Privacy Notice to California Employees and Independent Contractors

Effective Date: January 17, 2024


H Mart (“H Mart”, “we”, “our”, or “us”) provides this Privacy Notice for Employees and Independent Contractors (“Notice”), which supplements the information contained in our general Privacy Policy (available here, as updated from time to time, and which is incorporated herein by reference).

This Notice applies only to employees and independent contractors who reside in California (collectively, “you” or “your”). Any terms used in this Notice (whether or not capitalized) which are defi ned in the California Consumer Privacy Act of 2018 or its successor, the California Privacy Rights Act of 2020 (together, “CPRA”) have the same meaning as in such definitions.

We want you to understand our collection, use, disclosure, and retention of your “Personal Information,” which means any 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. You should also review all other agreements or terms that may apply to your relationship with us.

We may collect Personal Information from you in a variety of different situations and using a variety of different methods, including, but not limited to, on our website, your mobile device, through email, in physical locations, through written applications, through the mail, and/or over the telephone.

We are committed to protecting your privacy, and we use administrative, technical, and physical safeguards designed to protect your Personal Information from unauthorized access, disclosure, alteration, or loss.

Personal Information We Collect and Purposes for Use

In the previous 12 months, we have collected the categories of Personal Information identified in Table 1 below to administer any relationship you and we have with each other, comply with legal obligations, facilitate communications and efficiency, provide benefits, to ensure the safety of employees, independent contractors, facilities, and property, or for other purposes, as set forth below.


Categories of Personal Information We Collect and Purposes for Use


Categories of Personal Information Examples of Data within Category Purpose for Collection and Use
  • Name, postal address, internet protocol address, email address, emergency contact (address, email, phone number)
  • Administer the employee/contractor relationship
  • Comply with legal obligations
  • Facilitate communications and efficiency
  • Provide benefits
  • Ensure the safety of employees, contractors, facilities, and property
  • Birth date, national origin, country of residence
  • Demographic
Personal information categories listed in the California Customer Records statute
  • Name, address, telephone number
  • Administer the employee/contractor relationship
  • Comply with legal obligations
  • Facilitate communications and efficiency
  • Provide benefits
  • Ensure the safety of employees, contractors, facilities, and property
Protected classification characteristics under California or federal law
  • Gender, ethnicity, veteran status
  • Administer the employee/contractor relationship
  • Comply with legal obligations
  • Provide benefits
  • Work Opportunity Tax Credit
Internet or other similar network activity
  • Browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement
  • Administer the employee/contractor relationship
  • Facilitate communications and efficiency
  • Provide benefits
  • Ensure the safety of employees, contractors, facilities, and property
Geolocation data
  • Geographic location of occupants while in company vehicles
  • Facilitate communications and efficiency
  • Ensure the safety of employees, contractors, facilities, and property
Sensory data
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Facilitate communications and efficiency
  • Ensure the safety of employees, contractors, facilities, and property
Professional or employment-related information
  • Information about previous employment
  • Administer the employee/contractor relationship
  • Comply with legal obligations
  • Ensure the safety of employees, contractors, facilities, and property
Non-public education information
  • School records or transcripts
  • Green Card application
  • Marital and dependent status
  • Beneficiary and emergency contact information
  • Bank account details and payroll information
  • Wage and benefit information
  • Performance information
  • Insurance enrollment information
  • Start date
  • Employment location
  • Education and training
  • Employment records (including professional memberships, certifications, and licenses, references, work history, and proof of work eligibility)
  • Photograph
  • Other personal details included in a resume or cover letter
  • Immigration Status (I-9)
  • Administer the employee/contractor relationship
  • Comply with legal obligations
  • Provide benefits
  • Ensure the safety of employees, contractors, facilities, and property

Personal Information does not include publicly available information from government records or de-identified or aggregated consumer information.

Please note, however, that the specific pieces of information that we may have collected about any specific individual may differ due to the nature of the individual’s position, role, and benefits. We may have your Personal Information collected by our service providers, including recruiting firms, application processors, background check service providers, and the like.

Purpose for Collection of Personal Information

The purposes for our collection of Personal Information are described in Table 1. Additional information is provided below.

     A. Administer the Employee/Contractor Relationship

We keep and process Personal Information for normal employment and independent contractor engagement purposes. The Personal Information we hold and process will be used for management and administrative uses and only shared with others who have a need to know such information. We will keep and use it to enable us to run our business and manage our relationship with you effectively, lawfully and appropriately, and after your employment or engagement with us has ended for so long as we have a legitimate business need to retain such information. This includes using Personal Information to enable us to comply with any legal requirements associated with an employee or independent contractor relationship, to administer payroll, to provide and manage employee benefits (where applicable), to provide training, to ensure your health and safety, to comply with an employment or service contract, to demonstrate our commitment to equal employment opportunity and fair employment practices, and to otherwise enable you to perform your professional obligations and responsibilities at our company.

     B. Compliance with Legal Obligations

In certain situations, we may need to collect and process your Personal Information to comply with our legal obligations. These obligations include:

  • Tracking demographic information to confirm compliance with equal opportunity and non-discrimination policies and requirements;
  • Processing information relating to your health in order to comply with our obligations under applicable employment and safety and health laws;
  • Verification of employment;
  • Tax obligations;
  • Insurance coverage and unemployment; and/or,
  • Producing information relevant to any alleged violation of law or in compliance with a subpoena or other valid legal or regulatory request.

     C. Facilitate Communications

We use various tools and platforms that enable you to communicate with other employees and personnel and to access and share work product and other work-related materials more efficiently.

     D. Provide Benefits

We collect Personal Information, such as identifiers, protected classifications, and employment information, as is necessary for benefits administration.When you participate in certain benefits programs (as may be applicable to you), we may also generate a log of your activity, track internet and other network activity, and develop a user profile to provide those programs to you in a manner tailored to your preferences.

All benefits may not be available to all personnel, and we will only collect Personal Information to provide a benefit if you are eligible for and enrolled in that benefit. Employees should take care to read the specific terms applicable to any benefits program to understand the specific pieces of information collected.

     E. Ensure Safety

We collect various categories of Personal Information to ensure the health and safety of its employees, contractors, facilities, and property. Some information, such as identifiers, personal information, protected classifications, and possibly biometrics (e.g., fingerprint, image, etc.) under limited circumstances help verify your identity in specific facilities, as well as help screen for indicators of infectious diseases or vaccination status of those entering facilities. Other categories of information, such as geolocation data and sensory data, may assist us with ensuring the security of people, facilities, and property.

Disclosure of Your Personal Information

We may disclose your Personal Information to our service providers in order to fulfill a legitimate purpose for collecting or using that Person al Information (as permitted by CPRA). We have not sold or shared (as such terms are defined under the CPRA) and will not sell or share your Personal Information for monetary or other valuable consideration; however, our use and disclosure to third parties (such as data analytics providers) within the past twelve months of cookies, other website tracking technologies identifiers (e.g., IP addresses), and Internet or other similar network activity, may be considered a sale or sharing of Personal Information under the CPRA.

Retention of Personal Information

Any Personal Information collected by us or our service providers will be retained (i) during the period of person’s active employment/engagement; and, (ii) during the post-employment/engagement period as long as retention is reasonably necessary and proportionate to achieve the purposes for which it was collected and not otherwise incompatible with such purposes.

Sensitive Personal Information

Certain categories of Personal Information are deemed “sensitive” under CPRA. We may collect, use, and retain the following categories of “sensitive” Personal Information as described in Table 2 below.


Categories of “Sensitive” Personal Information We Collect and Purposes for Use


Category Examples of PI in the Category Purpose for Use
  • Social security number
  • Tax reporting & I-9, E-Verify
  • Driver’s license or state ID number
  • Passport number
  • I-9, E-Verify
Characteristics of protected classifications under California or federal law
  • Racial or ethnic origin
  • Gender
  • EEOC and similar state reporting
  • Veteran status
  • Work Opportunity Tax Credit
Biometric information based on characteristics
  • Fingerprint
  • To identify a specific person (e.g., ID verification, e.g., for time clocking systems)
  • Geographic location
  • Facilitate communications and efficiency
  • Ensure the safety of employees, contractors, facilities, and property
  • Bank account numbers
  • Direct deposit
  • Disability (optional) and health information
  • For FMLA, PSL, workers’ compensation, and other statutory or regulatory compliance

We may also use your sensitive Personal Information for any of the purposes set forth in Table 1 above. We do not use your sensitive Personal Information for the purpose of inferring characteristics or for any purpose other than those set forth in the CPRA Regulations, or for any purposes that would permit you to limit our use of such information. You may can learn more about these permitted purposes by reading the website page here.

Retention of your Personal Information

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any banking laws and regulations govern ed by various regulatory agencies, legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, we consider our statutory obligations, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes we process your Personal Information for, and whether we can achieve those purposes through other means. We specify the retention periods for your Personal Information in our data retention policy. Under some circumstances we may anonymize or de-identify your Personal Information so that it can no longer be associated with you, in which case it is no longer “Personal Information”. We reserve the right to use such anonymized or de-identified data for any legitimate business purpose without further notice to you or your consent. Once you are no longer an employee of the company, we will retain and securely destroy your Personal Information in accordance with our document retention policy and applicable laws and regulations.

Your Rights

California residents who are H Mart employees or independent contractors have the following rights (subject to certain exceptions as set out in CPRA): (a) access a copy of their Personal Information held by us; (b) have inaccuracies in their Personal Information to be corrected; (c) limit our use of sensitive Personal Information we collect (if any) to what is necessary to perform the services or provide the goods reasonably expected by an average consumer; (d) request information about the categories of Personal Information we collect and sell (if any) and data we share with third parties (the foregoing of which is described above in this Privacy Policy); (e) request that we provide information about the logic behind any automated decision-making and likely outcome of such processes; (f) transmit your Personal Information to another business; (g) request deletion of their Personal Information held by us; (h) opt-out of the use of automated decision-making technology, including profiling; and, (i) opt-out of the sale of their Personal Information (if any is being sold). You may exercise your rights by filling out our data request webform, available here.

Updates to the Notice

This Notice is subject to periodic revision and updated versions are effective when posted. The current version of this Notice will be posted or available on bulletin boards or other locations at our facilities.

We may be subject to certain laws and regulations relating to privacy and information security in more than one jurisdiction. If any term, covenant, condition, or provision of this Notice is held by a court of competent jurisdiction to be invalid, void, or unenforceable, it is the intent of this Notice that the scope of the rights and obligations of the Notice be reduced only for the affected jurisdiction and only to the extent dee med necessary under the laws of the local jurisdiction to render the provision reasonable and enforceable and the remainder of the provisions of the Notice will in no way be affected, impaired, or invalidated as a result.

Contact Us

If you have questions regarding this Notice, please contact

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