Bunge Privacy Notice for California Employees and Job Applicants

Effective Date: January 1, 2023

Last Reviewed on: January 31, 2023

This Privacy Notice for California Employees and Job Applicants applies solely to all job applicants and employees of Bunge North America and its affiliates (“Bunge,” the “Company,” “we,” “our,” or “us”) who reside in the State of California ("consumers", “employees” or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act (the “CPRA”), collectively referred to as “CCPA”.  Any terms defined in the CCPA have the same meaning when used in this notice. 

Information We Collect

Bunge collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information").  In particular, Bunge has collected the following categories of personal information from employees and job applicants within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES

 

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

 

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per FERPA (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, or transcripts.

NO

K. Inferences drawn from other personal information.

Creation of a unique profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

L. Sensitive Personal Information

A person’s social security, driver’s license, state issued identification card, or passport number.

YES

Sensitive Personal Information

The contents of a person’s mail, email, and text messages unless the business is the intended recipient of that communication.

YES

We may not collect each and every category of information indicated above from each employee or job applicant.

Additionally, personal information does not include the following:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, such as:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or information collected as part of a clinical trial covered by the Federal Policy for the Protection of Human Subjects;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Bunge obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or documents you upload.
  • Automatically from you. For example, through the use of cookies, pixels, and other similar technologies used on our website, and from other software that is used to protect the security and integrity of Bunge’s systems, devices, and applications. 
  • Third parties. For example, when you are a job applicant, we may obtain information about you from your references, and when you are an employee, we may obtain information about you from your manager, supervisor, or superiors. 

Use of Personal Information

We may use the personal information we collect for one or more of the following business purposes:

  • To consider your application for employment.
  • To offer and provide you employment.
  • To evaluate, offer, and provide you with employee benefits. 
  • To otherwise fulfill or meet the reason you provided the information. 
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Bunge's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Bunge about our employees and/or job applicants is among the assets transferred.

Bunge will not collect additional categories of personal information or use the personal information we collect from you for materially different, unrelated, or incompatible purposes without providing you notice.

Personal Information Retention

We retain personal information only for as long as necessary to fulfill the purpose(s) for which it was collected, consistent with Bunge’s data retention procedures. 

Disclosing, Sharing, and Selling Personal Information

Disclosures of Personal Information for a Business Purpose

Bunge may disclose your personal information to third parties.  When we disclose personal information to service providers and contractors for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the services under the contract and pursuant to Bunge’s instructions.

Bunge has disclosed your personal information to the following categories of third parties for a business purpose:

  • Service providers.
  • Contractors. 
  • Benefits providers. 
  • Affiliates.

In the preceding twelve (12) months, Bunge has disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category C: Protected classification characteristics under California or federal law
  • Category F: Internet and other similar network activity
  • Category H: Sensory Data
  • Category I: Professional or employment-related information 
  • Category L: Sensitive Personal Information

“Sales” or “Sharing” of Personal Information

In the preceding twelve (12) months, Bunge has not sold or shared any personal information of employees or job applicants. The terms “sold” and “shared” as used in the CCPA are intended to capture the disclosure of personal information for “cross-context behavioral advertising,” targeted advertising, and disclosures of information in exchange for money or other consideration. Bunge does not engage in these practices. 

Your Rights and Choices

The CCPA provides consumers (California residents, including employees) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Bunge disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your written request and verify your request (see Exercising Access, Data Portability, Update or Correction, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we disclose personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold, shared, or disclosed your personal information for a business purpose, two separate lists disclosing:
    • information sold or shared by identifying the personal information categories that each category of recipient purchased or that we shared for cross-context behavioral advertising and the categories of recipients to whom we sold or shared the personal information; and
    • information disclosed for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Update or Correct

You have the right to request that we update or correct personal information about you, where the information we have collected is inaccurate. 

Deletion Request Rights

You have the right to request that Bunge delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Update or Correction, and Deletion Rights), we will delete (and direct our service providers/contractors to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) or contractor(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Help ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes. 
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.

Right to Opt-Out of Certain Uses and Disclosures of Personal Information

You have the right to opt-out of the use of your personal information for the following purposes or to opt-out of the following practices, to the extent we engage in them:

  • Our “selling” or “sharing” of your personal information.
  • Automated decision making, and the right to access information about automated decision making, consistent with the scope of these rights within the CCPA and its regulations. 
  • To limit certain uses and disclosures of “sensitive personal information.”

We have not engaged in practices that implicate these rights in the last 12 months and have no plans to do so. Should those plans change, we shall make available Opt-Out and Opt-In forms, as applicable. 

Exercising Access, Data Portability, Update or Correction, and Deletion Rights

To exercise the access, data portability, update or correction, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us Toll-Free at 1-866-921-6714.
  • Sending us an Electronic Mail message to [email protected]  
  • Mailing Your Request to the Legal Department at:

ATTN: Data Privacy Officer
1391 Timberlake Manor Pkwy
Chesterfield, MO 63017

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or your authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale, sharing, or use and disclosure of sensitive personal information opt-out rights, see Right to Opt-Out of Certain Uses and Disclosures of Personal Information.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. 

Changes to Our Privacy Notice

Bunge reserves the right to amend this privacy notice for employees and job applicants at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. 

Contact Information

If you have any questions or comments about this notice, the ways in which Bunge collects and uses your personal information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

Phone: 1-866-921-6714

Email:  [email protected] 

Postal Address:
Bunge North America
Attn: Data Privacy Officer
1391 Timberlake Manor Pkwy
Chesterfield, MO 63017