WOODBINE HOSPITALITY LLC

EMPLOYEE AND APPLICANT INFORMATION PRIVACY POLICY

Woodbine Hospitality LLC (“Woodbine,” “we,” “us,” or “our”) respects the privacy of individuals who provide information to Woodbine in connection with employment or prospective employment. This Employee and Applicant Information Privacy Policy (the “Policy”) describes how Woodbine collects, uses, maintains, and protects information provided by applicants, candidates, employees, and former employees (collectively, “Individuals”).

Woodbine is committed to using employment-related information only for legitimate purposes related to its hiring, employment, and business operations and to protecting such information from unauthorized disclosure.

1. Information Covered by This Policy

This Policy applies to information provided by an Individual to Woodbine in connection with an application for employment, employment with Woodbine, or the administration or termination of an employment relationship.

Covered information may include, as applicable, an Individual’s name, address, telephone number, email address, Social Security number, employment history, education, professional qualifications, references, payroll and compensation information, tax and withholding information, benefits information, emergency-contact information, personnel records, and other information provided to or maintained by Woodbine in connection with the Individual’s employment.

This Policy applies regardless of whether information is provided directly by the Individual or obtained by Woodbine in connection with legitimate employment-related activities, such as reference checks or background screening.

2. Permitted Use of Information

Woodbine will use Individual information only for legitimate purposes directly related to evaluating, establishing, administering, or maintaining the Individual’s employment relationship with Woodbine or for Woodbine’s direct and legitimate business needs.

For applicants and candidates, permitted uses include:

· evaluating qualifications and suitability for employment;

· communicating regarding employment opportunities;

· conducting interviews and customary employment-screening activities;

· conducting reference and background checks, where appropriate and permitted by law;

· maintaining records relating to the hiring process; and

· complying with applicable legal and regulatory requirements.

For employees and former employees, permitted uses include:

· administering and maintaining personnel and employment records;

· processing payroll, compensation, tax withholding, and related matters;

· administering employee benefits and insurance;

· managing human resources functions;

· managing scheduling, attendance, performance, training, and other ordinary employment matters;

· communicating with employees regarding employment-related matters;

· administering Woodbine’s policies and procedures;

· performing accounting, financial, information technology, and other routine business functions;

· complying with applicable laws, regulations, governmental requirements, and legal obligations; and

· protecting Woodbine’s rights, property, employees, customers, and business operations.

Woodbine will not use Individual information for purposes unrelated to the Individual’s employment relationship with Woodbine or Woodbine’s legitimate business operations, except as otherwise permitted or required by applicable law.

3. Contracted Vendors and Service Providers

Woodbine may share Individual information with contracted vendors and service providers when reasonably necessary for those parties to perform routine and necessary services on behalf of Woodbine.

Such vendors may include providers of:

· payroll and tax-processing services;

· human resources and personnel administration;

· employee benefits and insurance administration;

· accounting and financial services;

· information technology and data-storage services;

· scheduling and workforce-management services; and

· other routine administrative or business services used by Woodbine in connection with its operations.

Woodbine will provide such vendors and service providers only the information reasonably necessary for them to perform their services and will take reasonable steps to require them to protect the confidentiality and security of such information.

4. No Sale or Unrelated Disclosure of Information

Woodbine will never sell, rent, lease, trade, or otherwise monetize Individual information.

Except as expressly permitted by this Policy or required by law, Woodbine will not disclose Individual information to third parties for advertising, marketing, solicitation, data brokerage, or other purposes unrelated to the Individual’s employment relationship with Woodbine or Woodbine’s legitimate business operations.

5. Legally Required Disclosures

Woodbine may disclose Individual information when required to do so by applicable law or pursuant to valid legal process.

If Woodbine receives a lawfully issued judicial subpoena or other legally binding judicial process demanding an Individual’s information, Woodbine will, to the extent legally permitted, promptly notify the Individual whose information has been demanded before producing the information so that the Individual may have an opportunity to seek appropriate protective or other legal relief.

Woodbine will not provide such notice where prohibited by applicable law, court order, or other legally binding restriction.

Nothing in this Policy prevents Woodbine from making disclosures to governmental authorities, law enforcement agencies, courts, regulators, or other persons when such disclosure is required by applicable law or otherwise legally authorized.

6. Retention of Information

Woodbine may retain Individual information for as long as reasonably necessary to administer the hiring or employment relationship, maintain appropriate business and employment records, comply with legal or regulatory requirements, resolve disputes, enforce agreements and policies, and protect Woodbine’s legitimate business interests.

Information concerning former employees may continue to be retained following termination of employment when reasonably necessary for these purposes.

7. Confidentiality

Woodbine expects its employees, managers, officers, and contracted service providers who have access to Individual information to maintain the confidentiality of such information and to use it only for authorized purposes.

Nothing in this Policy limits any separate confidentiality, nondisclosure, data-security, or privacy obligations imposed by law, contract, or Woodbine policy.

8. Changes to This Policy

Woodbine may amend this Policy from time to time to reflect changes in its business practices, technology, legal requirements, or employment practices.