1. Scope of Privacy Policy

When This Policy Applies

This Privacy Policy is intended solely for, and is applicable only to, current and former California employees. Where relevant, it also applies to job applicants, interns, agency workers, contractors, consultants, directors, and other individuals whose information we collect in connection with providing employment. For ease of reference, this Privacy Policy generally refers to employee data, but this does not indicate in any way that an individual is our employee.

When This Policy Does Not Apply

This Privacy Policy does not apply to individuals who are not California residents.

This Privacy Policy also does not apply to our collection and use of your personal information in a consumer or business-to-business capacity. For more information on our collection and use of your personal information in that capacity, including how we process opt-out preference signals, please see our online privacy policy available here.

2. Notice at Collection of Personal Information

Personal Information We Collect

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified, or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this Privacy Policy, we will refer to this information as “Personal Information.”

• Identifiers (name, alias, email address, postal address, Social Security number, driver’s license number, other types of state identification card numbers such as California ID Cards, passport number, Internet Protocol address)

• Unique personal identifiers (employee number, unique pseudonym, or user alias)

• Signature

• Telephone numbers

• Bank account number

• Corporate credit card number

• Medical/health information

• Insurance policy number or subscriber identification number

• Any unique identifier used by health insurer to identify employee

• Education information

• Professional or employment-related information (including employment history)

• Biometric information (fingerprint; imagery of face)

• Characteristics of protected classifications under California or federal law (race; sex/gender (including pregnancy, childbirth, breastfeeding and/or related medical conditions); gender identity/expression; age (40 and older); national or ethnic origin; disability (mental and physical, including HIV/AIDS, cancer, and genetic characteristics); citizenship or immigration status; marital status; medical condition (genetic characteristics, cancer or a record or history of cancer); military or veteran status; status as a victim of domestic violence, assault, or stalking; and requests for family care leave, for leave for an employee’s own serious health condition, or for pregnancy disability leave)

Sources of Personal Information

We collect Personal Information directly from you (California residents) and from recruiters; online providers (such as through LinkedIn and similar providers); background checks; benefits providers; payroll providers; company bankers; business partners; expense management service providers; internet service providers; staffing companies; references; other employees; former employers; educational institutions; government entities; medical providers; claims handlers; authentication and single sign-on providers; advertising networks; data analytics providers; operating systems, platforms, or software; professional employer organizations; social networks; and data brokers. We do not collect all categories of Personal Information from each source.

Purposes for Collection

We currently collect and have collected the above categories of Personal Information for all purposes of providing employment, including to:

• Process payroll;

• Enable recruiting services;

• Request you complete applications and forms associated with your employment or prospective employment;

• Consider you for potential employment;

• Perform background checks and drug testing;

• Administer and maintain corporate bank accounts;

• Manage corporate expenses;

• Administer and maintain benefits, including group health insurance, retirement accounts, employee compensation, and employee leave;

• Track time and attendance at work;

• Request you acknowledge your agreement to certain company policies;

• Verify your ability to work in this country;

• Identify you as a veteran;

• Process security clearances;

• Perform diversity and inclusion initiatives, including data analysis, development, and deployment;

• Perform company audits;

• Administer our wellness program;

• Administer and maintain employee recognition and rewards programs and platforms;

• Contact individuals for emergency purposes;

• Manage workers’ compensation claims;

• Manage your job-related performance;

• Arrange business travel;

• Investigate and handle disciplinary actions or termination;

• Establish training and/or development requirements;

• Detect lost/stolen equipment, fraud, or other types of wrongdoing;

• Grant and monitor your access to secure company facilities and files;

• Engage in corporate transactions requiring review of employee records and information, such as for evaluating potential mergers and acquisitions;

• Review web traffic and events, monitor for virus attacks and web content, and determine bandwidth consumption;

• Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance;

• Maintain commercial licenses for enterprise applications and platforms;

• Prevent the spread of illness and administer programs during a pandemic (e.g., COVID-19);

• Perform call monitoring and surveillance (e.g., CCTV);

• Comply with federal and state law;

• Enforce our legal rights; and

• Engage in other legitimate business purposes reasonably required for our day-to-day operations such as accounting, financial reporting, and business planning.

We also use your Personal Information for the purposes described in our Employee Handbook (including any supplements), Business Conduct and Ethics Principles Policy; Digital Security Program (DSP); and your offer letter (if applicable).

3. Disclosure of Personal Information

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy and, for each category, categories of recipients to whom we disclosed Personal Information.