CHS Mobile AppChicago Heights Steel
§ Legal

Privacy Policy

How we collect, use, and protect information in the CHS Mobile App

Effective date: June 1, 2026
Last updated: July 1, 2026
Applies to the CHS Mobile App, used by Chicago Heights Steel (CHS) and its internal divisions Highway Steel, Inc. (HSI) and Raw Materials, Inc. (RMI)

Chicago Heights Steel respects the privacy of the people who use the CHS Mobile App. This Privacy Policy explains, in plain terms, what information the app collects, why we collect it, how we use and share it, and the choices you have. We have aimed to keep it readable while still being complete.

In this policy, "Company," "we," "us," and "our" mean Chicago Heights Steel (CHS) together with its internal divisions Highway Steel, Inc. (HSI) and Raw Materials, Inc. (RMI). "App" means the CHS Mobile App and the systems that support it, including the mobile and desktop applications, the web portal, the clockhouse display screens, the badge and gate access-control hardware, and the server and database that run them. "You" means an employee, supervisor, security officer, administrator, or authorized contractor who uses the app. You can learn more about the Company at chs.com.

The app is a private tool for Company business. It is not offered to the public, and it is not intended for personal or consumer use.

1. How this policy fits with your employment

The app supports the working relationship between you and the Company, and we handle the information in it for ordinary business and employment purposes, as described below. Nothing in this policy changes your terms of employment, and where a collective bargaining agreement applies, that agreement governs the terms and conditions of employment. If a question about your information is not answered here, your supervisor or Human Resources can help.

Because the app continues to develop over time, the categories described below may grow as we add features. When we make a change that materially affects how we handle your information, we will update this policy, and where the law requires your consent for a new practice, we will ask for it before that practice begins.

2. Information we collect

We collect only what the app needs to do its job. Depending on your role and the features you use, that may include the following.

Identity and employment details

Your name, clock number, Company email address, and, where provided, your phone number, along with your role and access level (employee, supervisor, guard, or administrator), your division (CHS, HSI, or RMI), department and cost center, crew, shift, position, hire date, and supervisor. It may also include work-related records such as uniform and locker assignment, hard-hat issue date, access-card and gate-card numbers, and your notification preferences.

Account and sign-in information

The email and password managed by the app's sign-in service, the session tokens that keep you signed in, and, if you choose to use them, the basic profile details returned by Google or Apple when you sign in with one of those providers. We never receive the password for your Google or Apple account. If you turn on the optional fingerprint or face unlock offered by your device, that check is performed by your device and the app receives only a confirmation that it succeeded (see Section 4).

Time, attendance, and access activity

Clock-in and clock-out events, badge and RFID scans at the clockhouse and gates (including the scanner, direction, and time), open and closed work sessions, timecards and timesheet entries (hours, pay codes, crew, shift, comments, and unpaid time), supervisor approvals, and call-off, late-arrival, early-departure, and clock-issue reports.

Location information

When you use mobile clock-in, the app checks your device location at the moment you clock in or out to confirm that you are within an authorized clockhouse area. It records whether you were inside that area, and on Android it may note whether the device reports a falsified ("mock") location, which helps prevent time fraud. When you carry out certain equipment inspections or guard rounds, the app may also use your location, together with Bluetooth proximity, to identify the equipment nearest to you (for example, to fill in which machine you are inspecting) and to confirm that you reached a designated inspection point or guard checkpoint. During an active guard round, your location may be checked more than once so the app can verify that each scheduled point was visited. The app reads your location only while it is open and you are actively performing one of these tasks; it does not collect your location in the background, and it does not track your movements when you are off the clock or are not using the app.

Bluetooth, NFC, and proximity

The app may detect Bluetooth signals from Company clockhouse scanners, training beacons, or tagged equipment to confirm that you are physically near them. Where your device supports it, the app may also read a short-range NFC tag attached to a machine or other equipment when you hold your device close to it, so it can identify that equipment during an inspection or checkpoint. These signals are used only to identify and confirm proximity to Company equipment; they are not used to identify or track other people's devices.

Requests, signatures, and HR submissions

Time-off and schedule-change requests, family and medical leave requests, and pay-in-lieu requests, including the dates, hours, and notes you enter. It also includes the signatures you draw on screen to acknowledge or approve timecards, requests, training records, and inspections, and the attendance-point and paid-time-off balances tied to your record, which may be imported from the Company's payroll or HR system.

Health and safety information

The app includes a medical and injury reporting feature. When you or a supervisor submit a report, the app collects the injury, medical, near-miss, or incident details entered, such as the type of event, the date and location, the body part affected, the treatment given, and any witnesses. We treat this information as confidential. We use it for workplace safety, for required recordkeeping such as occupational safety logs, and to administer workers' compensation and related matters, and we share it only with the people who need it for those purposes. We do not use it to make unlawful employment decisions.

Inspections, training, and operational content

Training attendance and checklist results, equipment inspection records and equipment status, guard-round results, plant notifications and acknowledgments, and any photographs you capture as part of an inspection or report. Please keep photos focused on the equipment or condition at issue, since an image may incidentally include other people.

Messages and communications

Messages, alerts, and acknowledgments sent through the app, along with your related delivery preferences.

Device and technical information

Basic device and technical details such as device type, operating system, app version, language, and connection status, along with diagnostic and log information (for example, error logs and request records) that we use to run and secure the app. If you enable notifications, we store a device token used only to deliver them.

3. How we use information

We use the information above for legitimate business and employment purposes. These include signing you in and keeping your account secure; recording time and attendance and confirming on-site presence for mobile clock-in; collecting, reviewing, correcting, and approving timecards and hours, and preparing the data needed to run payroll through the Company's payroll system (see Section 6); administering time-off and schedule requests, attendance points, call-offs, schedules, training, equipment inspections, guard rounds, and access control; using location and Bluetooth proximity to identify nearby equipment, confirm presence at inspection points and checkpoints, and verify that scheduled rounds were completed; sending work-related notifications and messages relevant to your role; supporting workplace safety and required recordkeeping; detecting and preventing fraud, including time-clock spoofing, and protecting the safety and security of people, equipment, and facilities; and operating, troubleshooting, securing, and improving the app.

We do not use app information for advertising, and we do not sell it. We do not use it to make decisions about you that produce legal or similarly significant effects through automated means alone, without human review.

4. Biometric information and device unlock

The app does not use facial recognition, fingerprints, or any other biometric method to record time or attendance, and the Company does not collect, capture, or store any biometric identifier or biometric information as defined by the Illinois Biometric Information Privacy Act (740 ILCS 14, "BIPA"). Drawn signatures, badge and RFID cards, location, and Bluetooth proximity are not biometric identifiers under that law.

If you choose to enable fingerprint or face unlock to open the app, that feature is provided by your device's operating system, such as Touch ID or Face ID on Apple devices or the equivalent on Android. Your fingerprint and facial data stay on your device. They are never sent to, seen by, or stored by the app or the Company, and the app learns only whether the unlock succeeded. You can turn this option off at any time and continue to sign in with your email and password.

If this ever changes: Should the Company decide to introduce a feature that directly captures a biometric identifier, it will first publish a written biometric policy with a retention and destruction schedule, give you the notice BIPA requires, and obtain your written consent before that feature is turned on. The Company has no current plans to do so.

5. The app as a workplace system

The app is a Company system provided for work. We rely on our legitimate interest in administering employment, operating our facilities safely, keeping accurate time and pay records, and meeting our legal obligations, and, where it applies, on your consent, for example when you grant the device permissions for location, Bluetooth, camera, and notifications. To the extent the law allows, the Company may monitor and record activity in the app for security, integrity, safety, and operational reasons. You should not expect your use of the app to be private beyond what this policy describes and what the law requires.

6. How we share information

Payroll

The Company runs payroll through a third-party workforce system (currently UKG). The app does not calculate net pay, withhold or file taxes, or move money, and it does not collect bank-account numbers, routing numbers, or Social Security numbers for payroll. Instead, the app gathers approved hours, pay codes, cost centers, and related time data and provides that information to authorized payroll staff, who enter or import it into the payroll system. Once that data reaches the payroll system, it is handled under that provider's terms and the Company's payroll and HR practices rather than this policy.

Service providers

We use a small number of vendors to host and operate the app under contracts that limit them to providing services to us. These currently include, or may include, the following: Cloudflare, for secure network routing and delivery between the app and our server; Google, for Google sign-in and, during the transition away from the Company's legacy tools, Google Workspace (Sheets, Drive, and Apps Script) that still hold certain HR, timesheet, inspection, and reporting data; Apple, for optional single sign-on; the Google and Apple push-notification services, for delivering push notifications, and the email service the Company uses to send sign-in codes and notices; and UKG, the Company's payroll system, as described above. This list is current as of the effective date of this policy and may change as the app develops; we keep it up to date here.

Within the Company

Authorized Company personnel such as supervisors, HR, payroll, safety, and IT staff can see information on a need-to-know basis according to their role, and information may be shared among CHS, HSI, and RMI as needed to run shared workforce operations.

Legal, safety, and business changes

We may disclose information when we believe in good faith that it is necessary to comply with the law or legal process, to enforce Company policies or the Terms of Service, to respond to a safety or security situation, or in connection with a business transaction such as a merger, acquisition, or reorganization.

No sale of personal information

We do not sell, rent, or trade your personal information, and we do not share it for advertising.

7. Notifications and email

The app may send you work-related messages through in-app alerts, push notifications, and email, such as approvals, schedule and clock-in notices, plant alerts, training check-ins, and reminders. These are operational messages, not marketing. The app does not send text messages (SMS or MMS). You can control push notifications through your device settings and your in-app notification preferences. Because some messages carry time-sensitive work information, turning a channel off may delay your receipt of that information, and the Company may reach you another way.

8. How long we keep information

We keep information for as long as it is needed for the purposes in this policy and for as long as our recordkeeping obligations and the law require. In practice that means: raw access-control and scan logs are purged automatically on a regular schedule (currently about every 90 days); open work sessions are kept until they are closed; timecard and payroll-input records are kept for the periods required by federal and Illinois wage-and-hour and tax law; safety, injury, and medical reports are kept for the periods required by occupational safety (OSHA) and workers' compensation recordkeeping rules; training and inspection records are kept for the periods set by applicable law and Company policy; and time-off, attendance-point, and other HR records are kept while you are employed and for the period required afterward. When information is no longer needed for these purposes, we delete it or remove the details that identify you.

9. How we protect information

The Company maintains administrative, technical, and physical safeguards designed to protect the information in the app. These include encrypted connections between the app and our server, sign-in tokens that expire and that sign you out when access is withdrawn, role-based permissions that limit what each person can see, secure storage of credentials on your device, a self-hosted database with restricted access, and logging and monitoring. No system can be perfectly secure, so you also play a part by protecting your credentials and your device, as described in the Terms of Service. If a security incident affects your personal information, we will notify you and the appropriate authorities as required by applicable law, including the Illinois Personal Information Protection Act (815 ILCS 530).

10. Your choices and rights

You can review much of your information directly in the app, and you can ask your supervisor or HR to access or correct your records. You control the device permissions the app uses, such as location, Bluetooth, camera, and notifications, through your device settings, although some features, for example mobile clock-in, badge or QR scanning, inspection photos, and proximity or checkpoint verification, will not work without the related permission. Your access to the app is tied to your employment or engagement and may be suspended or removed when it ends. The Company is based in Illinois and follows Illinois law, including the Personal Information Protection Act (815 ILCS 530) and BIPA, and it also follows the law of Indiana and of any other state where its employees work. Many state privacy laws do not cover information handled in an employment context, but where you live in a state that gives employees additional rights to access, correct, or delete their information, or to limit certain uses, we will honor those rights as the law requires and will not retaliate against you for exercising them. You can contact us using Section 14 to make a request. You may also ask us to delete your CHS Mobile App account and associated personal data by using the data deletion request on our website, by emailing support@chs-mobile.com, or directly in the app (open Settings, then Delete account); we will delete what we can and explain anything we must keep to meet a legal or recordkeeping obligation.

11. Minors and children

The app is a workplace tool for the Company's workforce and authorized contractors. Most users are adults, but the Company may employ minors who are 16 or 17 in permitted seasonal or summer positions, and those employees may be given an app account. When that happens, we collect and handle their information only for the employment purposes described in this policy and consistent with the laws that protect working minors. The app is not directed to, and is not intended to be used by, children under 16, and we do not knowingly collect information from anyone under 16 through the app.

12. Where information is processed

Information in the app is stored and processed in the United States, on Company-controlled infrastructure and with the service providers listed in Section 6. It is not intended to be processed outside the United States.

13. Changes to this policy

We may update this policy from time to time. When we do, we will revise the date shown at the top and, for significant changes, provide notice through the app or by another reasonable method. Where the law requires your consent before a new use of your information begins, we will obtain it first. Your continued use of the app after an update takes effect means you are aware of the current policy, to the extent the law allows.

14. How to contact us

For questions about the CHS Mobile App itself, such as how a feature works or a technical problem, contact the CHS Mobile App support team at support@chs-mobile.com. For questions about this policy or your information that are not specific to the app, or to make a request about your information, contact the Company through chs.com or your Human Resources representative.

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