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Polaris Privacy Notice for Employees, Applicants, and Non-Employee Staff

Last Updated: July 1, 2024

 

Polaris Industries Inc. and its subsidiaries, affiliates, and brands (collectively, “Polaris,” “we,” “our,” and “us”) respect your privacy and are committed to the responsible management, use, and protection of personal information. Polaris includes, for example, Polaris Off-Road; Polaris On-Road (including Indian Motorcycle); Polaris Marine; Polaris Adventures; Kolpin; Pro Armor; Trail Tech; 509; and KLIM.

This Privacy Notice for Employees, Applicants, and Non-Employee Staff (“Notice”) describes how we collect, use, and share your personal information in the context of our relationship with you as an employee, applicant, or non-employee staff (i.e., individuals who are not employed by Polaris but have access to Polaris facilities, information systems, or networks), including information collected when you visit and use our Career websites (“Sites”). This Notice does not cover information collected when you use Polaris products, websites, mobile applications, or services as a consumer outside of your relationship with us as an employee, applicant, or non-employee staff. For example, our RIDE COMMAND Privacy Notice applies to use of RIDE COMMAND services, and the Polaris Privacy Notice applies to use of non-Career websites, mobile applications, and online services, and other interactions with us as a consumer, such as by telephone or at events.

Polaris’ processing of personal information is subject to the requirements of local laws, as applicable, and nothing in this Notice is intended to limit Polaris’ obligations and rights or your rights under applicable laws or any applicable workplace agreements (such as works council agreements). This Notice is not intended and shall not be interpreted to create any express or implied promise or contract for employment or otherwise.

Certain Polaris brands and entities may be subject to other privacy notices regarding their collection, use, and sharing of personal information in the context of their relationship with you as an employee, applicant, or non-employee staff that are separate from or supplement this Notice.

 

1. INFORMATION WE COLLECT

The types of information Polaris may collect include, but are not limited to:

 

  • Contact information (such as name; address; email address; telephone number; account login information, including, if applicable, social media account information for login purposes; internal employee number; beneficiary and emergency contact information; and signature)
  • National identification and work authorization information (such as social security number; national identification number; work authorization status; passport number; or other government identification number)
  • Demographic information (such as gender and date of birth, including for beneficiaries)
  • Employment details (such as your job title or position; office location; offer letter; employment contract; hire and termination dates; and performance history, disciplinary, and leave records)
  • Financial, salary, and benefits information (such as bank and retirement account information; salary, other compensation, tax, and benefit information; and other information necessary to administer payroll, taxes, and benefits)
  • Information related to your qualifications and background (such as your resume; CV; cover letter; skills; employment and educational history; degrees earned; professional licenses or certifications held; training completed; reference and background-check information; assessment responses (if applicable); and other information disclosed in your application for employment)
  • Audio, electronic, visual, or similar information (such as your communications with us; photos; and videos)
  • Feedback and sentiment information (such as responses to employee engagement and other surveys or requests for feedback)
  • Workplace, device, and usage data (such as electronic communications transmitted within the Polaris information and communications systems and networks; and information regarding access to and usage of Polaris facilities, information and communications systems and networks, devices, and applications, including through the use of personal devices accessing Polaris information and communications systems and networks)
  • Biometric information (such as fingerprint data for access to facilities or time-reporting systems, where applicable)
  • Geolocation data (such as precise geolocation data from Polaris-owned vehicles, where applicable)

 

Sensitive Personal Information. In accordance with applicable law, we may also collect information about you that may qualify as “Sensitive Personal Information” in some jurisdictions. This may include information about your racial or ethnic origin; religious, political, or philosophical beliefs; trade union membership; health; disabilities; or sexual orientation. We will use this information to comply with applicable laws, including anti-discrimination laws and government reporting obligations, and to help provide equal employment opportunities and, where applicable, work-related accommodations.

 

Your Responsibilities. Any information you submit must be accurate, complete, and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us. To the extent the personal information you provide in connection with a job application contains Sensitive Personal Information as defined above or your job evaluations or educational records, you expressly authorize Polaris to handle such information for the purposes of your job application.

 

2. COLLECTION OF INFORMATION FROM THIRD PARTIES AND PUBLIC SOURCES

As permitted by applicable law, we may collect information from third parties or public sources, such as your references; your prior employers and educational institutions; the third parties that we work with, such as professional recruiting firms; assessment and background-check providers; law enforcement; news sources; and public social media profiles.

 

3. INFORMATION COLLECTED AUTOMATICALLY WHEN YOU USE OUR SITES

When you visit and use our Sites, certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, IP address, and Internet browser type and version. We may collect similar information, such as your device type and identifier if you access the Sites through a mobile device.

Cookies and similar technologies. Our Sites may use cookies and similar technologies (pieces of information stored directly on the device you are using). Cookies allow us to collect information such as browser type, time spent on the Sites, pages visited, and language preferences. We and our service providers use the information for, among other things, security purposes, to facilitate navigation, personalize your experience, and to display information more effectively. In addition, we use cookies to gather statistical information about usage of the Sites in order to improve their design and functionality, understand how they’re used, and assist us with resolving questions about them.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. If you set your browser to reject cookies, parts of the Sites may not work for you.

Pixel tags, web beacons, clear GIFs, or other similar technologies: These may be used in connection with some Site pages to, among other things, track the actions of Site users and compile statistics about Site usage and response rates.

 
4. HOW WE MAY USE YOUR INFORMATION

The purposes for which we may use and process your personal information (and, where necessary, data for your dependents, beneficiaries, emergency contacts, and other individuals associated with your relationship with us) include:

Managing Our Relationship with You. If you are an employee, our purposes for processing your personal information may include, for example, fulfilling our obligations under your employment agreement; identifying and communicating with you; administering payroll and benefits; and conducting training and performance reviews.

If you are an applicant, our purposes for processing your personal information may include, for example, communicating with you about Polaris job opportunities, your application, and our Sites and policies; processing your application; assessing your capabilities and qualifications for particular opportunities at Polaris; scheduling and conducting interviews; and conducting lawful reference and background checks.

If we hire you, information we collect in connection with your application may be incorporated into our human resources system; become part of your employee file; and used for onboarding you and other employment-related purposes. We may also retain information related to your application for the purpose of considering whether your skills are suitable for other opportunities.

If you are non-employee staff, our purposes for processing your personal information may include, for example, communicating with and managing our relationship with you and providing you access to Polaris facilities, information systems, and networks.

General Business Purposes. We may also process your personal information for other legitimate business purposes, which may include, for example, general human resources administration (e.g., the attraction, retention and motivation of Polaris’ workforce, including Polaris’ recruitment, compensation, succession planning, performance assessment, training, and employee benefit administration efforts); compiling directories; general business management and operations; auditing and reporting purposes; management of information systems and networks; providing and improving employee services and our application and recruiting processes; enhancing the security and safety of Polaris employees, applicants, non-employee staff, assets, resources, properties and facilities; processing work-related claims; and investigating wrongful conduct or potential violations of our internal policies.

Legal Reasons. We may also process your personal information for legal reasons, such as: obtaining legal advice and establishing, exercising, or defending legal claims; complying with laws, regulatory requirements, contractual obligations, court orders, other legal process or obligations, or lawful requests from public and government authorities; detecting, preventing, and responding to fraud, intellectual property infringement, security issues, or violations of our agreements or law; and protecting the safety, rights, welfare, or property of Polaris, you, or others.

 

5. HOW WE MAY SHARE YOUR INFORMATION

Polaris may share your personal information with its subsidiaries and affiliates and other third parties, including vendors who provide services to us, to carry out the uses described above.

For example, Polaris may share your personal information with:

  • Vendors who assist us in conducting recruitment and employment activities (such as providers who assist us in administering payroll and benefits; hosting and operating the Sites; recruiting talent; administering and evaluating pre- and post-employment screening and assessments; and improving our recruiting practices).
  • Other entities to the extent that Polaris has a good faith belief that such disclosure is necessary to: obtain legal advice or establish, exercise, or defend legal claims; comply with laws, regulatory requirements, contractual obligations, court orders, other legal process or obligations, or lawful requests from public and government authorities; detect, prevent, or respond to fraud, intellectual property infringement, security issues, or violations of our agreements or law; or protect the safety, rights, welfare, or property of Polaris, you, or others, as required or permitted by applicable law.
  • Other entities in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).


We may otherwise share your personal information in accordance with your consent.

Since Polaris’ business and operations are international, Polaris has centralized certain elements of its human resources management. Accordingly, where Polaris is permitted to do so under applicable law, Polaris may transfer or provide your information to Polaris subsidiaries, affiliates, or third parties both in and outside of the country where you reside and/or work.

 

6. MONITORING BY POLARIS

Polaris monitors its information and communications systems and networks for purposes such as: protecting, managing, and supporting Polaris systems, devices, information, and assets; protecting individuals; recordkeeping; and investigating wrongful conduct or potential violations of Polaris policy. You should be aware that any messages, files, data, documents, social media posts, or any other types of information or communications transmitted, received, created, printed, or stored to, through, from, or on Polaris information and communications systems and networks (including through the use of personal devices accessing Polaris information and communications systems and networks) are presumed to be business-related and may be monitored or accessed by Polaris in accordance with applicable law. Employees should have no expectation of privacy with respect to such information and communications or their use of Polaris systems, networks, or equipment. All work product generated by employees, in whatever form (i.e., paper records, computer files or other format) is the property of Polaris.

Polaris may also monitor employee activities on Polaris’ facilities and property. Some of Polaris’ facilities are equipped with surveillance cameras. Except as otherwise prohibited by applicable law or any applicable workplace agreements (such as works council agreements), Polaris may use recorded images as Polaris deems appropriate for purposes such as the protection of the safety of Polaris’ employees and third parties, and to protect against theft, vandalism and damage to Polaris’ facilities and property, including disclosing such images and video to law enforcement authorities or appropriate governmental agencies or authorities.

 

7. INFORMATION SECURITY

Polaris maintains technical and organizational security measures designed to help protect your personal information from unauthorized access, disclosure, alteration, or destruction. Unfortunately, no data transmission or storage system is 100% secure or error free, and we cannot guarantee the security of the information we collect.

 

8. DATA RETENTION

We retain your personal information as long as necessary to fulfill the purposes outlined in this Notice unless a longer retention period is required or allowed by law. To determine the period for which your personal information is retained, Polaris considers factors such as: Polaris’ record retention policies and procedures; the sensitivity of the data and the purposes for which it was collected and is used; and applicable legal or contractual requirements to retain the data for a certain period of time, including any retention obligations related to actual or potential litigation or government investigations.

 

9. RIGHTS

Depending on where you reside (for example, if you are a United States resident and reside in California or a resident of the European Economic Area or Switzerland), you may have one or more rights with respect to your personal information, which may apply differently in different circumstances, and may be limited by applicable law. Examples of such rights include: rights to correct, delete, or obtain a copy of your personal information (or information about the categories of your personal information that we have collected); the right to data portability; and rights to withdraw consent for, object to, or restrict certain processing of your personal information. You may exercise these rights by submitting a request to us by email at [email protected].

Requests to exercise these rights are subject to our ability to reasonably verify your identity and request in light of the personal information relevant to the request and the requirements in applicable law. Please note that we may ask for additional information to verify your request before responding to it.

If we deny your request to exercise your rights with respect your personal information, you may, depending on applicable law, have the right to appeal our decision, which you may do by submitting an appeal by email to [email protected].

For more information about the rights of residents of the European Economic Area and Switzerland and how to exercise them, please see section 10, ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA AND SWITZERLAND, below.

For more information about the rights of California residents and how to exercise them, please see section 11, ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS, below.

 

10. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA AND SWITZERLAND

The controllers for personal data covered by this Notice are: the Polaris subsidiary or affiliate that employs or engages you, or to which you submit an application; Polaris Sales Europe SARL, Place de l’Industrie 2 1180 Rolle – Switzerland; and Polaris Industries Inc., 2100 Highway 55, Medina, MN 55340.

The contact information for Polaris’ data protection officer is:

By mail: Polaris Sales Europe SARL, Place de l’Industrie 2 1180 Rolle – Switzerland, Attention: Data Protection Officer
By email: [email protected]

Polaris’ Lawful Basis for Processing Your Personal Data

Our lawful basis for processing personal data covered by this Notice will depend on the purposes of the processing. To the extent we process personal data because it is necessary to perform a contract with you, such as an employment contract, our legal basis for that processing is that it is necessary for the performance of a contract with you.

When we are required to share personal data with law enforcement agencies or other governmental bodies, or we otherwise process personal information to comply with our legal obligations, we do so on the legal basis that we are under a legal obligation to do so.

We also process personal data on the lawful basis that it is necessary for Polaris’ legitimate business interests. Such legitimate business interests include, for example, general human resources administration; general business management and operations; management of our information systems and networks; enhancing the safety and security of our employees, applicants, non-employee staff, assets, resources, properties, and facilities; and the provision, assessment, and improvement of services for our employees, applicants, and non-employee staff.

We may use consent as our basis for processing to the extent we are required by applicable law. In such circumstances, individuals have the right to withdraw consent to such processing, but any withdrawal of consent will not affect the lawfulness of Polaris’ processing of such personal data until the time at which consent has been withdrawn or where Polaris has another legitimate basis under applicable law to process the relevant data.

Your Individual Rights


In accordance with applicable laws in the European Economic Area and Switzerland, you have the following rights with respect to your personal data, which apply differently in different circumstances, and may be limited by local law: (i) right of access, (ii) right to correction, (iii) right to erasure, (iv) right to restriction of processing, (v) right to data portability, (vi) right to object to certain types of processing, and (vii) right to withdraw consent to certain types of processing. Most of these rights are not absolute. You may exercise these rights by submitting a request to us at [email protected]. If you make a request to exercise your rights, we will respond within one month, but have the right to extend this period by two additional months, where necessary. If we extend the response period, we will let you know within one month from your request. Please note that we may ask for additional information to verify your request before responding to it.

We will seek to address any complaints submitted to us using the contact information listed in section 14, CONTACTING US, below. In addition, you have the right to lodge a complaint with your local supervisory authority or regulator.

 

11. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
 

During the past twelve months, we have collected Personal Information as described in this Notice, including the following “Categories” of “Personal Information,” as defined in the California Consumer Privacy Act of 2018 and related regulations (“CCPA”):

 

  • Identifiers

    Examples: Name, postal address, online identifier, internet protocol address, email address, social security number, driver’s license number, or other similar identifiers

  • Categories of Personal Information in California Civil Code Section 1798.80(e)

    Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, driver’s license number, insurance policy number, education, employment, employment history, or financial information

  • Characteristics of Protected Classifications under California or Federal Law

    Examples: Race, national origin, religion, age (over 40), gender, marital status, disability information, or military and veteran status

  • Commercial Information

    Examples: Records of vehicles, products, or services purchased through Polaris employee purchase programs

    Biometric information

    Examples: fingerprint data for access to facilities or time-reporting systems, where applicable

  • Internet or Other Electronic Network Activity Information

    Examples: Information about the systems to which you have access; or browsing history, search history, and information regarding your interaction with our Sites

  • Geolocation Data

    Examples: Precise geolocation data from Polaris-owned vehicles, where applicable

  • Audio, Electronic, Visual, or Similar Information

    Examples: Photos, videos, service call recordings, or facility camera footage

  • Professional or Employment-Related Information

    Examples: Occupation, job title, and employment history; resume, CV, and other application information; educational history; degrees earned; professional licenses or certifications held; training completed; or professional association membership information

  • Inferences Drawn from Personal Information

    Examples: Inferences about your preferences or inferences about your skills from your Professional or Employment-Related Information

  • Sensitive Personal Information

    Examples    : Social security number, driver’s license number, state identification card, or passport number; account login information; precise geolocation data; biometric information for purposes of identification; or information about racial or ethnic origin, religious or philosophical beliefs, union membership, health, or sexual orientation

We retain each of these Categories of Personal Information for as long as necessary to fulfill the purposes outlined in this Notice unless a longer retention period is required or allowed by law. To determine the period for which your Personal Information will be retained, Polaris considers criteria such as those described in section 8, DATA RETENTION, above.

We collect and use the Categories of Personal Information listed above for the categories of purposes described in section 4, HOW WE MAY USE YOUR INFORMATION, above. We collect Personal Information from the categories of sources identified in sections 1-3 of this Notice, above.

During the past twelve months, we have disclosed for a business purpose, each of the Categories of Personal Information listed above with the categories of third parties identified in section 5, HOW WE MAY SHARE YOUR INFORMATION.

California Privacy Rights

California residents have the right to make certain requests about their Personal Information under the CCPA. Specifically, if you are a California resident, you may request that we:

 

  • Provide access to and/or a copy of Personal Information we have about you;
  • Provide you information about: the Categories of Personal Information we have collected about you; the categories of sources of such information; the business or commercial purpose for collecting, selling, or sharing your Personal Information; and the categories of third parties to whom we disclose Personal Information;
  • Delete Personal Information we have about you, subject to the exceptions set out in the CCPA; or
  • Correct inaccurate Personal Information that we maintain about you.

You may exercise these rights by submitting a request to us at [email protected]. Please note that we may ask for additional information to verify your request before responding to it.

An authorized agent may initiate a request on your behalf, but we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right. To the extent legally permitted, we may also require that you directly verify the identity and authority of the authorized agent.

 

Please note that most of these rights are not absolute, and our response may be limited as permitted by the CCPA. For example:

  • Requests to exercise these rights are subject to our ability to reasonably verify your identity and request in light of the Personal Information relevant to the request and the requirements in the CCPA.
  • The right to have Personal Information deleted is subject to a number of exceptions set out in the CCPA, such as when we need to maintain the information to comply with our legal obligations.

California residents also have the right, as set out in the CCPA, to not receive discriminatory treatment, including retaliation, for exercising their rights under the CCPA.

 

12. WHERE WE PROCESS INFORMATION

We may process your information in the United States and other locations around the world. Those countries may not have the same level of protection for your personal information as your country. By using our Sites or providing us your information, you acknowledge and understand that your information will be transferred to and processed in the United States and these other countries.

 

13. UPDATES TO THIS NOTICE

We may change this Notice from time to time. Please review the “Last Updated” date at the top of this page to see when this Notice was last revised.

 

14. CONTACTING US
If you have any questions about this Notice, please contact us using the contact information below:

For residents of the European Economic Area or Switzerland, our contact information is:

By mail: Polaris Sales Europe SARL, Place de l’Industrie 2 1180 Rolle – Switzerland, Attention: EU Data Protection Officer

By email: [email protected]

 

For all others, our contact information is:

By mail: Polaris Industries Inc., 2100 Hwy 55 Medina, MN 55340,

Attention: Legal Department

By email: [email protected]