Dine Brands International, Inc. Applicant and Employee Privacy Notice Canada

Last Updated/Effective Date: August 1, 2023

1.0 Introduction

In this Applicant and Employee Privacy Notice (“Notice“), Dine Brands International, Inc. and its subsidiaries and affiliates (“Dine Brands”, “we”, or “us”) describe the types of information that we collect from job applicants and current and former employees, how we use that information, and how we may share that information in compliance with applicable privacy laws. Applicable privacy laws may include the Alberta Personal Information Protection Act and British Columbia Personal Information Protection Act, as applicable and as may be amended from time to time.

This Notice applies to current and former Dine Brands employees as well as applicants to open positions at Dine Brands. This Notice does not form a part of any contract of employment offered to job applicants hired by Dine Brands. Provisions of this Notice dealing with individuals employed with Dine Brands are not applicable until they begin working for us.

We may change this Notice from time to time, and we will post changes in an area of our website that is accessible to current and former Dine Brands employees.

When you apply to work for Dine Brands via one of our websites (“Sites”), you will be re-directed to our third-party service provider (e.g., Workday) to assist with assessing your suitability for employment with Dine Brands. When you follow a link to an external third-party service provider, this Notice no longer applies. Our third-party service provider will provide us with the information necessary for us to consider your application. Any information that you provide directly to our third-party service provider is governed by its privacy policy. For clarity, this Notice does not apply to Personal Information you provide directly to our third-party service provider. Dine Brands is not responsible for the privacy or security practices or the content of external websites, services, or products of such third-party services providers.

2.0 Categories of Personal Information We Collect

We may collect a range of Personal Information. “Personal Information” means information, recorded in any form, about an identifiable individual. Personal Information does not include certain contact information that enables an individual to be contacted at a place of business (“Business Contact Information”). Business Contact Information includes an individual’s name, position name or title, business telephone number, business address, business email address, business fax number, and may include other similar business information. We may collect the following types of Personal Information when you apply for a job with Dine Brands or during the course of your employment at Dine Brands:

• Your name, address, email address, telephone number, and other contact information;
• Your resume or CV, cover letter, previous and/or relevant work experience, or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process;
• Information from interviews you may have, if any;
• Details of the type of employment you are looking for, current and/or desired salary, other terms relating to compensation and benefits packages, and job preferences;
• Details of how you heard about the position you are applying for;
• Any sensitive and/or demographic information obtained during the hiring process such as Social Insurance Number, gender, information about your citizenship and/or nationality, medical or health information, and/or your racial or ethnic origin;
• Reference information and/or information received from background checks (as applicable), including information provided by third parties;
• Information relating to any previous applications you may have submitted to Dine Brands and/or any previous employment history with Dine Brands;
• Information about your educational and professional background from publicly available sources that we believe is relevant to your application or a potential future application;
• Banking information for direct deposit purposes, income history, income information, benefits information, and information regarding your beneficiaries; and
• Information collected from you automatically when you use our Sites, while using a Dine Brands device, or while connected to Dine Brands’ internet through cookies, web beacons, pixel tags, and other online tracking mechanisms. “Cookies” are small text files that can be placed on your hard drive when you visit our Sites, use a Dine Brands device, or connect to Dine Brands’ internet. These text files are created and sent to you by the web server with which you have made a connection through your web browser.

3.0  Information Collected From Other Sources

Subject to applicable law, we obtain information about individuals from various third-parties and public sources, and we may combine that data with Personal Information we have. For example:

• Dine Brands may collect application information from recruiters;
• Dine Brands may collect information regarding your past employment (including performance information) from former employers;
• Dine Brands may collect information regarding your citizenship or eligibility to work in the country where you would be employed;
• Dine Brands may collect your credit history and/or criminal record if you consent to a credit check or background check and such checks are reasonably required and connected to the position;
• Dine Brands may collect information relating to your qualifications to work with Dine Brands from your references; and
• Dine Brands will collect tax related information from the Canada Revenue Agency.

 4.0  Children Under 18

 We only employ those who are legally eligible to work at the location of employment, which is typically the age of majority (18 years old). Please do not send us application materials if you are under the legal age eligible for employment.

5.0 Purposes for Which We Collect Personal Information

 Dine Brands processes your Personal Information as described in this Notice for the following purposes:

• To manage the application process. We use your Personal Information to process your job application, verify the information you have provided in your application, communicate with you regarding your application, answer your questions regarding the application process, and confirm your eligibility for a position. We may also save your information for future job openings within Dine Brands.
• To manage the hiring process. We may use your Personal Information in the hiring process to conduct interviews. We may also use your Personal Information to perform background and reference checks—with your consent—if you are offered a position.
• To communicate with you. We may use your Personal Information to provide information to you, respond to your questions, notify you of changes to your compensation and benefits program, or notify you of emergencies.
• To manage the onboarding process. Upon being hired by Dine Brands, we will collect Personal Information when you complete new hire paperwork to assist us in administering salary and benefits and to assist us with complying with governmental and legal requirements.
• To administer compensation and benefits programs. We will use the Personal Information you provide to process payroll, pay taxes, help employees address employment-related tax issues, administer benefits, and handle work-related expense reimbursements. We may also use this Personal Information to manage requests for accommodation requests. We also use this to administer employee claims such as workers’ compensation or unemployment benefits.
• We may use Personal Information to communicate with you regarding the recruiting process, learn where you heard about Dine Brands, and evaluate and improve our recruiting process.
• For performance management. Dine Brands collects Personal Information in order to assess your performance, assist in career development, conduct pay and grading reviews, and handle any employment-related disputes. We may also use Personal Information to respond to violations of company policies and gather information for disciplinary actions. We may monitor any activity you perform online while using a Dine Brands device or while connected to Dine Brands’ internet such as monitoring the websites you visit and your activity on those websites. We may also track the emails you send using your Dine Brands-provided email address, the phone calls you make using a Dine Brands-provided device, and the chat messages you are involved in using the Dine Brands-provided instant messaging program.
• Educational and professional services. We may use your Personal Information to assist with education, training, and professional development.
• Law enforcement and courts. We may disclose your Personal Information in response to a subpoena, a search warrant, or other legally valid or required process. We may use your Personal Information to cooperate with law enforcement or other government entities.
• We may use Personal Information to comply with applicable legally required or industry standard business and employment recordkeeping requirements and to respond to governmental requests for information.
• Health and safety. We use Personal Information to protect your health and safety or the health and safety of others, including the use of technology to allow contact tracing if you may have been exposed to communicable diseases such as COVID-19. We may also use this information to respond to an employee-related emergency. We also use this Personal Information to protect our facilities and personal property.
• Protect our legal rights. We may use your Personal Information to protect our legal rights, defend a claim or lawsuit, and investigate or prevent actual or suspected loss or harm to persons or property. We may use your Personal Information to seek legal, accounting, or other professional advice. We may use your Personal Information when necessary to identify, contact, or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Dine Brands or any other party.
• We may use your Personal Information to monitor the use of our information systems and electronic resources, to conduct internal audits or investigations, and for the safety and security of Dine Brands employees, visitors, and facilities. We also may use such information to protect Dine Brands against illegal activity and misconduct such as fraud, deceptive practices, and security investigations. We use this to offer, operate, maintain, deliver, troubleshoot, and update the Sites, programs, network, and systems used by Dine Brands in the course of its business.
• Permitted purposes. We may use your Personal Information for other reasons as required or permitted by applicable privacy laws.

6.0 How We Share Your Personal Information

 We may share your Personal Information in the following circumstances:

• Within Dine Brands. We may share your Personal Information internally within Dine Brands and among Dine Brands’ affiliates for purposes of recruiting and/or evaluating applicants, resource planning, talent retention, human resources, and business administration functions. All Dine Brands employees who access or process Personal Information of applicants are required to comply with Dine Brands’ privacy and security policies.
• Service providers. We may share your Personal Information with third parties that help us provide and administer our talent and recruiting, human resources, and business functions. We may transfer Personal Information to an affiliated entity or use third party service providers in the operation of our business. Personal Information that is transferred outside Canada may be subject to law enforcement and other authorities in those countries. If you have questions about the disclosure of Personal Information to our affiliates or third-party service providers, please contact us at privacydesk@dinebrands.com.
• Legal requirements. We will cooperate with law enforcement and other governmental and regulatory agencies. We may disclose Personal Information for the following legal purposes:
• If we believe in good faith we are legally required to disclose that Personal Information.
• If we are advised to disclose Personal Information by our legal counsel.
• When necessary to identify, contact, or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Dine Brands or any other party.
• For tax and payment purposes (e.g., Canada Revenue Agency).
• To protect our rights or property, your health and safety, or the health and safety of others.
• To detect and investigate fraud or illegal activity or to respond to a government request.
• To respond to an emergency.
• Professional advisors. We may share Personal Information with our professional advisors, such as our attorneys and accountants, in their capacity as advisors, including for advice on potential or actual litigation matters.
• Change in ownership. We may use and disclose Personal Information in connection with the evaluation of a change of control of Dine Brands such as in the event of a merger, acquisition, or sale of assets. We may provide Personal Information in connection with a due diligence process, or it could be transferred as part of the change in control to subsequent owner(s). If we (or our assets) are acquired or if we go out of business, enter bankruptcy, or go through some other change in control or reorganization, Personal Information and other information could be one of the assets transferred to or acquired by a third party or reviewed as part of the due diligence process.

Dine Brands may collect, use, or disclose Personal Information without your knowledge or consent where it is permitted or required by applicable privacy laws, or other applicable law or regulatory requirements to do so.

7.0 De-Identified/Aggregate Information

 We may collect or create information that is de-identified or aggregate information that does not identify a natural person. “De-Identified Information” means that information has been rendered anonymous such that it cannot reasonably be used to identify a specific individual. Dine Brands is the sole and exclusive owner of De-Identified Information and may use or share such information for any legal business purpose. For example, Dine Brands may create aggregate information about applicants to learn about the success of its recruiting processes.

 8.0  Data Security

 Dine Brands makes commercially reasonable efforts to protect employees’ and applicants’ Personal Information. We protect Personal Information using technical and organizational measures designed to reduce the risks of loss, misuse, and unauthorized access, disclosure, alteration, and destruction of Personal Information appropriate to the type of Personal Information processed.

Notwithstanding our security safeguards, it is impossible to guarantee 100% security in all circumstances. Dine Brands employees and applicants are responsible for safeguarding the security of any password, user ID, or other forms of authentication involved in obtaining access to password-protected or secure areas of any Dine Brands-owned or licensed platforms. It is your sole responsibility to use the appropriate level of care whenever communicating with us.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem. If a breach of your Personal Information occurs, we will notify you of the breach if and as required under applicable privacy laws and any other applicable law. In order to protect you and your Personal Information, Dine Brands may suspend your use of any Dine Brands programs or platforms without notice pending an investigation if any breach of security is suspected.

 9.0 Retention of Your Personal Information

Personal Information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required or permitted by applicable law, taking into consideration any statutorily required minimum periods of time in applicable jurisdictions. Generally, this means your Personal Information will be retained until the end or your employment or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters, document the proper termination of your employment or work relationship, or to provide you with any ongoing benefits.

Personal Information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our systems, and we will also require third parties, as described in Section 6, to destroy or erase such Personal Information where applicable.

10.0  Accuracy of Personal Information

Dine Brands will make a reasonable effort to ensure that any Personal Information collected, used, or disclosed by or on its behalf is accurate and complete to the extent that is reasonable for its purpose in collecting, using, or disclosing the information.

11.0 Access to and/or Correction of Personal Information

Dine Brands is committed to ensuring that individuals have proper access to their Personal Information, subject to restrictions as set out in applicable privacy laws, and that responses to requests for access to, and the correction of, Personal Information are processed in compliance with such laws.

12.0 Withdrawing Consent

You may withdraw consent to the collection, use, or disclosure of your Personal information at any time, subject to legal or contractual restrictions and reasonable notice. Any request for withdrawal of consent should be referred to the Legal Department, as set out below.

13.0 Changes to this Notice

We may change this Notice from time to time, and we will post any changes on this page. Each version of this Notice is identified at the top of the page by its Effective Date.

14.0 Contact Us

For any questions, concerns, complaints relating to this Notice or Dine Brands’ treatment of Personal Information, please contact us as follows:

Legal Department

privacydesk@dinebrands.com

10 West Walnut Street, 4th Floor

Pasadena, California 91103

(866) 926-5019