Employee Privacy Policy

Introduction

Catterton Management Company, LLC (“L Catterton,” “we,” “us,” or “our”) complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. L Catterton has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov. At L Catterton, we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that L Catterton collects from or about you, and how we use and to whom we disclose that information.

Application

L Catterton has adopted a series of privacy policies in order to address the specific privacy concerns of certain groupings of individuals and specific issues relating to the processing of personal information. This Privacy Policy applies specifically to the personal information of all individuals who seek to be, are, or were employed by L Catterton (collectively, an "employee"), unless the personal information is collected, used or disclosed while using the L Catterton website. In cases involving disclosure of personal information while using the L Catterton website, please consult L Catterton’s "Website Privacy Statement".

If you are unsure of which Privacy Policy applies to you, please contact shari.miller@lcatterton.com for more information.

Policy of Compliance

It is L Catterton's policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy was developed to guide the activities of L Catterton in all of the jurisdictions in which we operate. In addition, specific privacy practices may be adopted to address the specific privacy requirements of particular jurisdictions.

This Privacy Policy has a limited scope and application and the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, then please contact the Office of Security Officer for more information.

What is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an employee, other than the employee's business title or business contact information when used or disclosed for the purpose of business communications. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific employee).

What Personal Information Do We Collect?

We collect and maintain different types of personal information about our employees, including the personal information contained in resumes and/or applications; references and interview notes; photographs and video; letters of offer and acceptance of employment; mandatory policy acknowledgement sign-off sheets; payroll information; including but not limited to social insurance number, pay check deposit information; wage and benefit information; forms 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; and beneficiary and emergency contact information.

In addition to the examples listed above, personal information also includes information such as name, home address, telephone, personal email address, date of birth, employee identification number and marital status, and any other information necessary to L Catterton's business purposes, which is voluntarily disclosed in the course of an employee's application for and employment with L Catterton.

As a general rule, L Catterton collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may utilize the services of third parties in our business and may also receive personal information collected about you by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Why Do We Collect Personal Information?

The personal information collected is used and disclosed for our business purposes, including establishing, managing or terminating your employment relationship with L Catterton. Such uses include: determining eligibility for initial employment, including the verification of references and qualifications; administering pay and benefits; processing employee work-related claims (e.g. worker compensation, insurance claims, etc.); establishing training and/or development requirements; conducting performance reviews and determining performance requirements; assessing qualifications for a particular job or task; gathering evidence for disciplinary action, or termination; establishing a contact point in the event of an emergency (such as next of kin); complying with applicable labor or employment laws; compiling directories; ensuring the security of company-held information; and such other purposes as are reasonably required by L Catterton.

How Do We Use Your Personal Information?

We may use your personal information for the purposes described in this Privacy Policy or for any additional purposes about which we will advise you. Where your consent is required by law, we will obtain your consent for the use or disclosure of your personal information.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

When Do We Share Your Personal Information?

We may share your personal information with our employees, contractors, consultants and other third parties who require such information to assist us with establishing, managing or terminating our employment relationship with you, including: parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you.

In some instances, such parties may also provide certain information technology and data processing services to us so that we may operate our business. We may share personal information with such parties both in and outside of your home jurisdiction, and as result, your personal information may be collected, used, processed, stored or disclosed in the United States of America, and in some cases, other countries. Personal information is only transferred by us to another country if this is required or permitted under the applicable privacy legislation, in particular only in as far as a reasonable level of data protection is assured in the recipient country. L Catterton accepts full accountability and responsibility for the protection of your Personal Information, according to the applicable privacy legislation and this Privacy Policy, during the course of these onward transfers to third parties.

When we share personal information about you 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.

In addition, personal information may be disclosed or transferred to another party outside of your home jurisdiction in the event of a change in ownership of, or a grant of a security interest in, all or a part of L Catterton through, for example, a sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Further, your personal information may be disclosed as permitted or required by in response to lawful requests by applicable local law enforcement agencies or regulatory agencies, or agencies with responsibility to oversee and enforce national security. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances and to comply with valid legal processes such as search warrants, subpoenas or court orders and during emergency situations or where necessary to protect the safety of a person or group of persons. Last, we may disclose information that is already publicly available or with your consent where such consent is required by law.

Notification and Consent

Privacy laws do not generally require L Catterton to obtain your consent for the collection, use or disclosure of personal information for the purpose of establishing, managing or terminating your employment relationship. In addition, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

How is Your Personal Information Protected?

L Catterton endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

How Long is Your Personal Information Retained?

Except as otherwise permitted or required by applicable law or regulatory requirements, L Catterton endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your employment, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information
You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact the Human Resources Department using the contact information set out below. Please note that any such communication must be in writing.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns?

L Catterton encourages you to contact us should you have a Privacy Shield-related (or general privacy-related) complaint. If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our VP of HR or any member of the Human Resources Department by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are unsatisfied with our response, you may be entitled to make a written submission to the Data Privacy Authority applicable for your jurisdiction.

Shari Miller, Associate General Counsel, is accountable for overseeing compliance with this Privacy Policy. Please contact Ms. Miller if you have any complaints arising under this Privacy Policy. The contact information for Ms. Miller is as follows: shari.miller@lcatterton.com.

For any complaints that cannot be resolved with L Catterton directly, L Catterton has chosen to cooperate with EU Data Protection Authorities (DPAs) and comply with the information and advice provided to it by an informal panel of DPAs in relation to such unresolved complaints (as further described in the Privacy Shield Principles). Please contact us to be directed to the relevant DPA contacts. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. L Catterton is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Revisions to this Privacy Policy

L Catterton may from time to time make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will communicate any revisions of this Privacy Policy. Any changes to this Privacy Policy will be effective from the time they are communicated, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, where your consent is required to such collection, use or disclosure, until we have obtained your consent to such change. This Privacy Policy was last reviewed on August 14, 2017.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by L Catterton’s Associate General Counsel, Shari Miller, with escalation to L Catterton’s Chief Compliance Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it shall mean 'including without limitation.”

This Privacy Policy does not create or confer upon any individual any rights, or impose upon L Catterton any rights or obligations outside of, or in addition to, any rights or obligations imposed by the privacy laws applicable to such individual's personal information. Should there be, in a specific case, any inconsistency between this Privacy Policy and such privacy laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

Last Updated August 14, 2017