California Employee and Applicant Privacy Notice
This Privacy Notice for California Employees (the &ldquo;Notice&rdquo;) applies to all job applicants, employees, owners, directors, officers, and contractors (collectively referred to in this Notice as &ldquo;employees&rdquo;) This Notice is provided to comply with the California Consumer Privacy Act of 2018 (&ldquo;CCPA&rdquo;).
We are committed to protecting the privacy and security of the information we collect and to being transparent about the purposes for which we use your information. This Notice sets forth our policies and practices for handling the information we collect and use in the employment context.
1. Updates
This Notice will be updated at least once every twelve (12) months to reflect changes in our business, legal, or regulatory obligations. The Company will not collect additional categories of your personal information or use your personal information already collected for additional purposes without providing you with a notice of our intent to do so. Any changes to this Notice will be effective from the date they are communicated to you. If we make any material changes to this Notice, we will notify you before such changes are effective.
2. Personal Information We Collect About You
Listed below are the categories of personal information that Company may process about employees: 3.1 Identifiers, including real name, alias, postal address, unique personal identifiers, email, account name, social security number, driver&rsquo;s license number, passport number, or other similar identifiers. In this context, a &ldquo;unique personal identifier&rdquo; means a persistent identifier that can be used to recognize an employee, or a device that is linked to an employee, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, or similar technology; unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers.
3.2 Characteristics of Protected Classifications Under California or Federal Law, including the following: race, skin color, national origin, religion (includes religious dress and grooming practices), sex/gender (includes pregnancy, childbirth, breastfeeding, and/ or related medical conditions), gender identity, gender expression, sexual orientation, marital status, medical condition (such as genetic characteristics, cancer, or a record or history of cancer), disability (such as mental and physical including HIV/AIDS, or cancer), military or veteran status, request for family care leave, request for leave for an employee&rsquo;s own serious health condition, request for pregnancy disability leave, and age.
3.3 Internet or Other Electronic Network Activity Information, including browsing history, search history, application access location, and information regarding an employee&rsquo;s interaction with an internet website, application, or advertisement, time and geolocation data related to use of an internet website, application, or physical access to a Company office location.
3.4 Professional or Employment-related Information, including job related data, maintained as part of the employment relationship that is present in: a job application or resume; an employment contract; a contractor agreement; a performance review; a disciplinary record; photos; biometric data, including imagery of your fingerprint, face, and voice recordings; information from employee expenses; browsing and search history; payroll and benefits related data; internal and external contact information; or information captured from video, audio, systems, or other forms of monitoring or surveillance.
3.5 Education Information, including information about an employee&rsquo;s educational background, such as education records, report cards, and transcripts that is not publicly available.
3.6 Inferences, including any information drawn from any of the personal information categories referenced above to create a profile about an employee reflecting the employee&rsquo;s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
4. Purposes for Collecting Your Personal Information
Company collects the personal information identified in Section 3 above for the reasons listed below.
4.1 To Recruit Employees, including to conduct employment related background screening and checks.
4.2 To Administer Benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management, and provision of online total reward information and statements.
4.3 To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools, and administration of stock option payments.
4.4 To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions, and staff re-structuring.
4.5 To Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of an employee&rsquo;s work-related responsibilities, ensuring compliance, training, examination, and other requirements with applicable regulatory bodies.
4.6 To Provide Our Employees with Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration
4.7 To Administer International Assignments, including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration, and filing obligations, addressing health requirements, and populating the International Mobility global system.
4.8 To Maintain Your Contact Information, including altering your details across relevant entities within the Company group of companies (for example personal, other employment, and transferring roles).
4.9 To Assist You in Case of Emergency, including maintenance of contact details for you and your dependents in case of personal or business emergency.
4.10 To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring compliance of employees&rsquo; ability to work in the U.S.
4.11 To Conduct Healthcare-Related Services, including conducting pre-employment and employment-related medical screenings for return-to-work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for travel.
4.12 To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training.
4.13 To Ensure a Safe and Efficient Working Environment, which includes Company actions relating to disciplinary actions, and code of conduct processes, and investigations.
4.14 To Maintain Security on Company Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of Company&rsquo;s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.
4.15 To Comply with Applicable Law or Regulatory Requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic, and Health, Safety, Security, and Environmental reporting.
5. Data Retention
Personal information will be retained for as long as necessary to fulfill the purposes outlined in this Notice, or as required by law. The criteria for determining retention periods include the nature of the data, the purposes for processing, and legal or regulatory requirements.
6. Third-Party Sharing
Personal information may be shared with third-party service providers who assist with various business operations, such as payroll processing, benefits administration, and IT services. We ensure that these third parties implement appropriate safeguards to protect the data and comply with applicable privacy laws.
7. Selling of Information
We have not &ldquo;sold&rdquo; Personal Information for purposes of the CCPA. For purposes of this Notice, &ldquo;sold&rdquo; or &ldquo;sale&rdquo; means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
8. Further Information
If you have any questions about this statement, please contact the Human Resources Department. 
&nbsp;
&nbsp;