Dot Employee Privacy Policy 

Last Updated: October 30, 2025

 

Explanation of Policy 

Dot Foods, Inc., Dot Transportation, Inc., Dot Foods Canada, Inc., and/or Dot Transportation Canada, Inc. (each, an “Employer” and collectively, “Dot” or “We”), have prepared this Dot Employee Privacy Policy (this “Policy”) to explain what personal information we are collecting in the course of your employment and how that information is used, as well as the choices and obligations you have with respect to your information. We treat your personal information with respect, and we collect, use, and share it only as described in this Policy. This Policy is in addition to other Dot policies governing workplace conduct and expectations. We may update and make changes to this Policy from time to time, so we encourage you to review it periodically. 

How is personal information defined? 

Different laws define “personal information” differently, but in general it means any information that identifies, relates to, describes, or could reasonably be linked with a particular individual. It does not include publicly available information.   

Categories of personal information we collect  

As your Employer, we may collect or receive the categories of personal information listed below. Not all categories will be collected for every Employer or every individual.   

• Basic Personal Identifiers, such as name, telephone number, physical address, email address, government-issued identifiers (e.g., national identification numbers and driver’s license numbers), and signatures.   

• Device and Online Identifiers, such as account login information, MAC address, IP address, cookie IDs, mobile ad IDs, and social media information.   

• Device, Internet and Other Network Activity Information, such as information about your browsing or search activity as well as your interactions with our websites, mobile applications, emails, or advertisements (for example keystroke patterns which help us determine if it is you or a bot interacting with us).   

• Demographic Information, such as age, gender, citizenship, ethnicity, date of birth, family or marital status,  education, professional and employment information.   

• Background Information, such as your criminal, employment, educational history, and credit standing, consistent with applicable law.  Before requesting a background check, we will obtain your informed and specific consent by asking you to sign an authorization form.  

• Biometric Information, such as voiceprints, imagery of the iris, retina and facial geometry, and fingerprints. See Appendix A for more special disclosures about biometric data. 

• Location Information, such as precise geo-location information.   

• Sensory Information, such as photographs and audio and video recordings from facility cameras for security and operational purposes, some of which may be flagged for human review using artificial intelligence for safety improvement purposes.  See Appendix B specific disclosures about how we are using artificial intelligence.  

• Inferences, such as individual preferences and characteristics, such as inferences drawn from and related to any assessment you may take as part of the interview screening process upon hire or during your tenure for promotional opportunities.   

• Message delivery and interaction data, such as time stamps, call times, status, etc.  

• Telematics Data, such as telematics data in corporate vehicles and devices. Telematics data involves the use of installed hardware to collect and transmit data about a vehicle or device which may include the vehicle or device’s location, use, and maintenance needs. 

We do not collect information from children 

We do not knowingly collect or solicit any information from anyone under the age of 16. Employer-provided equipment and mobile applications are intended to be used by our employees, all of whom are 16 or older.  If we learn that we have inadvertently collected personal information from a child under age 16, we will delete that information. 

How is personal information used? 

We collect personal information from you for employment-related purposes.  We will not use your personal information to market non-employment-related products or services to you without your consent. We may use your personal information for: 

• Fulfilling requests and obligations related to your employment, such as administering our payroll systems; 

• Providing access to our facilities, computer systems, software and equipment;  

• Delivering information to you about medical insurance and other the other benefits we offer;  

• Creating and maintaining records related to your employment, including performance evaluations, training, and career development; 

• Protecting, verifying and maintaining the safety, quality, security and integrity of our systems, processes, assets and other properties, and our business; 

• Updating our operational and technical functionality; 

• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them; 

• Conducting business analysis, such as analytics, projections, identifying areas for operational improvement; 

• Ensuring compliance with Dot policies and applicable laws or preparing legal claims or defenses necessary to protect the interests of Dot, our employees and our customers;  

• Communicating with you in the event of a crisis; 

• Supporting and improving employee safety; and 

• Encouraging employee engagement and retention. 

We also may use the information in other ways for which we provide specific notice at the time of collection.  To the extent we process or use deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law. 

How do we share your information?    

We will never share your personal information with a third-party for non-employment-related sales or marketing purposes. We may share your personal information with the following parties: 

• Our affiliates and companies in the same group of companies as us: Employer affiliates and subsidiaries (i.e., any organization or brand we own or control) or Dot Holdings Co (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies may use your personal information in the same way as we can under this Policy. 

• Our health benefit program providers: Personal information about you and your dependents can be used to determine your eligibility for health benefits as well as to help you select and enroll in the benefits programs that are right for you and your family.  A separate HIPAA Notice of Privacy Practices describes how your protected health information will be treated under Dot’s health and welfare benefit plans and can be found at .   

• Third parties at your request: You may choose to share your activities at the Employer with others through email, text, or on various social media networks.  

• Service providers and advisors: Third-party vendors and other service providers that perform services for us, on our behalf, such as phone carriers, SMS gateway providers, health care providers and/or insurance carriers (with your consent), or employee support platforms.  

• Law enforcement, regulators and other parties for legal reasons: Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our policies or to protect the security or integrity of our operating environment or systems; and/or (c) to exercise or protect the rights, property, or personal safety of Dot employees, our visitors, or others. 

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you. 

How do we store and protect your information?  

• Data storage and transfer:  We implement reasonable technical and organizational measures to protect your personal data. Your personal data is retained only as long as necessary to fulfill the purposes outlined above or to comply with legal requirements. 

• Keeping your information safe: Security of your information is very important to us, and we have put in place safeguards to preserve the integrity and security of information we collect and that we share with our service providers. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. If any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations. 

• Retention of your information: We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this Policy or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law or internal Dot policy. We dispose of the information we collect in accordance with our retention policies and procedures. 

  

Cross-border transfers 

We operate in the United States and Canada.  Personal information collected from our Canadian employees through Employer-provided devices or applications may be stored and processed in the United States where Dot Foods or its affiliates, subsidiaries, agents, or third-party service providers maintain facilities. By using the Employer-provided devices or applications, you acknowledge that such transfers of information outside of your country may occur, to the extent permissible under applicable law. 

 

How changes to this Policy will be made  

We may modify or update this Policy from time to time to reflect the changes in our business and practices, or to comply with changes to applicable law, and you should review this Policy periodically. We will update the “Last Updated” date at the top of this Policy when we post changes to this Policy. If you object to any changes, please consult with your manager or HR manager. Continuing to use Employer-provided devices or applications  after we publish changes to this Policy means that you are consenting to the changes. 

 

How to report an issue or contact us  

If you believe that we have not adhered to this Policy, or if you feel that you need to correct information about you, please contact us by form or by postal mail at Dot Foods-Legal Compliance, 1 Dot Way, Mt. Sterling, IL 62353.  Additionally, individual privacy rights requests can be made by contacting us at 217-773-4411.   

 If you are a California resident you can make certain requests regarding your personal information, and we will fulfill each request to the extent required by law. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial.  

  

Appendix A to Dot Employee Privacy Policy 

 Special Disclosures for Biometric Data 

 

What is Biometric Data? 

As used in this Policy, “Biometric Data” includes “biometric identifiers” and “biometric information,” as defined in the Illinois Biometric Information Privacy Act; “biometric information” as defined in the California Consumer Privacy Act and amended by the California Privacy Rights Act; “biometric data” as defined in the Colorado Privacy Act; “biometric identifier” as defined in the Texas Capture or Use of Biometric Identifier Act; “biometric identifier” as defined in the Washington Consumer Protection Act; and “biometric data” as defined in the Virginia Consumer Data Protection Act. 

Biometric identifier means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers also do not include, among other exclusions, information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996. 

Biometric information means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier and used to identify an individual. Biometric information does not include information derived from items or procedures excluded under the definition of biometric identifiers. 

 

How we may collect Biometric Data 

We use certain software and technologies licensed from third parties, including Windows Hello, timeclock technology, and other authentication mechanisms, for the purpose of fraud prevention, security, and identifying, or verifying the identity of, employees accessing our systems and property, including for example, when employees log into workstations, access secured areas, or clock in and out of work. Those software programs and technologies may collect, process, and store Biometric Data, including, for example, fingerprints, scans of face geometry, or other measurements of biological features unique to employees that could be used to identify them, or biometric information based on those identifiers.  

In addition, we use outward- and inward-facing dash cams equipped with Samsara Inc.’s Dual-Facing AI Dashcam technology in its fleet of trucks. That technology collects and processes information about a driver’s face for purposes of detecting and recording distracted-driving events, and therefore may capture biometric identifiers (such as scans of facial geometry) or biometric information based thereon. We use this technology for purposes of managing our fleet, improving driver safety, and reducing accidents. Before an employee begins, or continues, employment with us in a position for which the Samsara AI Dash Cam technology is used, the employee must execute a Consent, Waiver, and Release Regarding Collection of Biometric Data.  

If, and to the extent that, we possess Biometric Data, we will not sell, lease, trade, or otherwise profit from any such Biometric Data.  Our third-party licensors and vendors of software or other technologies used in this regard may be paid for their products or services.   

 

Consent 

Before we collect, capture, or otherwise obtain any of your Biometric Data, either directly or through any third-party licensor of software or other technology, we will first: 

1. inform you, or your legally authorized representative, in writing that Biometric Data is being collected, captured, otherwise obtained, or stored, and, as applicable, that Biometric Data may be disclosed to and/or processed by certain third-party licensors or vendors as part of that process; 
2. inform you, or your legally authorized representative, in writing of the specific purpose and length of time for which Biometric Data is being collected, stored, and used; and 
3. if required by law, receive a written release signed by you, or your legally authorized representative, authorizing the collection, capturing, storage, disclosure, and use of the Biometric Data as stated in the written release form. 

Disclosure 

We will not disclose, redisclose, or disseminate any Biometric Data unless:  

1. you, or your legally authorized representative, consent to such disclosure or dissemination; 
2. disclosure completes a financial transaction requested or authorized by you or your legally authorized representative; 
3. disclosure is required by State or Federal law or municipal ordinance; or 
4. disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction. 

 

Retention Schedule and Guidelines 

In circumstances where we possess Biometric Data, we will permanently destroy any Biometric Data in our possession, and request that any third-party licensors of software or technology in possession of any Biometric Data do the same, when the first of the following occurs: 

1. the initial purpose for collecting or obtaining such Biometric Data has been satisfied, such as if the employee’s employment with the Company is terminated, or the employee moves to a role within the Company for which Biometric Data is not collected, stored, or used; or  
2. within three (3) years of the employee’s last interaction with the Company. 

 

Storage, Transmission, and Protection of Any Biometric Data  

We will use a reasonable standard of care within our industry to store, transmit, and protect from disclosure any Biometric Data we may possess. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which we store, transmit, and protect from disclosure other confidential and sensitive information.  

 

Appendix B to Dot Employee Privacy Policy 

 

Special Disclosures for AI-Enhanced Safety and Monitoring 

 

How can AI help us enhance safety? 

We are committed to providing a safe and secure working environment. To help us achieve this, certain of our locations use an AI-powered workplace safety and operations platform to help them monitor and respond to safety and operational events in their physical environments through real-time video analytics and contextual insights, powered by computer vision and machine learning.  The purpose of this system is to proactively detect and mitigate safety risks and prevent accidents.   

How the system works: 

• Computer Vision: The system collects video clip and event data from cameras we control and processes them through a cloud environment to identify specific safety-related events, such as vehicle-person proximity.  

• No Personal Surveillance: This system is not intended to be used for continuous personal surveillance. It is focused on detecting workplace safety events and protecting our employees and property. 

• Human Oversight: The AI is an assistive tool only, and human oversight is maintained at all times. No automated decisions with legal or employment consequences may be made without human review. 

• Data Privacy: All data collected by this system is handled with strict confidentiality. Data not related to a safety event is automatically anonymized, deleted, or securely stored according to our data retention policy. Access to safety-related data is restricted to authorized personnel. Data collected may be used to train site-specific models in order to enable deployment of the solution at the site. We may grant permission for the system to train its general models on de-identified versions of the data we collect.