Employee Privacy Notice – California

Effective Date: January 1, 2020

Last Reviewed: 12/3/2020

Cavco and its family of brands including Cavco Durango, Cavco Homes, Cavco Homes Center, Cavco Texas, Cavco West, Chariot Eagle, Destiny Homes, Fairmont Homes, Fleetwood Homes, Friendship Homes, Lexington Homes, Nationwide Homes, Palm Harbor Homes, Palm Harbor Texas, Park Model RV’s, and PHN Commercial, (“Cavco,” “Company” or “we,” “our” or “us”) provide this Privacy Notice for California Consumers/Employees (the “CCPA Employee Privacy Notice”) to supplement the information contained in the Cavco Privacy Policy. This CCPA Employee Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”).

This CCPA Employee Privacy Notice applies only to Cavco employees residing in the State of California who are considered “consumers” under the CCPA and from whom we collect “personal information” as described in the CCPA. We provide you this notice because under the CCPA, California residents who are employees, employee applicants, or contractors qualify as consumers. For purposes of this CCPA Employee Privacy Notice, when we refer to “consumers” we mean you to the extent you are a California employee, employee applicant, or contractor.

Information We Collect

Cavco collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information“). We may collect personal information from you in a variety of different situations including, but not limited to on our website, your mobile device, through email, in physical locations, through the mail, and/or over the telephone.

In particular, Cavco has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed 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, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 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, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	Yes
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- 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) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Cavco obtains the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete related to your employment with Cavco and other personnel related documents and/or from services we provide you.
Indirectly from you. For example, from observing your actions on our website or from information that your computer, laptop, or mobile device transmits when interacting with our website or internal databases and network.
Third parties. For example, staffing and recruiting agencies with whom we contract for services and consumer reporting agencies when we perform employee background screenings.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job or become an employee, we will use that Personal Information in connection with your employment or potential employment.
To contact you and to inform you about benefits or information relating to your employment or potential employment.
To provide, support, personalize, and develop our website and services relating to your employment or potential employment.
To create, maintain, customize, and secure employment-related information or account with us.
To create and maintain a current and up-to-date employment personnel file for you.
To process your requests or transactions and prevent transactional fraud.
To administer payroll and other payment information.
To administer employment benefits, including but not limited to, health insurance, dental insurance, vision insurance, and 401k plan.
To provide you with support and to respond to your employment inquiries, including to investigate and address your concerns and monitor and improve our responses.
To help maintain the safety, security, and integrity of our internal services and databases and other technology assets, and business.
For research, analysis, and business development, including to develop and improve our business processes, website and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA or subsequently agreed to by you.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cavco’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cavco about our employees is among the assets transferred.

Cavco will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

For information generally on how Cavco shares personal information and to which entities, please refer to our Privacy Policy here.

Disclosure of Personal Information

In the preceding twelve (12) months, Cavco has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category E: Biometric information.
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
Category J: Non-public education information.
Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

Service providers, such as the Payroll system
Third parties with whom you direct us to share your Personal Information.
Other third parties such as consumer reporting agencies when we perform employee background screenings.

Sales of Personal Information

In the preceding twelve (12) months, Cavco has not sold your Personal Information.

Changes to Our CCPA Employee Privacy Notice

Cavco reserves the right to amend this CCPA Employee Privacy Notice at our discretion and at any time. When we make changes to this CCPA Employee Privacy Notice, we will update this Employee Data Privacy notice on Cavco’s website. Your continued use of our services, internal databases, network, website, or interaction with us through other methods following the posting of changes and/or our directing you to the updated CCPA Employee Privacy Notice constitutes your acknowledgment of such changes.

Contact Information

If you have any questions or comments about this CCPA Employee Privacy Notice, the ways in which Cavco collects and uses your information described above (and in the Cavco Privacy Policy), your choices and rights regarding such use, or how to exercise your rights under California law, please do not hesitate to contact us at:

By Mail:
Cavco Industries Inc.
3636 N Central Ave STE 1200
Phoenix, AZ 85012

By Email: Privacy@cavco.com