At Milk Specialties Global (“MSG” or “Company”), we take the protection of our employees’ personal data seriously. This Employee Privacy Notice (“Notice”) describes how we collect, process, and share personal data about our employees and contractors during and after your work with us. 

1) Types of Data Collected 

The types of employee and contractor data that MSG collects (directly from you or from public or third-party information sources) and shares depends on the nature of your position and role within MSG and the requirements of applicable laws in a relevant jurisdiction. Examples of this information may include, among other things: 

• contact information such as name, address, phone number, and personal email address; 
• personal information (e.g., date of birth, marital status, birth place, nationality, race, citizenship, gender, religion, preferred language, immigration status); 
• employment, performance, compensation, and benefits information (e.g., hire date, job title, position, attendance, department, business unit, supervisor, site, union, objectives, projects, performance reviews and ratings, salary, bonus, awards, retirement, family member/dependents’ names and dates of birth); 
• education and training information (e.g., education level, field and institution; professional licenses and certifications; training courses); 
• social security number, passport number, or other national identification number; 
• driver’s license number, vehicle license plate number; 
• financial information (e.g., bank account information; tax information; payroll information); 
• medical information, including pregnancy, physical, and mental disability status; 
• leave of absence documentation; 
• employment history, letters of recommendation, and references; 
• work restrictions and accommodations; 
• agreements that you enter into with MSG; 
• insurance enrollment information; 
• computer or facilities access and authentication information; 
• computer and Internet activity, such as browsing history and search history; 
• grievance resolutions; and 
• photographs and other visual images of you. 

The examples provided are not all-inclusive. MSG has collected all of the above categories of personal information from employees and/or contractors during the preceding twelve months. Certain information that we collect from you is required in order to establish the employment or contractor relationship with you. 

2) Purposes of Collecting Personal Data 

The personal information that we collect is processed for MSG’s business purposes, including establishing, managing, or terminating your employment or contractor relationship with us. Such uses include: 

• determining eligibility for initial employment, including the verification of references, qualifications, criminal history, and driving record; 
• administering pay and benefits; 
• managing your employment or contractor relationship; 
• processing employee work-related claims (e.g. worker compensation, insurance claims, etc.); 
• accounting and auditing; 
• establishing training and/or development requirements; 
• conducting performance reviews and determining performance requirements; 
• assessing qualifications for a particular job or task; 
• staffing and succession planning; 
• benefit administration services; 
• gathering evidence for disciplinary action or termination; 
• conducting and managing internal and external investigations; 
• establishing a contact point in the event of an emergency (such as next of kin); 
• conducting regular business operations; 
• complying with applicable law, including without limitation labor or employment statutes; 
• ensuring the security of company information and property; 
• determining eligibility to drive for company business;
• prosecuting and defending claims, including without limitation pre-dispute activity;
• responding to law enforcement and other government or legal inquiries; and
• such other purposes as are reasonably required by MSG. 

The uses provided are not all-inclusive.  We may also process your personal data for our own legitimate interests, including for the following purposes: 

• To prevent fraud. 
• To investigate and enforce compliance with MSG policies and procedures. 
• To engage in corporate transactions requiring review of employee and independent contractor records, such as for evaluating potential mergers and acquisitions involving MSG. 
• To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution. 
• To support internal administration with our affiliated entities. 
• To perform workforce analytics, data analytics, and benchmarking. 
• To administer and maintain MSG’s operations, including for safety purposes. 
• For marketing purposes. 
• To exercise or defend the legal rights of MSG. 

You will not be subject to decisions based on automated data processing without your prior consent. We do not sell the personal information, including any sensitive personal information, we collect about our employees contractors or share it with third parties for cross-context behavioral advertising. 

3) Disclosing Personal Data 

MSG may share your personal data, including your sensitive personal data, with our employees, contractors, consultants, vendors, and other parties who require such information to assist us with establishing, managing, or terminating our employment relationship with you, including parties that (a) provide products or services to us or on our behalf or (b) collaborate with us in the provision of products or services to you. In some instances, such parties may also provide certain information technology and data processing services to us so that we may operate our business. We may share personal data with such parties both in and outside of your home country, and, as a result, your personal data may be collected, used, processed, stored, or disclosed in jurisdictions outside of your home country.

Whenever we share data with third parties, we require that they use your information only for the purposes we’ve authorized, and for the limited reasons explained in this Notice. We also require these third parties to protect your personal information to at least the same standards that we do. 

In addition, personal data may be disclosed or transferred to another party in the event of a change in ownership of, or a grant of a security interest in, all or a part of MSG through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Notice, unless you consent otherwise. 

Further, your personal data may be disclosed: 

• as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
• to comply with valid legal processes such as search warrants, subpoenas, or court orders;
• to protect the rights and property of MSG;
• during emergency situations or where necessary to protect the safety of a person or group of persons;
• where the personal information is publicly available; or
• with your consent where such consent is required by law.

4) Retention of Employee Data 

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data as provided in our document retention policy; for as long as necessary to fulfill the purposes we collected it for; as required to satisfy any legal, accounting, or reporting obligations; or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means. Please refer to the Milk Specialties Global Data Retention Policy. 

Under some circumstances we may anonymize or de-identify your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. 

5) Data Security 

MSG uses technical and organizational safeguards designed to secure personal data against accidental loss and unauthorized access, use, alteration, or disclosures. 

6) Rights of California Residents 

If you are an MSG employee or contractor residing in California, you have certain rights as a data subject. These include the rights to access your personal data, correct your personal data, and delete your personal data. If you are a California resident and you would like to exercise your 5 

rights, please contact us (or have your authorized agent contact us) by emailing hrhelp@milkspecialties.com or calling 800-323-4274. Please provide your name, contact information, your relationship to us, and the details of your request. MSG may request additional information from you to help us confirm your identity before processing your request. 

Applicable law may allow or require us to deny your request. If we deny your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions. You have the right not to be retaliated against for exercising any of these rights. 

Some of the data we collect about employees and contractors is required in order to maintain our employment and contractor relationships. If you inquire about deletion of certain data needed to maintain those relationships, MSG may be unable to delete that data and still continue the relationship with you as an employee or contractor. 

7) Cross-Border Data Transfers 

MSG stores personal data primarily within the geographic region where it is collected. In cases where personal data is processed outside of the area in which it was collected, we ensure your personal data is protected with appropriate safeguards in accordance with applicable privacy laws. We also use industry standard data protection measures to safeguard all international transfers of personal data through data protection agreements with our service providers. 

8) Changes to this Privacy Notice 

We reserve the right to update this Notice at any time. When material changes are made to this Notice, MSG will provide employees and contractors with subsequent notice if required by laws or regulations. 

9) Contact Us 

If you have questions about our data processing or this Notice, please contact us at hrhelp@milkspecialties.com or 800-323-4274. 

Effective Date: July 2023.