Workforce Privacy Notice at Collection

Effective: October 31, 2024

Overview

This Notice explains your rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”) (Cal. Civ. Code § 1798.100 et seq.) and helps you understand how Ono Management LLC, dba Ono Hawaiian BBQ collects, uses, and retains your Personal Information in compliance with California law.  In this Notice, the terms “Company,” ”us,” “we,” “Ono,” and “our” refer to Ono Management LLC, dba Ono Hawaiian BBQ, and its affiliates and subsidiaries.

Who This Notice Applies To

The CPRA provides a right to notice at the collection for certain California residents, including current and former employees, and owners/officers/directors (“Workforce” or “you”); emergency contacts provided by Workforce; and individuals/dependents of Workforce whose Personal Information is provided to administer benefits.

This notice does not cover:

  • Your interactions with Ono outside the employment context, such as browsing Ono’s website or dining at one of our restaurants.  To learn more about how we collect and use information related to those types of interactions, please see our Ono Privacy Policy.
  • Job applicants. To learn more about how we collect and use information when you apply for a job with us or our recruiting purposes, please see our Ono Applicant Privacy Policy.

What We Collect

As further described below, Ono collects your Personal Information in connection with your employment with the Company.  Your “Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.  Personal Information does not include publicly available information from government records, de-identified information, or aggregated data.

As described in greater detail below, we collect Personal Information in the following ways:

  • Directly from You. We may collect Personal Information directly from you, such as during the job application or onboarding process, during your employment, and/or when you experience a change in your employment status with the Company.
  • From Third Parties. We may collect certain Personal Information about you from third parties. For example, this includes vendors that run background checks, vendors that administer the Company’s leave of absence and disability benefits, and references you provide to us.  Other employees may provide us with information about you, such as performance or evaluation information from a manager or supervisor. We may combine information that we collect from different sources.
  • When You Visit Our Locations.  When you visit our restaurants or facilities, we also collect identifiers and audio/visual data.
  • Automatically. When you access our networks, we collect system log data such as your IP address, browser type and language, device information, access times, and referring website addresses.

Please note that Personal Information does not include information based on activities performed on Ono assets. You do not own or have an expectation of privacy or rights under the CPRA regarding the following:

  1. Company information created, collected, or maintained on any technology assets owned, leased, or operated in whole or in part by the Company. The Company’s technology assets consist of all electronic devices, software, and means of electronic communication, including, but not limited to, Point of Sale systems, computers, and workstations, laptop computers, computer hardware, as well as computer software applications, associated files, and data that grant access to services like the internet, email, phone, voicemail, and instant messages. All information created, collected, or maintained by the Company’s technology assets is company property and provided to you solely for your use in conducting Company business.
  2. Company information Ono collects when monitoring premises, equipment, devices, computers, networks, applications, software, or similar company assets and resources to protect its worksites, employees, and computer systems.

Categories of Personal Information

The following discusses the categories of Personal Information we collected in the last twelve (12) months. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different purposes without first providing you notice.

  • Personal Identifiers.  We collect your name, online identifiers such as your account username and password associated with our systems, telephone numbers, email addresses, home and postal addresses, signature, and emergency contact information from you during our application and onboarding processes, and if you update your information with us.  We also collect your internet protocol (“IP”) address if you use a device to access our network.  Additionally, we collect your social security number or tax identification number, driver’s license or state identification card number, passport number, or other I-9 documentation to show your identity and authorization to work.
  • Characteristics of Protected Classifications Under California or Federal Law.  We may collect your date of birth, age, gender identity, race, racial, ethnic, or national origin, citizenship and immigration status, veteran or military status, disability information, marital status, or pregnancy and related information if you provide this information as part of your application, during onboarding, or while working at Ono.
  • Audio, Visual, or Similar Information.  We may collect information that may be used to identify you to other employees and/or our security personnel, such as your employee photograph or CCTV security camera recordings.  We may also take photographs or video recordings of you as part of our internal and external marketing efforts.  We collect those messages if you communicate with us through text or other instant messages.
  • Biometric Information.  If you leave a voicemail message with us, we collect your voice recordings to establish your identity and determine the nature of your request or message.  If you work at one of our restaurants or facilities that uses biometric time clocks, we collect your fingerprints to establish your identity when you use those time clocks.
  • Professional or Employment-Related Information. We collect information related to your employment history and resume during the application and background check process.  Additionally, we collect information from you during your employment with us, such as dates of employment, your work attendance, and records pertaining to your work performance.
  • Education Information. We collect your education history from you as part of your application and background check process or if you update your information with us.
  • Financial Information.  We collect financial information, including when you provide us with your bank account information to process payroll.
  • Health Insurance Information.  We collect health insurance information, such as your dependent or spouse's information, to process your health insurance enrollment and manage your benefits.
  • Medical Information. To the extent provided to us and to the extent permitted and required by applicable laws, as part of our benefits administration, we may collect information about your health, medical and treatment history, diagnoses, dates of service, provider name, and ability to work.
  • Internet or Other Electronic Network Activity & Analytics or Monitoring Data. If you use a device to access our network, we collect system log data like IP address, browser type and language, device information, access times, and referring website addresses as part of our system management and investigations into irregular, unauthorized, or unusual activity on our systems.

The following forms of data listed above constitute “Sensitive Personal Information”: Your social security, driver’s license, state identification card, and passport number; your bank account information; your racial, ethnic, and national origin; your biometric information; your citizenship and/or immigration status, and your health information, if provided to us.  We do not use or disclose Sensitive Personal Information, as defined by California law, for inferring characteristics or for purposes other than those permitted by law.

How We Use the Information We Collect

We use the Personal Information we collect for the following purposes:

  • Onboarding.  We use Personal Information to complete new hire paperwork, enroll you in our HR system, and set up your personnel file.
  • Benefits.  We use the Personal Information we collect to create benefits packages and, if eligible, provide you with employee benefits through third-party benefits administrators.
  • Payroll.  We use Personal Information to manage and pay you for services provided.
  • Leave and Accommodation Requests. We use the Personal Information we collect to evaluate and process time off, sick leave, leaves of absence, or accommodation requests if you make such requests.
  • Training, Performance Reviews, and Goals Monitoring. We use the personal information we collect to provide you with relevant training and feedback and support your career development.
  • Marketing.  We use the Personal Information we collect to engage in internal and external marketing efforts, but our use of Personal Information for external marketing efforts is only done with your affirmative consent.
  • Business Operations. We use Personal Information to guide our recruiting and hiring process, maintain files, and support our business operations and the operations of our parent(s), subsidiaries, and affiliates.
  • Security and Crime Prevention. We use Personal Information to secure our facilities and networks by monitoring access, conducting periodic security checks, and limiting access to our facilities.
  • Legal Compliance and Protection. We use the information we collect to comply with applicable laws and our legal obligations and to defend our company, property, and others in legal proceedings.

Please note that some of the internally provided applications and services we make available to you also include integrations, references, or links to services provided by providers whose privacy practices differ from ours. If you provide Personal Information via these integrations, references, or links or allow us to disclose It to them, that information is governed by their privacy statements.  Finally, we may share de-identified information in accordance with applicable law.

Additional Rights Under California Law

You may have certain rights under California law.  This may include a right to access, correct, or delete employee data, subject to applicable exceptions.  For example, we may retain your employee data to comply with legal obligations. To exercise your rights, contact us as described at the end of this notice to submit a request. Under California law, we are required to tell Californians if we “sell” or “share” Personal Information as that term is defined by applicable law.  Sell is defined under the law as disclosing personal information to a third party for monetary or other valuable consideration.  Share is specifically defined under the law as well.  Sharing means sharing Personal Information with a third party for cross-context behavioral advertising.

We do not “sell” or “share” employee data (including Personal Information and Sensitive Personal Information) based on our understanding of those terms. You may have different rights if you interact with the Company in other ways. For example, if you use our website, visit our privacy policy for information collection and rights for website users. If you are also an Ono customer or consumer, the privacy policy on our website applies to our interactions with you as a customer or consumer.

How We Retain Your Personal Information

To the extent permitted by applicable law, Ono will retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or other reporting requirements or obligations.  For example, we retain Personal Information in accordance with our obligations under applicable labor and employment law and as necessary to administer and carry out the employment relationship and our post-employment obligations.  We use the following criteria to determine retention periods:

  • How long the information is needed to provide our services and operate our business;
  • Whether there are contractual or legal obligations that exist that require us to retain the information for a period of time;
  • Whether any law, statute, or regulation allows for a specific retention period;
  • Whether an individual has agreed to a longer retention period;
  • Whether the data is considered to be sensitive data; and
  • What the expectation for retention was at the time the data was provided to us

How You Are Protected Against Discrimination & Retaliation

Ono will not unlawfully discriminate or retaliate against you for exercising your rights under the CPRA.  This commitment applies to all persons involved in our operations and prohibits unlawful discrimination or retaliation by any Company employee, including supervisors and coworkers.

How Other Ono Policies & Disclosures Apply

This Notice is in addition to the policies and disclosures in the Employee Handbook. If you are unsure whether this Notice applies to you, please get in touch with Human Resources at [email protected] or by phone at 909-594-3388.  This Notice does not form any part of any contract of employment.

Disclaimer

Nothing in this Notice restricts the Company’s ability to:

  • Comply with federal, state, or local laws;
  • Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
  • Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
  • Exercise or defend legal claims;
  • Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
  • Transfer Personal Information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of the Company.

Changes To This Notice

This Notice is reviewed and updated annually to ensure it accurately captures our practices and procedures.  In addition, from time to time, we may update this Notice to reflect changes required by law or our privacy practices or procedures.  The effective date for this version is posted in the footer below.  When we make material changes to this Notice, we will let you know by updating this Notice and the date at the footer of this Notice.

Privacy Policy

Our privacy policy for employees can be found here: https://onohawaiianbbq.com/Employee-privacy-policy.

Contact us

If you have questions about this Notice, please email [email protected] or call 877-236-9081.

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