California Employee Privacy Notice
Last Updated: November 10, 2020

This California Employee Privacy Notice (“CA Privacy Notice”), provided by Cresco Labs, LLC on its own behalf or in combination with one of its affiliates or subsidiaries (referenced as “Cresco”, “us”, “we”, “our”, the “Company”), is intended to provide California residents who are either a job applicant or as an employee of the Company, with notice of Cresco’s policies regarding the collection, use, and disclosure of personal information under the California Consumer Privacy Act of 2018 (“CCPA”).

We will not use or share your information with anyone except as described in this CA Privacy Notice and our Privacy Policy.

Please access and review this CA Privacy Notice to understand the categories of personal information that may be collected or may have been collected in the past twelve (12) months by Cresco and the reason the information was collected.

PERSONAL DATA WE COLLECT AND USE
While applying for a job with Cresco or while an employee of Cresco, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personal Identifiable Information (“PII”) is generally information that identifies, relates to, or could reasonably be linked with you or your household; however, PII does not include publicly available information that is from federal, state, or local government records, such as professional licenses and public real estate or property records. Examples of PII include, but are not limited to:
• Your first and last name;
• Residential address;
• Email address;
• Phone number;
• Occupational role;
• Company name;
• Social security number;
• Passport number;
• Date of Birth;
• Internet Protocol (“IP”) address;
• Geolocation data;
• Biometric data (e.g., fingerprints)
• Records of products purchased;
• Contact Details (e.g., telephone number, fax number, e-mail address, social media account); or
• Other information you voluntarily provide.

Cresco will only collect PII that you provide to us, or that we are authorized to obtain by either you or in accordance with applicable law. The types or forms of PII that we may collect from you will vary and be dependent on how you are interacting with Cresco as either a job applicant and/or an employee.

Employment Opportunities Listed Online
When a job applicant responds to a posted employment opportunity on a Cresco website and requests that the Company contact the job applicant, we may collect the job applicant’s name, email address and/or phone number to fulfill the request. In addition, using the internet your browser sends information (“Log Data”) whenever you visit our websites. Log data may include information such as your computer’s IP address, browser type, browser version, the pages of our websites that you visit, the time and date of your visit, the time spent on those pages and other statistics. Please see the Privacy Policy and Terms of Service maintained on each website for more information on Log Data, IP addresses and cookies.

Applying for Employment On or Offline
When a job applicant is asked to complete a job application, Cresco may collect from the applicant PII including but not limited to: name (and prior name(s) used), residential address, email address, phone number, emergency contact information, employment availability and work eligibility information, educational history, employment history, prior work performance, personal references, and a valid driver’s license. As part of the Company’s pre-employment process, we may collect information necessary and to pay your wages, and may also expect that you review certain policies or complete certain trainings and sign an acknowledgement indicating that you have done so.
During Employment

As an employee, in addition to the information collected through the job application as described above, Cresco may collect from the employee additional PII including but not limited to: photos, internal and external contact information, biometric data including imagery or mathematical representations of your fingerprints, face or voice recordings, information to process payroll including bank information for direct deposit, evaluate reimbursement requests, or apply for available benefits including personal information of family members which may be needed for benefit administration, information for employment related taxes, social security numbers, I-9 information, any information you provide when submit a request under FMLA or another law, information captured from video, audio, systems, or other forms of monitoring or surveillance, and any other information you have chosen to provide to Cresco.

Vendors, Suppliers and others Doing Business with the Company
When working with vendors, suppliers, and others doing business with Cresco, we may collect employment related information as described above on our behalf to provide pre-employment and employment services to the Company.

HOW WE USE YOUR INFORMATION
Cresco takes data privacy and data security very seriously. We only collect and use information in the employment context from job applicants and employees which is necessary to conduct our business operations, providing our services in accordance with applicable laws and regulations, identifying and communicating with you, and responding to requests or inquiries. Cresco collects employee PII as described above, for the following purposes:
• To contact you about employment opportunities and recruit employees;
• To consider your job application;
• To administer available benefits, including recording and processing eligibility of dependents, absence and leave monitoring, and insurance and accidental management;
• To process your payroll including payment of expenses or other compensation related payments;
• To conduct performance-related reviews;
• To monitor work-related required licenses and credentials;
• To maintain your contact information and assist you in the case of any emergency;
• To monitor your eligibility to work in the United States;
• To respond to requests from the employee’s recognized union representative; and
• To comply with any other applicable laws, regulatory requirements or legal requests.

HOW WE SHARE INFORMATION
We do not sell your PII to others.
We may share information about you to a third-party if the disclosure is reasonably related to performance of our business. These third parties and service providers can be classified in the following:

Affiliates/subsidiaries
Your PII may be disclosed with our locations, subsidiaries, affiliates such as JDRC Managed Services, LLC and CannaRoyalty Corp. In the event your information is shared, we will share only the information that is necessary.

Third-parties or Agents
Your PII may be disclosed to a third-party or agent (e.g., payroll and benefit services, IT support, Human Resources, etc.) in order to provide some of our services. These third-parties or agents have access to your PII only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.

Legal Requests
Your PII may be disclosed to a third-party if we are required to disclose because of contractual responsibilities, tax or audit requirements, court order, government regulation, applicable law, or if such disclosures is otherwise deemed necessary in support of any legal investigation or proceeding.

Changes to the Business Structure or Ownership
Your PII may be disclosed or transferred to a third-party in the event of any reorganization, merger, sale, joint-venture, assignment, transfer, or other disposition of all or any portion of the Company’s business, assets or ownership interest (including any bankruptcy or similar proceedings).

CHANGES TO THIS POLICY
We reserve the right, in our sole discretion, to modify, update, discontinue or otherwise change any portion of this CA Privacy Notice and the Privacy Policy, in whole or in part, at any time; however, the Privacy Policy will be updated at least every twelve (12) months to reflect changes in our business, legal or regulatory obligations. For changes to the Privacy Policy that we deem material, we will notify you through an email notice or by placing a prominent notice on our website or by changing the date on this page noting when the CA Privacy Notice was last updated.
While applying for a job with Cresco or as an employee of Cresco indicates you have read, accepted, and agreed to Cresco’s privacy practices, as outlined in this CA Privacy Notice, Privacy Policy and any applicable terms. While applying for a job with Cresco or continuing employment with Cresco after the date of any amendments to Cresco’s privacy practices, you agree to be bound by the amended privacy practices.

CONTACT US
If you have any questions about this CA Privacy Notice, please contact us using any of the following options.
Mail : Cresco Labs, LLC Email : complianceoffice@crescolabs.com
Attn: Compliance Office
400 W. Erie Suite 110
Chicago, IL 60654