Sun Communities and Sun Outdoors Careers

The California Privacy Rights Act (CPRA) imposes specific obligations on businesses processing Personal Information of team members who live and work in the State of California. Pursuant to the CPRA, Sun Communities and its subsidiaries (“Sun”, “Company”, “we” or “us”) is required to provide its California team members (“California Persons”) a notice, used at or before the point of collection of such Personal Information, that identifies the categories of Personal Information that may be collected and why Sun collects such information.

This California Team Member Privacy Notice (“Notice”) is intended to provide California Persons with the CPRA required notice.  Sun is committed to processing team member data securely and transparently.

1.    DEFINITIONS

1.1  “Personal Information” has the meaning as defined in the CPRA and includes information that is collected by Sun about you in the course of employment for employment related purposes and encompasses any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.  Personal Information does not include, for example: publicly available information from government records; de-identified or aggregated consumer information; or information excluded from the CPRA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA) and the Gramm-Leach-Bliley Act (GLBA). 

1.2  “Process”, “processed” or “processing” means any operation or set of operations which is performed on Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Information.

1.3  “Team member”, “team members”, “employee”, “employees” or “you” means an identified or identifiable natural person who is a California Person and who is acting as a Sun job applicant or employee. In this context “job applicant” refers to any person who has submitted their candidacy with Sun and “employee” or “team member” refers to any person who is employed at Sun as a regular or temporary worker.

1.4  “Data Controller” means a person, company, or other body that determines the purpose and means of personal data processing.

2.    DATA CONTROLLER

Sun is a Data Controller. The Company is a Maryland corporation, with its principal United States office at 27777 Franklin Road, Suite 300, Southfield, Michigan 48034.

3.    TEAM MEMBER RIGHTS

3.1  Right to Access

You have the right to access Personal Information which we may collect or retain about you. If requested, Sun will provide you with a copy of your Personal Information which we collect as permitted by the CPRA.

3.2  Right to Know

You have the right to request that we disclose the following about your Personal Information, as defined by the CPRA:

• The specific Personal Information we may collect;
• The categories of Personal Information we may collect;
• The categories of sources from which we may collect your Personal Information;
• The business purpose(s) for collecting or sharing your Personal Information;
• The categories of Personal Information we may disclose for business purposes; and
• The categories of third parties to whom we may share your Personal Information.

3.3  Right to Opt-Out

Sun does not sell Personal Information within the meaning of CPRA.

3.4  Right to Limit Sharing and Disclosure of Personal Information

You have the right to limit how your Personal Information is disclosed or shared with third parties, as defined in the CPRA.

3.5  Right to Deletion

In certain circumstances, you have the right to request the erasure of your Personal Information. Upon verifying the validity of a deletion request, we will delete your Personal Information from our records and instruct any service providers or third parties to delete your information, when applicable.

3.6  Right to Correct

In certain circumstances, you have the right to request correction of any inaccurate Personal Information. Upon verifying the validity of a verifiable correction request, we will use commercially reasonable efforts to correct your Personal Information as directed, considering the nature of the Personal Information and the purposes of maintaining your Personal Information.

3.7  Right to Seek Damages

In circumstances, you have the right to seek damages for breach of certain sensitive data as permitted under the CPRA. 

4.     PERSONAL INFORMATION WE COLLECT ABOUT YOU

Listed below are the categories of Personal Information that Sun may process about team members:

4.1  Identifiers, including real name, preferred name, postal address, unique personal identifiers, email addresses, phone numbers, account name, social security number, bank details, driver’s license number, passport number or other similar identifiers. In this context, a “unique personal identifier” means a persistent identifier that can be used to recognize a team member, or a device that is linked to a team member, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, or similar technology; unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers. 

4.2  Characteristics of Protected Classifications Under California or Federal Law,  including the following: race, skin color, national origin, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition (such as genetic characteristics, cancer or a record or history of cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request for family care leave, request for leave for a team member’s own serious health condition, request for pregnancy disability leave, request for other applicable leave, and age.

4.3  Internet or Other Electronic Network Activity Information, including browsing history, search history, application access location and information regarding a team member’s interaction with an internet website, application or advertisement, time and geolocation data related to use of an internet website, mobile application, or physical access to a Sun office location or system. 

4.4  Professional or Employment-related Information, including job related data, maintained as part of the employment relationship that is present in: a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; biometric data, including imagery of your fingerprint, face, and voice recordings; information from team member expense reports; browsing and search history; payroll and benefits related data; dependants, next of kin and their contact numbers, internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance.

4.5  Education Information, including information about a team member’s educational background, such as education records, licenses, certifications, report cards, and transcripts that is not publicly available. 

4.6  Inferences, including any information drawn from any of the Personal Information categories referenced above to create a profile about a team member reflecting the team member’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

5.    WHERE WE OBTAIN PERSONAL INFORMATION

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you
• Third parties

6.    PURPOSES FOR COLLECTING YOUR PERSONAL INFORMATION

Sun may collect the Personal Information identified in Section 3 above for the reasons listed below.

6.1  To Recruit Team Members, including to conduct employment-related background screening and checks. 

6.2  To Administer Benefits, such as medical, dental, optical, disability, life insurance, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.

6.3  To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation-related payments, including assigning amounts of bonus payments to individuals, administration of bonuses and administration of stock plans.

6.4  To Conduct Performance-Related Reviews, including performance reviews, talent planning/development, skills monitoring, transfers, promotions and re-assignments. 

6.5  To Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of a team member’s work-related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.

6.6  To Provide Team Members with Human Resources Management Services, including providing team member data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of team member claims, and travel administration.

6.7  To Maintain Your Contact Information, including altering your details across relevant entities within Sun’s family of companies. 

6.8  To Alert You in Case of Emergency, including maintenance of contact details for you and your dependents in case of personal or business emergency.

6.9  To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring compliance of team members’ ability to work in the U.S.

6.10  To Conduct Healthcare-Related Services, including conducting worker’s compensation and other employment-related medical screenings for return-to-work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of team members to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for duty.

6.11  To Facilitate a Better Working Environment, which includes conducting surveys, providing senior management information about other team members, and conducting training.

6.12  To Facilitate a Safe and Efficient Working Environment, which includes Sun’s actions relating to disciplinary actions and code of conduct processes and investigations.

6.13  To Maintain Security on Sun’s Websites and Internet-Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of Sun’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access. 

6.14  To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and Health, Safety, Security and Environmental reporting.

7.    DATA STORAGE AND SECURITY

Sun shall use a reasonable standard of care to store and protect your Personal Information. We use appropriate physical, technical and organizational security measures and procedures to protect Personal Information from unauthorized use, loss, alteration, destruction or modification. Sun shall retain your Personal Information until the initial purpose for collecting and retaining such data has been satisfied. If you subsequently agree to a new or additional purpose, your Personal Information may be retained for that.

This Notice does not apply to any information you may send to Sun by email or instant messaging programs, or through social media networks.  Email, social media, and instant messages are not recognized as secure communication forms.  Please do not send any information you consider private to us by email or instant message or through social media sites (e.g., Twitter, Facebook, etc.) due to the public nature of such postings. 

8.    EXERCISING YOUR RIGHTS

If you are a California resident, you can exercise any of your rights as described in this Notice and under applicable privacy laws by using the contact information provided in this Notice. We will not discriminate against you for exercising such rights. Except as described in this Notice or provided for under applicable privacy laws, there is no charge to exercise of your legal rights.

However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may:

• Charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or
• Refuse to act on the request and notify you of the reason for refusing the request.

9.    REQUEST VERIFICATION

To exercise your rights under the CPRA, you must submit a “verifiable consumer request.” Only you, or your authorized agent, may make a verifiable consumer request related to your Personal Information.

A verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. If we cannot verify your identity or authority to make the request, we will not be able to fulfill your request. The information provided for verification will only be used for that purpose. You can request access to your Personal Information or have your information deleted.

10.   CONTACT INFORMATION

Sun is not required to appoint a Data Protection Officer. However, we have appointed the following contact in the event you wish to exercise your rights under this Notice, have any questions regarding this Notice, or any questions about your rights with respect to your Personal Information.

Sun Communities, Inc.
Attn:  Chief Administrative Officer
27777 Franklin Road, Suite 300
Southfield, MI 48034
hr@suncommunities.com 

11.    UPDATES

This Notice will be updated from time to time to reflect changes in our business, legal or regulatory obligations.  Sun will not collect additional categories of your Personal Information or use your Personal Information already collected for additional purposes without providing you with a notice of our intent to do so. Any changes to this Notice will be effective from the date they are communicated to you. If we make any material changes to this Notice, we will notify existing team members by email before such changes are effective at your company-issued email address and will post the updated Notice on our careers websites for prospective candidates.

Effective Date:  1/1/2023