Effective Date: January 1, 2023
Last Updated: September 4, 2026
Holt of California (“Company,” “we,” “our,” or “us”) respects the privacy of our employees’ personal information.
Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), we are providing California employees with this comprehensive description of our online and offline practices regarding the collection, use, sale (if any), sharing (if any), and retention of their personal information as well as a description of the rights they have regarding their personal information.
From time to time, we may change this Privacy Policy. If we do, we will post an amended version here. You also may receive a copy by contacting us as described in the “How to Contact Us” section below.
When This Policy Applies
This Privacy Policy is intended solely for, and is applicable only to, current and former California employees. Where relevant, it also applies to job applicants, interns, agency workers, contractors, consultants, directors, and other individuals whose information we collect in connection with providing employment. For ease of reference, this Privacy Policy generally refers to employee personal information, but this does not indicate in any way that an individual is our employee.
When This Policy Does Not Apply
This Privacy Policy also does not apply to our collection and use of your personal information that we obtain from or about our customers, potential customers, website visitors and business partners. For more information on our collection and use of your personal information in that capacity, including how we process opt-out preference signals from website visitors, please see our online privacy policy available at www.holtca.com/privacy-policy/
The CCPA defines “personal information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
Below are the categories of Personal Information we currently collect and, in the 12 months prior to the Effective Date of this Privacy Policy, have collected from past, current, and potential employees. Note that this is a general list of the categories of Personal Information which might be collected, depending on the circumstances. Not all categories of Personal Information are collected from every individual.
Certain categories of Personal Information constitute “Sensitive Personal Information (SPI)” under the CCPA, including, without limitation, Social Security numbers; driver’s license, state identification card, and passport numbers; financial account, debit card, and corporate card information; precise geolocation data; medical and health-related information; biometric or physical characteristic data; contents of mail, email, and text messages where the Company is not the intended recipient; and information revealing protected classifications under California or federal law.
We collect and use SPI solely for purposes permitted by the CCPA and the associated implementing regulations, including to provide employment-related services, administer compensation and benefits, ensure workplace safety and security, comply with applicable laws, and secure Company systems and facilities. We do not use or disclose SPI for purposes of inferring characteristics about employees.
Sources of Personal Information
We collect Personal Information directly from you and from recruiters; staffing companies; references; former employers; educational institutions; online providers; government entities; other employees; business partners; payroll providers; benefits providers; medical providers; background check providers; company bankers; claims handlers; and single sign-on providers.
Purposes for Collection
We collect and use Personal Information for all purposes of providing employment and human resources-related services, including to:
We also use Personal Information for the purposes described in 1) any applicable policies posted on the employee intranet (The “HUB”), 2) our Employee Handbook or 3) our Code of Conduct, or otherwise provided to employees in writing.
The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy and the categories of recipients to whom we disclosed Personal Information.
| Categories of Personal Information | Categories of Recipients |
| Personal identifiers as disclosed in Section 2. | Human resource information systems; operating systems and platforms; customer relationship management systems; background check service providers; government or law enforcement entities; applicant and recruiter software; payroll/tax providers; expense management service providers; enterprise travel providers; data analytics providers; company bankers; authentication and single sign-on providers; security providers; mobile device management providers; accountants; lawyers; benefits providers; social networks; company insurers; consultants and other professional advisors |
| Medical and insurance information as disclosed in Section 2 | Human resource information systems; Benefits providers; company insurers |
| Education, employment history, and related information as disclosed in Section 2. | Human resource information systems; background check service providers; benefits providers; lawyers |
| Characteristics of protected classifications under California or federal law as disclosed in Section 2. | Human resource information systems benefits providers; company insurers; background check service providers; lawyers |
We disclosed Personal Information for the purposes described in the Purposes for Collection section above.
We have not sold or shared Personal Information in the twelve (12) months preceding the Effective Date of this Privacy Policy.
We do not disclose Personal Information for cross-context behavioral advertising purposes in the employment context.
We do not knowingly collect, sell, or share the Personal Information of individuals under 16 years of age.
We retain Personal Information for each category of Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide employment-related services, unless a longer retention period is required or permitted by law.
Retention periods are determined based on factors such as the duration of employment or the job application process, applicable Statutes of Limitation, regulatory and legal requirements, internal audit needs, and ongoing disputes or investigations.
If you are a California employee, you have the following rights with respect to your Personal Information:
Because we use SPI only for purposes permitted by the CCPA, employees generally do not need to submit a request to limit such use; however, requests may be submitted using the methods described below.
You may submit a request to know, delete, and/or correct through our interactive webform available on the HUB under Human Resources or at holtca.com/privacy-policy or by calling us at 1.866.465.6107.
If you submit a request to delete online, we may ask you to confirm separately that you want your Personal Information deleted.
If you are submitting a request on behalf of a California employee, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California employee.
In addition to the CCPA rights discussed above, California law provides current and former employees with the right to request certain information relating to their employment, such as the right to access their personnel file and payroll records. Because these requests are governed by laws that contain different requirements than the CCPA, we handle such requests separately from CCPA requests. If you would like to make such a request, please contact the Human Resources Department at 1.866.465.6107.
If you would like to update your personal information, such as to notify us of a change of name or address, or if you have questions about your employment, please contact Human Resources by emailing [email protected].
We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California employee on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.
For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
If we deny your request to know, delete, or correct Personal Information, you may appeal our decision by contacting Human Resources at [email protected] or by calling 1.888.866.9985. We will review and respond to appeals in accordance with applicable law.
When we hire you, we provide you with other policies and procedures that govern your use of our offices, networks, computers, and other devices. We have the right to monitor your use of our offices and electronic resources in accordance with those policies and procedures.
For more information, please read our Employee Handbook regarding policies stored on the employee intranet also known as the “HUB”. You can obtain copies of all the Company’s policies by emailing Human Resources at [email protected].
We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.
To contact us for questions or concerns about our privacy policies or practices please email Human Resources at [email protected] or call 1.888.866.9985.
Holt of California is proud to be a member of the elite group of Caterpillar® dealers worldwide. We provide jobs to close to 800 employees, working to bring equipment solutions for the diverse needs of our customers.
Our customers are the reason we exist. At Holt of California we pride ourselves on superior customer satisfaction. As our customers’ needs change, we adapt and grow to meet and exceed their expectations by offering them a full range of products and services.
