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Employee Privacy Notice

PURPOSE OF THIS NOTICE

XPEL and its affiliated companies are committed to maintaining the accuracy, confidentiality, and security of your personal information. This Privacy Notice describes (1) the types of personal information we collect, (2) how we collect, use, disclose, transfer, and store the information, and (3) your rights as it relates to your personal information.  

If you have any questions regarding this Privacy Notice, please email privacy@xpel.com or call (833) 258-2058.

PURPOSE OF COLLECTING PERSONAL INFORMATION

XPEL collects and processes your personal information to meet our legal, statutory, and contractual obligations. This information enables us to recruit, employ, pay, provide benefits, and train you in the course of your employment with XPEL.  XPEL will never collect any unnecessary personal data from you and does not process your information in any way other than as specified in this notice.

This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

DATA PROTECTION PRINCIPLES

We will comply with data protection law, which says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

USE OF PERSONAL INFORMATION

XPEL only collects and processes your personal information if we have a legal basis for doing so.  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the person's identity has been removed (anonymous data).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health, sexual orientation or criminal convictions.

The personal information collected by XPEL is used as follows:

  • recruitment and pre-employment screening
  • benefits administration
  • administration of payment for salary, expenses, bonuses, stock options or other incentives
  • performance management and career planning
  • monitoring registrations with regulatory bodies 
  • arranging and coordinating business-related travel, transportation, and accommodation
  • obtaining business-related insurance policies 
  • international assignment administration, including documenting assignment entitlements, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax filing obligations, addressing health requirements
  • monitoring and ensuring compliance of employees’ ability to work in a particular country
  • absence and sickness monitoring
  • vacation and leave request processing
  • equal opportunities monitoring
  • reporting, including local, regional, company, headcount, management information, demographic and statutory reporting
  • administration of termination of employment and/or assignment
  • disciplinary, capability, grievance, complaint and code of conduct processes and other investigations
  • providing references on your behalf when you request us to do so
  • maintaining contact details for you, and your dependents in case of personal or business emergency
  • administration and handling of employee claims
  • validating identity of personnel
  • management of XPEL’s software and hardware computer assets
  • staff surveys
  • facilitating electronic mail communications from your work account for purposes of conducting XPEL’s business
  • whistleblowing reports
  • security monitoring

In addition, XPEL may share your information with third parties that we engage to process your personal data on our behalf.  This may include:  

  • recruitment providers 
  • payroll and benefits administrators
  • technology service providers, 
  • insurance brokers, providers, and administrators, 
  • financial institutions,
  • travel agencies, or 
  • our professional service providers including legal counsel, accountants, tax advisors, and consultants. 

XPEL may also disclose your personal data to related or affiliated companies where it is necessary for internal reporting, for purposes of the employment relationship and corporate management reasons. XPEL may also disclose your personal data with other business entities in connection with the relocation, assignment, merger, sale, or other transfer of all or a portion of our business or assets to such a business entity.  XPEL will use reasonable efforts to ensure that any successor business entity will honor the terms of this Privacy Notice.  Where required by law or to protect our legal rights, XPEL may disclose your personal data to government agencies, regulators, and law enforcement agencies.

In all instances, when the processing of personal information is carried out by a third-party data processor on our behalf, XPEL takes steps to ensure that appropriate security measures are in place to prevent unauthorized access to or use of your data.  

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies. 

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform the contract we have entered into with you.
  2. Where we need to comply with a legal obligation.
  3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests. 

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else's interests).
  2. Where it is needed in the public interest or for official purposes.

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION 

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

PROTECTING PERSONAL INFORMATION

In accordance with applicable data privacy/protection laws, XPEL has implemented appropriate physical, electronic, and administrative safeguards to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, destruction, or modification.

These measures are regularly reviewed, evaluated, and updated to proactively identify new or emerging security threats.   

Where data processing is carried out on XPEL’s behalf by a third-party, XPEL takes steps to ensure that appropriate security measures are in place to prevent unauthorized disclosure of personal information.

TYPES OF PERSONAL DATA COLLECTED

Personal Data is defined as any information that can be used to identify an individual either on its own or when combined with other available data.  

XPEL collects personal data about you from a variety of sources including information we collect from you directly.  Personal data may be collected from the following sources: 

  • Submitted CV’s
  • Job forums and recruitment agencies 
  • Direct from candidates for employment and employees
  • Applications submitted electronically or through XPEL’s website (www.xpel.com) 
  • Enrollment applications for company-provided benefits
  • From third parties with your consent (including references and prior employers)
  • Websites associated with you and social media platforms (e.g., LinkedIn)
  • Publicly accessible sources
  • Background check service providers as permitted by law
  • Employee reviews, evaluations, and internal reporting processes. 

The information XPEL collects includes the following categories of personal data: 

• First and last name

• Curriculum vitae

• Address

• Qualifications

• Personal email address

• Performance management reviews

• Personal phone numbers

• Nationality

• Gender

• Birth country / location

• Marital status/ civil partnership status

• Date of birth / age

• Race

• Vacation requests

• Participation in the retirement plan

• Immigration status

• Driver’s license number

• Dependents

• Emergency contact

• Union membership

• Social security number or equivalent

• Employee ID

• Photo and video (for identification purposes)

• Termination date

• Bank details

• Hire date

• Business unit / Department / Job function

• Salary and compensation information

• Employment status, location, cost center

• Standard hours worked

• Disciplinary information

• Absence details

• Corporate credit card information

• Training data

• Professional accomplishments

• Assigned computers/technology

We may also collect, store and use the following more sensitive types of personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation, and political opinions.
  • Trade union membership.
  • Information about your health, including any medical condition and sickness records, including:
    • where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill health, injury or disability, the records relating to that decision;
    • details of any absences (other than holidays) from work including time on statutory parental leave and sick leave;
    • any health information in relation to a claim made under the permanent health insurance scheme; and
    • where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
  • Genetic information and biometric data.
  • Information about criminal convictions and offences.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

Special categories of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation, or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

  1. In limited circumstances, with your explicit written consent.
  2. Where we need to carry out our legal obligations or exercise rights in connection with employment. 
  3. Where it is needed in the public interest, such as for equal opportunities monitoring.
  4. Where it is necessary to protect you or another person from harm.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

SITUATIONS IN WHICH WE WILL USE YOUR SENSITIVE PERSONAL INFORMATION

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below.

  • We will use information about your physical or mental health, or disability status, to:
    • ensure your health and safety in the workplace;
    • assess your fitness to work; 
    • provide appropriate workplace adjustments; 
    • monitor and manage sickness absence; and 
    • administer benefits. 

We need to process this information to exercise rights and perform obligations in connection with your employment.

  • If we reasonably believe that you or another person are at risk of harm and the processing is necessary to protect you or them from physical, mental or emotional harm or to protect physical, mental or emotional well-being.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation to ensure meaningful equal opportunity monitoring and reporting.

INFORMATION ABOUT CRIMINAL CONVICTIONS

We may only use information relating to criminal convictions where the law allows us to do so. This is usually where that processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy.

We do not envisage that we will hold information about criminal convictions. 

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. 

AUTOMATED DECISION-MAKING

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

  1. Where we have notified you of the decision and given you one month to request a reconsideration.
  2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
  3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means. However, we will notify you in writing if this position changes.

DATA SHARING

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Third parties include third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: payroll pension administration,] [benefits provision and administration, and IT services. 

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

DATA RETENTION

XPEL retains your personal data no longer than is reasonably necessary for the purposes for which it was collected and processed and in accordance with XPEL’s data retention policy, except as required by applicable law or to comply with our legal obligations, resolve disputes, and enforce our agreements. 

To determine the appropriate retention period for personal data, we consider: 

  • The amount, nature and sensitivity of the personal data.
  • The potential risk of harm from unauthorised use or disclosure of your personal data
  • The purposes for which we process your personal data and whether we can achieve those purposes through other means.
  • The applicable legal requirements. 

In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use that information without further notice to you. Once you are no longer an employee, worker or contractor of the company, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

EUROPEAN UNION DATA PROTECTION RIGHTS AND ADDITIONAL INFORMATION

Employees in the European Union are afforded specific rights under the EU’s General Data Protection Regulation (“GDPR”).  These rights are discussed in Appendix A to this Privacy Notice.  Additional information for employees in the European Union is described in Appendix B to this Privacy Notice.

CHANGES TO THIS PRIVACY NOTICE

XPEL may change this Privacy Notice from time to time.  The current version will always be available from XPEL in hard copy and on XPEL’s intranet. Changes and additions to this Privacy Notice are effective from the date they are posted to XPEL’s intranet.  

CONTACT INFORMATION

If you have any questions regarding this Privacy Notice, your rights, or XPEL’s use of your personal data, please email privacy@xpel.com or call (833) 258-2058.

APPENDIX A

Employees in the European Union, unless otherwise provided in the GDPR, have the following rights related to your personal data:  

  • The right to request a copy of your personal data which the XPEL holds about you.
  • The right to request that XPEL correct any personal data if it is inaccurate or out of date. 
  • The right to request your personal data be erased where it is no longer necessary for XPEL to retain such data. 
  • The right to restrict the processing of personal data. 
  • The right to receive the personal data you provided XPEL in a structured and commonly used format so that it can be transmitted to another data controller.  
  • The right object to the processing of personal data.
  • If consent to process personal data was obtained by XPEL, the right to withdraw your consent to the processing at any time. 

Please note that the above rights are not absolute, and XPEL may be entitled by law to refuse or limit the requests.  

EXERCISING YOUR RIGHTS

You can exercise any of your rights as described in this Privacy Notice and under applicable data protection laws by contacting XPEL as provided in the Contact Information section.

Where XPEL has reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

APPENDIX B

TRANSFER OF DATA ABROAD

In connection with your employment, XPEL may transfer your personal information outside of the EEA to our related or affiliated entities and our third-party service providers located outside the EEA. This includes the USA.

Where personal information is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal information, XPEL takes the necessary steps to provide appropriate safeguards to protect your personal information.

If you want further information on the specific mechanism used by XPEL when transferring your personal information out of the EEA, please contact us using the contact information in the Contact Information section. 

LODGING A COMPLAINT

XPEL only processes your personal information as described in this Privacy Notice and in accordance with applicable data privacy/protection laws.  If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information please contact us as provided in the Contact Information section.

Employees in the European Union also have the right to complain to your local Data Protection Authority.  A full list of National Data Authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en. 

Last Modified on: June 28, 2024