Applicant Privacy Notice

• all activity on the Company’s information systems if you access or are provided access to such systems, such as internet browsing history, search history, and email communications.
• all activity on communications systems if used in connection with the application or review process, including phone calls, call logs, voice mails, text messages, chat logs, and app use.
• your interaction with an internet website application, or advertisement.

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 where permitted by law and relevant to the position
• professional licenses, certifications, educational degrees
• work authorization
• fitness for duty data and reports, if required for the position

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).

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:

• health information (information relating to an applicant’s accommodation request.) We collect and use this information only for lawful employment-related purposes and maintain it in a confidential manner, consistent with applicable federal, state, and local laws.

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. We use your Personal Information for the purposes listed below, unless otherwise notified.

• Collecting and processing 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.
• Evaluating an individual’s appropriateness for a particular position at the Company.
• Communicating with you about a current application or future job opportunities.
• Maintaining records and complying with record retention requirements.
• Complying with applicable state and federal laws including, without limitation labor, employment, equal employment opportunity, and related laws.
• Providing requested accommodations.
• Preventing unauthorized access to or use of the Company’s property, including the Company’s information systems, electronic devices, network, and data.
• Ensuring compliance with the Company’s policies and procedures.
• Facilitating the efficient and secure use of the Company’s information systems.
• Investigating complaints, grievances, and suspected violations of Company policy; establishing, responding to and managing legal claims against the Company and/or its personnel including civil discovery in litigation.
• Protecting the legal rights, privacy, safety or property of Company or its employees, agents, contractors, customers, or the public.
• Designing, implementing, and promoting the Company’s Equal Employment Opportunity programs.
• 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.
• Carrying 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.

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, interview with us, or otherwise communicate or interact with us.
• 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 or from public websites as permitted by their terms of use.
• Third parties. We may collect information about you from third parties such as your employer, references, recruiters, 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 as necessary for the purposes described in this Privacy Notice. For example, we share your personal information with the following categories of parties:

• Subsidiaries, affiliates and related entities (e.g., for a reward of the contract under a different subsidiary, or within the proposal stage, sharing a resume with a sister subsidiary).
• Service Providers and contractors: We use service providers to operate, host and facilitate our operations and business (including human resources and recruiting operations). These include without limitation recruiting services; hosting, technology and communication providers; security and fraud prevention consultants; analytics providers; background and reference check screening services; data storage providers; and providers of hiring process management and administration tools.
• Professional advisors: We may share your personal information with our professional advisors such as lawyers, consultants, auditors, and accountants for purposes of receiving professional services.
• Third parties related to government, legal or law enforcement purposes: 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; or (4) investigate claims or allegations or to establish, exercise or defend legal claims.
• Third parties at your direction (e.g., a reference).
• Parties to a business transfer: Your personal information may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or part) or for evaluation of such an activity.

We may disclose, or disclosed in the preceding 12 months, these categories of personal information to service providers and contractors:

• Identifiers and other Contact Information
• Protected classification information
• Internet or other electronic network activity
• Audio, electronic, visual, or similar information
• Education or Professional and Employment information, including veteran status or other similar identifiers.
• Sensitive information

Retention. We retain Personal Information for as long as is reasonably necessary to fulfill the purposes for which it was collected, including managing the recruitment and application process, and related purpose, unless a longer retention period is required or permitted by law.

Retention periods vary depending on the category of Personal Information and the purpose for which it was collected. For example, applicant information is typically retained for up to two (2) years following the conclusion of the application process, unless a longer period is required to comply with legal, regulatory, or reporting obligations. If you are hired, your Personal Information will become part of your employee file and will be retained in accordance with applicable employment record retention requirements and the Company’s data retention schedule.

We may retain Personal Information for longer periods where necessary to comply with applicable laws, resolve disputes, enforce our agreements and policies, or for other legitimate business purposes permitted by law. We may also retain Personal Information in a deidentified or aggregated form so that it can no longer reasonably be associated with you.

In determining appropriate retention periods, we consider factors such as the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized access or use, the purposes for which the information is processed, and applicable legal requirements.

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

Right to Opt Out of the Sale or Sharing of Your Personal Information. The Company does not sell or share, as those terms are defined by the CCPA, any category of Personal Information we collect about you as an applicant. In addition, we do not have actual knowledge that we sell or share the Personal Information of individuals under the age of 16 years.

Right to Limit the Use and Disclosure of Sensitive Personal Information. The Company does not use or disclose your Sensitive Personal Information for purposes other than those permitted by the CCPA (e.g., necessary for application and recruitment-related purposes 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).

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

• the categories of Personal Information we 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 categories of Personal Information that we sold or shared about you, and for each category identified, the categories of third parties to whom we sold or shared that particular category of Personal Information.
• the categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of service providers or contractors to whom we disclosed that particular category of Personal Information.
• the specific pieces of Personal Information collected.

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.

Right to Request Correction. You have the right to request that we correct any inaccurate Personal Information we maintain about you, taking into account the nature of that information and purpose for processing it.

Right to Withdraw Consent. If we request and you provide your consent to process certain Personal Information, you may freely withdraw your consent at any time.

Right to Opt Out of Automated Decisionmaking (“ADMT”), Access Information about ADMT, and Appeal an ADMT Decision. The CCPA provides for certain rights related to the use of ADMT for significant decisions; however, we do not use ADMT to make significant decisions about you.
We will not 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. The Company reserves the right to only respond to verifiable Requests to Know, Delete, or Correct that are submitted as instructed. A verifiable request is one made by:

• 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 applicant. 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 (“an Authorized Agent”) to act on your behalf. When you submit a Request to Know, Correct, or Delete through an Authorized Agent, we may require the Authorized Agent to provide proof that you gave the agent signed permission to submit the request, and you may be required to either (i) verify your identity with us or (ii) directly confirm with us that you provided permission to the Authorized Agent to submit the request. These requirements do not apply when you have provided the Authorized Agent with a valid power of attorney pursuant to California Probate Code sections 4000–4465. 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.

Response. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will cover the 12-month period preceding the receipt of your verifiable request. With respect to personal information collected on and after January 1, 2022, and to the extent expressly permitted by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not be impossible or require a disproportionate effort by us.

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

Changes to Statement. The Company reserves the right to amend this Notice at any time without advance notice. If the Company makes material changes as to how it collects, uses, or discloses Personal Information, the Company will provide notice in accordance with applicable law.