Workplace Privacy Notice

This privacy policy applies to the collection and processing of personal data relating to current and former employees, job applicants, contractors, temporary workers, and other individuals recruited or hired (collectively, personnel or you) by JOE & THE JUICE, its affiliates and subsidiaries (we, us, or JOE & THE JUICE). JOE & THE JUICE, acting as the data controller, will collect and process personal data about personnel as necessary and in accordance with this privacy policy.

This Privacy Policy describes what personal data we collect, when and why we collect it and how we will use it. Importantly, it also outlines your rights and how you may exercise your rights as a data subject with respect to your data.

We kindly ask you to carefully read through this Privacy Policy in order to understand how we process your personal data in connection with your employment.

If you have any questions or requests concerning our Privacy Policy or how we handle your data, please do not hesitate to contact our data protection team at privacy@joejuice.com.
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1.     What information do we collect and when do we collect it?

We collect a number of categories of personal data related to your employment with us. We may collect, store, and use the following categories of personal information about you:

Personal identifiers:

• We collect your personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• We collect your bank account details, payroll records, and tax status information for payroll and tax purposes.
• We collect your Driver’s License number, Passport number, nationality/visa status, national identification number, or related information to verify your employment eligibility and to provide travel arrangements for you.
• We collect your Social Security number for tax purposes.
• We collect information about your health, such as medical conditions and health and sickness records, when you report this information to the company. This includes details of any absences (other than holidays) from work, including time on statutory parental leave and sick leave; records related to administering and maintaining your healthcare and other benefits; and information about conditions needed for pensions and permanent health insurance purposes when you leave employment and the reason for leaving is related to your health.

Protected classifications:

• We collect your date of birth and gender in order to verify your identity.
• We collect information related to your marital status and dependents for tax and benefits administration purposes.
• We collect and maintain information about your racial and ethnic origin, disability status, or sexual orientation if you choose to provide it during the application or onboarding process. We use this information only to support our efforts to attract and maintain a diverse workforce, including reporting required by federal law.

Commercial Information:

‍We do not collect information related to any commercial transactions.

Biometric Information:

As described above, we collect some information about your health. We otherwise do not collect information about your physiological, biological, or behavioural characteristics.

Internet or Other Electronic Network Activity Information:

We collect information about your use of Joe & the Juice computers and networks, including your use of the internet and your email communications using company computers or systems, applications, hardware, systems, content, resources, and internet-based information used, generated, or accessed by you.

Geolocation Data:

‍ We may collect geolocation data about you if, for example, you are operating a company-issued vehicle or device, such as a company-issued mobile phone, as part of the fulfilment of your employment duties.

Audio, electronic, visual, thermal, olfactory, or similar information:

‍We store photographs of you for identity verification and we may record you on building security cameras. Your telephone calls may be monitored or recorded when accessing company resources, such as IT services. In addition, your calls may be monitored or recorded if you are interacting with a customer or member of the public in a customer service capacity. We collect recordings from CCTV in the bars. We do not collect any of your thermal, olfactory, or similar information. We use this information to ensure compliance with all company policies and to maintain the security of our personnel, systems, and locations.

Professional or employment-related information:

We collect information about your professional and employment-related background through the recruitment process, including copies of right to work documentation, references, and other information included in a CV or cover letter or as part of your application to work at Joe & the Juice. We use this information to evaluate your suitability for particular positions, tasks, or responsibilities. In addition, for certain roles, we may use an initial interview process, which uses artificial intelligence to create a report on each candidate which is then reviewed by the recruitment team. Further details about how your information will be used during this process can be found at https://sapia.ai/privacy-policy/.

• We collect information related to background checks, including criminal record checks, where permitted by law. We may also conduct a background check for current employees to determine eligibility for promotion or reassignment in the same manner as just described. We use this information to evaluate your suitability for particular positions, tasks, or responsibilities.
• Your personnel file also includes information you provided during the employment application process, such as your work history, start and separation date, training records and professional memberships, and salary history.
• We collect information regarding your salary, annual leave, retirement, time information, work performance, disciplinary actions, warnings, and/or grievance information. We also collect information regarding job titles, salary history, work history, working hours, holidays, absences, training history and records, position within the company (which is part of the company’s Moneyball structure), personality and cognitive ability tests, development plans, and professional memberships.
• We collect information regarding your business expenses, including travel arrangements or other expense reimbursement requests.
• For purposes of administering employee benefits, we collect health information, pension information, your marital status, and dependent information.

Education Information:

‍Your employment records include information you provided during the employment process about the educational institutions you have attended or your level of education. We also collect and maintain information about any professional licenses you hold, certifications you receive, or additional education or training you undertake during your employment.  We use this information to evaluate your suitability for particular positions, tasks, or responsibilities.
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2.     Why do we collect this data?

Just as it’s crucial that you understand what and when we are collecting your data, it’s equally as important for you to understand why we are processing that personal data. We will only process your data if we have a justifiable reason to do so in accordance with the applicable data protection law.

We will process your data for the following reasons:

a)     Personnel administration, including conclusion of employment contracts and decisions related to your employment; reviewing your performance; evaluating your development as an employee; setting your job duties and assessing our staffing needs; assessing your qualifications for other roles within the company or promotion; determining salary and compensation for grievance or other disciplinary procedures, including termination; management of warnings, complaints and collegial difficulties, if any; dealing with legal disputes involving you or other employees and contractors, including accidents at work; and ascertaining your fitness for work;

b)     Payroll administration, including reporting to the tax authorities, pension schemes, holiday accounts, and authorities that develop statistics;

c)     Benefits administration;

d)     Business purposes, including conducting data analytics studies to review and better understand employee retention and attrition rates; ascertaining and fulfilling education, training, and development requirements; and conducting KPI projects, for instance employee satisfaction measurements;

e)     Management of work injuries;

f)      International recruitment, including secondment;

g)     Offering internal communication platforms;

h)     Video surveillance in the bars to prevent crimes;

i)      General system administration, development of IT systems, monitoring activity from email accounts and access hereto in business-critical situations;

j)      Security measures and compliance with health and safety obligations, including ensuring the physical safety of our facilities, resources, employees, and other people from threats; preventing fraud and securing our systems, data, resources, and facilities from unauthorized access or exploitation; monitoring compliance with our IT policies; ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems, and preventing malicious software distribution; and investigating theft and other illegal activities;

k)     Marketing, for instance in the bars or on the internet etc.

l)      To comply with applicable legal regulations, including personal data protection regulations; and

m)   To safeguard JOE & THE JUICE’s other legitimate interests, for instance:

i.       Documentation requirements;

ii.      Putting in place, maintaining and testing technical and organisational security measures;

iii.     Investigating and reporting suspected personal data breaches and other irregularities for instance company credit card spend, if any;

iv.    Handling requests and complaints from data subjects and others, if any;

v.     Handling inspections and queries by supervisory authorities, if any;

vi.    Handling disputes with data subjects and third parties, if any;

vii.   Compliance with legal obligations, including verifying that you are legally permitted to work in the relevant jurisdiction;

viii.  Statistical analysis in order to develop and improve conditions for employees in JOE & THE JUICE; and

ix.    Mergers, acquisitions, divestures, or the sale of the company or parts thereof, including preparing information memorandum, preparing and conducting due diligence, assessing investments and other activities in such processes.  
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3.     How do we collect this data?

The personal data collected in connection with your employment with us is primarily collected from you directly. We collect personal information about employees, workers, contractors, and job applicants through the application and recruitment process, directly from candidates, employment agencies, and screening services or other background-check providers. We may collect additional information from third parties including former employers, credit reference agencies, or other sources that supply employment verification services.

We also collect additional personal information in the course of job-related activities throughout the period you work for us. This can be in the form of information you provide directly to us or information which we collect automatically about you, such as monitoring computer access and usage.

The consequences of not providing the personal data are that we may not be able to fulfil our legal and contractual obligations in connection with your employment. If you do grant us your consent, you may withdraw your consent at any time. If you withdraw the consent, this will not affect the lawfulness of the processing prior to the withdrawal. Please contact us at privacy@joejuice.com if you wish to exercise this right.

In addition to this, we may collect information from colleagues or third parties such as:

a)     Your manager or supervisors;

b)     Your doctor in case of absence due to sickness;

c)     Our provider of credit cards if you have a company credit card;

d)     Our internal IT systems; and

e)     Public authorities such as tax authorities.
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4.     What is the legal basis for the collection and processing of the personal data?‍

The legal bases for collection and processing of your personal data are the following:  

a)     The processing is necessary for the performance of the employment contract to which you are a party, cf. article 6(1)(b) of the GDPR.

b)     The processing is necessary for the compliance with a legal obligation to which Joe & The Juice is subject, including those outlined by relevant tax laws, laws concerning workers’ compensation, laws concerning employment, including those laws or regulations that govern employee illness and sickness benefits and employee holiday rights, and any other law or regulation that makes it necessary for certain employee information to be collected.

c)     The processing is necessary for the purpose of legitimate interests pursued by Joe & The Juice, cf. article 6(1)(f) of the GDPR, in particular:

i.       Internal use of photos of you in order for other employees to contact and identify you;

ii.      Use of badges for the purposes of illustrating positions and finished training courses;

iii.     Participation in certain KPI projects;

iv.    Participation in marketing campaigns;

v.     Assessment of employees’ eligibility of secondment on the basis of the employees’ applications;

vi.    Offering internal communication platforms;

vii.   Use of video surveillance in the bars for the purposes of preventing and solving crimes;

viii.  The processing is necessary to establish, exercise or defend a legal claim, for instance, in business-critical situations in which access to an employee’s email account is necessary;

ix.    The processing of data related to criminal offences is necessary to pursue a legitimate interest and is permitted by relevant European Union or Member State law.

x.     The processing is necessary to comply with legal obligations outside the European Union;

xi.    General system administration, development of IT systems and monitoring activity of email accounts; and

xii.   Investigations and reporting of irregularities.

d)     You have consented to the processing, cf. article 6(1)(a) of the GDPR, e.g. participation in certain KPI projects and marketing campaigns.
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5.     Disclosure of personal data to other controllers

The personal data will be disclosed to and shared with the following recipients:

a)     Tax authorities;

b)     Public authorities who are required to assess the information;

c)     Pension funds;

d)     Insurance companies;

e)     Phone companies;

f)      Providers of credit cards;

g)     Travel agencies;

h)     Public authorities in the country of secondment;

i)      The police; and

j)      Other JOE & THE JUICE entities.

The legal bases for the disclosure of your personal data are the following:

a)     The disclosure is necessary for the performance of the employment contract to which you are a party;

b)     The disclosure is necessary for the purpose of legitimate interests pursued by us, in particular in case of work-related travels, certain personal data will be disclosed to our travel agency who assists with booking of tickets, hotels, cars, etc.;

c)     You have consented to the disclosure of your personal data;

d)     In the case of secondment to a country abroad, the legal basis of the disclosure is that the processing is necessary in order to take steps at your request prior to entering into a new contract. JOE & THE JUICE will assist with residence and work permit and in that connection, certain personal data will be disclosed to the relevant public authorities upon request.

As mentioned earlier in this Privacy Notice, you have the right to withdraw your consent. If you withdraw the consent, this will not affect the lawfulness of the processing and disclosure prior to the withdrawal. Please contact us at privacy@joejuice.com if you wish to exercise such right.  
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6.     Transfer of personal data to data processors

We use a number of data processors who provide systems and services to us, including but not limited to the following categories:

a)     IT providers who both offer the systems and tools and store personal data on JOE & THE JUICE’s behalf;

b)     Payroll administration provider;

c)     Provider of online communication platforms; and

d)     Provider of personality and cognitive ability tests.
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7.     Transfer of personal data to service providers

We also disclose personal information to service providers, which are companies we use to support our business and who are bound by law and contractual obligations to keep your personal information confidential. Service providers may use information we share with them only for the purposes for which we disclose it to them. The categories of service providers that we share information with and the services they provide are:

• ‍Payroll services providers that assist us in calculating and disbursing your salary and other compensation.‍
• Auditing and accounting firms, such as firms that assist us in the creation of our financial records.‍
• Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.‍
• Recruitment vendors that assist with the application process, including assessing candidate qualifications and providing the platform through which candidates submit their candidacy.‍
• Analytics services, including entities that analyze traffic to and on our website and assist with identifying and communicating with potential customers. ‍
• Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.‍
• IT vendors, such as entities that assist with website design, hosting and maintenance; data and software storage; and network operation.

When you choose to enrol in certain employee benefit programs, we share information with the external parties that we have contracted with to provide benefits to you. This disclosure is done at your direction and involves information necessary for you to enrol in the benefit program. The external parties may collect additional information about you in connection with providing the benefit and may use and share that information in ways outlined with their own privacy notices.
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8.     Sale of personal information

The California Consumer Privacy Act (“CCPA”) defines “selling” personal information as disclosing it to an external party for monetary or other benefit. We do not sell your personal information to any third parties. However, we may disclose aggregated or deidentified information without restriction. ‍
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9.     International transfers of personal data

We may transfer the personal data to recipients located in countries outside the EU/EEA. If we transfer personal data to recipients in countries outside the EU/EEA, we will, if required, put a contract or other means in place to ensure that your data is adequately protected. For instance, when transferring to IT Software Platforms, general system management platforms, Contract signing or Data storage and management systems we will be using the European Commission’s standard contractual clauses or the EU-U.S. Privacy Shield (only relevant for transfers to the US). Wherever your personal information is transferred, stored or processed by us, we will take commercially reasonable steps to safeguard the privacy of your personal information.

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10.  Retention period

We store the personal data for as long as necessary to fulfil the purposes above. Subject to country-specific data protection and retention laws and regulations, most of the personal data will be deleted 5 years after the date of termination of the employment contract.  In specific cases personal data may be stored for a longer period in case of a dispute. Personal data in video recordings from video surveillance will only be stored for 30 days. If personal data are no longer relevant during the employment, we delete them once their purposes for processing have been achieved.  
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11.  Your rights

Subject to local data protection legislation, you enjoy the following rights in relation to your data that we process:

a)     The right to request access to the personal data: you are entitled to access any information of yours that we are processing.

b)     The right to rectification of the personal data: if your information is incorrect or inaccurate you are entitled to have this information corrected.

c)     The right to erasure of the personal data: you may ask us to delete your personal data from our systems. We will of course comply with such request, unless an exception applies.

d)     The right to restriction of processing: you may also request that we restrict the processing of your personal data. If requested by you, it means that the processing of your data going forward will be suppressed or blocked altogether. If you exercise this right, your information may still be stored by us, but it will not be used any further.

e)     The right to object to the processing of the personal data: you are entitled to object to the processing of your data in certain circumstances.

f)      The right to data portability: you are entitled to receive a copy of your personal data in a transferable format for your own purposes. However, please note that this right is subject to certain conditions under applicable data protection law.

You also have the right to lodge a complaint with the competent supervisory authority, such as the Danish Data Protection Agency or the relevant supervisory authority located within the market or country that you are placed. Please consult the relevant websites for each supervisory authority for how to submit a complaint.  
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12.  Your California Privacy Rights

Persons with disabilities may obtain this notice in alternative format.  Please send your request to: privacy@joejuice.com  

The California Consumer Privacy Act (“CCPA”) provides California residents, referred to in the law as “consumers,” with rights to receive certain disclosures regarding the collection, use and sharing of personal information, as well as rights to access and control personal information. The CCPA defines “personal information” to mean “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California resident. Certain information we collect may be exempt from the CCPA because it is considered public information (because it is made available by a government entity) or covered by a federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect personal information about you that is subject to the CCPA, that information, our practices, and your rights are described in the below disclosures.

Right to Information Regarding the Categories of Personal Information Collected, Sold, and Disclosed

You have the right to obtain information regarding the categories of personal information we collect, sell, or disclose. That information is provided in this privacy notice. We collect the categories of information described in the Information We Collect About You section above. The categories we use to describe the information are those enumerated in the CCPA.

Right to Access and Request Deletion of Information

We are not obliged at this time to comply with requests from former or current employees or contractors who request access to or deletion of information that was collected and used solely in the context of their role as a former or current employee, job applicant, or contractor.

Joe & the Juice allows you to request your personnel file as a matter of policy and as consistent with California law. If permitted, the review will be held at a mutually convenient time, usually during normal business hours. A member of the Human Resources Department will assist you in your review. Personnel files are the property of Joe & the Juice. Personnel files are maintained by the Human Resources Department and may not be taken outside of the Human Resources Department.

Right to Information Regarding Participation in Data Sharing for Financial Incentives

We may run promotions from time to time whereby we incentivize an employee, worker, or contractor to share certain pieces of information with us. Participation in any of these incentives is voluntary, and you may opt out of the data sharing at any time.

Right to Opt Out of Sale of Personal Information to Third Parties

The CCPA defines “selling” personal information as disclosing it to an external party for monetary or other benefit. We currently do not sell your personal information to any third parties.

Notice of California Employee Data Collection and Sharing Practices

We collect the categories of information described in the Information We Collect About You section above. The categories we use to describe the information are those enumerated in the CCPA.
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13.  Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. We use physical, administrative, and technical safeguards to secure personal information. The safety and security of your information also depends on you. You are responsible for following all Joe & the Juice security policies, which can be found on Joe & the Juice’s intranet, including but not limited to Joe & The Juice’s Password Policy.

Unfortunately, the storage and processing of information via internet-connected computers can never be completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information stored or processed by us. Any provision of personal information to us is at your own risk.
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14.  Changes to this Privacy Policy

We reserve the right to update this notice at any time and we will provide you with a new privacy notice when we make any material updates. We may also notify you in other ways from time to time about the processing of your personal information.
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15.  Contact

Please contact us if you have any questions in regard to the protection of your personal data or if you wish to exercise your legal rights.

Contact details of the controller:

JOE & THE JUICE A/S

Østergade 26a, 3 SAL

DK 1100 Copenhagen K

Denmark

CVR-no.: 26 58 93 55

E-mail address: privacy@joejuice.com