This privacy notice (the “Notice”) describes the ways that Ontario Refrigeration Service, Inc. (“Company”, “we”, “us”, “our”), collects and uses your personal data as a candidate (“you” or “candidate”). We work with data processors to whom we have instructed to collect, store, and process personal information on our behalf for the purposes of providing our services, for example, Recruit, as a recruiting and applicant tracking platform (“Platform”), to handle your personal data as a candidate. It also describes the rights and options available to you with respect to your personal data.

We may have an additional privacy notice(s) explaining our own specific privacy practices related to your personal data (“Company Notice”).

Please note that this Notice is provided only for transparency purposes. If you have any questions related to your personal data, you should contact the Company directly.

We are the responsible party for the candidates’ personal data when provided to the Platform in the context of your candidacy. We determine the means and purposes for the processing of your personal data.

1. Personal data processed

We receive personal data about you as a candidate for positions at the Company, such as: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you, the Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the Company about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy. If you submit your candidacy by email or online, then you are the main source of the personal data. Your personal data can also originate from other sources, such as LinkedIn profiles, recruitment agencies, headhunters, and referrals.

2. How your personal data is used. Legal basis.

We will use your personal data in accordance with our Company Notice (if any available to you), including to evaluate and consider you as a candidate for positions, in accordance with its processes and policies for evaluating employment candidates, to contact you for your candidacy status and interviews, to schedule meetings and interviews, amongst others.

The lawful bases we rely on for processing personal information are (if applicable to us under privacy law):

1. You gave us your consent to the processing of your personal data (for one or more specific purposes);

2. Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;

3. Processing is necessary for the purposes of the legitimate interest; and/or

4. Processing is necessary for compliance with a legal obligation to which the controller is subject.

If you have questions about these uses, please contact us. Please note that the legal basis is provided for GDPR purposes only.

3. Who will process your data

1. We may share your personal data with our service providers and vendors who assist us to collect, process, and store your personal data, including Recruit (who provide us with the Platform), in the context of your candidacy. These companies are authorized to use your personal data as necessary to provide these services or as otherwise authorized by us. Recruit’s privacy policy is available here.

2. Personal data may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly).

3. We may share your general recruitment status with third parties who submitted your candidacy to us.

4. If your details are submitted to the Company by a third-party (such as an employee of the Company or a recruiting agency), the Company can give the third-party access to your name, photo and some of the general recruitment status.

5. If you apply to a job opening using a unique referral link that was provided to you by an employee of the Company to which you are applying, the Company may share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link.

6. The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of the Company and to provide feedback to third-parties who submit candidates to the Company regarding their submission.

7. If we are required to disclose your information by a judicial, governmental and/or regulatory authority to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.

8. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events.

9. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.

If you wish to receive further information, please contact us.

4. Security and data retention

1. Retention. We will retain your personal data for as long as we need it to assess you as a candidate or as long as we have a valid legal basis. In accordance with our internal data retention policies and practices, we can decide whether to keep your personal data, delete it, or pseudonymize/anonymize it.

2. Security. We implement industry-standard measures to reduce the risks of damage, loss, unauthorized access, or use of your personal data. However, these measures do not provide absolute information security.

5. International data transfers

We host your personal data in connection with our use of the Platform either in the European Economic Area, in the US, in the country where we are located, or in countries deemed as providing an adequate level of data protection.

Your data will be accessible in the country where we or our service providers are located, the UK, the US, and countries deemed as providing an adequate level of data protection.

See here the Platform’s vendors. For more information, please contact us.

6. Your rights

Your rights may vary, depending on the applicable law. These rights may not be available in certain jurisdictions and/or may be subject to certain derogations or limitations. You may have the following rights:

1. To ask us to receive a copy of your personal data that is stored on our servers, including the Platform;

2. to update, correct and/or delete your personal data;

3. to request the restriction of processing concerning your personal data or to object the processing of your personal data;

4. to request to obtain a copy of your personal data in a structured, commonly used and machine-readable format;

5. If we rely on consent, please note that you have the right to withdraw consent at any time; and/or

6. to lodge a complaint with a supervisory authority.

If you wish to exercise any of these rights, please contact us. If you choose to exercise any of your rights, we will handle these requests in accordance with applicable law, but please note that the exercise of some of those rights may have some consequences for your application as a candidate.

In the context of the Platform, we do not use any automated decision-making related to your personal data.

7. Minors

We do not intend to collect personal data of children. If you have reason to suspect that children's data is collected, you are kindly requested to immediately report it to us. If you have questions regarding children’s personal data, contact us.

8. Changes to this privacy notice

From time to time, we may change or update this Notice. If we do so, we will make efforts to notify you of such changes by any means.

9. Contact us

You may send requests, responses, questions, and complaints by contacting us.

Privacy Policy

Privacy Notice to California Job Applicants

Ontario Refrigeration Service, Inc. (the “Company” or “we”) provide this California Privacy Notice (“Notice”) to describe our privacy practices with respect to our collection of Personal Information as required under the California Consumer Privacy Act (“CCPA”). This Notice applies only to job applicants and candidates for employment who are residents of the State of California and from whom we collect “Personal Information” as defined in the CCPA.

1. Information We Collect From or About Job Applicants

We may collect Personal Information from you in a variety of different situations and using a variety of different methods, including, but not limited to, your mobile device, through email, in physical locations, through written applications, through the mail, and/or over the telephone. Generally, we may collect, receive, maintain, and use the following categories of Personal Information, depending on the particular purpose and to the extent permitted under applicable law. The examples provided for each category are not intended to be an exhaustive list or an indication of all specific pieces of information we collect from or about you in each category, but rather the examples are to provide you a meaningful understanding of the types of information that may be collected within each category.

Personal Identifiers

Name or alias.

If hired, then your name will be retained permanently and the rest will be retained for the duration of employment plus 7 years.

If not hired, it will be retained for 4 years from when the position is filled or the date we receive your information, whichever is longer.

Contact Information

Home, postal or mailing address, email address, home phone number, cell phone number.

If hired, this data will be retained permanently.

If not hired, it will be retained for 4 years from when the position is filled or the date we receive your information, whichever is longer.

Pre-Hire Information

Information provided in your resume, information gathered as part of background screening and reference checks, information recorded in job interview notes by persons conducting job interviews for the Company, information contained in candidate evaluation records and assessments, information in work product samples you provided, and voluntary disclosures by you.

If hired, this data will be retained for the duration of employment plus 7 years.

If not hired, it will be retained for 4 years from when the position is filled or the date we receive your information, whichever is longer.

Employment History

Information regarding prior job experience, positions held, and when permitted by applicable law your salary history or expectations.

If hired, this data will be retained for the duration of employment plus 7 years.

If not hired, it will be retained for 4 years from when the position is filled or the date we receive your information, whichever is longer.

Education Information

Information contained in your resume regarding educational history and information in transcripts or records of degrees and vocational certifications obtained.

If hired, this data will be retained for the duration of employment plus 7 years.

If not hired, it will be retained for 4 years from when the position is filled or the date we receive your information, whichever is longer.

Inferences

Based on analysis of the personal information collected, we may develop inferences regarding job applicants’ predispositions, behavior, attitudes, intelligence, abilities, and aptitudes for purposes of recruiting and hiring assessments and decisions.

If hired, this data will be retained for the duration of employment plus 7 years.

If not hired, it will be retained for 4 years from when the position is filled or the date we receive your information, whichever is longer.

Personal information does not include:

• Publicly available information from government records.

• Information that a business has a reasonable basis to believe is lawfully made available to the general public by the job applicant or from widely distributed media.

• Information made available by a person to whom the job applicant has disclosed the information if the job applicant has not restricted the information to a specific audience.

• De-identified or aggregated information.

2. How We Use Personal Information and Sensitive Personal Information

The Personal Information and Sensitive Personal Information we collect, and our use of Personal Information and Sensitive Personal Information, may vary depending on the circumstances. This Notice is intended to provide an overall description of our collection and use of Personal Information and Sensitive Personal Information. Generally, we may use or disclose Personal Information and Sensitive Personal Information we collect from you or about you for one or more of the following purposes:

• To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job with the Company, we will use that Personal Information in connection with your candidacy for employment.

• To evaluate, make, and communicate decisions regarding your job application and candidacy for employment.

• To obtain and verify background checks, references, and employment history.

• To communicate with you regarding your candidacy for employment.

• To keep your application on file even if you did not get the job applied for, in case there is another position for which we want to consider you as a candidate even if you do not formally apply.

• To evaluate and improve our recruiting methods and strategies.

• To engage in corporate transactions requiring review or disclosure of job applicant records subject to non-disclosure agreements, such as for evaluating potential mergers and acquisitions of the Company.

• To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company related to recruiting or processing of data from or about job applicants.

• To improve job applicant experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.

• To protect against malicious or illegal activity and prosecute those responsible.

• To prevent identity theft.

• To verify and respond to consumer requests from job applicants under applicable consumer privacy laws.

3. Retention of Personal Information

We will retain each category of personal information in accordance with our established data retention schedule as indicated above. Some of the retention periods in the retention schedule above are measured from a particular point in time that has not occurred yet, such as the end of employment or end of a relationship (whether business, contractual, or transactional) plus a certain number of years. Where no particular event is defined in the retention schedule as the point from which the retention period is measured, we will measure the retention period from either (1) the date the record or data was collected, created, or last modified, (2) the date of the particular transaction to which the record or data pertains, or (3) another triggering event that is determined to be reasonable and appropriate based on the nature of the data and the legal/business needs for its continued use.

In deciding how long to retain each category of Personal Information that we collect, we consider many criteria, including, but not limited to: the business purposes for which the Personal Information was collected; relevant federal, state, and local recordkeeping laws; applicable statutes of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations.

We apply our data retention procedures on an annual basis to determine if the business purposes for collecting the Personal Information, and legal reasons for retaining the Personal Information, have both expired. If so, we will purge the information in a secure manner.

4. Sale/Sharing of Information to Third Parties

The Company does not and will not sell your Personal Information or Sensitive Personal Information for any monetary or other valuable consideration. The Company does not and will not share your Personal Information or Sensitive Personal Information for cross-context behavioral advertising.

By submitting my application materials (e.g., resume, cover letter and/or other materials), I acknowledge and confirm that I have received and read and understand this disclosure and I hereby authorize and consent to the Company’s use of the Personal Information and Sensitive Personal Information it collects, receives, or maintains for the business purposes identified above.

Effective 1/1/2026