Employee and Staff Privacy Notice and Notice of Collection

This Employee and Staff Privacy Notice (“Notice”) describes how M.D.C. Holdings, Inc. and its subsidiary entities (collectively, “Company,” “we,” “our,” or “us”) collect, use, maintain, protect, and disclose personal information about you before, during, and after your working relationship with us. This Notice also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.

This Notice applies to all current and former employees, workers, contractors, and any other individuals who are working for MDC but are not directly employed (collectively, “staff member(s)” or “you”).

Please read this Notice carefully. If you have any questions or need to access this Notice in an alternative format due to having a disability, please contact HROperations@mdch.com or 888.550.7016 option 6.

You can jump to particular topics by going to the headings below:

Personal Information We Collect
How We Collect Your Personal Information
How We Process Your Personal Information
How We Share Your Personal Information
How Long We Retain Your Personal Information
How We Protect Your Personal Information
Your Choices
Changes To This Privacy Notice
Contact Information
Additional Information for California Residents

1. Personal Information We Collect

To carry out our activities and obligations, we collect, store, and process different types of personal information, some of which we require to administer the employment or other working relationship with you. For the purposes of this Notice, “personal information” means any information about an identified or identifiable natural person regardless of whether it is held in paper, electronic, or any other format.

The following provides examples of the categories of personal information we may collect and how we process such information.

Context	Types of Information	Primary Purpose for Collection and Use of Information
Identification Information	Name, date of birth, alias, account name, IP address, employee identification number, government-issued identification number and/or document (e.g., driver’s license number, state identification card number, passport number, national identification number, Native American tribal document, birth certificate, social security number, etc.), residency and work permit status, signature, physical characteristics or description, and other similar documents and/or identification information used to verify work eligibility.	We process this type of information for our legitimate business purposes, including general human resources administration and to comply with legal obligations, such as employment eligibility verification laws. We also process some of this type of information to identify persons who log into and attend virtual meetings of M.D.C. Holdings, Inc.’s shareholders.
Contact Information	Home address, postal address, telephone number(s), e-mail address(es), beneficiary and emergency contact details, and other similar contact information.	We process this type of information to fulfil our obligations to you, including managing our employment or working relationship with you (e.g., communicating with you). We also process this type of information for our legitimate business purposes, such as to assist you in the case of an emergency, including maintenance of contact details for you, and your dependents or emergency contacts in the case of a personal or business emergency.
Payroll and Taxes	Rate of pay, salary, bonus, bank account details, tax status and withholding information (i.e., marital status, dependents, etc.), social security number or other taxpayer/government identification number, and other information necessary to administer payroll and taxes.	We process this type of information to fulfil our obligations to you, including administering payroll and benefits, making expense reimbursements and other compensation-related payments, and tax reporting.
Benefits-Related Information	Spouse, beneficiary, and dependent information, retirement account information, paid and unpaid leave-of-absence information, and other information necessary to administer benefits.	We process this type of information to fulfil our obligations to you, including administering and maintaining benefits, such as medical, dental, optical, additional wellness programs, 401(k) and/or retirement plans, and additional fringe benefit programs, including recording and processing eligibility of dependents, absence and leave monitoring, and insurance.
Health-Related Information	Information about job-related medical conditions that impact your ability to perform your job with or without a reasonable accommodation, and health and sickness related information related to reasons for time away from work.	We process this type of information for our legitimate business purposes (where permissible and in accordance with applicable law), including ascertaining your fitness to perform your job duties with or without a reasonable accommodation, managing absences from work, and complying with legal obligations related to health and safety.
Demographic Data	Please note, under federal and some local laws, we are required to collect and report certain demographic workforce data to federal, state, and/or local government agencies for civil rights enforcement purposes. Your submission of this information is voluntary. This includes date of birth and gender as well as more sensitive personal information, including information relating to racial and ethnic origin, religious, political, or philosophical beliefs, trade union membership, and/or other characteristics of protected classifications pursuant to law. We may also ask you to voluntarily self-identify whether you belong to additional protected classes (disability status, sexual orientation, veteran status, etc.), to promote diversity, equity, and inclusion within the company.	We process this type of information for a variety of reasons, and this will vary in the different jurisdictions in which we operate. In some jurisdictions, we are required to collect and report certain demographic workforce data to federal, state, and/or local government agencies. We also process this type of information for our legitimate business purposes (where permissible and in accordance with applicable law), including promoting diversity, equity, and inclusion within the company.
Recruitment	Educational and professional background information, such as academic and professional qualifications, education, CV/Resume, reference letters, interview notes, credit history, and criminal records data (utilized for background check and vetting purposes where permissible and in accordance with applicable law).	We process this type of information for our legitimate business purposes, including determining eligibility for hiring, verifying references and qualifications, and making business decisions about your recruitment or employment. We also process this type of information to fulfil our obligations under your employment contract, offer letter, or other commitments we’ve made to you, including general human resources administration and business management.
Terms of Employment	Employment details, such as your job titles/position, office location, letters of offer and acceptance of employment, and/or employment agreements or other working arrangements, hire/re-hire date, termination date, performance history, disciplinary information, professional memberships, business travel arrangements, and leave of absence, sick time, and vacation/holiday records.	We process this type of information to fulfil our obligations under your employment contract, offer letter, or other commitments we’ve made to you, including managing our employment or working relationship with you, conducting performance reviews, managing and determining performance requirements, making decisions about salary reviews and compensation, assessing qualifications for a particular job or task, including decisions about promotions, and making decisions about your continued employment or engagement. We also process this type of information for our legitimate business purposes, including general business management and operations, accounting, auditing, and identifying persons who log into and attend virtual meetings of M.D.C. Holdings, Inc.’s shareholders.
Qualifications and Training	We collect information from individuals concerning the training that they receive from us or from third parties. Where applicable, we also collect information related to licensing and certifications.	We process this type of information for our legitimate business purposes, including establishing training and/or development requirements, understanding and recording qualifications of the individuals that work with us, and in some cases complying with any statutory, regulatory, or contractual obligation regarding the training or qualification of certain staff.
Investigations	Details of any workplace investigations.	We process this type of information for our legitimate business purposes, including ensuring a safe working environment, investigating all information related to potential violations of workplace policies, procedures, protocols, concerns, and/or complaints.
IT and Communications Information	Information about your use of our information technology (IT) and communications systems. For more information about what we monitor, please refer to the Acceptable Use Policy and the Use of Own Device Policy available at http://mdcweb.mdch.com and from the IT department and to the Corporate Code of Conduct, which is available at ir.richmondamerican.com.	We process this type of information for our legitimate business purposes (where permissible and in accordance with applicable law), including managing network and IT systems security, monitoring the use of our IT and communication systems, ensuring compliance with our internal policies and procedures, protecting confidential information, intellectual property, and other business interests, and investigating unlawful or improper acts.
Video, Voice, and Images	Audio-visual information, such as photographs, video images like closed-circuit television (“CCTV”), call monitoring records, and voicemails.	We process this type of information for our legitimate business purposes (where permissible and in accordance with applicable law), including compiling and maintaining internal directories (such as directories of employees and staff), securing our facilities and equipment, protecting our property, and identifying persons who log into and attend virtual meetings of M.D.C. Holdings, Inc.’s shareholders.

2. How We Collect Your Personal Information

Most often, we collect personal information from you directly, including through the application and recruitment process as well as in the course of your employment or working relationship with us.

In some cases, we also collect personal information about you from third parties, such as employment agencies, former employers, and personal and professional references, or public sources. For example, to the extent permitted by law, before and during the course of your employment or working relationship with us, we may collect information from public social media sources, such as your LinkedIn profile, for recruitment purposes. We may also conduct lawful background screenings, to the extent permitted by law, through a third-party vendor for information about your past education, employment, credit, and/or criminal history. Before we conduct a background check, we will provide you with acknowledgement and authorization forms, which will comply with all applicable laws. Additionally, if there is an investigation of an employee matter, we may obtain information relevant to the incident from external sources, including private parties and/or law enforcement.

We will also collect additional personal information in the course of job-related activities. This may include monitoring communications and use of MDC’s IT equipment and systems, or from other staff members or supervisors. For more information about what MDC monitors, please refer to the Acceptable Use Policy and the Use of Own Device Policy available at http://mdcweb.mdch.com and from the IT department, and to the Corporate Code of Conduct, which is available at ir.richmondamerican.com.

3. How We Process Your Personal Information

In addition to the purposes and uses described elsewhere in this Notice, we may process your personal information for the following purposes:

To manage your employment or other working relationship with us, including payroll and benefits administration, business management and planning, processing employee work-related claims (for example, insurance and worker’s compensation claims); accounting and auditing, conducting performance reviews and determining performance requirements, and assessing qualifications for a particular job or task.
To comply with applicable legal and regulatory obligations, including those related to labor and employment, health and safety, tax, and anti-discrimination laws.
To ensure a safe working environment, including investigating potential misconduct.
To protect health and safety in the workplace.
To detect and protect against malicious, deceptive, fraudulent, or illegal activity, violations of our policies, or other types of wrongdoing.
To enforce, exercise, investigate, or defend legal claims, and enforce disciplinary actions or termination.
To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution. This may include monitoring communications and use of MDC’s IT equipment and systems (where permitted by, and in accordance with, applicable law). For more information about what MDC monitors, please refer to the Acceptable Use Policy and the Use of Own Device Policy available at http://mdcweb.mdch.com and from the IT department, and to the Corporate Code of Conduct, which is available at ir.richmondamerican.com.
To conduct data analytics analyses to review and better understand employee retention and attrition rates.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
For other lawful or legitimate purposes which may be reasonable to plan, organize, and carry out administrative tasks required for day-to-day operations.

In addition to the specific situations discussed elsewhere in this Notice, we share your personal information in the following situations, where permitted or required by applicable law:

Affiliates. We share your information with our subsidiaries and affiliates in the course of our normal business operations. In the context of an acquisition, we may share information with another company, including during any negotiation stages.
MDC Staff Members. Other individuals within the company may have access to your information, subject to applicable legal requirements. For instance, all staff members can access phone and electronic directories. Depending upon the type of processing and its purposes, your personal information may be shared with staff members within the Human Resources, Finance or IT Department, staff members in charge of the security of our facilities, your supervisor, and your supervisor’s supervisor.
Service Providers. We share your information with our contractors, vendors, and service providers that assist us with administering the employment or working relationship with you and/or provide services to us or on our behalf. For example, service providers may include, but are not limited to, payroll processors, benefits administration providers, data storage or hosting providers, marketing/events agencies, and recruitment agencies.
Other Third Parties. We may share certain information with third parties who provide professional services (such as attorneys, auditors, accountants, and management consultants), professional bodies, and regulatory authorities in the normal course of business.
Legal or Regulatory Requests and Investigations. We may disclose your information to third parties under the following circumstances (i) to comply with relevant laws or regulations, or to respond to a court order or administrative or judicial process, such as a subpoena, warrant, discovery request, or government audit; (ii) in response to lawful requests by public authorities (such as national security or law enforcement); and (iii) as necessary to establish, investigate, exercise or defend against potential, threatened, or actual litigation (such as adverse parties in litigation). We may also need to share your information with tax authorities, courts, regulators, the police, and other governmental authorities where we are required or permitted to do so by law.
Protection of the Company or Others. We may share your information where necessary to protect MDC, including to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
Disclosures with Your Consent. We may ask to share your information with other unaffiliated third parties who are not described elsewhere in this Notice. For example, we may share your information with third parties to whom you or your representatives authorize us to disclose personal information in connection with products or services we or they provide to you.

5. How Long We Retain Your Personal Information

Except as otherwise permitted or required by applicable law or regulation, we endeavour to retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, and the purposes for which we process your personal information.

Generally, this means we will keep your personal information until the end of your employment or other working relationship with us, plus a reasonable period of time thereafter. Details of retention periods for your personal information are available in our Records Retention Policy, which is available at http://mdcweb.mdch.com/.

6. How We Protect Your Personal Information

We maintain reasonable physical, technical, and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to help protect your personal information against loss, unauthorized access or disclosure, modification, or destruction. While we use reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any privacy or security event relating to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

7. Your Choices

Some jurisdictions give you a right to make the following choices regarding your personal information:

Request access to and obtain a copy of the personal information we have about you, including information about how we process your personal information;
Request correction (or rectification) of any inaccurate or incomplete personal information we have about you;
Request erasure (or deletion) of your personal information, subject to certain limitations and exceptions;
Restrict or object to the processing of your personal information under certain circumstances; and
If applicable, request to receive access to your personal information in a portable, machine-readable format.

In most situations, our processing of your personal information is not based upon your consent. However, if we rely on your consent to process your personal information, you may revoke your consent to such processing.

Please note, not all these rights are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request. This may occur because the law permits or requires us to do so.

If you want to exercise any of the above rights, please call us at: 800.605.9010 or submit a request through our web page at: https://www.richmondamerican.com/ccpa. We do not discriminate against individuals that exercise state-conferred rights. Please note that in order to fulfil your request, we may need you to provide certain personal information to verify your identity. We may verify your identity in person, by phone call, or via email. Depending on your request, we will ask for information such as your name, your employee ID, the last four digits of your social security number and/or your date of birth. We may also ask you to provide a signed and declaration confirming your identity.

In some circumstances, you may designate an authorized agent to submit a request on your behalf to access, correct, or delete your personal information. To do so, you must (1) provide that authorized agent written, signed, and notarized permission to submit such request, and (2) verify your own identity directly with us.

If you are submitting a request on behalf of another person, please call us at: 800.605.9010 or submit a request through our web page at: https://www.richmondamerican.com/ccpa. You must provide written and notarized proof that you have been authorized by the individual to act on his or her behalf. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized to submit such request.

8. Changes To This Privacy Notice

We may update or change this Notice from time to time. You can see when this Notice was last updated by referring to the date at the end of this Notice. To the extent we make material changes, the Notice that was in place at the time you submitted personal information to us will generally govern that information.

9. Contact Information

If you have any questions about this Notice, would like additional information, or would like to make a request to exercise any of your rights, please call us at: 800.605.9010 or submit a request through our web page at: https://www.richmondamerican.com/ccpa.

10. Additional Information for California Residents

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of this Notice:

Categories of Personal Information Collected and Disclosed

California law requires organizations to disclose whether certain categories of personal information are collected, “sold,” or disclosed for an organization’s “business purpose” (as those terms are defined under California law). We do not use third-party cookies or similar tracking technologies that collect data over time and across different websites for purposes of targeted advertising with our staff. We do not “sell” or “share” personal information about staff members (as such terms are defined under California law). The following describes the categories of personal information we collect and to whom we disclose such information for business purposes. Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity.

Categories of Personal Information	Disclosures for a Business Purposes
Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, email address, IP address, account name, or other similar identifiers.	Affiliates or subsidiaries Business partners Internet service providers Operating systems and platforms Other Service Providers
Other identifying information, such as physical characteristics or description, date of birth, and signature.	Affiliates or subsidiaries Business partners Other Service Providers
Financial information, such as banking details, tax information, payroll information, and withholdings.	Affiliates or subsidiaries Business partners Other Service Providers
Health and safety information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, other medical information, and health insurance policy information.	Affiliates or subsidiaries Other Service Providers
Characteristics of protected classifications under California or federal law, such as age, race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status to the extent disclosed by the staff member.	Affiliates or subsidiaries Other Service Providers
Internet or other electronic network activity information, such as your search history, browsing history, login information, and IP addresses on company information systems and networks.	Affiliates or subsidiaries Internet service providers Operating systems and platforms Other Service Providers
Sensory information, such as audio, electronic, visual, thermal, olfactory, or similar information. This may include call monitoring and video surveillance and in some cases COVID-19 or other public health related temperature checks.	Affiliates or subsidiaries Other Service Providers
Professional or employment-related information, such as work history, academic and professional qualifications, educational records, references, interview notes, job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.	Affiliates or subsidiaries Business partners Other Service Providers
Inferences drawn from any of the information listed above, such as profile or summary about a staff member's preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.	Affiliates or subsidiaries Business partners Other Service Providers

California Sensitive Information Disclosure. Some of the personal information we collect as described above is considered “sensitive personal information” under California law. We collect the following categories of sensitive personal information (as defined under California law): social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; information concerning health; and information concerning sex life or sexual orientation. This information is collected in order to administer your relationship with us, including fulfilling any obligation that we have to provide you with compensation and/or benefits; determine eligibility for employment; conduct background checks (where permitted by applicable law); comply with applicable laws and regulations; create, maintain, and secure online employee accounts; arrange business travel; manage and monitor employee access to MDC facilities, equipment, and systems; investigate potential breaches of MDC’s internal policies and procedures and enforce compliance with them; and exercise or defend the legal rights of MDC and its employees and affiliates, customers, contractors, and agents. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.

Last Updated and Effective Date. June 14, 2023

Acknowledgment of Receipt

Acknowledgement and Authorization to Share Personal Information

I acknowledge that on the date indicated below, I received a copy of MDC’s Privacy Notice, that I read and understood it, including those sections that described MDC’s ability to monitor telephone, electronic mail, internet, or other communications made at work, including those made using personal password protected accounts, if such communications use any MDC resources. I also hereby authorize MDC to disclose information relating to my employment to third parties that provide benefits or other employment-related services for the benefit of MDC’s employees and staff. I further represent that I have obtained the consent of any third parties, including dependents and beneficiaries, about whom I have provided personal information to MDC in connection with the benefits and other employment-related services offered to me under the terms of my employment. I understand that I can request a list of all third parties that provide benefits or other employment-related services by contacting [the Human Resources office].

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Employee and Staff Privacy Notice and Notice of Collection

1. Personal Information We Collect

2. How We Collect Your Personal Information

3. How We Process Your Personal Information

5. How Long We Retain Your Personal Information

6. How We Protect Your Personal Information

7. Your Choices

8. Changes To This Privacy Notice

9. Contact Information

10. Additional Information for California Residents

Acknowledgment of Receipt

Employee and Staff Privacy Notice and Notice of Collection

1. Personal Information We Collect

2. How We Collect Your Personal Information

3. How We Process Your Personal Information

4. How We Share Your Personal Information

5. How Long We Retain Your Personal Information

6. How We Protect Your Personal Information

7. Your Choices

8. Changes To This Privacy Notice

9. Contact Information

10. Additional Information for California Residents

Acknowledgment of Receipt