Privacy Notice for Potential Team Members

Privacy Notice for Potential Team Members

Status: Version: 1.2

Prepared by: Privacy Office

Date Created: 12/16/2019

Date Last Revised: 01/18/2023

5508 Lonas Drive
Knoxville, Tennessee 37909

Privacy Notice for Pilot Travel Centers LLC Potential Team Members

We understand that your privacy is important to you, and we are committed to respecting your privacy and protecting your Personal Information (PI).

This Privacy Notice applies to individuals seeking employment with Pilot Travel Centers LLC, owned and/or operated subsidiaries and affiliates, including, but not limited to any Pilot Corporation collectively referred to as Pilot Company (“PTC” or ”us” or “we” or “our”).

We are providing this Privacy Notice to help you better understand the following:

• What Personal Information We Collect
• Why We Collect and How We Use Personal Information
• Rights and Choices About How We Use and Disclose Your Information
• How We Update this Privacy Notice

THE PROVISIONS OF THIS PRIVACY NOTICE DO NOT ESTABLISH ADDITIONAL CONTRACTUAL RIGHTS OR OBLIGATIONS, IN WHOLE OR IN PART, BETWEEN PTC AND YOU.

1. What Personal Information We Collect:

Any PI that you submit to us on this job application will be collected and processed by PTC, where permissible by relevant, applicable law. We generally collect the following categories of PI for the purposes disclosed in the “Why We Collect and How We Use Personal Information” section of this Privacy Notice:

• Identifiers and Categories of personal information described in California’s data breach notification law
• Personally Identifiable Information such as name, date of birth, postal address, phone numbers, email address, social security number, etc.
• Professional or Employment-Related Information
• Recruitment Information such as resume and curriculum vitae (CV) details, previous work experiences, educational background, certificates, licenses and vocational records, information of general interests, membership to associations, any information you have provided us during the interviews, information gathered from reference persons whose contact details you have provided to us, leaving date and your reason for leaving, information related to immigration, right-to-work, residence status, pre-hire assessments, etc.
• Protected Classifications
• Sensory Information such as voice recordings for inquiries, video / photographic images that may be captured in public areas or PTC facilities for security reasons, photographic images for company ID or access card, etc.
• Recruitment Information such as resume and curriculum vitae (CV) details, previous work experiences, educational background, certificates, licenses and vocational records, information of general interests, membership to associations, any information you have provided us during the interviews, information gathered from reference persons whose contact details you have provided to us, leaving date and your reason for leaving, information related to immigration, right-to-work, residence status, pre-hire assessments, etc.
• Audio, electronic, visual, thermal, olfactory, or similar information
  • Sensory Information such as voice recordings for inquiries, video / photographic images that may be captured in public areas or PTC facilities for security reasons, photographic images for company ID or access card, etc.

2. Why We Collect and How We Use Personal Information:

Your PI will be used by PTC to carry out our application process, and your information may be used for the following purposes to the extent permitted by applicable law:

• Analytical Purposes: To evaluate website and mobile application usage, traffic, and purchasing patterns, determine the effectiveness of advertising and marketing campaigns, etc.
• Communication Purposes: To manage communications via text message / SMS, push notification, inbox messaging, email, telephone, or physical mail for business or customer service reasons and / or to review and respond to customer service inquiries, etc.
• Equal Employment Opportunity Purposes: To comply with laws, regulations, and guidance pertaining to equal employment opportunity and anti-discrimination, etc.
• Legal, Regulatory, or Insurance Purposes: To comply with applicable law, legal proceedings, court orders, garnishments, government mandates, and respond to requests from legal authorities, enforce law requirements, investigate injury claims, respond to environmental laws and regulations, apply for Intellectual Property protections, provide and administer workers’ compensation, etc.
• Personnel and Performance Management Purposes: To manage processes related to employment application and hiring, employee onboarding, training, development planning, succession review, goal setting, engagement surveys, performance management, employee offboarding, etc.
• Security Management and Monitoring: To detect security incidents, protect against and investigate malicious, deceptive, fraudulent, or illegal activity or prosecute individuals responsible for that activity, secure PTC’s premises, assets, and information for the purposes of fraud or crime prevention, suppression, or detection, ensure compliance with PTC’s Acceptable Use Policy (AUP), terms of use, or communication security requirements, enforce contractual terms of use, etc.
• Other Business Purposes: To provide products, services, or information to PTC and business partners, communicate for business or customer service reasons, perform outplacement services, carry out any other legitimate reason such as changes to our policies or in response to an inquiry, etc.

If you are offered and accept employment with PTC, the PI collected during the application and recruitment process may become part of your employment record.

PTC is committed to the privacy and security of your PI. Following industry-leading practices, when we collect, use, process, or disclose your PI, we take reasonable steps to ensure it is treated securely and in accordance with this Privacy Notice.

3. Rights And Choices About How We Use and Disclose Your Information

PTC values our applicants and wants them to understand their rights, regarding the PI that we have collected on them. There are numerous state laws that combine to specify the following rights:

1. Right to Access – the right to know the PI we have collected about you
2. Right to Delete – the right to delete the PI we have collected about you (dependent on your location; restrictions apply)
3. Right to Rectify – the right to correct/amend PI we have collected about you
4. Right to Restrict – the right to limit the use or disclosure of certain categories of PI
5. Right to Opt Out of Sale or Sharing – the right to opt-out of the sale or sharing of PI we have collected about you
6. Right to Withdraw Consent – the right to withdraw your consent to the collection, use, or disclosure of your PI (dependent on your location)

If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.

If requests from an applicant are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the applicant of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

PTC will not discriminate against applicants for exercising any of the rights described herein. This includes denying goods or services, charging different prices, or providing a different level or quality of service. However, PTC can offer applicant’s different rates (or service) if that difference is reasonably related to the value of the applicant’s data.

Access Rights – Requests to Know

The Right to Access Personal Information Collected, Disclosed, or Sold

You have the right to request that PTC disclose the PI we collected about you. Upon the receipt of a verified request and in accordance with our data retention policy, we will provide the following:

• Categories of PI we collected about you;
• Categories of sources for the PI we collected about you;
• Our business or commercial purpose for collecting, disclosing, or selling that PI;
• Categories of third parties with whom we share that PI; and
• Specific pieces of PI we collected about you.

Please note that there may be instances where access to your PI may be restricted by law. If we are unable to verify your identity, we may request additional information for the express purpose of validating your identity. If we are prohibited from fulfilling your request for the disclosure of all or some of your PI, we will advise you of the specific reasons for restricting access, barring any legal or regulatory limitations.

We will not provide specific pieces of PI if the disclosure creates a substantial, articulable, and unreasonable risk to (1) the security of that PI, (2) the consumer’s account with us, or (3) the security of our systems or networks. We will not disclose Social Security numbers, driver’s license numbers, other government-issued identification numbers, financial account numbers, health insurance numbers, medical identification numbers, account passwords, and security questions and answers.

Instructions for Submitting Access Requests

PTC provides three options to submit Access Requests. Individuals may submit their Access Request by:

• Accessing our online portal: privacy.pilotflyingj.com
• Calling one of our toll-free numbers:
• 1-888-496-7108, for United States residents
• 1-855-701-0605, for Canadian residents
• If available, visiting a travel center and using the In-Store Kiosk, in California locations only

Process to Verify Access Requests

To verify the identity of the individual who has made an Access request, PTC may require individuals to submit additional information. PTC may ask individuals to provide: first name, last name, date of birth, address, phone number, and email address. After providing the information necessary to complete the request, you will be verified with a third-party identity verification service. Once this request has been verified, the Privacy Office will begin to process your request.

Do Not Sell My Personal Information

Right to Opt-Out of the Sale or Sharing of Personal Information

We partner with other companies and businesses to deliver interest-based ads to you, which enable us to provide our Services and relevant offers to you.

In working with other companies and businesses, we may disclose personal information in a way that meets the criteria of “selling” or “sharing” personal information as defined under state privacy laws.

You can request to opt-out of this “sale or sharing” of your personal information by clicking on the “Do Not Sell or Share My Personal Information” link here or elsewhere on our platform, where you will find instructions on opting out of the use of your personal information for interest-based advertising.

You have the right to opt-out of the sale or sharing of the PI that PTC has collected on you. As used within the context of this Privacy Notice, “Sell” refers to the act of selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, the PI we have collected during the normal course of business, to another business or a third party for monetary or valuable consideration. You are not required to create an account or enroll in any of our loyalty programs in order to exercise your rights under this provision.

If you choose to exercise this right, PTC will refrain from selling your PI for a period of one year. After this period, we may contact you to obtain your consent to sell your PI.

We do not sell the PI of minors under 16 years of age without affirmative authorization where required by law. For more information, please view the Personal Information Collection for Consumers Under 16 section in this Privacy Policy.

Instructions for Submitting Do Not Sell or Share Requests

PTC provides three options to submit Do Not Sell or Share Requests. Individuals may submit their Do Not Sell Requests by:

• Accessing our online portal: privacy.pilotflyingj.com
• Calling one of our toll-free numbers:
• 1-888-496-7108, for United States residents
• 1-855-701-0605, for Canadian residents
• If available, visiting a travel center and using the In-Store Kiosk, in California locations only

Upon receiving a request to opt-out, we will act upon it as soon as feasibly possible and in accordance with any applicable law. We will notify all third parties to whom we have sold your PI, as required by law. We will notify you when this has been completed.

If we have a good-faith, reasonable, and documented belief that a request to opt-out is fraudulent, we may deny the request. In this scenario, we will inform the requesting party that we will not comply with the request and provide an explanation of why we believe the request is fraudulent.

Opting-In After Opting-Out of the Sale or Sharing of Personal Information

If you have previously opted-out of the sale or sharing of your PI and would like to opt-in, you can do the following:

• If you are a Loyalty member, you can change the setting in your Loyalty account, via the Loyalty Portal.
• you are not a Loyalty member, you opt-in by registering for a Loyalty account.

We use a two-step opt-in process through which you must first clearly request to opt-in and then second separately confirm your choice to opt-in.

Authorized Agents

You may designate an Authorized Agent to make requests on your behalf. Under the California Consumer Privacy Act, an Authorized Agent is defined as “a natural person or a business entity registered with the Secretary of State that a consumer has authorized to act on their behalf”. We may deny a request from an Authorized Agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

If acting as an Authorized Agent on behalf of a consumer, please contact our Privacy Office at privacy@pilotflyingj.com.

Notice to California Residents

Access Requests

Under the California Consumer Privacy Act, PTC is required to respond to no more than two access requests in a rolling 12-month period.

Deletion Requests

As a resident of California, in addition to the individual rights mentioned in this Privacy Notice, you also have the right to request the deletion of your Personal Information.

The Right to the Deletion of Personal Information

You have the right to request that PTC delete any of your PI that we collected from you and retained, subject to certain exceptions. We respect your right to request the deletion of your PI and would like to inform you of what happens if we are able to honor your request. If you choose to delete your PI, this will result in us deleting your PI from the associated loyalty account. As a result of the deletion of your PI, you will:

1. Forfeit your points and forfeit the ability to earn new points;
2. Forfeit your credits and the ability to earn new credits, including, but not limited to: parking, showers, Wi-Fi, and coffee;
3. Forfeit the ability to log in to the Pilot Flying J mobile app and all associated non-guest mode features (i.e., mobile fueling, mobile shower reservations, myOffers program - including saving and redeeming offers);
4. Forfeit the ability to log into PTC WiFi;
5. Forfeit the ability to reserve a parking space online;
6. Forfeit the ability to get a receipt at the kiosk after 24 hours or at a different store;
7. Forfeit the ability to reserve a shower at the kiosk or in the Pilot Flying J mobile app;
8. Forfeit the ability to access the loyalty portal and perform functions within the loyalty portal, including, but not limited to: saving offers and checking point balances;
9. Forfeit the ability to reserve or print a slip for a Prime Parking space at the kiosk;
10. Forfeit the right to participate in some loyalty-based sweepstakes; and
11. Forfeit all rewards, perks and discounts tied to loyalty, including, but not limited to loyalty-based fuel discounts.

After a request is completed, it is your responsibility to remove the Pilot Flying J Application from your devices, as information may still be gathered by Pilot Travel Centers LLC if it remains installed.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Fulfill the employment or business purpose for which it was collected.
• Comply with a legal obligation; and/or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Instructions for Submitting Deletion Requests

• Accessing our online portal: privacy.pilotflyingj.com
• Calling one of our toll-free numbers:
• 1-888-496-7108, for United States residents
• If available, visiting a travel center and using the In-Store Kiosk, in California locations only

Process to Verify Deletion Requests

To verify the identity of the individual who has made Deletion request, PTC may require individuals to submit additional information. PTC may ask individuals to provide: first name, last name, date of birth, address, phone number, and email address. After providing the information necessary to complete the request, you will be verified with a third-party identity verification service. Once this request has been verified, the Privacy Office will begin to process your request

Denial of Deletion Requests

If we deny your request, we will (1) inform you that we will not comply with the request and describe the basis for the denial, including any applicable statutory and regulatory exceptions; (2) delete the PI that is not subject to the exception; and (3) not use the PI retained for any other purpose than provided for by the applicable exception(s).

Authorized Agents

You may designate an Authorized Agent to make requests on your behalf. Under the California Consumer Privacy Act, an Authorized Agent is defined as “a natural person or a business entity registered with the Secretary of State that a consumer has authorized to act on their behalf”. We may deny a request from an Authorized Agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

If acting as an Authorized Agent on behalf of a consumer, please contact our Privacy Office at privacy@pilotflyingj.com.

Notice to Canadian Residents – Amendment and Withdrawal of Consent Requests

As a resident of Canada, in addition to the Access and Do Not Sell My Personal Information rights mentioned in this Privacy Notice, you also have the right to request the amendment of your PI, if you believe it is inaccurate and the right to withdraw consent for the collection, use, and disclosure of your PI.

The Right to Amendment of Personal Information

You have the right to request that PTC amend any of your PI that you believe to be inaccurate, incomplete, or not up to date.

PTC will take reasonable steps to correct the information so that it is accurate, complete, and up-to-dateup to date. This may include transmitting the amended information to third parties who have access to the information in question.

Instructions for Submitting Amendment Requests

Individuals may submit their Amendment Request by:

• Calling our Guest Services Team: 1-877-866-7378

The Right to Withdraw Consent for the Collection, Use, or Disclosure of Personal Information

You have the right to withdraw consent, at any time, for the collection, use, or disclosure of Personal Information. We respect your right to withdraw consent and would like to inform you of what happens if we are able to honor your request. If you choose to withdraw consent, this will result in deleting information from associated accounts, including loyalty accounts. As a result, you will:

• Forfeit your points and forfeit the ability to earn new points;
• Forfeit your credits and the ability to earn new credits, including, but not limited to: parking, showers, Wi-Fi, and coffee;
• Forfeit the ability to log in to the Pilot Flying J mobile app and all associated non-guest mode features (i.e., mobile fueling, mobile shower reservations, myOffers program - including saving and redeeming offers);
• Forfeit the ability to log into PTC WiFi;
• Forfeit the ability to reserve a parking space online;
• Forfeit the ability to get a receipt at the kiosk after 24 hours or at a different store;
• Forfeit the ability to reserve a shower at the kiosk or in the Pilot Flying J mobile app;
• Forfeit the ability to access the loyalty portal and perform functions within the loyalty portal, including, but not limited to: saving offers and checking point balances;
• Forfeit the ability to reserve or print a slip for a Prime Parking space at the kiosk;
• Forfeit the right to participate in some loyalty-based sweepstakes; and
• Forfeit all rewards, perks and discounts tied to loyalty, including, but not limited to loyalty-based fuel discounts.

After a request is completed, it is your responsibility to remove the Pilot Flying J Application from your devices, as information may still be gathered by Pilot Travel Centers LLC if it remains installed.

Instructions for Submitting Withdrawal of Consent Requests

Individuals may submit their Request by:

• Accessing our online portal: privacy.pilotflyingj.com
• Calling our toll-free number, 1-855-701-0605

Process to Verify Withdrawal of Consent Requests

To verify the identity of the individual who has made a Withdrawal of Consent request, PTC may require individuals to submit additional information. PTC may ask individuals to provide: first name, last name, date of birth, address, phone number, and email address. After providing the information necessary to complete the request, you will be verified with a third-party identity verification service. Once this request has been verified, the Privacy Office will begin to process your request.

Contact Us for More Information

If you have questions or concerns about our Privacy Policy and privacy practices, please contact our Privacy Leader at privacy@pilotflyingj.com, via telephone at 1-877-866-7378, or at the address provided below:

Pilot Flying J
Attention: Privacy Leader
5508 Lonas Dr.
Knoxville, TN 37909

4. How We Update This Privacy Notice

PTC may change this notice from time to time at its sole discretion. We will post any changes to www.pilotflyingj.com/applicant-privacy-notice. Each version of the notice is identified by its effective date.

This Applicant Privacy Notice is effective January 18, 2023.