PRIVACY NOTICE AT COLLECTION (CCPA/CPRA) FOR CALIFORNIA EMPLOYEES

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About this Notice. This privacy notice sets out how Samuel Hale and its affiliated companies collect and use personal information about you in compliance with our obligations under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). This notice is intended to comply with all applicable laws, such as the California Consumer Privacy Act as well as the California Privacy Rights Act.

We take the privacy of our employees very seriously. Please read this notice carefully as it contains important information on the personal information that we collect, why we collect it, how long we keep it, and whether it is sold to or shared with third parties. This notice will be updated regularly.

Key Terms. The following key terms are used in this notice:

· We, us, our: Samuel Hale, LLC; Samuel Hale 2, LLC; Samuel Hale Exchange, LLC, as well as any other entity affiliated or owned by Employinsure LLC.

· Personal information. Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular individual.

· Sensitive personal information. Personal information revealing an individual’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email, and text messages where the business is not the intended recipient, genetic data, and biometric information.

· Biometric Information. An individual’s physiological, biological, or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

Other terms used but not defined will have the meaning set forth in the CCPA, as amended by the CPRA, Cal. Civ. Code §§ 1798.100—1798.199.100, and accompanying regulations set forth under Cal. Code Regs. tit. 11, § 7000 et seq.

Personal Information We Collect About You. We may collect and use the following categories of personal information about you:

Categories of Personal Information Collected

· Identifiers: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

· Personal information as defined in Customer Records law: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, other financial information, medical information, health insurance information.

· Characteristics of protected classifications under California or federal law such as race, religion, national origin, age, sex, sexual orientation, pregnancy, familial status, disability, military or veteran status, and genetic information.

· Biometric information.

· Geolocation data.

· Audio, electronic, visual, thermal, olfactory, or similar information such as photographs and call recordings.

· Professional or employment-related information, such as work history, prior employer, references, qualifications, skills and experience, human resources data, emergency contact information, and data necessary for benefits and related administrative services.

How and Why We Use Your Personal Information. We use your personal information for the following purposes:

Purposes for Collecting and Using Your Personal Information

Managing Human Resource Functions:

· To open and maintain employee records

· To communicate with you for internal business purposes or emergencies

· To determine your eligibility to work and fulfill our obligations to regulators

· To address our legal obligations

· To pay you or provide workers compensation coverage or other benefits

· To take action regarding disciplinary, capability, grievance, arbitration of clams

· To conduct equal employment opportunity and DEI initiatives

· To insure compliance with policies

· To record and monitor your hours of work

· To recruit, hire, and onboard into our service systems

· To perform background or credit checks

· To increase employee engagement

· To pay bonuses and provide PACT benefits

· To provide Training and career development

· Managing payroll and business expenses

· Administering leave requests

· Employee communications

· Administration of benefits

· Promoting employee health and safety

Conducting business operations:

· Recordkeeping and reporting requirements

· Strategic planning

· Maintaining security

· Emergency response and business continuity

· Conducting audits

· Pursuing or defending legal or administrative claims

Monitoring:

· Compliance with internal policies and procedures

· Use of company resources

· Any other monitoring activities permitted by applicable laws

Compliance with:

· Legal and regulatory obligations

· Court or other government directives

· Internal policies and procedures

Investigating:

· Reports of wrongdoing

· Policy violations

· Internal complaint

Whether Personal Information Will Be Sold or Shared. We do not sell the personal information of employees. We do share information with outside vendors that we use to process employee payroll, benefits such as: The PACT; the employee pension trust; benefit providers/vendors; software providers to transmit information to vendors, or process payroll or other financial calculations.

How Long Your Personal Information Will Be Kept. We will keep your personal information for as long as is necessary while you are employed by us. Thereafter, we will keep your personal information:

· To respond to any questions, complaints or claims made by you or on your behalf

· To show that we treated you fairly; or

· To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

Contact. If you have any questions or concerns about this notice or the information we collect about you, please contact a Samuel Hale human resources representative at [email protected] or 855-726-4253. For further contact details, visit www.samuelhale.com.