Applicant Privacy Notice

• all activity on the Company’s information systems, such as internet browsing history, search history, and email communications.
• all activity on communications systems including phone calls, call logs, voice mails, text messages, chat logs, and app use.

Professional and employment-related information. This category includes without limitation:

• data submitted with employment applications including employment history, recommendations, etc.
• background check, personal security clearance check, and criminal history
• biometric information
• work authorization
• fitness for duty data and reports

Education information. This category includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).

Limited medical information. This category includes without limitation:

• symptoms and other indicators of exposure to the coronavirus, COVID-19
• fitness for duty data and reports
• leave of absence information including family obligations, physical and mental health data concerning employee and his or her family members
• travel information and information regarding close contacts
• COVID-19-related doctor’s notes for absences or work restrictions, medical leave of absence records, requests for accommodation, interactive process records, and correspondence with you and your healthcare provider(s) regarding any request for accommodation or medical leave of absence related to COVID-19, COVID19 vaccination-related information.

Audio, Electronic, Visual, or Similar Information. This category includes, without limitation, information collected from CCTV footage on premises.

Sensitive Personal Information. This category includes sensitive information such as:

• social security, driver’s license, state identification card, or passport number
• account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
• precise geolocation.
• racial or ethnic origin, citizenship, immigration status, religious or philosophical beliefs, or union membership.
• content of mail, email, and text messages unless the Company is the intended recipient of the communication.

Inferences drawn from the PI in the categories above.

Please note that PI for purposes of this Notice does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern; information that is deidentified or aggregated; and information subject to certain other laws such as the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Protection Act, the Health Insurance Portability and Accountability Act (HIPAA), the Fair Credit Reporting Act (FCRA), etc.

Purposes Personal Information is Used. The Company collects and uses PI for the recruitment and application process, for its business-related purposes, and for legal compliance. Personal information collected is only used for purposes listed below, unless otherwise notified.

• Collect and process employment applications, including confirming eligibility for employment, background and related checks including fitness for duty, personal security clearance processing, onboarding, and related recruiting efforts, as necessary.
• Obtaining and/or maintaining a facility clearance, obtain and/or maintain security guard license as well as processing payroll and employee benefit plan and program design and administration including enrollment and claims handling, and leave of absence administration.
• Evaluate an individual’s appropriateness for a particular position at the Company now or in the future, or promotion to a new position.
• Communicate with you about your application.
• Maintaining personnel records and record retention requirements.
• Complying with applicable state and federal labor, employment, equal employment opportunity, and related laws.
• Preventing unauthorized access to or use of the Company’s property, including the Company’s information systems, electronic devices, network, and data.
• Ensure compliance with the Company’s information systems policies and procedures.
• Facilitate the efficient and secure use of the Company’s information systems.
• Investigating complaints, grievances, and suspected violations of Company policy.
• Protect the legal rights, privacy, safety or property of Company or its employees, agents, contractors, customers, or the public.
• Protect against fraud or other illegal activity or for risk management purposes.
• Enforce the Site’s terms of use.
• Carry out a license, sale or transfer of all or a portion of the business or assets (including in connection with any bankruptcy or similar proceedings), or manage or arrange for acquisitions, mergers, and re-organizations.
• Design, implement, and promote the Company’s Equal Employment Opportunity programs.
• Improve safety of our facilities for employees, customers, and the public with regard to use of Company property and equipment.
• Complying with federal, state, and local orders, identifying potential COVID-19 symptoms, and protecting the workplace.
• Engaging in human capital analytics, including but not limited to, identifying certain correlations about individuals and success on their jobs, analyzing data to improve processes, and analyzing employee preferences to inform HR Policies, Programs and Procedures.

The Company may add to the purposes it uses Personal Information. In that case, the Company will inform you.

Sources of Personal Information.

• You. We may collect personal information directly from you or through your use of our facilities or systems, when you send us an email, or otherwise communicate or interact with us. We may also collect information automatically from you when you visit our website, use our information systems, etc.
• Related Entities and Affiliates. We may collect information about you from our related parties and
  affiliates.
• Social media and related services. We may collect information about you through your social media services consistent with your settings on such services.
• Third parties. We may collect information about you from third parties such as your employer, references, or other third-party sources that are lawfully entitled to share your personal information with us. This may include service providers or contractors who collect or process your personal information on our behalf.

Disclosures. To carry out the purposes outlined above, we may disclose your personal information to our related entities, or affiliates; our business partners; service providers, contractors, and vendors (e.g., background check providers, third-party staffing agencies, information technology providers, data storage providers, etc.); professional advisors (e.g., lawyers, auditors, accountants, consultants); and government entities (e.g., regulatory agencies, law enforcement). We may also authorize our service providers to collect personal information on our behalf.

We may disclose your personal information to third parties, as necessary, to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; (4) investigate claims or allegations or to establish, exercise or defend legal claims; or (5) evaluate or perform a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires all or part of the assets of our business.

The following chart lists the categories of third parties to whom we disclose or may have disclosed these categories of personal information in the preceding 12 months.

Selling and Sharing Personal Information. The Company does not sell or share, as those terms are defined by the CCPA, any category of personal information collected. In addition, we do not have actual knowledge that we sell or share the personal information of individuals under the age of 16 years.

Disclosing Sensitive Personal Information. We do not use or disclose your Sensitive Personal Information for purposes that, with limited exceptions, are not necessary for application and recruitment related purpose for which we collect it or as reasonably expected by an average individual in this context or for other permitted purposes under the CCPA or as authorized by regulation.

Retention. We retain your Personal Information for as long as is necessary to fulfill the purpose for which it was collected (e.g., to manage the application process, etc.) and in accordance with the Company’s data retention schedule and applicable law. We may retain your Personal Information for longer if it is necessary to comply with our legal or reporting obligations (e.g., if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, address other legitimate business needs, or as permitted or required by applicable law. We may also retain your Personal Information in a deidentified or aggregated form so that it can no longer be associated with you.

To determine the appropriate retention period for your Personal Information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your Personal Information; and applicable legal requirements. Personal Information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated information.

California Resident Individual Rights Requests. Individuals who are residents of the State of California have certain individual rights as outlined below, subject to certain limitations.

Right To Know About Personal Information Collected or Disclosed. You have the right to request information beyond what we have disclosed above regarding the following, to the extent applicable:

• the categories of personal information the Company collected about you.
• the categories of sources from which that personal information was collected.
• the business or commercial purposes for which that information was collected, sold, or shared.
• the categories of third parties to whom the information was disclosed.
• the specific pieces of personal information collected.

Upon receipt of a verifiable Request to Know (see below), and as required by applicable law, we will provide a response to such request.

Right To Request Deletion of Your Personal Information. You have the right to request that we delete the Personal Information we collected or maintain about you. Once we receive your request, we will let you know what, if any, Personal Information we can delete from our records and will direct any service providers and contractors to whom we disclosed your Personal Information to also delete your Personal Information from their records. There may be circumstances where we cannot delete your Personal Information or direct service providers or contractors to delete your Personal Information from their records. Such instances include, without limitation, when the information at issue is maintained: (a) to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which you provided the information, or (b) to comply with a legal obligation.

Upon receipt of a verifiable Request to Delete (see below), and as required by applicable law, we will provide a response to such requests.

Right to Request Correction. You have the right to request that the Company correct any inaccurate Personal Information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable Request to Correct (see below), and as required by the CCPA, we will provide a response to such requests.

We will not discriminate or retaliate against you for exercising any of the rights described above.

Submitting CCPA Rights Requests. To submit a CCPA Rights request, please contact us 888-232-9574 or email us at alutiiqjobs@alutiiq.com. We reserve the right to only respond to verifiable Requests to Know, Delete, or Correct that are submitted as instructed. A verifiable consumer request is one made by any individual who is:

• the individual who is the subject of the request,
• an individual on behalf of the individual’s minor child, or
• the authorized agent of the individual.

What to submit. If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the individual. In general, we may ask you to provide identifying information that we already maintain about you, or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive Personal Information to verify your identity. We may not be able to respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. However, making a verifiable request does not require you to create an account with us.

Additionally, you will need to describe your request in sufficient detail to allow us to review, understand, assess, and respond. We will not use the Personal Information we collect from an individual to determine a verifiable request for any other purpose, except as required or permitted by law.

Authorized Agent. You may authorize a natural person or a business (the Agent) to act on your behalf. When you submit a Request to Know, Correct, or Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

If you have questions about this notice, you may call 888-232-9574 or email alutiiqjobs@alutiiq.com.

Changes to Statement. We reserve the right to amend this Notice at any time without advance notice.