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Job Applicant Privacy Statement

Effective Date: July 1, 2023

Thank you for your interest in employment with Total Wine & More! This Job Applicant Privacy Statement (the “Statement”) applies to personal information Retail Services & Systems, Inc. d/b/a Total Wine & More, and their U.S.-based affiliated companies doing business under Total Wine & More brands and associated brands (collectively referred to as “Total Wine”) collect in connection with applications for employment with Total Wine, including those submitted via our websites, mobile apps, or other digital interfaces. This Statement applies to individuals who are applying for employment with Total Wine within the United States.

Statement table of contents

  1. Acceptance of and changes to this Statement
  2. Recruiting SMS text messaging terms
  3. Personal Information we collect and process
  4. How your Personal Information is collected
  5. How we use your Personal Information
  6. How we disclose and share your personal information
  7. How we protect your personal information
  8. Retention
  9. Cookie policy and opting out
  10. Additional notice to California residents
  11. How to contact us

1. Acceptance of and changes to this Statement

As Total Wine continues to improve the services, products, and features we provide, this Statement is subject to change. We reserve the right to amend this Statement at any time by posting the amended statement on our website and updating the Effective Date at the top of this page.

By using the Total Wine site and services, you signify your acceptance of this Statement. If you do not agree with any position or statement herein, your sole option is to discontinue use of the Store or Sites. Your continued use of any portion of the Stores or Sites following notification or posting of such changes constitutes your acceptance of those changes. If you have questions or concerns about our specific policies, please send an e-mail to privacy@totalwine.com.

2. Recruiting SMS text messaging terms

By providing your mobile phone number as part of your Total Wine employment application and clicking “Submit,” you are enrolling in the Total Wine recruiting text messaging program and expressly consent to receive text messages from Total Wine & More or others texting on its behalf to your phone number(s).

You agree that you are the account holder for the phone number provided or have the account holder’s consent to enroll and are at least 18 or older. The Total Wine recruiting text message program is a multiple message program that delivers information about how to apply for Total Wine & More jobs and information about the recruiting process, such as your scheduled interview time or information about a job offer or job orientation if you are selected for a position. The texts will be sent via automated technology. You may opt out at any time by texting STOP to the number sending the message or any text reminder. After you text “STOP” you will receive one additional SMS message to confirm that you have been unsubscribed. If you would like to join or opt-in again, you can sign back up by texting “START” to any text reminder and you will start receiving messages from Total Wine recruiting again. For help on this specific program, please email careers@totalwine.com or contact your local Total Wine & More store.

Carriers are not liable for delayed or undelivered messages. Message and data rates may apply. If you have any questions about your text plan or data plan, please contact your wireless provider. If you have any questions regarding privacy, please read the below Job Applicant Privacy Policy.

3. Personal Information we collect and process

We collect Personal Information that you provide during the application process, which may include the following:

  • Contact information, such as your name, postal and email addresses, and phone numbers;
  • Identification information, such as your name, signature, date of birth, postal address, physical address, personal email address, personal phone numbers, social security number, government issued ID information, and identifiers and login credentials associated with our Careers website;
  • Your work experience (e.g., employment history, company, location and contact details, job title, start and end date, supervisor name), educational background (e.g., school/university, location, highest level of education, major area of study, graduation year, degree, GPA), professional certifications, relevant prior trainings or courses, confirmation of reliable transportation, language capabilities, your area/department/role of interest within Total Wine, total compensation expectation, work schedule preferences, first possible start date, the fact that you might be subject to a non-compete, applicable termination/notice periods, restrictive covenant or any other agreement that might affect your ability to accept a position and work at Total Wine, references, letters of recommendation, interview notes, the source you heard about the job vacancy, and availabilities to schedule an in person interview;
  • Volunteering experience, family members who work at Total Wine and the nature of your relationship to them, your right to work in the United States and/or your selected location, and any limitations on your right to work associated with your employment sponsorship, if applicable;
  • Information related to demographics or protected characteristics, such as your age and gender and gender identity should you choose to provide it;
  • Photo(s);
  • Video recording of interviews and assessments of video interviews;
  • The results of other application-related assessments;
  • Commercial Information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Inferences about you or these information categories that may reflect your: preferences, characteristics, predispositions, behavior, attitudes, skills, abilities, or aptitudes; and
  • We may collect minimal sensitive personal information, as defined in the applicable state privacy laws, but only with your consent.  Such minimal sensitive personal information consists of your social security number  and account passwords used to access the career website, which are encrypted and inaccessible to the Total Wine in the ordinary course of business.  We do not use sensitive personal information for inferring characteristics about you.

You may have the option to add attachments or further information (e.g., a CV or Resume, a cover letter or message, certifications or skills, language capabilities or a letter of recommendation) which might contain additional personal information. Such attachments and further information will be treated in the same way as other personal information you provide to us during the application process.

We may collect certain additional information that is not part of your application, such as military and/or veteran status, race/ethnicity, your ability to perform expected physical requirements of the position for which you are applying, medical conditions if disclosed to us, physical limitations or other medical or health-related workplace accommodations, the results of background screening searches including credit and criminal background checks, educational background checks, drug and alcohol testing, and other pre-employment screenings.

Please also refer to the “How we collect your Personal Information” section of our Privacy Policy for additional information.

We also may collect device and browsing information, including information about your phone, tablet, computer, or device, and online browsing activity. This information may include IP addresses, unique device identifiers, cookie identifiers, device and browser settings and information, geolocation information, and Internet service provider information. It also may include information about when and how you access and use our website, such as the date and time of your visit or use, the websites you visit before coming and after leaving our website, how you navigate and what actions you take on our website, and jobs you view or apply for.  Please refer to the “Notice of cookies & clickstream technology, including opting out” section of our Privacy Policy for additional information, including details on how to opt-out of cookies through your browser settings and other means.

4. How your Personal Information is collected

We collect most of your Personal Information directly from you – in person, by telephone, or email, or through systems that facilitate collection of information from you (e.g., the online administrative systems for employment applications, benefits, 401(k), and more), for example. However, we may also collect Personal Information:

  • From publicly accessible sources (e.g., court records, social media sites, social networking sites);
  • Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers); and
  • Indirect or passive sources (e.g., cookies on our Sites; our IT systems; building security systems; etc.).

If you chose a third party to submit your application for positions with Total Wine or to fill out your application for you, we may receive information about you, which might contain additional personal information. Such information will be treated in the same way as other personal information you provide to us during the application process.

Please also refer to the “How we collect your Personal Information” section of our Privacy Policy for additional information.

5. How we use your Personal Information

We use this information to assess your qualifications for employment and other related services during the application and recruitment stage. This includes contacting you after you have applied, contacting references that you have provided as well as potentially carrying out background checks. We may also contact you about any other jobs we think may be of interest to you. We also may use your information to comply with any applicable legal obligations, internal record-keeping, reporting, analytics-related obligations, as well as to establish, exercise or defend against any legal claims.

Please also refer to the “How we use your Personal Information” section of our Privacy Policy for additional information.

6. How we disclose and share your Personal Information

In order to carry out the application and recruitment process under this Statement, your information may be shared with other Total Wine employees such as your potential manager(s), members of the human resources team as well as other individuals within Total Wine. Your information also may be shared with various third parties that assist us during the recruitment process. For example, we use third party service providers to collect your information as well as for other services such as carrying out background checks, work-related assessments or pre-employment screenings. We may also share information with third parties when we believe in good faith that the disclosure is required to comply with a verified request we receive from you, or a court order, subpoena, warrant or legal process.

We only allow our service providers to handle your Personal Information if we are satisfied, they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers relating to ensure they can only use your Personal Information to provide services to us and to you.

We may also share your information in the event of a merger, acquisition, asset sale or other related transaction, or when we believe in good faith that disclosure is required by law or to protect the safety of our employees, the public or Total Wine property.  We will typically anonymize Personal Information, but this may not always be possible.

For students, we may share information with your university in order to verify your application and/or employment status at your or your university’s request.

Please also refer to the “How we disclose your Personal Information” section of our Privacy Policy for additional information.

7. How we protect your Personal Information

We aim to protect Personal Information by implementing and maintaining reasonable security, such as by using reasonable organizational, technological, and physical safeguards appropriate to the sensitivity of the Personal Information we hold. We take commercially reasonable measures to safeguard your Personal Information, but we cannot guarantee its absolute security.  Please also refer to the “Security of your Personal Information” section of our Privacy Policy for additional information.

8. Retention

Total Wine will retain the personal information that we process pursuant to this Statement for the duration of time necessary to assess your qualifications for employment, and for the period of time thereafter as provided in our retention policies. You may also elect to have your information remain with Total Wine, for example, if you continue to maintain a career profile on one of our websites.

9. Cookie policy and opting out

Like many companies, we use cookies on our Sites. Cookies are pieces of information shared between your web browser and a website. Use of cookies enables a faster and easier experience for the user.  Please refer to the “Notice of cookies & clickstream technology, including opting out” section of our Privacy Policy for additional information, including details on how to opt-out of cookies through your browser settings and other means.

Our website may contain features that let you sign up to receive communications (such as mobile text messaging) about future Total Wine job openings, as well as communications about our brand. If you use sign up for these communications, you can opt-out of these communications at any time.

10. Additional notice to California residents

California law requires us to disclose the following additional information with respect to our privacy practices.  If you are a California resident, this section applies to you in addition to the rest of the Privacy Policy.

Shine the Light

Under California’s “Shine The Light” law (California Civil Code Section 1798.83), California residents may annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. However, no information is shared with third parties for their own marketing purposes except where expressly authorized by you.

Categories of Personal Information disclosed for business or commercial purposes over the last 12 months

We describe the Personal Information we have collected from California applicants in the 12 months preceding the effective date of this Statement in the part titled “Personal Information we collect and process,” above. This information may be shared to third parties and includes the following, which may or may not be part of your application, as specified in your application and this Statement:

  • Contact information, such as your name (first, middle, last), home address/country, telephone number and email address, your birth day and month, and your age;
  • Your work experience (e.g., employment history, company, location and contact details, job title, start and end date, supervisor name), educational background (e.g., school/university, location, highest level of education, major area of study, graduation year, degree, GPA), professional certifications, relevant prior trainings or courses, confirmation of reliable transportation, language capabilities, your area/department/role of interest within Total Wine, total compensation expectation, work schedule preferences, first possible start date, the fact that you might be subject to a non-compete, applicable termination/notice periods, restrictive covenant or any other agreement that might affect your ability to accept a position and work at Total Wine, references, letters of recommendation, interview notes, the source you heard about the job vacancy, and availabilities to schedule an in person interview;
  • Volunteering experience, family members who work at Total Wine and the nature of your relationship to them, your right to work in the United States and/or your selected location, and any limitations on your right to work associated with your employment sponsorship, if applicable;
  • Your gender, if you choose to provide it;
  • Information we need to provide you with an offer (e.g., compensation expectations, start date, job title);
  • Photo(s);
  • Video recording of interviews and assessments of video interviews;
  • The results of other application-related assessments; and
  • We may collect minimal sensitive personal information, as defined in the applicable state privacy laws, but only with your consent.  Such minimal sensitive personal information consists of account passwords used to access the Sites, which are encrypted and inaccessible to the Total Wine in the ordinary course of business.  We do not use sensitive personal information for inferring characteristics about you.

Categories of parties with whom we sell or share Personal Information sold or shared with over the last 12 months

We do not “sell” your Personal Information in exchange for money. However, California state law views the “sale” of Personal Information more broadly, to include any transfer to another business or third party for valuable consideration. During the 12-month period prior to the effective date of this Statement, and to carry out the application and recruitment process under this Statement, your information may be shared with other Total Wine employees such as your potential manager(s), members of the human resources team as well as other individuals within Total Wine. Your Personal Information also may be shared with various third parties that assist us during the recruitment process. For example, we use third party service providers to collect your information as well as for other services such as carrying out background checks, work-related assessments or pre-employment screenings. We may also share information with third parties when we believe in good faith that the disclosure is required to comply with a verified request we receive from you, or a court order, subpoena, warrant or legal process.

Your rights

As a California resident, you have rights related to the collection and use of your Personal Information.  You may exercise your rights through Total Wine’s Privacy Portal.

Right to Know Collected Personal Information

You have the right to know, and request disclosure of:

  • The categories of Personal Information we have collected about you, including sensitive personal information;
  • The categories of sources from which the Personal Information is collected;
  • Our business or commercial purpose for collecting, selling, or sharing Personal Information;
  • The categories of third parties to whom we disclose Personal Information, if any; and
  • The specific pieces of Personal Information we have collected about you.

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the Personal Information to you free of charge at a greater frequency than is required by California Law.
Right to Know Disclosed, Sold, or Shared Personal Information In connection with any Personal Information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
  • The categories of Personal Information about you that we sold or shared and the categories of third parties to whom the Personal Information was sold or shared; and
  • The categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom the Personal Information was disclosed for a business purpose.
Right to Opt-Out of Sale or Sharing You have the right to opt-out of the sale of your Personal Information or sharing of your Personal Information. If you exercise your right to opt-out of the sale or sharing of your Personal Information, we will refrain from selling or sharing your Personal Information, unless you subsequently provide express authorization for the sale or sharing of your Personal Information.
Right to Limit Use of Sensitive Personal Information

In California, you have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

  • Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
  • To perform the services in the “How we use your Personal Information” section above; and
  • As authorized by further regulation.
Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers or contractors to delete your personal information from their records.
  • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.

Please note that we may not delete your personal information if it is reasonably necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Correction If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

 

 

11. How to contact us

Phone: 1-855-330-6673
Email: privacy@totalwine.com
Mail:

Total Wine & More, Store Support Center
6600 Rockledge Drive, Suite 150
Bethesda, MD 20817
Attn: Customer Care/Privacy