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CWGS Workplace Privacy Notice

Effective Date:  January 1, 2022

CWGS Group, LLC and the Camping World and Good Sam family of companies (“CWGS,” “we,” “us,” “our”) are committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you when you apply for, and during and after your, employment with us (collectively, your “employment”). This privacy notice applies to all current and former applicants, employees, and contractors (collectively “personnel”).

This privacy notice does not form part of any contract of employment or other contract to provide services.

Overview

Our processing of information related to your employment will vary depending upon the circumstances in which we have interacted with you. This privacy notice describes our overall privacy practices – in some cases, different or additional notices about our information processing practices may apply.

In this overview, we summarize the information we collect and how we use it, which is further explained in our privacy notice below.

CATEGORIES OF PERSONAL INFORMATION THAT WE COLLECT USES OF THE PERSONAL INFORMATION THAT WE COLLECT
Identifiers
Internet or other electronics network usage data
Geolocation data
Audio, video and other electronic data
Professional or employment-related information
Education information
Protected Classifications
  • Decisions related to your employment
  • Business purposes
  • Administering payments and benefits
  • Security measures and complying with health and safety obligations
  • Compliance with legal obligations

Types of Information We Collect and How We Collect It

We collect information about employees, workers, contactors, and job applicants through the application and recruitment process, directly from candidates, from employment agencies, and from screening services or other background-check providers. We may collect additional information from third parties including former employers, credit reference agencies, or other sources that supply employment verification services.

We may collect additional information in the course of job-related activities throughout the period you work for us. This can be in the form of information you provide directly to us or information which we collect automatically about you, such as monitoring computer access and usage.

We may collect the following categories of personal information about you:

  • Identifiers:
    • Personal contact details such as name, title, addresses, telephone numbers and personal email addresses
    • Bank account details, payroll records, and tax status information
    • Driver's License number, Passport number, nationality/visa status, or related information
    • Social Security Number
    • Information about your health, such as medical conditions and health and sickness records. This includes details of any absences (other than holidays) from work, including time on statutory or parental leave and sick leave; information related to testing for controlled substances; your vaccination records; COVID-19 test results; records related to administering and maintaining your healthcare and other benefits; and information about a condition needed for pensions and permanent health insurance purposes when you leave employment and the reason for leaving is related to your health.
  • Internet or other electronic network activity information: We collect information about your use of CWGS computers, devices, and networks, including your use of the internet and your email communications using company computers or systems.
  • Geolocation data: We may collect geolocation data about you if, for example, you are operating a company-issued device, such as a company-issued mobile phone, or connecting to the company’s VPN, as part of the fulfillment of your employment duties.
  • Audio, visual and other electronic data: We store photographs of you, and we may record you on building security cameras. Your telephone calls and other electronic activity may be monitored or recorded when accessing company resources. In addition, your calls may be monitored or recorded if you are interacting with a customer or member of the public in a customer service capacity or if you call a field location on a recorded line.
  • Professional or employment-related information: We collect information about your professional and employment-related background through the recruitment process (including copies of right to work documentation, references, and other information included in a resume or cover letter or as part of your application to work at CWGS). We collect information regarding your salary, annual leave, retirement, work performance, disciplinary actions, and/or grievance information. We also may collect information regarding job titles, salary history, work history, working hours, holidays, absences, training records, and professional memberships.
  • Education information: Your employment records include information you provided during the employment process about the educational institutions you have attended or your level of education. We also collect and maintain information about any professional licenses you hold, certifications you receive, or additional education or training you undertake during your employment.
  • Protected classifications: We collect your date of birth, gender, marital status and dependents, and information about your racial and ethnic origin, or disability status if you choose to provide it during the application or onboarding process.

How We Use the Information We Collect

We will only use your personal information as permitted by law. We may use the information we collect for the following purposes:

  • Decisions related to your employment, including identity verification; reviewing your performance; evaluating your development as an employee; setting your job duties and assessing our staffing needs; assessing your qualifications for other roles within the company or promotion; determining salary and other compensation; managing grievance or other disciplinary procedures, including termination; dealing with legal disputes involving you or other personnel, including accidents at work, wage disputes, and other and employment-based litigation; and ascertaining your fitness for work.
  • Business purposes, including conducting data analytics studies to review and better understand employee retention and attrition rates; ascertaining and fulfilling education, training, and development requirements and opportunities; and attracting and maintaining a diverse workforce, including reporting required by federal law.
  • Administering payments and benefits, including making tax and other required deductions, including validly authorized garnishments; and administering our benefits programs.
  • Security measures and complying with health and safety obligations, including ensuring the physical safety of our facilities, resources, personnel, and other people from threats; preventing fraud and to secure our systems, data, resources, and facilities from unauthorized access or exploitation; monitoring compliance with our IT and other policies; ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems, and preventing malicious software distribution; and investigating theft and other illegal activities.
  • Compliance with legal obligations, including verifying that you are legally permitted to work in the United States and to administer workers compensation benefits.

In some circumstances, we may aggregate or deidentify your information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

How We Share the Information We Collect

  • Affiliates, subsidiaries, and other CWGS companies
  • Service providers we engage to perform functions on our behalf such as:
    • Payroll services providers that assist us in calculating and disbursing your salary and other compensation.
    • Benefits service providers that assist us in administering health care, workers’ compensation, and other benefits, including leave absence management and workplace accommodation requests.
    • Auditing and accounting firms, such as firms that assist us in the creation of our financial records.
    • Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
    • Recruitment vendors that assist with the application process, including assessing candidate qualifications and providing the platform through which candidates submit their candidacy.
    • Analytics services, including entities that analyze traffic to and on our website and assist with identifying and communicating with potential customers.
    • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
    • IT vendors, such as entities that assist with website design, hosting and maintenance; data and software storage; and network operation.

    These companies are restricted from using your information in any manner other than as directed or permitted by us. There are limited circumstances in which the service provider collects data directly from you when their privacy policies may also apply.

  • Buyer or other successor if we sell certain of our businesses or assets to other companies in connection with a merger, acquisition, or bankruptcy. When such transactions take place, your information may constitute a part of the transferred business assets. In the event that we, or any of our affiliates, sell some, all, or substantially all of our assets to another company, your information likely will be disclosed and transferred as an asset to such company.
  • External parties when required by law or to protect CWGS or other persons as described in this privacy notice.

We may share aggregated or deidentified data at our discretion, including with marketing agencies, media agencies, and analytics providers.

Data Security

We use a combination of physical, technical, and administrative safeguards to protect the information we process about you. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

You are responsible for comply with all CWGS security and other policies.

Special Information for California Residents

The California Consumer Privacy Act (“CCPA”) defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

The CCPA provides California residents with rights to receive certain disclosures regarding a business’ processing of “Personal Information,” as well as rights to know/access, delete, and opt-out of the sale of Personal Information. Please note that while we describe these rights below, we are not obliged at this time to comply with requests from personnel who make a request solely in the context of their role as a former or current employee, job applicant, or contractor.

Right to Know/Access Information

You have the right (up to twice per year subject to certain exemptions) to know the following (for the prior 12 months):

  • Categories or Personal Information collected
  • Categories of sources of Personal Information collected
  • Categories of Personal Information disclosed for a business purpose or sold
  • Categories of third parties to whom Personal Information was disclosed for a business purpose or sold
  • The business or commercial purpose for using Personal Information
  • A copy of the specific pieces of Personal Information collected

Right to Request Deletion of Information

You have the right to request in certain circumstances that we delete any Personal Information that we have collected about you (subject to certain exemptions).

Right to Opt-Out of Sale of Personal Information to Third Parties

You have the right to opt out of any sale of your Personal Information by us. Please note that your right to opt out does not apply to our sharing of Personal Information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the Personal Information only for that function.

Right to Non-Discrimination and Information Regarding Participation in Financial Incentives

You have the right to be free from discrimination based on your exercise of your CCPA rights.

Changes to this Privacy Notice

We may update this privacy notice at any time and will provide any updated copy of this notice on our Career Portal.

If you have any questions about this privacy notice, please contact us [email protected].