Employee Privacy Notice

EMPLOYEE PRIVACY NOTICE

(Version 1.0 | Rev 01/01/2024)

This Employee Privacy Notice (“Privacy Notice”) describes the collection, use,
retention, and sharing of your personal information through the course of your tenure
with HireTalent, and its subsidiaries, and affiliates (“HIRETALENT”, “we,” “us,” or “our”).

I. APPLICABILITY

This Privacy Notice applies to personal information collected from personnel of
HIRETALENT. The term “personnel” includes employees, applicants who have
received a conditional offer, and those that work on a non-permanent basis, such as
temporary and contract workers, independent contractors, consultants, and interns.

II. COLLECTION, USE, AND RETENTION OF PERSONAL INFORMATION

During the course of your tenure with HIRETALENT, we collect personal information
about you, as well as personal information related to your spouse, emergency contact
(s), legal dependent(s), or family member(s) (collectively, “Dependents”), where there is
a legitimate reason to do so in connection with our relationship with you. To the extent
we collect personal information on your Dependents, you should inform your
Dependents that you are providing this information to us and why, and make sure that it
is acceptable to them. We will retain this information for seven (7) years, unless
otherwise disclosed below, or until we have received a request to delete this
information.

A. Information Collected From Employees

Through your tenure with HIRETALENT, HIRETALENT will collect personal information
for:

  • Conditional Job Offer. When you receive a conditional job offer with
    HIRETALENT, we collect from you your personal identifiers (name, email
    address, physical address, telephone number), your professional or employment
    information (resume, cover letter, employment history, and educational
    history/information, credentials, license), criminal history,  sensitive personal
    information (social security number, date of birth, and driver’s license number,
    state identification card number, or passport number), protected categories (race,
    gender, ethnicity, disability status, military or veteran status/spouse status, age
    range.), vaccination status (documentation and/or card, if applicable), health
    information (pre-employment screenings, vaccination status), tax information
    (federal and state tax forms), work authorization status, emergency contact
    information, and payment information (bank details, routing and account
    number). We use this information to conduct pre-employment background screenings, verify work authorization, and as necessary to comply with applicable laws.
  • Administer compensation and/or benefits. We collect from you as well as from
    governmental entities, your identifiers (name, telephone number, physical
    address, email address (if provided), date of birth,), sensitive personal
    information (Social Security number, driver’s license number, state identification
    number, and/or passport (if provided)), protected classifications (marital status,
    age, gender, disability status (if provided), veteran status (if provided)),
    beneficiary information (name, telephone number, email address, date of birth,
    social security number), health information for ADA, FMLA, and workplace
    accommodations (if applicable), financial information (bank account and routing
    number), and professional or employment-related information (hours worked,
    meal and rest breaks). We use this information to administer compensation and
    benefits, such as medical, dental, and retirement benefits, as applicable to you.
    We also collect from you your Dependents’ identifiers (name, telephone number,
    physical address, email address (if provided), date of birth), protected categories
    (marital status, gender), and sensitive personal information (Social Security
    number). We use this Dependent information to process their eligibility as your
    dependents for the purpose of benefits, and administer enrolled Dependent’s
    benefits.

For independent contractors, we will collect your W-9 Information, business name,
business registration information, Social Security number or Taxpayer Identification
Number (TIN), and business insurance policy information.

  • Administer reimbursements. We collect from you and from our payment card
    vendors, your identifiers (name, physical address), financial information (bank
    account and routing number), corporate financial information (HIRETALENT-
    issued credit card), purchases through HIRETALENT’s travel service, and details
    of travel or expenses incurred in connection with your tenure. We use this
    information to issue reimbursements.
  • Career Development. We collect, from you, your identifiers (name) and
    professional or employment-related information (licenses, credentials,
    employment history, resume/CV, disciplinary evaluations, performance reviews,
    terms and conditions of employment) and educational information (educational
    institution). We use this information to identify, deliver, and track training needs
    and outcomes, to help with career development, succession, planning, and
    workforce management and to manage professional requirements, certifications
    and memberships and to manage relationships with vendors.
  • Conduct performance reviews. We collect from you your identifiers (name) and
    professional information (licenses, credentials, employment history, educational
    history, resume/CV) and create inferences based on this information regarding
    overall performance and future performance. We use this to conduct
    performance reviews and evaluate personnel for internal opportunities.
  • Conduct background checks. We collect your identifiers (name, address
    history, date of birth), criminal history information, and sensitive personal
    information (Social Security number). We use this information to conduct third-
    party background checks for employment purposes. Once you receive a
    conditional offer letter for a position with HIRETALENT we also collect from credit
    reporting agencies your commercial information, i.e., credit report (open lines of
    credit, outstanding balances, auto or student loans, foreclosures, late or missed
    payments, any bankruptcies and collection accounts, and other information
    returned in your credit report). We use this credit check to assess your fitness
    and suitability to the role you have applied for.
  • Create a personnel file. We collect, from you your identifiers (name, date of
    birth, telephone number, physical address, date of birth), commercial information
    (credit report information which may include employment and education history,
    criminal history, military service, professional references), health information
    (vaccination status), emergency contact information, referral information, and
    professional or employment-related information (licenses, credentials,
    employment history, references, educational history, resume/CV, disciplinary
    evaluations, performance reviews, terms and conditions of employment, skills,
    qualifications, experience, travel history, professional/occupational memberships,
    and time-off work), and inferences from analysis of this information. We use this
    personal information to maintain your personnel file, create personnel
    biographies, and for internal recruitment purposes (assessing your eligibility for
    other positions within HIRETALENT).
  • Handle general human resources functions. We collect, from you, your
    identifiers (name, email address, telephone number, physical address), your
    protected classification (work authorization status), and your Dependent’s
    identifiers (name, address, email address, telephone number) and Dependent’s
    protected category (marital or family status). We use this information to handle
    general human resources functions, such as personnel support, termination, and
    emergency contact procedures.
  • Issue tax forms. We collect, from you, your identifiers (name, physical address,
    Social Security number, date of birth) and tax information (marital status, withholding details). We use this information to issue tax forms and comply with
    tax reporting requirements.
  • Monitor compliance with equal opportunities and anti-discrimination
    laws. We collect, from you, as well as from governmental entities, and
    background check providers protected classifications (race, color, national origin,
    ethnicity, age, citizenship status, sex, military or veteran status/spouse status,
    any disabilities you may have). We use this information to comply with our
    obligations under these laws, equal opportunities and anti-discrimination laws.
  • Monitor work-related licenses and credentials. We collect from you as well as
    from educational institutions, personal and professional references your
    identifiers (name) and your professional information (licenses, credentials,
    employment history, educational history, resume/CV). We use this information to
    manage work-related licenses and credentials.
  • Promote safety and security. We collect from you and automatically from
    closed circuit cameras your physiological characteristics (photographs, images,
    video from closed-circuit cameras). We collect this information from you and
    closed-circuit cameras. We use the photographs and images to create security
    badges to promote the safety and security of HIRETALENT employees,
    contractors, visitors, customers, and consumers.
  • Participate in recorded telephone calls and videoconference calls. We
    collect from you your physiological characteristics (images and video of your
    physical appearance) and auditory information (recording of your voice) while
    you participate in a telephone conversation on a recorded telephone line or
    videoconference. We collect this information to facilitate the communication with
    clients, business partners, and other third parties with whom we communicate,
    compliance purpose, training, and quality assurance.
  • Implement our diversity, equality, add inclusion programs. We collect from
    you your protected categories (race, color, national origin, ethnicity, sex
    (including pregnancy, childbirth, and related medical conditions), disability, age,
    citizenship status, marital status, sexual orientation, gender identity and gender
    expression, veteran or military status/spouse status). With your consent, we use
    this information to implement our diversity, equality, and inclusion programs.

B. Information We Collect From Third Parties

During your employment with HIRETALENT, we collect personal information from the
following third parties for the purposes described below.

  • Verify your education. We collect from you as well as from background check
    providers, and education institutions, your non-public education information
    (verification of education level completed, verification of dates enrolled in
    educational institutions). We use this information to verify your education for
    employment purposes.
  • Verify your employment history. We will collect your employment information
    (employment history) from your previous employers. We will use this information
    to verify the accuracy of the information you provide to us during the application
    process.
  • Review drug test results. When we request a drug test, we will collect from the
    drug test provider your health information (the results of the drug test). We will
    collect this information to determine whether you are taking any illegal
    substances. If the drug test results identify marijuana in your body, we may
    collect your medical marijuana card information to confirm you are legally
    permitted to consume marijuana.
  • Information from references. When you provide references with your
    application, we will receive from your references your professional or
    employment information (confirmation of details on your resume/CV,
    certifications, qualifications, employment history, educational history) and
    inferences drawn from your references, such as their thoughts on your behavior,
    intelligence, abilities, and aptitudes. We use this personal information to assess
    your suitability for the position for which you have applied.
  • Health or Vaccination Providers. We receive the conclusions drawn from your
    health examination, eye exam, and vaccination status (i.e., whether you passed
    the examination or have the requisite vaccinations, and not your health
    information) from the health examination/vaccination provider. We use this
    information to determine whether you fulfil our health examination or vaccination
    requirements.

C. Information We Collect Automatically via Cookies and Other Trackers

During your employment with HIRETALENT, we automatically collect personal
information for the purposes described below when you use HIRETALENT property
within the scope of your employment.

  • Conduct IT security and management: We collect information when you use
    the HIRETALENT systems, internet and electronic network activity information
    (username, password, IP address, browsing history, search history, websites
    visited, interactions with websites, system login date and time). We use this
    information to ensure compliance with HIRETALENT’S policies and procedures, to protect data assets of HIRETALENT, for authentication purposes, and to
    provide IT support. We also collect additional information as may be included in
    phone recordings, email, or other messaging correspondence conducted on or
    through HIRETALENT devices.

III. HOW WE SHARE YOUR PERSONAL INFORMATION

  • General Sharing
    We share your personal information as follows:
    Within HIRETALENT. We share personnel information within HIRETALENT to
    receive IT services/security, Human Resources, tax and accounting, and general
    business and employment management. Access to personal information is
    limited to those on a need-to-know basis.
  • With Service Providers. We will share your personal information to our service
    providers to assist us in managing and administrating your tenure. These service
    providers include IT support, health insurance, payroll, expense processing,
    benefits plans, and professional advisors (accountants, legal).
  • With Third Parties. We will share your personal information with third parties,
    such as legal advisors, law enforcement agencies, or governmental/regulatory
    bodies in order to protect our legal interests and other rights, protect against
    fraud or other illegal activities, for risk management purposes, and to comply with
    our legal obligations.
  • During a corporate reorganization. In the event that we enter into, or intend to
    enter into, a transaction that alters the structure of our business, such as a
    reorganization, merger, acquisition, sale, joint venture, assignment,
    consolidation, transfer, change of control, or other disposition of all or any portion
    of our business, assets or stock, we will share personnel personal information.
  • With our Clients or Managed Service Providers. We share personnel
    information with the entity with which you applied and the Managed Service
    Provider that serves as an intermediary with our Client to provide our service to
    you and to our Client.
  • Legal Purposes. We will share personal information where we are legally
    required to do so, such as response to court orders, law enforcement, or legal
    process including for national security purposes; to establish, protect, or exercise
    our legal rights, as required to enforce our agreements or other contracts; to
    defend against legal claims or demands; or to comply with the requirements of
    any applicable law.

Sharing in the Preceding Twelve (12) Months

For Business Purposes. In the preceding twelve (12) months, HIRETALENT has
disclosed the following categories of personal information for a business purpose to the
following categories of third parties: We have disclosed your personal identifiers,
protected classifications, professional or employment related information, internet or
other electronic network information, and your customer records information to service
providers that help us perform employment-related functions, including whether you
meet the qualifications for the position for which you applied. These service providers
include IT support, background check companies, payroll processors, expense
processors, health insurance providers, Clients, Managed Service Providers, and
benefits providers.

  • We have disclosed your personal identifiers and internet or other electronic
    network information to IT support to detect security incidents, protect against
    malicious, deceptive, fraudulent, or illegal activity, and to identify and repair errors
    that impair functionality.
  • We have disclosed your personal identifiers and internet or other electronic
    network activity information to IT support to help us maintain the quality and
    safety of HIRETALENT devices or to improve, upgrade, or enhance
    HIRETALENT devices.

For Sale or Sharing. HIRETALENT does not sell or share personnel personal
information.

IV. RIGHTS OF CALIFORNIA EMPLOYEES

The California Privacy Rights Act, (CPRA) entitles California residents to certain rights.
To the extent the CPRA applies to our processing of your personal information, you are
entitled to the following rights:

  • Right to Access/Know. You have the right to request what personal information
    we have collected, used, disclosed, and sold about you, unless doing so proves
    impossible or would involve disproportionate effort.
  • Right to Deletion. You have the right to request the deletion of your personal
    information that we collect or maintain, subject to certain exceptions. Once we
    receive your request to delete and confirm your identity, we will delete (and notify
    any service providers or third parties, who we have shared or sold your personal
    information to, to delete) your personal information, unless an exception applies
    under applicable law.
  • Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale or
    sharing of your personal information to third parties. HIRETALENT does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years. HIRETALENT does not sell or share personnel personal information.
  • Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt-out, correct, or limit use of sensitive personal information under the CPRA.
  • Right to correct. You have the right to correct inaccurate personal information that we collect or maintain.

To exercise your right to access/know, correct, or delete your personal information, you
may submit a request toll-free at 1-800-762-6318 or via
email data.privacy@HireTalent.com. You can also exercise your rights by
visiting our California Privacy Rights Act page. For requests submitted via telephone or
email, you must provide us with sufficient information that allows us to reasonably verify
you are the person about whom we collected the personal information and describe
your request with sufficient detail to allow us to properly evaluate and respond to it. If we
are not able to verify your identity for access and deletion requests with the information
provided, we may ask you for additional pieces of information.

Using an Authorized agent

Only you, or a person that you authorize to act on your behalf, may make a request
related to your personal information. If a consumer is using an authorized agent to
submit a CCPA/CPRA privacy request to know (disclosure report) or delete their
personal information, the following is required.

  • Using an authorized agent without power of attorney to submit a request to
    know or delete
  • Signed permission from the consumer authorizing the agent to submit the
    CCPA privacy request(s) on their behalf. Describe the type of privacy
    request(s) being requesting (know/disclosure report and/or deletion).
  • The consumer must verify their own identity directly with the us by
    submitting information or documentation that provides sufficient proof of
    identification, such as:

    • a Social Security number or a copy of a social security card issued
      by the Social Security Administration,
    • a certified or official copy of a birth certificate issued by the entity
      authorized to issue the birth certificate, or
    • a copy of a driver’s license, an identification card issued by the motor vehicle administration, or any other government issued identification.
  • Using an authorized agent with power of attorney to submit a request to
    know or delete: If you have provided the authorized agent with power of
    attorney pursuant to California Probate Code sections 4000 to 4465, provide only
    the following: the valid power of attorney executed lawfully under California
    Probate Code sections 4121 to 4130.
  • Using an authorized agent to submit an opt-out request: Please provide
    written permission, signed by the consumer, authorizing the agent to submit the
    opt-out request.
  • Using an authorized agent with power of attorney to submit a request to
    know or delete: If you have provided the authorized agent with power of
    attorney pursuant to California Probate Code sections 4000 to 4465, provide only
    the following: the valid power of attorney executed lawfully under California
    Probate Code sections 4121 to 4130.
  • Using an authorized agent to submit an opt-out request: Please provide
    written permission, signed by the consumer, authorizing the agent to submit the
    opt-out request.

V. SECURITY

We implement and maintain reasonable security measures to protect the personal
information we collect and maintain. These security measures include encryption,
access controls, and employee training. However, no security measure or modality of
data transmission over the Internet is 100% secure and we are unable to guarantee the
absolute security of the personal information we have collected from you.

VI. CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice is subject to change at the sole discretion of HIRETALENT. If we
make any changes, we will announce those changes by email and on our website and
we will indicate the date the changes go into effect. If we make any changes that
materially affect your privacy rights, we will announce those changes by email and on
our website, and obtain your consent, if required.

VII. CONTACT US

For questions about this Privacy Notice, please contact your Human Resources
at privacyn@HireTalent.com