Job Applicant and Candidate Privacy Policy

Please read this Job Applicant and Candidate Privacy Policy (the "Privacy Policy") carefully before applying for a job through this Site. If you do not agree to the terms of this Privacy Policy, please do not submit Personal Information ("PI") or apply for a job through this Site. In such a case, you may contact us at the contact information provided below for further information about how to apply for a position.

This Privacy Policy applies to the web sites and online offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device, or other technology, manner or means (each, a "Site" and collectively, the "Sites") that are offered by Constellation Brands, Inc. and its subsidiaries and affiliates ("Constellation", "we" or "us").

Your use of Constellation services is also governed by any applicable terms and our general Privacy Policy. By applying for a job through this Site, you understand and consent that your information will be submitted to the entire Constellation Affiliated Group.

Categories and types of PI that we collect about you

This Privacy Policy covers the PI you share with us and/or which may be acquired or produced by Constellation during the application or recruitment process including:

• Identifiers, including your name, address, email address, telephone number and other contact information;
• Professional or employment-related information, including 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;
• Characteristics of protected classifications, including any sensitive and/or demographic information obtained during the application or recruitment process such as gender, information about your citizenship and/or nationality, medical or health information and/or your racial or ethnic origin (to the extent permitted by applicable law);
• Other information, including:

• Information from interviews and phone-screenings you may have, if any;
• Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
• Details of how you heard about the position you are applying for;
• Reference information and/or information received from background checks (to the extent permitted by applicable law) , including information provided by third parties; and/or
• Information relating to any previous applications you may have made to Constellation and/or any previous employment history with Constellation.

Sources of PI

PI about you will be collected either directly from you via online forms, by-email, in person, in writing or via telephone, as well as through other activities in the course of your application with our company. PI may also be collected from third parties, including from references, former employers, and recruitment agencies, subject to the requirements of applicable law.

Why we collect and use your PI

You can be assured that all of your PI will be used and disclosed only for the legitimate business purposes of administering your application and completing the on-boarding/new hire process, should you be offered and accept a position with Constellation, including:

• Assessing your skills, qualifications and interests against our career opportunities;
• Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job;
• Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at Constellation;
• Creating and/or submitting reports as required under any local laws and/or regulations, where applicable;
• Making improvements to Constellation’s application and/or recruitment process; and/or
• Complying with applicable laws, regulations, legal processes or enforceable governmental requests.

We will also use your PI to protect the rights and property of Constellation, our users, applicants, candidates, employees or the public as required or permitted by law. If you are offered and accept employment with Constellation, the PI collected during the application and recruitment process will become part of your employment record.

Who may have access to your PI

Your PI will be processed and stored on the systems used by us in the United States and in other countries. Only authorized personnel worldwide, including human resources, legal, and appropriate managers, will have access to your PI for legitimate business purposes such as management and analysis of job applications. If you have been referred for a job at Constellation by a current Constellation employee, with your consent, we may inform that employee about the progress of your application and let the Constellation employee know the outcome of the process. In some cases, if it is identified that you have attended the same university/school or shared the same previous employer during the same period as a current Constellation employee we may consult with that employee for feedback on you. However, wherever PI may be stored, used, processed, accessed or disclosed, Constellation has taken appropriate steps to ensure that your PI is adequately protected in accordance with Constellation policies and applicable laws and regulations. In particular, where PI is transferred to countries that may not provide a level of protection to PI equivalent to that provided by your home country, Constellation has entered into certain data transfer contracts, including appropriate contractual clauses based on the EU Model Clauses where appropriate. PIPI

How we may share your PI

Constellation shares your PI for its own business purposes only, as follows:

• Within the Constellation Affiliated Group: We share your PI among the Constellation Affiliated Group, as necessary to conduct recruiting and hiring activities. If you transfer to another company within the Constellation affiliates, you agree that we may send, at the request of your new employer, your personnel file (which contains PI about you) to your new employer, so that it may administer your new employment relationship. We will retain any PI (either original or copies) that is required for compliance with the statutory requirements or legitimate business purposes.
• With certain third parties, whether affiliated or unaffiliated, to process PI under appropriate instructions ("Data Processors"), specifically Data Processors we engage may carry out instructions related to IT system support, compliance screening, background checks, and other activities, and will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the PI, and to process the PI only as instructed. We enter into agreements to manage how those third parties can access, use, and disclose such data and to ensure appropriate measures are in place to protect that data. Specifically, we prohibit those third parties from selling, retaining, using or disclosing your PI for any purpose other than performing the services requested by Constellation.
• With other third parties. Constellation may sometimes be required to disclose your PI to external third parties such as to local labour authorities, courts and tribunals, regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.

Additional information regarding the collection, use, processing, and transfer of PI for purposes of your employment relationship will be provide via separate policies and procedures if you are offered a position with Constellation.

Record Retention

Constellation will retain PI no longer than is necessary to carry out the purposes listed in this Privacy Policy and/or as required by applicable law, except as described below.

With your consent, in the event that you are not offered a position with Constellation or decline an offer from us, we will retain your PI for a period of up to two years on the above mentioned systems in order that we may inform you of other positions, which we believe may be suitable to you. PI retained for this purpose will be processed, used, disclosed and stored in accordance with the conditions of this Privacy Policy. If you do not want your PI retained for this purpose, you may withdraw your consent at any time by contacting us as described below.

How we secure your PI

Constellation uses advanced technology and well-defined practices as required by applicable law to help ensure that your PI is protected from unauthorized access, use, misuse, modification, disclosure and destruction.

Your Rights

To the extent required by applicable law, you may the right to access, review, correct, delete, or object to our use of your PI. If you should have any questions about your rights, please contact us as described below.

Verification of Information

Please note that any misleading, false or willful omission of PI may be sufficient reason for refusal of, suspension or dismissal from employment.

Contact

If you should have any questions about the processing of your PI by Constellation, please contact privacy@cbrands.com.