Workplace Privacy Policy

Harkins Theatres Workplace Privacy Notice


Harkins Administrative Services Inc. and its affiliated companies (“Company”, “we”, or “us”) are committed to protecting the privacy and security of your personal information. This Privacy Notice (“Notice”) describes how we collect and use personal information about you when you apply to work for us, during your employment with us, and after you are no longer employed by us (collectively, your “employment”). It applies to all current and former applicants, employees, workers, and contractors (collectively “personnel”).

It is important that you read and retain this Notice so you are aware of how and why we are using your information and your rights with respect to your information.  Please also read any other privacy notice we may provide on occasions when we collect specific personal information that may not be covered by this Notice.

This Notice does not form part of any contract of employment or other contract to provide services.  We may update this Notice at any time (as described below under “Changes to this Notice”).

Information We Collect About You


For purposes of this Notice, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual. We may collect, store, and use the following categories of personal information about you:

Personal Identifiers:

· We collect your personal contact information, such as your name, title, address, telephone number, and personal email address.

· We collect certain information about your health, such as medical conditions and health records, when you report such information to the Company. This information        includes details about certain absences from work, including time spent on leave; information related to testing for controlled substances; records related to administering and maintaining your healthcare and other benefits; and information about a medical condition needed for long-term health insurance purposes when you leave employment for a health-related reason.

Additional Personal Identifiers (sensitive):

·We collect certain financial information about you, such as bank account details, payroll records, and tax status information. We use this information to administer your pay and benefits and to record tax information about you.

·We collect your Social Security Number for identification and tax administration purposes.

·We may collect your driver’s license number, passport number, nationality, visa status, and related information to verify your employment eligibility and to arrange travel for you.

Commercial Information: This Notice does not apply to information related to your purchase and use of the Company’s products and services for your personal or household use.

Biometric Information: We collect your fingerprint to verify your identity for shift scheduling purposes. We use this information to ensure compliance with Company policies and to maintain the security of our network, systems, premises, information, and personnel.

Protected Classifications: We collect your date of birth and gender in order to verify your identity. We collect your marital status, family status, and information about dependents for tax and benefits administration purposes. We also collect information about your racial and ethnic origin, disability status, religious affiliation, and sexual orientation if you choose to provide it or if you request an accommodation. We use this information only to support our efforts to attract and maintain a diverse workforce and to make legally required reports to government agencies.

Internet and Other Electronic Network Activity Information: We collect information about your use of the Company network, computers, and devices, including your use of the Internet and your email communications using Company computers, devices, or systems. We use this information to ensure compliance with Company policies and to maintain the security of our network, systems, premises, information, and personnel.

Geolocation Data: We may collect geolocation data about you if, for example, you are operating a Company-issued vehicle or device, such as a Company cellphone. We use this information to ensure compliance with Company policies and to maintain the security of our network, systems, premises, information, and personnel.

Audio, electronic, visual, thermal, olfactory, or similar information: We store photographs of you for identity verification, security cameras on our premises may capture visual information about you, and your telephone calls and other electronic activity may be monitored or recorded when you access Company resources, such as IT services, and when you interact with a guest or member of the public. We use this information to ensure compliance with Company policies and to maintain the security of our network, systems, premises, information, and personnel.

Professional or employment-related information: We collect information about your professional and employment-related background through the recruitment process (including copies of right to work documentation, references, and information included in a resume, cover letter, or job application). We may collect information about your job titles, salary history, work history, working hours, holidays, absences, training records, and professional memberships. We also may collect information about your current employment, including your salary, annual leave, retirement, work performance, disciplinary actions, and grievances. We use this information to determine your eligibility for particular responsibilities and positions and to ensure compliance with Company policies and applicable laws.

Education information: We may collect information about the educational institutions you have attended and your level of education. We also may collect information about any professional licenses or certifications you hold and additional education or training you undertake before or during your employment.  We use this information to ensure compliance with all Company policies and to evaluate your performance and eligibility for particular positions and responsibilities.

Inferences drawn to create a profile: We do not create profiles about you reflecting your preferences or characteristics.

How We Collect Your Personal Information


From You: We collect personal information from you during the application process, onboarding process, and during your employment as you perform job-related activities and tasks.

From Third Parties: We may collect personal information from third parties during the recruitment or promotion process, including from employment agencies, screening services and other background-check providers, former employers, credit reference agencies, or other sources that supply employment verification services.

Automatically:  We may collect information about you during your employment automatically, such as when we monitor your Company computer and device access and when our security cameras record visual information about you.

How We Use Personal Information About You


We will only use your personal information as permitted by law for the following reasons:

·making decisions related to your employment, including deciding whether to hire you; determining your salary and other compensation; setting your job duties; reviewing your performance; evaluating your professional development and qualifications for other positions within the Company; assessing our staffing needs; addressing grievances; administering any necessary disciplinary procedures; handling legal disputes and workplace accidents; and ascertaining your fitness for work.

·business purposes, including reviewing and studying employee retention and attrition rates, internal auditing, and fulfilling any education, training, and development requirements.

·administering compensation and benefits, including making required deductions.

·providing security and safety and ensuring compliance with Company policies, including providing security for you, other personnel, guests and other people, our premises, and our resources; preventing fraud and securing our network, computers, devices, systems, information, resources, and premises from unauthorized access, exploitation, and malicious software; monitoring compliance with our Company policies; and investigating theft and other illegal activities.

·compliance with legal obligations, including verifying you are legally permitted to work in the United States and complying with all other applicable federal, state, and local laws and regulations.

We may use any and all of the information we collect from you for any of the purposes described in this Notice (unless limitations are expressly listed). We also may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the information was collected. 

Disclosure of Your Personal Information


We may disclose the personal information we collect as described in this Notice:

·to our affiliates and other Company-related legal entities.

·to service providers, which are companies we use to support our business that are bound by law and/or contractual obligations to keep your personal information confidential. Service providers may use information we share with them only for the specific purposes for which we disclose it to them. The following are the categories of service providers with which we share information and the services they provide:

o   payroll services providers that assist us with disbursing your salary and other compensation.

o   auditing and accounting firms that assist us in the creation of our financial records.

o   professional services consultants that perform analytics, assist with improving our business, provide legal or insurance services, or supply project-based resources and assistance.

o   recruitment vendors that assist with the application process, including providing the platform through which candidates apply and background-check services.

o   security vendors that assist with security incident verification and response, service notifications, and fraud prevention.

o   IT vendors that assist with data and software platforms, storage, and network operation.

·to other external parties when required by law or to protect Company personnel or other people, as described in this Notice.

·to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding, in which personal information held by the Company about our personnel is among the assets transferred. If this happens, the recipient of the personal information will continue to honor the promises made in this Notice and provide you with notice of any changes.

We do not sell the personal information of personnel to any third parties.

Special Information for California Residents


The California Consumer Privacy Act (“CCPA”) provides California residents, referred to by the CCPA as “consumers,” with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to access and control personal information. The CCPA defines “personal information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California resident.

Certain information we collect may be exempt from the CCPA because it is considered public information (because it is made available by a government entity) or covered by a federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act. To the extent we collect personal information about you that is subject to the CCPA, that information, our practices, and your rights are described in the below disclosures.

Right to Information Regarding the Categories of Your Personal Information That We Collect or Disclose: You have the right to obtain information regarding the categories of personal information about you that we collect or disclose (we do not sell your personal information.) We provide that information above (under “Information We Collect About You”), separated by the categories listed in the CCPA.


Right to Access and Request Deletion of Information: At this time the CCPA does not require us to comply with requests from personnel to access or delete personal information that was collected and used solely in the context of their role as Company personnel.


Right to Information Regarding Participation in Financial Incentives: We may run promotions from time to time that incentivize personnel to share certain personal information with us. Participation in any of these incentives will be voluntary, and you may opt out and stop sharing information at any time.


Right to Opt Out of Sale of Personal Information to Third Parties: Under the CCPA, “selling” personal information means disclosing it to a third party for monetary or other benefit. While you have the right to opt out of any “sale” of personal information, we do not sell your personal information to any third party. Please note that your right to opt out does not apply to our sharing of information with service providers, which are third parties we engage to perform specific functions on our behalf and are legally and contractually obligated to use the information only for those functions.


Notice of California Employee Data Collection and Sharing Practices: We collect the categories of information described above (under “Information We Collect About You”). We use the categories listed in the CCPA.


Data Security


We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. We use physical, administrative, and technical safeguards to secure personal information. The safety and security of your information also depends on you. You are responsible for following all Company security policies.

Unfortunately, the reality is that storage and processing of information via Internet-connected computers can never be completely secure. While we do our best to protect your personal information, we cannot guarantee the security of your personal information, which you provide at your own risk.

Changes to this Notice


We reserve the right to update this Notice at any time. If we make substantial updates to this Notice we will provide you with an updated version. We may also notify you in other ways from time to time about the processing of your personal information.

This Notice was last updated on January 1, 2020.

Questions about this Notice


If you have any questions about this Notice, or if you would like to obtain an alternative, accessible version of this Notice, please contact Employee Relations at