Effective date:  January 10, 2020
Last Reviewed: January 1, 2023

California Employee Privacy Notice

Mercedes-Benz Research and Development North America, Inc., including its affiliates (“MBRDNA,” “we,” “us,” or “our”) provides this California Employee Privacy Notice (“Notice”) to notify you of our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”).

This Notice applies only to individuals residing in the State of California who are considered “Consumers” (as defined in the CCPA) – namely, job applicants, employees, and contractors of MBRDNA – from whom we collect “Personal Information” (as defined in the CCPA). When we refer to Consumers, we mean you to the extent you are a California employee, employee applicant, or contractor of MBRDNA.

1. Categories of Information We Collect

We may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, in physical locations, through the mail, and/or over the telephone. MBRDNA collects the following categories of Personal Information, including Sensitive Personal Information, from Consumers:

Personal Information Category Examples Collected Business Purpose for Collection
A. Identifiers A real name, alias, postal address, telephone number, mobile device ID, Internet Protocol address, email address, Social Security number, driver’s license number, passport number. Yes For administrative employment purposes.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, medical information, or health insurance information. Yes For administrative employment purposes.
C. Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Yes For administrative employment purposes.
D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes For administrative employment purposes.
E. Biometric information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Yes For administrative employment purposes.
F. Internet or other electronic network activity information Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes For administrative employment purposes.
G. Geolocation data Physical location or movements. Yes

For administrative employment purposes.

 

For research and development purposes when related to your job duties or when you opt-in.

H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. Yes For administrative employment purposes.
I. Professional or employment-related information. Current or past job history or performance evaluations. Yes For administrative employment purposes.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Yes For administrative employment purposes.
K. Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes For administrative employment purposes.

 

Sensitive Personal Information Category Examples Collected Business Purpose for Collection
A. Government identifiers Social security, driver’s license, state identification card, or passport number. Yes For administrative employment purposes.
B. Complete account access credentials Account log-in, financial account, debit card, or credit card number combined with required security or access code, password, or credentials allowing access to an account. Yes For administrative employment purposes.
C. Precise geolocation Geolocation within a radius of 1,850 feet. Yes

For administrative employment purposes.

 

For research and development purposes when related to your job duties, or when you opt-in.

D. Racial or ethnic origin, religious or philosophical beliefs, or union membership   Yes For administrative employment purposes.
E. Mail, email, or text message contents not directed to MBRDNA Contents of any message that is not sent to MBRDNA. Yes For administrative employment purposes.
F. Genetic data Data pertaining to your DNA or genes. Yes For administrative employment purposes.
G. Uniquely identifying biometric information Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. Yes For administrative employment purposes.
H. Health information   Yes For administrative employment purposes.
I. Information relating to sex life or sexual orientation   Yes For administrative employment purposes.

Personal information does not include:

  • Publicly available information or lawfully obtained, truthful information that is a matter of public concern.
  • Deidentified or aggregate consumer information.

2. Categories of Sources of Personal Information

MBRDNA obtains the categories of Personal Information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or services we provide you.
  • Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications.
  • Third parties. For example, from recruiters who submit your information to us for an employment position that may interest you and consumer reporting agencies for employment background checks.

3. Retention of Personal Information

MBRDNA retains each category of Personal Information listed above only for as long as necessary to fulfill the business purpose for which it was collected. Once it is no longer useful for the business purpose, it is either anonymized or deleted.

4. How We Use Personal Information

MBRDNA may use the Personal Information identified above for one or more of the following business purposes:

  • To Meet the Purpose For Which You Provided the Information. For example, if you share your name and contact information to apply for a job, we will use that Personal Information in connection with your employment or employment application.
  • To Contact You, including to inform you about benefits or information relating to your employment or employment application.
  • To Provide Human Resources Management Services, including but not limited to hiring, conducting background checks, onboarding new employees, managing and maintaining employer-employee relations, managing MBRDNA relations with independent contractors, providing employee training and development, undertaking internal research, termination, separation, payroll, reimbursement, and other functions related to employment or potential employment with MBRDNA.
  • To Administer Benefits, including to maintain group health insurance benefits, 401(k) and retirement plans, leaves of absence, and other MBRDNA benefits, as applicable.
  • To Maintain Your Information, including to secure personnel files, emergency contact information, customize, and secure your information or account with us.
  • To Support and Develop MBRDNA’s Website and Human Resources Systems, including services relating to your employment or employment application.
  • To Process Requests, including to process transactions and prevent transactional fraud.
  • To Provide Support, including to respond to your inquiries, to investigate and address your concerns, and monitor and improve our responses.
  • To Maintain the Security of Our Systems, including the app or website, services, databases and other technology assets, data, and business.
  • To Ensure a Safe Working Environment, including to protect the rights, property, or safety of MBRDNA, its personnel, guests, or others.
  • For Research, Analysis, and Business Development, including to develop and improve our business processes, website, products and services.
  • To Comply with Applicable Law or Regulations, such as to respond to law enforcement requests, or to comply with laws related to records retention and employer reporting obligations.
  • To Evaluate or Conduct a Merger, including divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all MBRDNA’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by MBRDNA is among the assets transferred.

5. How We Disclose Personal Information

We may disclose your Personal Information to third parties for business purposes.  When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.  In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

Personal Information Category

Examples

Disclosed

Business Purpose for Disclosure

A. Identifiers

A real name, alias, postal address, telephone number, mobile device ID, Internet Protocol address, email address, Social Security number, driver’s license number, passport number.

Yes

For administrative employment purposes.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, medical information, or health insurance information.

Yes

For administrative employment purposes.

C. Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Yes

For administrative employment purposes.

D. Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

For administrative employment purposes.

E. Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Yes

For administrative employment purposes.

F. Internet or other electronic network activity information

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Yes

For administrative employment purposes.

G. Geolocation data

Physical location or movements.

Yes

For administrative employment purposes.

 

For research and development purposes when related to your job duties or when you opt-in.

H. Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

Yes

For administrative employment purposes.

I. Professional or employment-related information.

Current or past job history or performance evaluations.

Yes

For administrative employment purposes.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Yes

For administrative employment purposes.

K. Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

For administrative employment purposes.

 

Sensitive Personal Information Category

Examples

Disclosed

Business Purpose for Disclosure

A. Government identifiers

Social security, driver’s license, state identification card, or passport number.

Yes

For administrative employment purposes.

B. Complete account access credentials

Account log-in, financial account, debit card, or credit card number combined with required security or access code, password, or credentials allowing access to an account.

Yes

For administrative employment purposes.

C. Precise geolocation

Geolocation within a radius of 1,850 feet.

Yes

For administrative employment purposes.

 

For research and development purposes when related to your job duties or when you opt-in.

D. Racial or ethnic origin, religious or philosophical beliefs, or union membership

 

Yes

For administrative employment purposes.

E. Mail, email, or text message contents not directed to MBRDNA

Contents of any message that is not sent to MBRDNA.

Yes

For administrative employment purposes.

F. Genetic data

Data pertaining to your DNA or genes.

Yes

For administrative employment purposes.

G. Uniquely identifying biometric information

Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

Yes

For administrative employment purposes.

H. Health information

 

Yes

For administrative employment purposes.

I. Information relating to sex life or sexual orientation

 

Yes

For administrative employment purposes.

To the extent permitted by applicable law, your Personal Information may be disclosed to the following categories of third parties:

  • to our affiliates for the purposes described in this Privacy Notice
  • to our third-party service providers who provide services such as payroll and benefits providers
  • to a third party in the event of any direct or indirect reorganization, including merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)
  • to a third party where we either aggregate, anonymize, de-identify or otherwise strip data of all personally identifiable characteristics
  • in connection with the essential purposes described above (e.g., to comply with legal obligations)

In the preceding twelve (12) months, MBRDNA has not “sold” or “shared” Personal Information, as those terms are defined in the CCPA.

6. How to Access and Control Your Personal Information

If you are a resident of the State of California and upon a verified request, you may request:

(1) the correction, update, or deletion (subject to certain exceptions) of your Personal Information,(2) the categories of Personal Information MBRDNA has collected,
(3) the categories of sources from which MBRDNA has collected your Personal Information,
(4) the business or commercial purpose(s) for collecting and disclosing your Personal Information,
(5) a copy of your Personal Information retained by MBRDNA, to be delivered in a structured, commonly used and machine readable format to review or to transfer or transmit to another entity without hindrance, to the extent that that is technically feasible,
(6) the categories of third parties with whom MBRDNA shares your Personal Information, and
(7) the specific pieces of Personal Information MBRDNA has collected about you, and
(8) to limit the use and disclosure of sensitive information.

Please note that under the CCPA as amended by the CPRA, you have the right to opt-out of the sale of your Personal Information to third parties, however, MBRDNA does not “sell” Personal Information, as that term is defined in the CCPA. You also have the right to opt-out of “sharing” your information for advertising purposes, however, MBRDNA does not share your information for advertising purposes as it is defined in the law.

We may need you to provide additional information to verify your request, such as providing certain data elements so that we can confirm they match the Personal Information already maintained by us.  We will not use this additional information for anything other than handling your request.  You may designate an authorized agent to make a request in certain circumstances on your behalf.  Such authorized agent must be registered with the California Secretary of State.  We endeavor to respond to all such requests within forty-five (45) days, although there may be a brief delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party.  If we require more time, we will inform you of the reason and extension period in writing.  We will not discriminate against you for exercising your rights.

Any of the above requests may be made by contacting us at:
Attn: Data Protection
MBRDNA
309 North Pastoria Avenue
Sunnyvale, CA USA 94085
data.protection.mbrdna@mercedes-benz.com
Toll-free number: 1-888-655-1703

Please refer to “California Employee Privacy Notice” in your message.

7. Changes to Our California Employee Privacy Notice

MBRDNA reserves the right to modify this Notice at our discretion and at any time.  Please review it occasionally to keep up to date on our privacy practices.  If MBRDNA makes changes to this Notice, the updated page will be posted in a timely manner and the date at the top of the Notice will reflect the date it was last updated.