Global Employee Privacy Notice

This Global Employee Privacy Notice ("Employee Privacy Notice” or “Notice”) applies throughout the global Ecolab enterprise to all employees and independent contractors. This Notice outlines the personal information that Ecolab may collect during your employment relationship with Ecolab, how Ecolab uses and safeguards that information, and with whom we may share it.

This Employee Privacy Notice is designed to set a uniform standard for every Ecolab entity with respect to its protection of employee personal information. Ecolab acknowledges that certain laws may impose additional requirements than those described in this Employee Privacy Notice. As such, this Notice is supplemental to the public-facing Privacy Policy. In addition, any local notices or privacy-related disclosures specific to your country of residence shall supersede this Employee Privacy Notice, to the degree to which there is a conflict.

Personal information (also commonly known as personally identifiable information or personal data) is information that can be used to identify you, or any other individual to whom the information may relate. Certain information is required to establish the employment relationship while other information is collected throughout the duration of your employment. Ecolab collects information consistent with what is allowed by law in your country of residence. Certain information, such as gender, race, and religion, may only be collected where legally permissible in your jurisdiction.

The personal information that we collect in conjunction with your employment may include the following:

• Name and contact information, including emergency contact information (for example, address; phone number; email, fax);
• Personnel information (for example, date of birth, marital status, birthplace, nationality, residency, citizenship, work permit status, military status, nationality, preferred language);
• Payment information (for example, personal bank account information, tax-related forms and information, Ecolab corporate card number);
• Identification information (for example, SSN or other national identification number, passport number, driver’s license number, license plate number);
• Account information (for example, login credentials for Ecolab Job Portal or other employee portals);
• Employment information (for example, dates of employment, compensation and benefits, union affiliation, retirement, insurance, beneficiaries, work restrictions and accommodations, grievance resolutions, performance);
• Position information (for example, Ecolab identification number, job title, department/business unit, supervisor, site, computer and facilities access);
• Education and training (for example, education level, field and institution, competency assessments, professional licenses and certifications, or training courses);
• Professional history (for example, previous employers or previous positions; letters of recommendation);
• Attendance information (for example, paid time off (“PTO”) and requests for PTO, and all other leave of absence requests);
• Communication information (for example, voicemails, e-mails, correspondence, documents, and other work product and communications created, stored or transmitted using our networks, applications, devices, computers, or communications equipment; survey information);
• Information collected from the hiring and termination processes (for example, interview information, CV or resume, cover letters, references, reference letters, background and credit checks, transcripts, pre-hire interactions, letters of reference, letters of offer and acceptance dates of hire, start and end dates, resignation date and reasons);
• Industrial hygiene exposure assessment and monitoring information;
• Other information provided in forms as required for benefits, payroll, or human resources, in accordance with applicable laws;
• Image and likeness information, where permitted by law and/or after subsequent notice where required by law (for example, identification photo, CCTV footage, other images or photographs, and key card use times and locations);
• Technology information and information outlined via Ecolab’s Cookie Notice, when accessing certain Ecolab sites, where permitted by local law, including where an employee may be able to opt-out of such information collection (for example, browsing, online, or other use information from company devices or on company networks, work device IP addresses, User I.D., password, and any other credentials used to access Ecolab systems, applications, devices, computers, or communications equipment);
• Unique personal identifiers affiliated with certain website tracking technology as described in Ecolab’s Cookie Notice, and as you can opt-out of consistent with that Cookie Notice (for example device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; or other forms of persistent identifiers). Please note that, while this Employee Privacy Notice applies across all employee activity, the applicability of cookies and the affiliated cookie notice may vary if you are on certain websites outside of www.ecolab.com.
• Other information that may be exchanged in the course of engaging in the employment relationship with Ecolab.

Some personal information, such as biometric information, precise location data, gender, race, religious, and health information, as well as communications where we are not the intended recipient, is considered sensitive personal information under certain data privacy regulations. We do not collect sensitive personal information in all jurisdictions in which we operate. Where required by law, your explicit consent to collection, processing, or transferring of such sensitive personal information will be obtained. Appropriate security and protection measures will be provided that will be congruent with the nature and risks associated with the data and processing activities.

When providing personal information to Ecolab as described in this Employee Privacy Notice, that personal information is typically collected directly from you, and you will know the precise personal information being collected by us.

In certain limited circumstances, third-party service providers may also collect information on behalf of Ecolab (for example for the purposes of background checks, screening, etc.), though such collection of your information will always be within the context of your employment, and we will inform you that a third party is collecting your information at the time of collection. Finally, certain information may be collected from customers, associates, or others that you may engage with in the course of your employment with Ecolab (for example customer surveys for performance review and similar purposes).

Subject to the terms of this Employee Privacy Notice, Ecolab uses the above-described categories of personal information in several ways. Unless otherwise stated specifically, the above information may be used for any of the purposes listed below. These purposes are not all inclusive, and you may receive subsequent notice about additional purposes for other, specific types of processing. Ecolab may use your personal information to:

• Determine your eligibility for employment, including verification of references and qualifications;
• Administer pay and benefits to you; • Assess qualifications for a particular job or task;
• Enable communication and networking among employees;
• Comply with applicable labor or employment statutes;
• Contact you regarding other recruitment opportunities;
• Provide general information about Ecolab;
• Respond to your queries and requests;
• Process work-related claims (for example worker compensation and insurance claims);
• Provide training or other developmental requirements;
• Conduct performance reviews and disciplinary action;
• Establish contact in the event of an emergency;
• Comply with legal obligations, including health and safety requirements, and requests for information from government agencies, and security investigations, or to assert or defend a legal claim;
• Compile employee directories;
• Ensure the security of company-held information;
• Manage staffing resources, financial planning, corporate compliance, internal audits, and other administration;
• Administer our applications, software, and electronic systems;
• Improve employee satisfaction and performance;
• Prevent potentially fraudulent, prohibited, or illegal activities;
• Generally manage all aspects of the employment relationship, including but not limited to establishing, maintaining, and terminating employment relationships, general operations, and administrative, financial, and human resources related purposes;
• For other such purposes as are necessary and reasonably required by Ecolab for which you will receive subsequent notice if it is a material deviation from the above purposes.

In applicable countries, the information that you provide in the equal opportunities section of a job application will be used for the sole purpose of monitoring equal opportunities within the Ecolab global enterprise. Ecolab does not use this information for marketing purposes.

Ecolab may collect similar or related information or use personal information for a similar or related purpose consistent with laws and regulations of a particular jurisdiction. Where required, subsequent notice will be provided prior to further collection. Depending on your jurisdiction, you may have data subject rights such as deletion, correction, or limitation of use. Such data subject rights, and the jurisdictions where they are applicable, are described below or in jurisdiction-specific notices.

Certain information collected is required to establish and maintain the employment relationship. If you choose not to provide required information, we may not be able to pursue or continue an employment contract or provide all of the benefits of employment that would otherwise be available to you. You may inquire at any time as to whether certain information is required or optional and understand how removal of certain information may impact you.

We may provide any of the described categories of personal information to Ecolab employees, consultants, affiliates or other businesses or persons for the purpose of processing such information on our behalf in order to establish, manage, or terminate the employment relationship with you. In such cases, we require that these parties agree to protect the confidentiality of such information consistent with the terms of this Employee Privacy Notice as well as the public-facing Ecolab Privacy Notice and any internal privacy compliance standards, and the laws and regulations of the jurisdiction in which you live.

Parties receiving your information may include:

• Our affiliates and related companies;
• Business partners, contractors, and channel partners, which are not considered affiliated companies;
• Third-party vendors or service providers providing crucial services and necessary to support your employment or application and or provide you certain employment-related services (including for purposes addressed outlined in the preceding section);
• Third parties who may provide professional advice (for example, lawyers, bankers, accountants);
• Government agencies or other parties in response to legal process or other requests, where permitted by law;
• With other persons or third parties with whom you have requested that we share information.

Except as described above, we will not share your personal information with other, third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you have the ability to opt-in or opt-out.

In addition, we may release personal information: (i) to the extent we have a good-faith belief that such action is necessary to comply with any applicable law; (ii) to enforce our rights and/or make or defend claims related to your employment with Ecolab, protect ourselves against any liability, defend ourselves against any claims, protect the rights, property and personal safety of any person, or protect the public welfare; (iii) when disclosure is required to protect the security of other persons, consistent with applicable laws (iv) to respond to a court order, subpoena, search warrant, or other legal process, to the extent permitted and as restricted by law; (v) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of our assets; or (vi) for an additional purpose that is directly related to the original purpose for which the personal information was collected.

Ecolab will retain your personal information only for as long as is necessary for the purposes set out in this Employee Privacy Notice, which is typically the length of your employment, plus at least an additional year following the termination of the employment relationship.

In certain jurisdictions, the length of time that your personal information will be retained may vary depending on local law. You may inquire with your manager or contact Ecolab as described herein for the retention period that is specific to your jurisdiction. Further, we may retain and use personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

If you are located outside the United States, in particular if you are located in Canada, Brazil, the European Union (“EU”), the European Economic Area (“EEA”), New Zealand, the Republic of South Africa, Switzerland, the United Kingdom, or other countries with similar data privacy laws, please note that we and our servers are located in the United States. Any information that you provide to us may be transferred to and processed in the United States or other countries around the world where we do business. Although this may include recipients of information located in countries where there may be a lower level of legal protection for your personal information than in your country, we will make efforts to protect your information in accordance with requirements applicable to the law in your particular jurisdiction and take steps to only share with third parties that offer similar protection. By engaging with and providing personal information and other data that Ecolab may legitimately collect, process, use or transfer in connection with your relationship with Ecolab, you unambiguously consent to your information being collected, processed, used, and transferred as disclosed herein.

If you are located in the EU or a jurisdiction with a similar law, the GDPR or its local equivalent may grant you certain rights under the law. In particular, the right to access, correct, and delete the personal information we hold about you. Ecolab will retain your personal information for the length of time you engage with our services as described in the retention section of this Notice, until you request deletion of such personal information. Ecolab is considered the Data Controller (or equivalent distinction) with regard to your personal information. You can find our contact information as described herein or in other portions of the Service.

In certain circumstances, you have the following data protection rights:

• The right to access, update, or delete the personal information we have on you.
• The right of rectification. You have the right to have your personal information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your personal information.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the personal information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

In order make a request regarding your personal information, please contact your manager, HR, or dataprivacy@ecolab.com. If you are a job applicant, you can request deletion of your job applicant information directly in the job applicant portal after logging in to your applicant account.

If you have a comment, question, or complaint about how we are handling your personal information, we hope that you contact us as described herein to allow us to resolve the matter. In addition, if you are located in the EEA, you may submit a complaint regarding the processing of your personal information to a regulatory authority.

The following links may assist you in finding the appropriate regulator:

• In the UK, you have the right to lodge a complaint with the Information Commissioner: www.ico.org.uk
• In Switzerland, you have the right to contact the Federal Data Protection and Information Commissioner (FDPIC): FDPIC
• In the EU, you have the right to lodge a complaint with your local data protection authority. To find your local authority, you can check the list on the European Data Protection Board website: https://edpb.europa.eu/about-edpb/board/members_en
• In South Africa, you have the right to file a complaint with the Information Regulator: https://www.justice.gov.za/inforeg/index.html
• In Brazil, you have the right to lodge a complaint with the National Data Protection Authority (ANPD)
• In Argentina, you have the right to contact the National Directorate for Personal Data Protection: PDP
• In Canada, you have the right to lodge a complaint with the Office of the Privacy Commissioner in Canada: Office of the Privacy Commissioner in Canada
• In Japan, you have the right to contact the personal information Protection Commission. https://www.ppc.go.jp/en/
• In Australia, you have the right to lodge a complaint with the Privacy Commissioner: Australian Information Commissioner
• In New Zealand, you can contact the Privacy Commissioner’s office: www.privacy.org.nz

Legal Basis for Processing

If you are located in the EEA or a jurisdiction that requires a similar legal basis for processing, our legal basis for collecting and using the personal information described in this Notice depends on the personal information we collect and the specific context in which we collect it.

We may process personal information because:

• It is necessary for the performance of a contract between you and Ecolab;
• You have given us consent to do so (in applicable jurisdictions);
• The processing is in our legitimate interest as the Controller, when that legitimate interest is not overridden by your rights;
• Ecolab must comply with the law.

Where certain sensitive personal information is processed based on your explicit consent, you may have the right to withdraw such consent at any time. To do so, please contact us as described in this Privacy Notice. If there is a different legal basis that would permit us to continue processing your personal information after withdrawing consent, we will notify you of that legal basis at the time of your request.

Ecolab will take reasonable steps to protect your Personal Data in Ecolab’s possession and secure against risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction. We employ industry-standard security measures designed to protect the security of all information collected during the employment relationship. Ecolab periodically reviews its security measures in an effort to ensure the privacy of personal information. However, the security of information transmitted through the internet or via a mobile device can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data.

You are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of Ecolab’s systems that you have been granted access to based on your position. In order to protect you and your information, we may suspend your access to any Ecolab systems, without notice, pending an investigation, if any breach of security is suspected.

Ecolab will take reasonable precautions to ensure that your personal information is only used for the purposes for which it was collected as described in this Employee and Applicant Privacy Notice. Ecolab will take steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. However, Ecolab relies upon you to assist in providing accurate updates to your personal information.

Ecolab reserves the right to modify this Privacy Notice from time to time in order that it accurately reflects the regulatory environment and our data collection principles. When material changes are made to this Privacy Notice, Ecolab will provide you with the revised notice. This Employee and Applicant Privacy Notice was last modified as of August of 2023.

If you have any questions or comments about this Privacy Notice or the Service provided by Ecolab, please contact us at 844-880-8355 or dataprivacy@ecolab.com.