Employee & Applicant Privacy Notice 

Effective Date: 12/19/2025

Last Updated: 12/19/2025

This Employee & Applicant Privacy Notice (“Notice”) describes how DH Wine Compliance (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information relating to employees, job applicants, contractors, and former workers who reside in California, in accordance with the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

This Notice applies to personal information collected and processed through our Human Resources Information System (HRIS), including Paylocity, and related employment systems and processes.

1. Scope of This Notice

This Notice applies to:

• Job applicants

• Current employees

• Former employees

• Independent contractors and consultants

It does not apply to information collected through our public website or client services, which are governed by a separate Privacy Policy.

2. Categories of Personal Information We Collect

Depending on your relationship with the Company, we may collect the following categories of personal information:

A. Identifiers

• Full name

• Home address

• Email address

• Telephone number

• Employee ID number

• Social Security number

• Date of birth

B. Employment & Professional Information

• Job title, department, and reporting structure

• Employment history and qualifications

• Performance evaluations and disciplinary records

• Work schedules and attendance records

C. Payroll & Financial Information

• Bank account and direct deposit details

• Compensation, bonuses, and commissions

• Tax withholding information (W-4, state equivalents)

D. Benefits Information

• Health, dental, vision, and retirement plan information

• Dependent and beneficiary information

• Leave and accommodation records

E. Compliance & Legal Information

• I-9 and work authorization documentation

• Background check and verification results (where permitted by law)

• Training and certification records

• Workplace investigation records

F. Technical & System Information

• HRIS login credentials

• System access logs

• Device and usage information related to HR platforms

3. Purpose for Collection and Use

We collect and use personal information solely for legitimate business and employment-related purposes, including:

• Recruitment, hiring, and onboarding

• Payroll processing and benefits administration

• Workforce management and internal operations

• Compliance with federal, state, and local employment laws

• Health, safety, and security operations

• Performance management and training

• Separation, offboarding, and record retention

We do not sell or share employee personal information for cross-context behavioral advertising.

4. Legal Basis for Processing 

Under California law, we process personal information as necessary to:

• Perform employment-related obligations

• Comply with legal and regulatory requirements

• Protect the rights and safety of the Company and its workforce

Certain information is required by law. Failure to provide it may affect employment eligibility or benefits administration.

5. Disclosure of Personal Information

We may disclose personal information to the following categories of recipients only as necessary:

• HRIS and payroll providers (including Paylocity)

• Benefits administrators and insurance providers

• Background check and verification vendors

• Government agencies and regulators (e.g., IRS, DOL, EDD)

• Legal, accounting, and compliance advisors

All service providers are contractually required to safeguard personal information and use it only for authorized purposes.

6. Data Retention

We retain employee and applicant personal information in accordance with:

• California employment laws

• Federal recordkeeping requirements

• Legitimate business needs

Retention periods vary by record type (e.g., payroll, tax, benefits, personnel files). Data is securely deleted or anonymized when no longer required.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, or misuse.

While no system is infallible, we take data protection seriously and continuously evaluate our security practices.

8. California Privacy Rights

California residents have the right to:

• Know what personal information we collect and use

• Request access to their personal information

• Request correction of inaccurate information

• Request deletion of personal information, subject to legal exceptions

• Limit the use of sensitive personal information (where applicable)

• Be free from retaliation for exercising privacy rights

Requests may be submitted as described below. We will verify identity before processing requests.

9. Exercising Your Rights

To submit a privacy request or ask questions about this Notice, contact:

DH Wine Compliance

Human Resources

hr@dhwinecompliance.com

707-528-8500

Requests will be handled within the timeframes required by California law.

10. Updates to This Notice

We may update this Notice periodically to reflect changes in law or business practices. Updated versions will be made available through our HRIS or employee handbook.

Continued employment or engagement after updates constitutes acknowledgment of the revised Notice.