Privacy Notice for Potential Team Members
Version: 2.1
Prepared by: Privacy Office
Date Created: December 2019
Date Last Revised: July 2024
Knoxville, Tennessee 37909
Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** Privacy Notice for Pilot Travel Centers LLC Potential Team Members We understand that your privacy is important to you, and we are committed to respecting your privacy and protecting your Personal Information (PI).
This Privacy Notice applies to individuals seeking employment with Pilot Travel Centers LLC, owned and / or operated subsidiaries and affiliates collectively referred to as Pilot “PTC” or ”us” or “we” or “our”). We are providing this Privacy Notice to help you better understand the following:
• What Personal Information We Collect
• Why We Collect and How and Why We Use and Disclose Personal Information
• Rights and Choices About How We Use and Disclose Your Information
• How We Update this Privacy Notice
This Privacy Notice may be subject to modification from time to time, notably in the event of changes to legislation or the introduction of new laws. We recommend that you check this Privacy Notice regularly. THE PROVISIONS OF THIS PRIVACY NOTICE DO NOT ESTABLISH ADDITIONAL CONTRACTUAL RIGHTS OR OBLIGATIONS, IN WHOLE OR IN PART, BETWEEN PTC AND YOU. 1. What Personal Information We Collect:
We collect the following categories of personal information and have collected the same categories in the 12 months prior to the date of this Privacy Notice:
• Personal Information
o Personal Identifiers
Personal Information
Account Information
Financial Information
Social Media Information
Unique Device Identifiers
o Protected Classifications (Characteristics)
Health Information
Sensory Information
Demographic Information
o Commercial Information
Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-****
Recruitment and Employment-Related Information
o Internet/Other Electronic Network Activity
Digital Information
o Geolocation Data
Location Data
o Inferences
Inferences
o Other
Content and Information You Voluntarily Share
General Information Collected from Other Sources
• Sensitive Personal Information (SPI)
o Personal Information
Government Identifiers
Account Information
Geolocation Information (precise)
Demographic Information
Health Information
2. PERSONAL INFORMATION – DISCLOSURES FOR BUSINESS PURPOSES AND SALES/SHARING FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING Category of Personal
Information That We Collect
or Receive
PTC and our Service Providers
May Process Personal
Information for these
Business Purposes
Categories of Third Parties to
Whom We Sell, Share,
Personal Information
Personal Information name, address,
phone number, email address
Administrative
Analytical
Communication
Development
Equal Employment Opportunity
Legal, Regulatory, or Insurance
Personnel and Performance
Management
Security Management and Monitoring
Other Business Purposes
AdTech and Analytics companies
Account Information (when you create
one) email and text communication,
positions previously applied for,
previously held positions with Pilot or
Berkshire Hathaway
Administrative
Analytical
Communication
Equal Employment Opportunity
Legal, Regulatory, or Insurance
Personnel and Performance
Management
Security Management and Monitoring
Other Business Purposes
AdTech and Analytics companies
Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** Financial Information
Not collected as part of the recruiting
and application process
N/A
Social Media Information social media
handles/aliases, URL you share as part of
the application process
Administrative AdTech and Analytics companies
Unique Device Identifiers electronic
device model, browser type, MAC
address, IP address
Analytical
Development
Security Management and Monitoring
Other Business Purposes
AdTech and Analytics companies
Health Information disability or health
condition information you share as part
of the application process
Administrative
Legal, Regulatory, or Insurance
N/A
Sensory Information voice recordings or
video / photographic images that may be
captured during virtual interviews, in
public areas, or in PTC facilities for
security reasons
Administrative
Identity Verification
Legal, Regulatory, or Insurance
Communication
Equal Employment Opportunity
Legal, Regulatory, or Insurance
Security Management and Monitoring
N/A
Demographic Information age,
military/veteran status, language
preferences, gender, ethnicity you share
as part of the application process
Administrative
Analytical
Communication
Development
Equal Employment Opportunity
Legal, Regulatory, or Insurance
Personnel and Performance
Management
Security Management and Monitoring
N/A
Recruitment Information resume and
curriculum vitae (CV) details, previous
work experiences, educational
background, certificates, licenses and
vocational records, information of
general interests, membership to
associations, any information you have
provided us during the interviews,
information gathered from reference
persons whose contact details you have
provided to us, leaving date and your
reason for leaving, information related to
immigration, right-to-work, residence
status, pre-hire assessments
Administrative
Analytical
Communication
Equal Employment Opportunity
Legal, Regulatory, or Insurance
Personnel and Performance
Management
Other Business Purposes
N/A
Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** Commercial/Transaction
Not collected as part of the application
process
N/A
Digital Information browsing history and
regional geolocation information;
website and app usage information
Administrative
Analytical
Development
Security Management and Monitoring
AdTech and Analytics companies
Geolocation Data collected as part of the
application process, while using our
platforms or services, or shared with us
by third parties
Administrative
Analytical
Development
Equal Employment Opportunity
Legal, Regulatory, or Insurance
Personnel and Performance
Management
Security Management and Monitoring
Other Business Purposes
AdTech and Analytics companies
Inferences qualifications
Administrative
Analytical
Communication
Equal Employment Opportunity
Legal, Regulatory, or Insurance
Personnel and Performance
Management
N/A
Content and information you voluntarily
share
Administrative
Analytical
Communication
Development
Equal Employment Opportunity
Legal, Regulatory, or Insurance
Personnel and Performance
Management
Security Management and Monitoring
Other Business Purposes
AdTech and Analytics companies
General information collected from
other sources
Administrative
Analytical
Communication
Development
Equal Employment Opportunity
Legal, Regulatory, or Insurance
Personnel and Performance
Management
Security Management and Monitoring
Other Business Purposes
AdTech and Analytics companies
Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** 3. SENSITIVE PERSONAL INFORMATION (SPI) (applicant) - – DISCLOSURES FOR BUSINESS PURPOSES AND SALES/SHARING FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING Category of Personal
Information That We Collect
or Receive
PTC and our Service Providers
May Process Personal
Information for these
Business Purposes
Categories of Third Parties to
Whom We Sell, Share, or
Disclose Personal Information
Government Identifiers social security
number, state identification number,
passport
Identity Verification
Legal, Regulatory, or Insurance
Background Check
Equal Employment Opportunity
Legal, Regulatory, or Insurance
Other Business Purposes
N/A
Account Information account log-in with
password or passcode
Administrative
Equal Employment Opportunity
Security Management and Monitoring
N/A
Financial Information
Not collected as part of the employment
application process
N/A
Precise Geographic Information
Administrative
Analytical
Audits and Controls Testing
Equal Employment Opportunity
Other Business Purposes
N/A
Demographic Information race/ethnic
origin, gender, citizenship/citizenship
status, veteran status
Equal Employment Opportunity
N/A
Biometric Information
Not collected as part of the employment
application process
NA
Health Information such as health
conditions/diagnoses, etc.
Equal Employment Opportunity
N/A
Children’s Information (under 16)
Not collected as part of the employment
application process
N/A
Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** Sensitive Personal Information
Inferences
PTC does not make sensitive personal
inferences nor use sensitive personal
information to make inferences about an
applicant.
N/A
We may also disclose personal information to third parties for the following reasons:
• Corporate Transactions - We may disclose personal information, as part of any actual or contemplated merger, sale, transfer of assets, acquisition, bankruptcy, or similar event, including related to due diligence conducted prior to such event, where permitted by law.
• Legal / Government - We may share your personal information where we believe the disclosure is required by law, or otherwise necessary to comply with the law, regulatory requirements, requests from public authorities, or to enforce our agreements or policies, to protect the rights and property of our team members, the company, our partners or the public (including for fraud prevention purposes and to prevent, investigate and prosecute criminal activities).
• Safety / Physical Security – We may disclose, where permitted by law, your personal information to our affiliates and other persons and entities for the purpose of protecting the rights, safety, security, and property of our customers, team members, and the public. We may also disclose this information to protect and enforce our rights – including for fraud prevention purposes and to prevent, investigate and prosecute criminal activities – and to assist others to do the same. To opt out of the sale of your personal information, please submit a Do Not Sell or Share request at privacy.pilotflyingj.com.
As an applicant for employment, you are responsible for ensuring that the personal information you submit to us is correct and true. If you choose not to provide certain information, we may not be able to process your applications.
4. Why We Collect and How We Use Personal Information: Your PI will be used by PTC to carry out our application process, and your information may be used or collected for the following business or commercial purposes to the extent permitted by applicable law:
• Administrative Purposes: To service and maintain account(s) or systems or networks, or for other management or administrative purposes, etc.
• Analytical Purposes: To evaluate website and mobile application usage, traffic, and purchasing patterns, determine the effectiveness of advertising and marketing campaigns, etc.
• Communication Purposes: To manage communications via text message / SMS, push notification, inbox messaging, email, telephone, or physical mail for business or customer service reasons and / or to review and respond to customer service inquiries, etc. Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-****
• Equal Employment Opportunity Purposes: To comply with laws, regulations, and guidance pertaining to equal employment opportunity and anti-discrimination, etc.
• Legal, Regulatory, or Insurance Purposes: To comply with applicable law, legal proceedings, court orders, garnishments, government mandates, and respond to requests from legal authorities, enforce law requirements, investigate injury claims, respond to environmental laws and regulations, apply for Intellectual Property protections, provide and administer workers’ compensation, etc.
• Personnel and Performance Management Purposes: To manage processes related to employment application and hiring processes.
• Security Management and Monitoring: To detect security incidents, protect against and investigate malicious, deceptive, fraudulent, or illegal activity or prosecute individuals responsible for that activity, secure PTC’s premises, assets, and information for the purposes of fraud or crime prevention, suppression, or detection, ensure compliance with applicable policies and terms of use.
• Other Business Purposes: To provide products, services, or information to PTC and business partners, communicate for business or customer service reasons, perform outplacement services, carry out any other legitimate reason such as changes to our policies or in response to an inquiry, etc.
If you are offered and accept employment with PTC, the PI collected during the application and recruitment process may become part of your employment record. 5. Retention Period
We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Notice. We will delete or de-identify information when it is no longer needed to fulfill these purposes unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will continue to store it securely according to our internal data policies and take reasonable measures to prevent further processing your information. We are required by privacy laws to maintain records of individual rights requests and how we responded to such requests for at least 24 months. We only use information obtained from any individual rights requests for recordkeeping purposes. 6. Sources of Collection and How We Collect Personal Information PTC utilizes various technical and non-technical sources to collect your PI. PTC collects your PI in Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** circumstances including, but not limited to:
You visit our corporate office, travel centers, or other businesses;
You communicate with us by USPS mail;
You use our guest Wi-Fi service either in-store or in a PTC office;
You interact with us through our Electronic Platform (e.g., Pilot Flying J mobile application, website, chat feature, email, or social media);
You use location-based features via computer, mobile device, or while using the Pilot Flying J mobile application;
You contact Guest Services;
You submit an employment application to us;
You accept an employment offer, or contract with us;
You otherwise voluntarily provide us or any third parties, on our behalf, with information. In addition to the collection methods referenced above, we may also collect your PI:
From our affiliates and/or service providers;
From third-party verification services;
From on premise surveillance systems;
From third parties with whom coordination is required;
From law enforcement or regulators for safety and security purposes;
Through the use of technology (e.g. cookies, web beacons, pixel tags, and geolocation services).
Notwithstanding anything else in this notice, we may share data that has been aggregated or deidentified in such a manner that it is no longer considered personal information for any purpose. When we share aggregated or deidentified data, we require recipients to refrain from reidentifying the data and to pass this obligation on to downstream recipients. 7. Cookies and Online Tracking Technologies
Pilot and some of our third-party business partners (such as advertising services and analytics providers) use cookies, beacons, pixels, and other tracking technologies when you visit any of our websites or use any of our Pilot Flying J mobile applications, including when you submit your job application. These technologies help us to bring you a more cohesive and worthwhile experience. Cookies
A cookie is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a "session cookie") or a future session (a "persistent cookie"). Many browsers are designed to accept cookies by default; however, you can modify your browser settings Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** either to notify you when you have received a cookie or to refuse to accept cookies. Please note that certain areas of our websites and applications may not function properly if you set your browser not to accept cookies.
Some examples of why we use cookies:
• To learn about how you interact with our websites
• To detect and prevent fraud
• To conduct analytics activities
• To improve our websites and services
• To facilitate Interest Based Advertising
Other Online Tracking Technologies
In many cases, the collection of your personal information using these online tracking technologies is controlled by Pilot. However, in some cases the data collected through use of these cookies is controlled by our vendors or other third parties. When a third-party controls that collection, Pilot strives to provide you with links to those providers where you can submit privacy requests related to their services. Examples of other online tracking technologies we may use: Beacons/Pixels
These are embedded images or objects that are used on web pages or emails. They help companies to unobtrusively understand how visitors navigate website pages and can verify when specific content has been accessed. We may use web beacons or pixels to:
• Improve our websites and services
• Detect and prevent fraud
• Verify system and server integrity
• Better understand how many people visit our webpages or view specific content Embedded Scripts
We may use embedded scripts that collect information about your interactions with our websites, mobile apps, and advertisements. These scripts are temporarily loaded into your web browser and are active only while you are connected to our website, mobile app, or advertisement. Location Technology
We may use global positioning or other location identifying technologies to locate your device. This helps Pilot ensure we are compliant with geographically significant regulations, as well as other consumer services like finding the next Pilot location or booking driver services like showers and parking. In-app Tracking
Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** Mobile application tracking may include a variety of technologies like software development kit (SDK), device identifiers such as mobile ad IDs (MAID), or identifiers for advertisers (IDFA) that associates your user activity on a given app and helps us track activity across multiple apps and/or devices. Device and Activity Monitoring
We may use technologies that monitor and record your interactions with our websites and mobile apps, such as your keystrokes and click-related activity. These technologies may also collect and analyze information from your device, such your operating system, plug-ins, and system fonts. We may monitor devices and activity:
• To enhance and customize your experience
• To better respond to your inquiries and requests
• To detect and prevent fraud
• To detect cyber incidents and other malicious activity
• To verify systems and server availability and integrity
• To troubleshoot issues
• To improve our websites, mobile apps, and services More information on controlling interest-based advertising on apps on your mobile device, visit http://www.aboutads.info/appchoices
Third-party Analytics
Pilot may use analytics providers - like Google Analytics, Adobe Analytics, or others - to obtain analytical information about our websites and applications. These providers may use cookies and other tracking technologies that help us analyze how our guests use or interact with our websites, services, advertisements, and mobile applications.
For more information about Google Analytics, please see the Google Analytics Terms of Use and the Google Analytics Privacy Policy.
• https://marketingplatform.google.com/about/analytics/terms/us/
• https://policies.google.com/privacy
In addition to other universal opt out mechanisms, you may exercise choices regarding the use of browser cookies from Google Analytics by downloading the Google Analytics Opt-out Browser Add-on.
• https://tools.google.com/dlpage/gaoptout
Learn more about Adobe Analytics by visiting the Adobe Privacy Center.
• https://www.adobe.com/privacy.html
You can also make choices about data collection for certain companies by visiting an industry consumer choice platform such as the NAI (https://optout.networkadvertising.org/) or DAA
(https://optout.aboutads.info/). You may still receive ads after limiting processing of information for interest-based advertising, but those ads may be less relevant to your interests. Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** 8. Safeguarding Collected Information
To protect the PI collected or transmitted, PTC has physical, technical, and procedural safeguards in place. These safeguards are based on industry best practices and standards, and the requirements of applicable legislation.
Please note, however, that while PTC attempts to safeguard your PI, no method of transmitting or storing electronic information is ever completely secure, and thus we make no warranty, express, implied, or otherwise, that your information will never be accessed, used, or released in a manner that is inconsistent with this Privacy Notice.
9. California Residents - Rights And Choices About How We Use and Disclose Your Information
Understanding Your Individual Rights
California residents have the following rights with respect to personal information (PI) we have collected about them in their capacity as a job applicant:
1. Right to Access – the right to know the PI we have collected about you 2. Right to Delete – the right to delete the PI we have collected about you subject to various exceptions 3. Right to Correct – the right to correct/amend PI we have collected about you 4. Right to a Portable Copy - the right to request a copy of the PI we have collected about you 5. Right to Opt Out of Sale or Sharing – the right to opt-out of the sale or sharing of PI we have collected about you
If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we may provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable. If requests from an applicant are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the applicant of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested. PTC will not discriminate against applicants for exercising any of the rights described herein. This includes denying goods or services, charging different prices, or providing a different level or quality of service. However, PTC can offer applicant’s different rates (or service) if that difference is reasonably related to the value of the applicant’s data.
Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** 9.1. Access Rights
The Right to Access Personal Information Collected, Disclosed, or Sold You have the right to request that PTC disclose the PI we collected about you. Upon the receipt of a verified request and in accordance with our internal data policies, we will provide the following:
• Categories of PI we collected about you;
• Categories of sources for the PI we collected about you;
• Our business or commercial purpose for collecting, sharing, or selling that PI;
• Categories of third parties with whom we disclose that PI; and
• Specific pieces of PI we collected about you.
Please note that there may be instances where access to your PI may be restricted by law. If we are unable to verify your identity, we may request additional information for the express purpose of validating your identity. If we are prohibited from fulfilling your request for the disclosure of all or some of your PI, we will advise you of the specific reasons for restricting access, barring any legal or regulatory limitations. We will not provide specific pieces of PI if the disclosure creates a substantial, articulable, and unreasonable risk to (1) the security of that PI, (2) the individual’s account with us, or (3) the security of our systems or networks. We will not disclose Social Security numbers, driver’s license numbers, other government-issued identification numbers, financial account numbers, health insurance numbers, medical identification numbers, account passwords, and security questions and answers. Instructions for Submitting Requests
PTC provides the following options to submit requests to access, delete, or correct personal information . Individuals may submit their Access Request by:
• Accessing our online portal: privacy.pilotflyingj.com
• Calling our one of our toll-free numbers:
o 1-888-***-****, for United States residents
o 1-855-***-****, for Canadian residents
Process to Verify Requests
To verify the identity of the individual who has made a request, PTC may require individuals to submit additional information. PTC may ask individuals to provide certain identifiers. After providing the information necessary to complete the request, you will be verified with a third-party identity verification service. Once this request has been verified, the Privacy Office will begin to process your request. 9.2. Rights to Opt Out
Right to Opt-Out of the Sale or Sharing of Personal Information We may disclose personal information in a way that constitutes a “sale” of personal information or “sharing” personal information for cross-context behavioral advertising. Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** You can request to opt-out of this “sale” or “sharing” of your personal information by clicking on the “Do Not Sell or Share My Personal Information” link here or by following options outlined below (“Instructions for Submitting Do Not Sell or Share Requests”).
You have the right to opt-out of the sale or sharing of the PI that PTC has collected on you. As used within the context of this Privacy Notice, “Sell” refers to the act of selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, the PI we have collected during the normal course of business, to another business or a third party for monetary or valuable consideration.
If you choose to exercise this right, PTC will refrain from selling your PI for a period of one year. After this period, we may contact you to obtain your consent to sell your PI. We do not sell or share the PI of minors under 16 years of age without affirmative authorization where required by law. For more information, please view the Personal Information of Minors section in this Privacy Policy.
Instructions for Submitting Do Not Sell or Share Requests [or Right to Limit Use of SPI] PTC provides the following options to submit Do Not Sell or Share Requests. Individuals may submit their Do Not Sell Requests by:
• Accessing our online portal: privacy.pilotflyingj.com
• Calling our one of our toll-free numbers:
o 1-888-***-****, for United States residents
o 1-855-***-****, for Canadian residents
Upon receiving a request to opt-out, we will act upon it as soon as feasibly possible and in accordance with any applicable law. We will notify all third parties to whom we have sold your PI, as required by law. We will notify you when this has been completed.
If we have a good-faith, reasonable, and documented belief that a request to opt-out is fraudulent, we may deny the request. In this scenario, we will inform the requesting party that we will not comply with the request and provide an explanation of why we believe the request is fraudulent. 10. Opt-out Preference Signals
An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of website visitors and communicates that visitor’s choice to opt out of the sale and sharing of personal information for cross- context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools. We recognize the Global Privacy Control signal and do so at the browser level. It does not apply to personal information we may collect offline or that we may associate only with your name or email address. This means that if the signal is sent through a specific browser, we will recognize it for that browser only, and Pilot Travel Centers LLC 5508 Lonas Drive Knoxville, TN 37909 1-800-***-**** only with respect to the identifiers for that browser. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information
(https://globalprivacycontrol.org/).
Opting-In After Opting-Out of the Sale or Sharing of Personal Information If you have previously opted-out of the sale or sharing of your PI and would like to opt-in, you can do the following:
• If you are a Loyalty member, you can change the setting in your Loyalty account, via the Loyalty Portal
• If you are not a Loyalty member, you opt-in by registering for a Loyalty account. We use a two-step opt