Privacy Policy

Contents

• Scope of this Policy
• Collection of Personal Information and Sensitive Personal Information
• Sources of Personal Information
• To Whom We Disclose Personal Information
• Reasons Why We Collect, Use, Retain, and Disclose Personal Information
• Retention of Personal Information
• Third Party Vendors
• Business Transfers
• Compliance with Law and Safety
• External Links
• Children Under the Age of 16
• How We Protect the Information that We Collect
• International Visitors
• Rights Under the CCPA and CPRA
• Consent to Terms and Conditions
• Changes to Our Privacy Policy
• Consumers With Disabilities
• Questions About the Policy

Scope of this Policy

Tlingit Haida Tribal Business Corporation (the “Company” or “we”) has developed this privacy policy for itself and its wholly-owned subsidiaries out of respect for the privacy of our customers, visitors to our website, job applicants, and independent contractors. This policy describes the personal information we collect, use, and disclose about individual consumers, job applicants, and contractors who visit or interact with this website, contract with us to provide services, apply for a position of employment, or otherwise interact or do business with us.

Whenever you visit our website, we will collect some information from you automatically simply by you visiting and navigating through this site, and some voluntarily when you submit information using a form on the website, enroll in or subscribe to our newsletter or marketing communications, request information, or use any of the other interactive portions of our website. Through this website, we will collect information that can identify you and/or your activity.

Additionally, whenever you communicate, interact, or do business with us, we will be collecting personal information from you or about you in the course of our interaction or dealings with you, whether online or offline, or whether you are contracted to perform services for us or apply for a position of employment.

This policy does not apply to our current and former employees and their family members, dependents, and beneficiaries. If you are a California resident (who is a current or former employee of the Company or a family member, dependent, or beneficiary of any of our current or former employees), you may request access to our Employee Privacy Policy by sending an email to legal@thtbc.com.

Collection of Personal Information and Sensitive Personal Information

Based on your specific transactions and interactions with us or our website, we will or may collect, and we have in the last 12 months collected, the following categories of personal information about you. For each category of information, the categories of third parties and service providers to whom we have disclosed the information in the last 12 months are detailed in the chart below. The examples provided for each category are not intended to be an exhaustive list or an indication of all specific pieces of information we collect from or about you in each category, but rather the examples are to provide you a meaningful understanding of the types of information that may be collected within each category.

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information the Company may collect from or about consumers, independent contractors, or job applicants:

1. Personal Identifiers (social security number, driver’s license or state identification card number, passport number)
2. Geolocation Data (IP address)

Personal information does not include:

• Publicly available information from government records.
• Information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer, independent contractor, or applicant, or from widely distributed media.
• Information made available by a person to whom the consumer, independent contractor, or applicant has disclosed the information if the consumer, independent contractor, or applicant has not restricted the information to a specific audience.
• Deidentified or aggregated information.

Sources of Personal Information

We may collect your personal information from the following sources:

• You the consumer, independent contractor, or job applicant, when you visit the website and voluntarily submit information through forms on the website, when you visit any of our stores or physical locations, when you purchase or inquire about any of our products or services when you enter into a contract to perform services for us, or when you apply for a position of employment
• Our employees, contractors, vendors, visitors, other consumers, and affiliates based on your interactions with them (if any)
• We utilize cookies to automatically collect information about our website visitors
• HR support vendors
• Career sites or platforms like LinkedIn, Indeed, and ZipRecruiter
• Company systems, networks, software applications, and databases you log into or use in the course of applying for a position with the Company, interacting with our website, or otherwise interacting with us in any other capacity, including from vendors the Company engages to manage or host such systems, networks, applications or databases
• Personal references and former employers (if you are a job applicant)
• Schools, universities, or other educational institutions which you attended (if you are a job applicant)

To Whom We Disclose Personal Information

We may disclose your personal information to the following categories of service providers, contractors, or third parties:

• Financial institutions
• Government agencies
• Consumer reporting agencies or credit reporting agencies
• Talent acquisition management systems, and other vendors providing services for purposes of our human resources information system (HRIS) and management of job applicant data and recruiting process
• Insurance carriers, administrators, and brokers
• Corporate customers (meaning an entity, as opposed to a natural person, that purchases, leases, or finances any of our products or services)
• Our affiliated entities

Reasons Why We Collect, Use, Retain, and Disclose Personal Information

We may collect and disclose your personal information for any of the following business purposes:

1. 1. To fulfill or meet the purpose for which you provided the information.
   2. To process and submit financing applications, including to apply for credit, or credit pre-qualification.
   3. To process, complete, and maintain records on transactions.
   4. To provide warranty coverage on products and services.
   5. To retain your selection for Text opt in/opt out to ensure customers who opted out are not sent any text messages.
   6. To provide and communicate recall notifications to customers.
   7. To schedule, manage and keep track of customer appointments.
   8. To complete appraisals.
   9. To maintain records of when customers decline a service or sale.
   10. To respond to consumer inquiries, including requests for information, customer support online, phone calls, and in-store inquiries.
   11. To provide interest-based and targeted advertising.
   12. To contact you by email, telephone calls, mail, SMS, or other equivalent forms of communication regarding updates or informative communications related to the functionalities, services, or other information you requested or asked the Company to provide to you.
   13. To improve user experience on our website.
   14. To understand the demographics of our website visitors.
   15. To detect security incidents.
   16. To debug, identify, and repair errors that impair existing intended functionality of our website.
   17. To protect against malicious or illegal activity and prosecute those responsible.
   18. To verify and respond to consumer requests.
   19. To prevent identity theft.

• JOB APPLICANT PURPOSES:

1. 1. 1. To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job with the Company, we will use that Personal Information in connection with your candidacy for employment.
      2. To comply with local, state, and federal law and regulations requiring employers to maintain certain records, as well as local, state, and federal law, regulations, ordinances, guidelines, and orders relating to infectious diseases, pandemics, outbreaks, and public health emergencies, including applicable reporting requirements.
      3. To evaluate your job application and candidacy for employment.
      4. To obtain and verify background check and references.
      5. To communicate with you regarding your candidacy for employment.
      6. To permit you to create a job applicant profile, which you can use for filling out future applications if you do not get the job you are apply for.
      7. To keep your application on file even if you did not get the job applied for, in case there is another position for which we want to consider you as a candidate even if you do not formally apply.
      8. To evaluate and improve our recruiting methods and strategies.
      9. To engage in lawful monitoring of job applicant activities and communications when they are on Company premises, or utilizing Company internet and WiFi connections, computers, networks, devices, software applications or systems.
      10. To engage in corporate transactions requiring review or disclosure of job applicant records subject to non-disclosure agreements, such as for evaluating potential mergers and acquisitions of the Company.
      11. To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company related to recruiting or processing of data from or about job applicants.
      12. To improve job applicant experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
      13. To reduce the risk of spreading infectious diseases in or through the workplace.

• INDEPENDENT CONTRACTOR AND BUSINESS-TO-BUSINESS PURPOSES:

1. 1. To fulfill or meet the purpose for which you provided the information.
   2. To comply with state and federal law and regulations requiring businesses to maintain certain records (accident or safety records, and tax records/1099 forms).
   3. To engage the services of independent contractors and compensate them for services.
   4. To evaluate, make, and communicate decisions regarding an independent contractor, including decisions to hire and/or terminate.
   5. To grant independent contractors access to secure Company facilities, systems, networks, computers, and equipment, and maintain information on who accessed such facilities, systems, networks, computers, and equipment, and what they did therein or thereon.
   6. To implement, monitor, and manage electronic security measures on independent contractor devices that are used to access Company networks and systems.
   7. To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company.
   8. To improve user experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
   9. To reduce the risk of spreading infectious diseases in or through the workplace.

We do NOT and will not sell your personal information in exchange for monetary or other valuable consideration. We do not share your personal information for cross-context behavioral advertising.

We do not and will not use or disclose your sensitive personal information for purposes other than the following: 

1. To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
2. To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information.
3. To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
4. To ensure the physical safety of natural persons.
5. For short-term, transient use.
6. To perform services on behalf of the Company.
7. To verify or maintain the quality or safety of a product, service or device that is owned, manufactured, manufactured for, or controlled by the Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the Company.
8. For purposes that do not involve inferring characteristics about consumers, contractors, and job applicants.

Retention of Personal Information

We will retain each category of Personal Information in accordance with our established data retention schedule as indicated above. Some of the retention periods in the retention schedule above are measured from a particular point in time that has not occurred yet, such as the end of employment or end of a relationship (whether business, contractual, or transactional) plus a certain number of years. Where no particular event is defined in the retention schedule as the point from which the retention period is measured, we will measure the retention period from either: (1) the date the record or data was collected, created, or last modified; (2) the date of the particular transaction to which the record or data pertains; or (3) another triggering event that is determined to be reasonable and appropriate based on the nature of the data and the legal/business needs for its continued use.

In deciding how long to retain each category of personal information that we collect, we consider many criteria, including, but not limited to: the business purposes for which the Personal Information was collected; relevant federal, state and local recordkeeping laws; applicable statutes of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations.

We apply our data retention procedures on an annual basis to determine if the business purposes for collecting the personal information, and legal reasons for retaining the personal information, have both expired. If so, we will purge the information in a secure manner.

Third Party Vendors

We may use other companies and individuals to perform certain functions on our behalf. Examples include administering e-mail services and running special promotions. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose.

Business Transfers

In the event we sell or transfer a particular portion of our business assets, information of consumers, contractors and applicants may be one of the business assets transferred as part of the transaction. If substantially all of our assets are acquired, information of consumers, contractors and applicants may be transferred as part of the acquisition.

Compliance with Law and Safety

We may disclose specific personal and/or sensitive personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect our employees or the public.

Use of Cookies and Other Tracking Technologies

Cookies are small files that a website may transfer to a user’s computer that reside there for either the duration of the browsing session (session cookies) or on a permanent, until deleted, basis (persistent cookies) that may be used to identify a user, a user’s machine, or a user’s behavior. We only use session cookies on the website that collect data pertaining to your interaction with our website for purposes of understanding and collecting statistics about our website traffic, number of unique visits, and what job postings are being clicked on. Data collected through session cookies is not retained after your session ends due to inactivity or when you close your browser. We also collect IP addresses which, unlike session cookie data, are stored for 60 days and then deleted.

You may delete cookies from your web browser at any time or block cookies on your equipment, but this may affect the functioning of or even block the website. You can prevent saving of cookies (disable and delete them) by changing your browser settings accordingly at any time. It is possible that some functions will not be available on our website when use of cookies is deactivated. Check the settings of your browser. Below you can find some guidance:

• Safari
• Opera
• Internet Explorer
• Google Chrome
• Mozilla

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals.

External Links

Our website contains links to other sites. We are not responsible for the privacy practices or the content of such websites. To help ensure the protection of your privacy, we recommend that you review the Privacy Policy of any site you visit via a link from our website.

Children Under the Age of 16

We do not knowingly sell or share the personal information of consumers under 16 years of age.

How We Protect the Information that We Collect

The protection of the information that we collect about visitors to our websites is of the utmost importance to us and we take every reasonable measure to ensure that protection, including:

• We keep automatically collected data and voluntarily collected data separate at all times.
• We use commercially reasonable tools and techniques to protect against unauthorized access to our systems.
• We restrict access to private information to those who need such access in the course of their duties for us.

International Visitors

We do not target, market to, or offer our products or services to consumers outside of the United States. You agree not to submit your personally identifiable information through the website if you reside outside the United States. If we become aware that a person residing inside the European Economic Area, European Union, Great Britain, or Switzerland has submitted specific form data to us and requests its deletion, we will delete it.

Rights Under the CCPA and CPRA 

This section of the Privacy Policy applies only to California residents who are natural persons. If you are a California resident, you have the following rights pursuant to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

1. Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected about you, (2) the categories of sources from which the personal information was collected, (3) the business or commercial purpose for collecting, selling, or sharing this information, and (4) the categories of personal information that we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose;
2. Right to Access. The right to request, up to 2 times in a 12-month period, that we disclose to you, free of charge, the specific pieces of personal information we have collected from or about you;
3. Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
4. Right to Correct. The right to request that we correct inaccurate personal information (to the extent such an inaccuracy exists) that we maintain about you;
5. The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and
6. The right to not be discriminated or retaliated against for exercising any of the above rights, including an applicant’s and independent contractor’s right not to be retaliated against for exercising the above rights.

You can submit any of the above types of consumer requests through any of the two options below:

1. Submit a request by email to legal@thtbc.com.
2. Call our privacy toll-free line at (888) 295-4404.

How We Will Verify That it is Really You Submitting the Request

If you are a California resident, when you submit a Right to Know, Right to Access, Right to Delete, or Right to Correct request through one of the methods provided above, we will ask you to provide some information in order to verify your identity and respond to your request. Specifically, we will ask you to verify information that can be used to link your identity to particular records in our possession, which depends on the nature of your relationship and interaction with us.

Responding to Your Right to Know, Right to Access, Right to Delete, and Right to Correct Requests

Upon receiving a verifiable request from a California resident, we will confirm receipt of the request no later than 10 business days after receiving it. We endeavor to respond to a verifiable request within 45 calendar days of its receipt. If we require more time (up to an additional 45 calendar days, or 90 calendar days total from the date we receive your request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

For a request to correct inaccurate personal information, we will accept, review, and consider any documentation that you provide, and we may require that you provide documentation to rebut our own documentation that the personal information is accurate. You should make a good-faith effort to provide us with all necessarily information at the time that you make the request to correct. We may deny a request to correct if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive. If we deny your request to correct, we shall inform you of our decision not to comply and provide an explanation as to why we cannot comply with a request, if applicable.

If You Have an Authorized Agent:

If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf. To do so, you must either: (a) execute a valid, verifiable, and notarized power of attorney; or (b) provide other written, signed authorization that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf, and we will also contact you and ask you for information to verify your own identity directly with us and not through your authorized agent. We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that they have been authorized by you to act on your behalf.

Consent to Terms and Conditions

By using this website, you consent to all terms and conditions expressed in this Privacy Policy.

Changes to Our Privacy Policy

As our services evolve and we perceive the need or desirability of using information collected in other ways, we may from time to time amend this Privacy Policy. We encourage you to check our website frequently to see the current Privacy Policy in effect and any changes that may have been made to them. If we make material changes to this Privacy Policy, we will post the revised Privacy Policy and the revised effective date on this website. Please check back here periodically or contact us at the address listed at the end of this Privacy Policy.

Consumers With Disabilities

This policy is in a form that is accessible to consumers with disabilities.

Questions About the Policy

This website is owned and operated by Tlingit Haida Tribal Business Corp. If you have any questions about this Privacy Policy, please contact us at legal@thtbc.com or call (888) 295-4404.

**This policy was last updated March 27, 2024.