description of the reason we are unable to disclose it. You may make a Right to Know or a Data Portability Personnel Request up to two (2) times within a 12-month period at no charge, although you may have other rights to access certain pieces of your Personal Information under applicable labor and employment laws.

·         Correction. You have the right to request that we correct any inaccurate Personal Information we maintain about you to ensure that it is complete, accurate, and as current as possible. You may review and correct some Personal Information about yourself by logging into Knowles Corporation’s intranet and accessing your human resources profile page. You may also request that we correct the Personal Information we have about you as described below under Exercising Your CPRA Privacy Rights. In some cases, we may require you to provide reasonable documentation to show that the Personal Information we have about you is incorrect and what the correct Personal Information may be. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

·         Deletion. You have the right to request that Knowles Corporation delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your Personnel Request (see Exercising Your CPRA Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies pursuant to the CPRA. Some exceptions to your right to delete include if we are required to retain your Personal Information to maintain your Personnel relationship with us, to detect security incidents or protect against other malicious activities, and to comply with legal obligations (among others). We may also retain your Personal Information for other internal and lawful uses that are compatible with the context in which we collected it.

·         Limiting Our Uses and Disclosures of SPI. You have the right to request that Knowles Corporation limit its uses and disclosures of your Sensitive Personal Information to only those purposes specifically enumerated in the CPRA. Currently, we do not use or disclose your Sensitive Personal Information for purposes other than those expressly permitted by the CPRA. Should this change in the future, we will update this California Personnel Privacy Notice and provide you with methods to limit the use and disclosure of Sensitive Personal Information.

·         Non-Discrimination. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not do any of the following as a result of you exercising your CPRA rights: (a) terminate your employment or other similar contractual relationship with Knowles Corporation; (b) provide you with different compensation, benefits, work hours, or terms of employment or other similar relationship as Knowles Corporation Personnel; or (c) suggest that you may receive different compensation, benefits, work hours, or terms of employment or other similar relationship as Knowles Corporation Personnel.

Exercising Your CPRA Privacy Rights

To exercise the rights described above, please submit a request (a “Personnel Request”) to us by:

·         Calling us at 855-657-8022.

·         Emailing us at dataprivacy@knowles.com.

If you fail to make your Personnel Request in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above or provide you with information on how to submit the request or remedy any deficiencies with your request.

Only you, or your Authorized Agent that you authorize to act on your behalf, may make a Personnel Request related to your Personal Information. To designate an Authorized Agent, see Authorized Agents below.

All Personnel Requests must:

·         Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Agent of such a person. This may include:

o   Showing your badge if you make your request in-person.

o   Providing other information about yourself (such as verifying your home address, date of birth, and the last four digits of your Social Security number).

·         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 which Personal Information relates to you or the individual for whom you are making the request as their Authorized Agent.

We will only use Personal Information provided in a Personnel Request to verify the requestor’s identity or authority to make the request.

Authorized Agents

You may authorize your agent to exercise your rights under the CPRA on your behalf by registering your agent with the California Secretary of State (an “Authorized Agent”). You may also provide your Authorized Agent with power of attorney to exercise your rights in accordance with applicable laws. We may request that your Authorized Agent submit proof of identity and that they have been authorized exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.

10.               Changes to This California Personnel Privacy Notice

We reserve the right to amend this California Personnel Privacy Notice at our discretion and at any time. When we make changes to this California Personnel Privacy Notice, we will notify you regarding the updated notice through Knowles Corporation’s communication channels, including through paper or email (or other electronic) notices, and update the notice’s effective date.

11.               Contact Information

If you have any questions or comments about this California Personnel Privacy Notice, the ways in which Knowles Corporation collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us through the Legal department.