Privacy Policy

Last updated: Oct 15, 2025

1. Introduction

This Privacy Policy (“Policy”) describes how Crystal Clean, LLC (“the Company,” “we,” “our,”

or “us”) collects, uses, discloses, and protects personal information processed through the CC

Mobile mobile application (“the App”).

The App is intended solely for internal use by employees of Crystal Clean, LLC. It is not

publicly available and may only be distributed through internal company systems, Apple

Business Manager, or TestFlight.

By using the App, you acknowledge that your information will be collected and processed in

accordance with this Policy and the Company’s internal data protection and IT security

policies.

2. Information We Collect

We collect limited categories of information necessary to provide, maintain, and secure the

App. The types of data collected include the following:

a. Contact Information

We collect your name and work email address when you sign in to the App or interact with

company systems. This information is used to verify your identity, facilitate login, and enable

internal communication and app functionality.

This information is linked to your user account and may be used for internal tracking and

activity association within the App.

b. Location Information

The App may collect and process your precise device location to enable features that depend

on geographic data, such as confirming worksite presence, supporting operational tasks, or

providing location-based services.

Location data is collected only while using the App and is linked to your company account for

internal business purposes. It may also be used for internal monitoring and security tracking as

permitted under company policy.

c. User Content

If you capture or upload photos or videos using the App (for example, to document assets,

verify site conditions, or scan QR codes), that content is stored and used solely for internal

operational purposes.

User-generated content is associated with your employee account and may be used for

compliance, quality assurance, and workflow verification. The Company does not share or

disclose such content outside its internal systems unless required by law.

d. Diagnostic Information

The App automatically collects diagnostic data to maintain performance and reliability. This

may include:

Crash data, which helps identify and resolve application errors;

Performance data, which monitors system responsiveness and efficiency; and

Other diagnostic data, which supports technical troubleshooting and service

improvement.

This data is used exclusively for application functionality and maintenance and is not

associated with your identity beyond what is necessary to support technical operations.

3. How We Use Information

The Company processes personal and technical information for the following purposes:

1. To authenticate and manage employee access to the App;

2. To enable and maintain internal business functionality;

3. To provide operational support, troubleshooting, and performance monitoring;

4. To comply with internal security, auditing, and compliance requirements; and

5. To ensure the integrity and reliability of internal company systems.

All data is used solely for internal, legitimate business purposes in connection with your

employment or contracted role.

4. Legal Basis for Processing

Processing of employee information through the App is based on the Company’s legitimate

business interests, internal compliance obligations, and the need to perform employment or

contractor-related functions.

Where required by law, consent may be obtained for specific uses such as enabling location or

camera access.

5. Data Sharing and Disclosure

The Company does not sell, rent, or otherwise disclose personal information to third parties for

commercial purposes.

Information collected through the App may be disclosed only under the following limited

circumstances:

• To internal departments, including IT, Security, and Operations, for administrative,

operational, or support purposes;

• To third-party service providers who perform services on our behalf (such as cloud

hosting, mobile device management, or authentication), subject to confidentiality and

data protection agreements; or

• When required to comply with applicable law, regulation, legal process, or internal

policy.

6. Data Security

We implement and maintain appropriate administrative, technical, and physical safeguards to

protect all data collected or processed through the App.

These measures include, but are not limited to:

• Encryption of data in transit and at rest using industry-standard protocols;

• Secure authentication mechanisms (including company-managed login systems or

single sign-on);

• Access controls and permissions limited to authorized personnel; and

• Regular audits and monitoring to prevent unauthorized access or misuse.

Employees are expected to use the App in accordance with all applicable company security

and data handling policies.

7. Data Retention

Personal and diagnostic data are retained only for as long as necessary to fulfill the purposes

outlined in this Policy, comply with legal obligations, or satisfy internal auditing requirements.

When the data is no longer required, it will be securely deleted, anonymized, or otherwise

disposed of in accordance with the Company’s data retention and disposal policies.

8. Tracking and Analytics

Although certain data is identified as “used for tracking” within Apple’s App Store privacy

categories, the App does not engage in advertising, third-party analytics, or behavioral

profiling.

Any data considered “tracking” under Apple’s definition refers exclusively to internal monitoring

necessary for authentication, functionality, and security purposes.

9. Employee Rights

Depending on applicable law and internal company policy, employees may have the right to:

• Request correction of their personal information;

• Object to specific data processing activities; or

• Submit privacy or data protection complaints through internal channels.

Requests should be directed to helpdesk@crystal-clean.com or your designated HR or IT

representative.

10. Children’s Privacy

The App is not designed for, directed toward, or intended for individuals under the age of 18.

No data from minors is knowingly collected or processed.

11. Changes to This Policy

The Company may update this Privacy Policy periodically to reflect operational, legal, or

technical changes.

Material updates will be communicated to employees via internal communication channels

such as company email or the corporate intranet.

Continued use of the App following any changes constitutes acknowledgment of the updated

Policy.

12. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or the Company’s

data practices, you may contact:

Crystal Clean

Email:

helpdesk@crystal-clean.com

Address:

2000 Center Drive Suite East C300

Hoffman Estates, IL 60192