AMERICANBUILT
Privacy and Legal
GILLIG LLC PRIVACY POLICY FOR RIGHT FIRST TIME
GILLIG LLC (“GILLIG,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy (the “Privacy Policy”) is intended to describe how we collect, use, and share information that we collect through the Right First Time app and website (collectively, “Right First Time”).
Please note that certain requirements and disclosures in this Privacy Policy may be subject to exemption or otherwise may not apply to you based, for example, on applicable law or regulations. This Privacy Policy does not form a contract between GILLIG and you.
1. INFORMATION WE COLLECT
As described in this Privacy Policy, we may collect certain Personal Information from or about you in connection with our provision of Right First Time. “Personal Information,” for purposes of this Privacy Policy, generally includes information that we collect to provide Right First Time that may be used to identify you specifically.
You may not be required to provide all of the Personal Information identified in this Privacy Policy to use Right First Time; however, please be advised that if you do not provide Personal Information requested by us, we may be unable to provide full functionality of Right First Time to you.
1.1 Categories of Personal Information. We may collect the following categories of Personal Information:
Categories of Personal Information
Examples of Personal Information
Identifiers
Name, employee number, network ID, email address, device ID, geolocation, department, work center, build station, and IP address
Personal information categories listed in the California Customer Records law
Name, employee number, employee email, PIN number, network ID, device ID, geolocation, department, work center, build station, and IP address
Internet or other electronic network activity information
Right First Time usage and history, clickstream data, device and operating system type, navigation paths, date/time stamps, cookie identifiers, and other information about device characteristics and how you interact with Right First Time
Geolocation data
Device location, WIFI node, IP address, build station
Audio, electrical, visual, thermal, olfactory, or similar information
Photographs of installations at build stations
Professional or employment-related information
Work history, build station, department, work center, and product defects
Inference information
Inferences based on information about an individual to create a profile about characteristics, behavior, abilities, or aptitudes
1.2 Sensitive or special categories of Personal Information. We do not collect sensitive or special categories of Personal Information through Right First Time, except as required or permitted by applicable law.
1.3 Internet Activity, Cookies, and Similar Technologies. We may collect certain Personal Information using cookies and other technologies, such as web beacons, device IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and other purposes. When you use Right First Time, we may also automatically collect certain data about your device, including information about your device, web browser, IP address, time zone, and geolocation. Additionally, as you use Right First Time, we may collect information about your use of Right First Time, including about the individual web pages or app screens that you view and information about how you interact with Right First Time. Our Use of Cookies and Similar Technologies section contains more information and options to control or opt-out of certain data collection or uses related to cookies and similar technologies.
1.4 Anonymous or De-identified Data. We may create aggregated, de-identified, or anonymous information from Personal Information by removing data components (such as your name, email address or linkable tracking ID) that make the data identifiable or through aggregation, obfuscation or other means. For example, we may use aggregated, de-identified or anonymized information to understand how to improve or enhance Right First Time or our products. So long as the aggregated, de-identified, or anonymous information is not identifiable, our use of such aggregated, de-identified, or anonymized information is not Personal Information or subject to this Privacy Policy.
2. SOURCES OF INFORMATION AND PURPOSES OF COLLECTION
The following is intended to describe the various sources through which we may collect Personal Information in Right First Time and the purposes for which we collect it in Right First Time:
Categories of Personal Information from Source
-
Identifiers
-
Personal Information categories listed in the California Customer Records law
-
Internet or similar network activity
-
Geolocation data
-
Professional or employment-related information
-
Inference information
Categories of Personal Information from Source
-
Provide and improve our products and construction and manufacturing processes
-
Provide and enhance Right First Time
-
Operate our business
-
Manage our relationship with service providers, vendors, customers, and business partners
-
Administer payroll and benefits
-
Investigate, protect, enforce, or defend the legal rights, privacy, safety or property of us or others
-
Tax and other government filing requirements
-
Workforce management (including conducting trainings, promotions, workplace evaluations, internal investigations, and performance reviews)
-
Protect against unauthorized
-
access, security incidents, fraud, and other malicious or illegal activity
-
Comply with legal and regulatory obligations
Sources of Personal Information
Through Your Employment and/or Engagement with Us
We may collect Personal Information from you when interacting with Right First Time and in connection with your employment with us.
3. HOW WE MAY SHARE INFORMATION
We may share Personal Information as described in this Privacy Policy, including with the following categories of third parties:
Categories of Third Parties with Whom We Share Personal Information
Categories of Personal Information We Share
Related Companies and Affiliates
We may share Personal Information collected through Right First Time with related companies and affiliates, which means (a) each of our past, present, and future parents, divisions, subsidiaries, partnerships, affiliates (such as entities with common ownership with us), joint ventures, joint venturers and other related entities (whether or not such entities are wholly owned); (b) the past, present, and future owners, trustees, fiduciaries, administrators, shareholders, members, directors, officers, partners, associates, agents, representatives, employees, and attorneys of each entity listed in subpart (a) of this paragraph; and (c) the predecessors, successors, and assigns of each entity and person listed in subparts (a) and (b) of this paragraph.
-
Identifiers
-
Personal information categories listed in the California Consumer Records law
-
Internet or similar network activity
-
Geolocation data
-
Audio, electrical, visual, thermal, olfactory, or similar information
-
Professional or employment-related information
-
Inference information
Union Partners, Technical and Operational Vendors, Service Providers and Business Partners
We may engage third parties to perform certain functions on our behalf or to provide certain materials or supplies to us. To do so, we may disclose Personal Information to our union partners or our third-party vendors, service providers, and business partners in order to maintain and operate Right First Time, to provide, improve, and personalize Right First Time, to improve the quality of the materials and supplies, to improve the quality of construction of our products, and for other technical and processing functions. We may also share Personal Information with service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal or fraudulent activity or other threats and for legal compliance purposes or pursuant to legal process.
-
Identifiers
-
Personal information categories listed in the California Consumer Records law
-
Internet or similar network activity
-
Geolocation data
-
Audio, electrical, visual, thermal, olfactory, or similar information
-
Professional or employment-related information
-
Inference information
Customers
We may provide our customers with information about the manufacturing and quality data about their products.
-
Geolocation data
-
Audio, electrical, visual, thermal, olfactory, or similar information
-
Inference information
Government Entities
We may share Personal Information with government entities and agencies, regulators, law enforcement, and other third parties, including to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or pursuant to legal process, and to establish or exercise our legal rights or for fraud or crime-prevention purposes or for the protection of the rights, property, or safety of our company or third parties.
-
Identifiers
-
Personal information categories listed in the California Consumer Records law
-
Internet or similar network activity
-
Geolocation data
-
Audio, electrical, visual, thermal, olfactory, or similar information
-
Professional or employment-related information
-
Inference information
Professional Service Firms
We may share Personal Information with professional service firms in connection with our legal and regulatory obligations and to establish or exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants.
-
Identifiers
-
Personal information categories listed in the California Consumer Records law
-
Internet or similar network activity
-
Geolocation data
-
Audio, electrical, visual, thermal, olfactory, or similar information
-
Professional or employment-related information
-
Inference information
Corporate Transactions
Subject to applicable law, we reserve the right to transfer some or all Personal Information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets. If any such transaction occurs, the purchaser will be entitled to use and disclose the Personal Information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding Personal Information as described in this Privacy Policy.
-
Identifiers
-
Personal information categories listed in the California Consumer Records law
-
Internet or similar network activity
-
Geolocation data
-
Audio, electrical, visual, thermal, olfactory, or similar information
-
Professional or employment-related information
-
Inference information
4. LINKS TO OTHER SITES
Right First Time may contain links or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”). Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites. We encourage you to read the privacy policies of any Third-Party Site with which you choose to interact.
5. USE OF COOKIES AND SIMILAR TECHNOLOGIES
A “cookie” is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to the server (for example, when requesting a web page from the same domain that created the cookie). The purpose of cookies is to remember the browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may serve to track personal information previously entered by a user on Right First Time. Cookies can remember login information, preferences, and similar information. Cookies, as well as other tracking technologies, such as HTML5 local storage, and Local Shared Objects (such as “Flash” cookies), and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data. We may use cookies to collect certain information about you and your use of our services and offerings, such as IP addresses, domain names, and the type of device, operating system, and web browser being used. We may also use cookies to identify your device when you revisit Right First Time to, for example, recall your authentication information or to track statistical information related to navigation throughout Right First Time.
We may also use web beacons or "pixels," and in certain circumstances may collect IP address, screen resolution and browser software and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data.
6. INFORMATION FROM CHILDREN UNDER 18 YEARS OF AGE
Right First Time is intended for use by individuals 18 years of age or older. We do not knowingly collect information from individuals under the age of 13 years without parental consent. However, if you are a parent, legal guardian, or personal representative of a minor child, you may, in compliance with the Terms of Use, use our Service on behalf of such minor child. Any information you provide us on behalf of your minor child will be treated in accordance with this Privacy Policy. If we learn that we have received any information from an individual under the age of 13 without parental consent, we will take steps to remove the data as permitted by law.
If you believe an individual under 13 years of age has provided us with Personal Information without parental consent, please contact us using the information in the "CONTACT US" section below.
7. RETENTION OF PERSONAL INFORMATION
We will retain Personal Information collected through Right First Time for as long as necessary to fulfill the business purposes for which we obtained the Personal Information, including to provide our services and offerings, or for such longer period as may be required or permitted by applicable law. We will also retain your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the purposes for processing your Personal Information and associated legal bases; (iii) the existence of a legal obligation as to the retention period; and (iv) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
8. SECURITY AND INTEGRITY OF INFORMATION
The security, integrity, and confidentiality of Personal Information are important to us. We implement and employ technical and organizational security measures to safeguard Personal Information.
Of course, we cannot fully eliminate security risks associated with the storage and transmission of Personal Information, as no security measures are perfect or impenetrable. If you have an account with us, you must keep your password secure and your account confidential. If you have reason to believe that the security of your account has been compromised, please notify us immediately in accordance with the "CONTACT US" section below.
9. TRANSFER OF DATA FROM THE U.S.
We may transfer Personal Information to our affiliates or our service providers in locations around the world for the purposes described in this Privacy Policy. Whenever Personal Information is transferred, stored, or processed by us, we will take reasonable steps to safeguard the privacy of your Personal Information. Those steps may include implementing standard contractual clauses or similar contracts where recognized by law, obtaining your consent, or other lawful means of transferring personal information.
10. UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. We encourage you to review this Privacy Policy often to stay informed of how we may process your information.
11. CONTACT US
For more information or if you have questions or concerns about our privacy practices, please contact us by email or by mail or phone using the details provided below:
451 Discovery Drive, Livermore, CA 94551
(510) 264-5000
Disadvantaged Business Enterprise (DBE) Policy
DBE Program
Objectives/Policy Statement
GILLIG LLC (hereinafter GILLIG) has established a Disadvantaged Business Enterprise (DBE) program in accordance with regulations of the U.S. Department of Transportation (DOT), 49 CFR Part 26. GILLIG has received Federal financial assistance from the Department of Transportation and as a condition of receiving this assistance, GILLIG has signed an assurance that it will comply with 49 CFR Part 26.
It is the policy of GILLIG to ensure that DBEs as defined in Part 26, have an equal opportunity to receive and participate in DOT–assisted contracts. It is also our policy:
1. To ensure nondiscrimination in the award and administration of DOT – assisted contracts;
2. To create a level playing field on which DBEs can compete fairly for DOT-assisted contracts;
3. To ensure that the DBE Program is narrowly tailored in accordance with applicable law;
4. To ensure that only firms that fully meet 49 CFR Part 26 eligibility standards are permitted to participate as DBEs;
5. To help remove barriers to the participation of DBEs in DOT assisted contracts
The Vice President of Manufacturing and Supply Chain has been designated as the DBE Liaison Officer. In that capacity, the Vice President of Manufacturing and Supply Chain is responsible for implementing all aspects of the DBE program. Implementation of the DBE program is accorded the same priority as compliance with all other legal obligations incurred by GILLIG in its financial assistance agreements with the Department of Transportation.
GILLIG has disseminated this policy statement to the officers of GILLIG and all of the components of our organization.
Derek Maunus
President
April 7, 2015
CA Transparency in Supply Chains Act of 2010 (SB 657)
The California Transparency in Supply Chains Act of 2010 (SB 657) requires covered manufacturers and retailers operating in California to post disclosures about their efforts to eradicate slavery and human trafficking from their supply chains.
GILLIG LLC (“GILLIG”) is a wholly owned subsidiary of Arkay Acquisition LLC (“Arkay”), a holding company established in 2008 by the Crown family to acquire GILLIG. All business transaction of Arkay are conducted through GILLIG.
As laid out in the GILLIG Materials Department Code of Ethics: GILLIG LLC and its affiliates will never use forced, indentured or involuntary labor in any of its operations. As part of our commitment to our local and global communities, GILLIG will not tolerate any instances of human trafficking or other forced labor. We will also never conduct business with any third parties who engage in human trafficking or forced labor.
Verification:
During periodic site visits to suppliers, GILLIG Supply Chain Personnel will review working conditions and note any concerns that involuntary labor may be in use.
Audits:
GILLIG applies a risk-based approach to determine which suppliers require a GILLIG audit. Due to GILLIG’s responsibility to comply with Buy America Requirements (49 CFR 661) our supply chain’s components are largely produced in the United States. Our US based supply chain represents a low risk that forced, indentured or involuntary labor is used to manufacture our components. We continually re-evaluate all risks to our supply chain and adjust audit requirements accordingly.
Certifications:
GILLIG Terms and Conditions require all suppliers to certify that all material was built without the use of forced, indentured or involuntary labor.
Accountability:
GILLIG’s Terms and Conditions require that suppliers certify that all materials sold to GILLIG are produced without forced, indentured or involuntary labor. Failure to comply could result in termination of the supplier relationship. Any GILLIG personnel found to be knowingly using any involuntary labor will be subject to GILLIG’s progressive discipline policy.
Training:
GILLIG provides training to Supply Chain personnel to ensure they are following the Materials Department Code of Ethics and understand GILLIG’s Terms and Conditions.