Privacy Policy | Zenith Energy

Overview

Zenith Energy U.S. LP, including its subsidiaries and affiliates ("we", "us", "our", the "Company"). "You" or "Your" or "Worker" refers to you as a full or part-time employee of the Company.

The Company values and respects your privacy and takes the necessary means to ensure its protection.

In this Worker Privacy Policy and notice ("Worker Privacy Policy"), we describe what information we collect from you, why we collect it and use it, and your rights with respect to this information. This Worker Privacy Policy contains the policies, procedures, and practices to be followed by the Company pertaining to the collection, use, and disclosure of Personal Information and data ("Personal Information") of an identifiable person that is a present, future, or past employee of the Company.

The Company values and respects your privacy and takes the necessary means to ensure its protection.

If you have any questions regarding this Worker Privacy Policy, please do not hesitate to reach out to Human Resources. Our goal is to make sure that you understand your rights and our obligations under this Worker Privacy Policy.

While this Worker Privacy Policy is intended to describe the broadest range of our information processing activities, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular state may limit the types of Personal Information we can collect or the manner in which we process that information. In those instances, we adjust our internal policies and practices to reflect the requirements of local law.

For specific privacy policies applicable to the entity by which you are employed please contact Human Resources.

California residents should review Appendix A for notice required under the California Consumer Privacy Act.

We are a U.S. company with our headquarters in Houston, TX. This means that Personal Information may be used, processed, and transferred to our headquarters, corporate offices and other states and territories, and that these jurisdictions may not offer the same level of data protection as the state where you reside.

However, we will ensure that appropriate or suitable safeguards are in place to protect your Personal Information and that the transfer of your Personal Information is in compliance with applicable privacy and data protection laws.

Who is Collecting your Personal Information?

The Company will be the entity that is responsible for collecting your Personal Information.

However, please note that the Company operates a group-wide IT system in order to harmonize our IT infrastructure and its use (the "System"). Therefore, the Company's subsidiaries and affiliates may also collect or process your Personal Information on behalf of the Company.

The System also holds data on all Workers. Insofar as the System serves to improve and harmonize most of the human resources ("HR") processes within the Company.

Applicability of Other Privacy Policies

The websites of the Company or its affiliates and subsidiaries may have separate privacy policies and terms of use that apply to their use. Additionally, some of our products and services may have separate privacy policies and terms of use that apply to their use. Any of your Personal Information collected in connection with your use of those websites or products and services are not subject to this Worker Privacy Policy.

Third Party Services

In some cases, you may provide Personal Information to third parties that the Company works with or that provide services to the Company. This includes, for example, ADP Human Resources Information systems, benefits providers, training platforms, and security or access software providers at our facilities. The use of such third-party websites may be governed by separate terms of use and privacy policies which are not under our control and are not subject to this Worker Privacy Policy. Please contact such third parties for questions regarding their privacy practices, as well as if you would like to have them delete your Personal Information.

What is Personal Information?

Personal Information, also known as personally identifiable information or personal data, for purposes of this Worker Privacy Policy means any information that (i) directly and clearly identifies an individual, or (ii) can be used in combination with other information to identify an individual. Personal Information does not include such information if it is anonymous or if it has been rendered de-identified by removing personal identifiers or that is considered publicly available.

Please note that for California residents, the term Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household as defined in the CCPA.

Examples of Personal Information include:

An individual's name.
Employee ID number.
Home address.
Home phone number.
Personal email address.
Names of family members.
Date of birth.

What is Sensitive Personal Information?

Sensitive Personal Information is a subset of Personal Information that may be more sensitive in nature for the individual concerned. Examples of sensitive Personal Information include:

Race and ethnic information.
Sexual orientation.
Biometric data.
Social security or other taxpayer/government issued identification numbers.
Financial information.
Criminal records.⁠

⁠What Personal Information Do We Collect?

We collect and maintain different types of Personal Information about you in accordance with applicable law. This includes the following:

Name, gender, home address and telephone number, date of birth, marital status, employee identification number, and emergency contacts.
Residency and work permit status, military status, nationality and passport information.
Social security or other taxpayer/government identification number.
Payroll information, banking details.
Wage and benefit information.
Retirement account information.
Sick pay, Vacation or Paid Time Off ("PTO"), retirement accounts, , insurance and other benefits information (including the gender, age, nationality and passport information for any spouse, minor children or other eligible dependents and beneficiaries).
Information from interviews and phone-screenings you may have had, if any.
Date of hire, date(s) of promotions(s), work history, technical skills, educational background, professional certifications and registrations, language capabilities, and training records.
Beneficiary and emergency contact information.
Forms and information relating to the application for, or in respect of changes to, employee health and welfare benefits; including, short- and long-term disability, medical and dental care, etc.
Clothing sizes,
Records of work absences, vacation/paid time off, entitlement and requests, salary history and expectations, performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures (including monitoring compliance with and enforcing our policies).
Where permitted by law and applicable we may collect the results of credit and criminal background checks, the results of drug and alcohol testing, screening, health certifications, driver’s license number, vehicle registration and driving history.
Information required for us to comply with laws, the requests and directions of law enforcement authorities or court orders (e.g., child support and debt payment information).
Acknowledgements regarding our policies, including employee handbooks, ethics and/or conflicts of interest policies and computer and other corporate resource usage policies.
Information captured on security systems, including Closed Circuit Television ("CCTV") and key card entry systems.
Voicemails, e-mails, correspondence, documents, and other work product and communications created, stored or transmitted using our networks, applications, devices, computers or communications equipment.
Date of resignation or termination, reason for resignation or termination, information relating to administering termination of employment (e.g. references).
Letters of offer and acceptance of employment.
Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process.
References and interview notes.
Information relating to any previous applications you may have made to the Company and/or any previous employment history with the Company.

Apart from Personal Information relating to yourself, you may also provide us with Personal Information of third parties, notably your dependents and other family members, for purposes of your HR administration and management, including the administration of benefits and to contact your next-of-kin in an emergency. Before you provide such third-party Personal Information to us you must first inform these third parties of any such data which you intend to provide and of the processing to be carried out by us. You must ensure and secure evidence that these third parties, or their legal representatives if they are minors, have given their free and express consent that their Personal Information may be processed by the Company and/or its affiliates and subcontractors for the purposes described in this Privacy Policy.

How Do We Collect Personal Information?

Generally, we collect Personal Information directly from you in circumstances where you provide Personal Information (during the onboarding process, for example). However, in some instances, the Personal Information we collect has been inferred about you based on other information you provide us, through your interactions with us, or from third parties. When we collect your Personal Information from third parties it is either because you have given us express consent to do so, your consent was implied by your actions (e.g., your use of a third-party employee service made available to you by us), or because you provided explicit consent to the third party to provide the Personal Information to us or the third party otherwise has the right to provide the Personal Information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect Personal Information about you without your knowledge or consent. We reserve the right to monitor the use of our premises, equipment, devices, computers, network, applications, software, and similar assets and resources. In the event such monitoring occurs, it may result in the collection of Personal Information about you. This monitoring may include the use of Close Circuit TV cameras in and around our premises. If required by applicable law, we will notify you of such monitoring and obtain your consent.

How Do We Use Your Personal Information?

We may collect and process your Personal Information in our systems for various purposes subject to local laws and any applicable collective bargaining agreements, including:

Recruitment, training, development, promotion, career and succession planning;
Appropriate vetting for recruitment and team allocation including, where relevant and appropriate credit checks, right to work verification, identity fraud checks, relevant employment history, relevant regulatory status and professional qualifications;
Providing and administering remuneration, salary, benefits and incentive schemes and providing relevant information to payroll;
Allocating and managing duties and responsibilities and the business activities to which they relate;
Managing and operating conduct, performance, capability, absence and grievance related reviews, allegations, complaints, investigations and processes and other informal and formal HR processes and making related management decisions;
Conducting surveys for benchmarking and identifying improved ways of working employee relations and engagement at work (these will often be anonymous but may include profiling data such as age to support analysis of results);
Processing information about absence or medical leave regarding physical or mental health or condition in order to assess eligibility for incapacity or permanent disability related remuneration or benefits, determine fitness for work, facilitate a return to work, make adjustments or accommodations to duties or the workplace and make management decisions regarding employment or engagement or continued employment or engagement or redeployment and conduct related management processes;
For planning, managing and carrying out restructuring or redundancies or other change programs including appropriate consultation, selection, alternative employment searches and related management decisions;
Operating email, IT, Internet, intranet, social media, HR related and other company policies and procedures. The company carries out monitoring of its IT systems to protect and maintain the systems, to ensure compliance with its policies and to locate information through searches where needed for a legitimate business purpose;
Complying with applicable laws and regulation;
Monitoring programs to ensure equality of opportunity and diversity with regard to personal characteristics protected under local anti-discrimination laws;
Planning, due diligence and implementation in relation to a commercial transaction or service transfer involving the Company that impacts on your relationship with the Company (for example mergers and acquisitions or a transfer of your employment under automatic transfer rules);
For business operational and reporting documentation such as the preparation of annual reports or tenders for work or client team records including the use of your personal photo;
In order to operate the relationship with third party customer and suppliers including the disclosure of relevant vetting information in line with the appropriate requirements of regulated customers to those customers, contact or professional CV details or resume, or or disclosure of information to data processors for the provision of services to the Company;
Where relevant for publishing appropriate internal or external communications or publicity material including via social media in appropriate circumstances, provided that privacy rights are preserved;
To support HR administration and management and maintaining and processing general records necessary to manage the employment or worker relationship and operate the contract of employment or engagement;
To centralize HR administration and management processing operations in an efficient manner for the benefit of our employees and to change access permissions;
To provide support and maintenance for the System;
To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you;
To comply with lawful requests by public authorities (including without limitation to meet national security or law enforcement requirements), discovery requests, or where otherwise required or permitted by applicable laws, court orders, government regulations, or regulatory authorities (including without limitation data protection, tax and employment), whether within or outside your state; and
Other purposes permitted by applicable privacy and data protection legislation including where applicable, legitimate interests pursued by the Company where this is not overridden by the interests or fundamental rights and freedoms of employees.

Sharing Personal Information

Your Personal Information may be shared, including to our affiliates, subsidiaries, and other third parties, as follows:

Where you request us or provide your consent to us.
In order to carry out the uses of Personal Information described above (see, How We Process and Use Your Personal Information).
When using or collaborating with third parties in the operation of our business, including in connection with providing many of the benefits and services we offer our employees (e.g., human resources information systems, financial investment service providers, insurance providers). When we share Personal Information with third parties we typically require that they only use or disclose such Personal Information in a manner consistent with the use and disclosure provisions of this Privacy Policy and applicable law.
We may buy or sell businesses and other assets. In such transactions, employee information is generally one of the transferred business assets and we reserve the right to include your Personal Information as an asset in any such transfer. Also, in the event that we, or substantially all of our assets, are acquired, your Personal Information may be one of the transferred assets.
Where required by law, by order or requirement of a court, administrative agency, or government tribunal, which includes in response to a lawful request by public authorities, including to meet national security or law enforcement requirements or in response to legal process.
If we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property.
As necessary to protect the rights, privacy, safety, or property of an identifiable person or group or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm the rights, property or safety of the Company, our users, applicants, candidates, employees or the public or as otherwise required by law.
Where the Personal Information is public.
To seek advice from our lawyers and other professional advisors.
To professional advisors (e.g. bankers, lawyers, accountants) and potential buyers and vendors in connection with the sale, disposal or acquisition by use of a business or assets.

NOTE: we do not sell your Personal Information as those terms are defined under applicable privacy laws.

Resolving Concerns

If you have questions or concerns regarding the handling of your Personal Information, please contact your Human Resources Department. Alternatively, you may also anonymously report violations of our Worker Privacy Policy or any relevant law online at www.lighthouse-services.com/zenithemus, via email at reports@lighthouse-services.com or by phone at 844-990-0002.

Changes to Privacy Policy

We may change this Privacy Policy at any time. If we do so, we will inform you via the email address that you provided during your onboarding process and/or your work email with the Company. The effective date of this Worker Privacy Policy is set forth above.

Security of Collected Information

We are committed to protecting the security of the Personal Information collected, and we take reasonable physical, electronic, and administrative safeguards to help protect the information from unauthorized or inappropriate access or use.

You, and any other employee of the Company, are obligated to keep confidential any and all information, including Personal Information, that you obtained or accessed while working for the Company. This includes any information that you obtained while using any of the Company’s facilities, electronic devices, the System, or any other source of information, digital or tangible, that belongs to the Company or is under the Company’s control or ownership.

If you have, accidently or not, accessed information that you are not allowed to access under your job definition, you must immediately report the incident to your supervisor, HR, and the legal department.

Appendix A - Privacy Notice under the California Privacy Rights Act ("California Notice")

If you are a California resident and a Worker of the Company, this serves as our privacy notice to you in compliance with the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA"). We will refer to the CCPA and CPRA collectively as "California Privacy Laws".

This California Notice refers only to the rights of California residents under the California Privacy Laws. However, other California laws may govern access to certain employment records. For example, California Labor Code Section 1198.5 governs an employee’s right to inspect and receive a copy of certain personnel records the employer maintains relating to the employee’s performance or any grievance concerning the employee. We reserve the right to object to a request under this California Notice to the extent it conflicts with obligations we may have under such other California laws or federal laws.

This California Notice supplements our Worker Privacy Policy.

Under the California Privacy Laws, Personal Information for purposes of this notice is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Notice at Collection

The following list the categories of Personal Information from Workers, the purposes for the collection, and whether that information is sold or shared. For retention purposes, we maintain all Personal Information for the period of employment, and thereafter as required by law or as set forth in our retention policy. We do not sell or share the Personal Information of any California Workers or any California residents under 16 years of age.

Category	Collected	Business or Commercial Purpose	Sold or Shared
A. Identifiers.	Yes, See What Personal Information Do We Collect? Examples include name, address, email address, and telephone number.	To process employment applications, to process payroll and benefits, for overall management of Workers, for safety and security, and for other purposes described in How Do We Use Your Personal Information?	No
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Yes, See What Personal Information Do We Collect? Examples include social security number, driver’s license number, banking information for payroll purposes, health insurance information, and health information collected for employment purposes, and employment and education history.	To process employment applications, to process payroll and benefits, for safety and security, for overall management of Workers and for other purposes described in How Do We Use Your Personal Information?	No
C. Protected classification characteristics under California or federal law.	Yes, we collect demographic workforce data, including race/ethnicity and gender.	For EEOC and other legal compliance and for other purposes described in How Do We Use Your Personal Information?.	No
D. Commercial information.	No.	Not applicable	No
E. Biometric information.	No.	Not applicable	No
F. Internet or other similar network activity.	Yes, See What Personal Information Do We Collect? Examples include login/logout logs, websites visited, and devices used.	For safety and security of Company systems, for overall management of Workers and for other purposes described in How Do We Use Your Personal Information?	No
G. Geolocation data.	Yes, See What Personal Information Do Collect? Examples include mobile device monitoring systems.	For safety and security of Company systems, tracking of lost or stolen devices, for overall management of Workers and for other purposes described in How Do We Use Your Personal Information?	No
H. Audio, electronic, visual, thermal, olfactory, or similar information.	Yes, See What Personal Information Do We Collect? Examples include photos for badges or promotional purposes, security footage, and voice mail.	For safety and security of Company systems, tracking of lost or stolen devices, for overall management of Workers and for other purposes described in How Do We Use Your Personal Information?	No
I. Professional or employment-related information.	Yes, See What Personal Information Do We Collect?	To process employment applications, for promotional purposes, for overall management of Workers and for other purposes described in How Do We Use Your Personal Information?	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Yes, See What Personal Information Do We Collect? Examples include educational information provided in resumes and records of training provided by Company.	To process employment applications, for promotional purposes, for overall management of Workers and for other purposes described in How Do We Use Your Personal Information?	No
K. Inferences drawn from other Personal Information.	Yes, See What Personal Information Do We Collect? Examples include performance reviews	To process employment applications, for overall management of Workers and for other purposes described in How Do We Use Your Personal Information?	No
L. Sensitive Personal Information	Yes, See What Personal Information Do We Collect? Examples include social security number, driver’s license number	To process employment applications, to process payroll and benefits, for overall management of Workers and for other purposes described in How Do We Use Your Personal Information?	No

Notice of Personal Information Collected and Disclosed in Past 12 Months

This will serve as notice of the Personal Information collected in the past 12 months from Workers, the Business or Commercial Purpose of the collection, and the categories of sources of the Personal Information. We have collected the following categories of Personal Information: Identifiers; Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); Protected classification characteristics under California or federal law; Internet or other similar network activity; Geolocation data; Audio, electronic, visual, thermal, olfactory, or similar information; Professional or employment-related information; Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99); Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer"s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and Sensitive Personal Information.

We use each category of Personal Information for the business or commercial purposes listed under "Purpose" in the Notice at Collection and in the section entitled How Do We Use Your Personal Information?

The following are the categories of sources of the Personal Information collected:

California Workers
Recruiters or Online Employment Marketplaces (such as Indeed)
Benefits Providers
Payroll Providers
Training Providers
Security Systems Providers
Badge Access Providers
IT Service Providers and Data Analytics Providers
Consumer Credit Agencies

Statement of Disclosure of Personal Information in the Past 12 months

In the past 12 months, we have disclosed all of the categories of Personal Information listed above to entities—such as payroll providers, benefits administrators, security companies—that perform services on our behalf. We have also disclosed all of the categories of California Worker Personal Information listed in the California Notice at Collection—except biometric and geolocation data—to governmental entities and counsel representing third parties in response to legal process and legal proceedings. We have also disclosed limited contact information—name and email address—to vendors and customers for customer service, contracting and business development, and general operational purposes.

Statement Regarding Use and Disclosure of Sensitive Personal Information

The Company only uses and discloses sensitive personal information that it collects about California Workers for the purposes specified in Civil Code section 1798.121(a). The Company does not infer characteristics about you regarding your sensitive personal information.

Your Rights Under California Privacy Laws

You have the following rights under California Privacy Laws:

The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we have disclosed Personal Information, and the specific pieces of Personal Information we have collected about you ("Request to Know”);
The right to delete Personal Information that we have collected from you, subject to certain exceptions ("Request to Delete");
The right to correct inaccurate Personal Information that we maintain about you ("Request to Correct");
If we sell or share your Personal Information, the right to opt-out of the sale or sharing of your Personal Information. Since we do not sell or share your Personal Information, we are not required to provide this opt-out;
If we use or disclose your Sensitive Personal Information for reasons other than those permitted under the California Privacy Laws, the right to limit the use or disclosure of your sensitive Personal Information. Since we do not infer characteristics about you based on your Sensitive Personal Information or use or disclose your Sensitive Personal Information for uses not specified in Section 1798.121(a), we do not have to offer this right to limit; and
The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including your right not to be retaliated against for the exercise of your CCPA rights.

Methods For Submitting Requests

You may submit Requests to Know, Requests to Correct and Requests to Delete in one of the following methods:

(a) sending an email to dataprotection@zenithterminals.com; or (b) by calling the following number: 844-990-0002. In the case of a Request to Delete, we may use a two-step process for online requests to delete, where you must (1) submit the Request to Delete and then (2) separately confirm that you want your Personal Information deleted.

Verification of Requests

We will need to verify your identity to respond to Requests to Know, Requests to Correct, and Requests to Delete. Depending on the nature of the request and the Personal Information that is the subject of the request, we may request two or more pieces of Personal Information, including a government-issued identification, for the purpose of verifying identity, and a signed declaration, under penalty of perjury, that the requestor is the person whose Personal Information is the subject of the request.

Authorized Agent

As a California resident, you have the right to designate an agent to exercise these rights on your behalf. In such a case, we may require you to do either of the following: (1) verify your own identity directly with us or (2) directly confirm with the Company that you have provided the authorized agent permission to submit the request. Alternatively, you or your authorized agent can provide us a power of attorney pursuant to Probate Code sections 4121 through 4130. Please contact us at dataprotection@zenithterminals.com for more information if you wish to submit a request through an authorized agent.

Contact Us

If you have questions about our privacy policies or practices or this California Notice, please contact us at dataprotection@zenithterminals.com.

US Worker Privacy Policy and Notice