California Applicant Privacy Policy

Last Updated: January 30, 2023

This California Applicant Privacy Policy describes how the Outform Group (“Outform,” “we,” and “us”) collects, uses, and discloses the Personal Information we collect about you when you apply for a job with Outform

This Privacy Policy applies to job applicants who reside in California. Please review this Privacy Policy carefully. This Privacy Policy does not form part of any contract of employment or other contract to provide services and does not give you any contractual rights.

1. PERSONAL INFORMATION WE COLLECT
“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. During the past 12 months, we may have collected the following categories of Personal Information about you:

• Identifiers ► including your name, home address, phone numbers, and government-issued IDs (such as your Social Security numbers, visa and passport information).

• Information within our recruiting records ► including your signatures, information about criminal convictions and offenses (such as information from legal proceedings), and drug test results.

• Characteristics of protected classifications under California or federal law ► including your age, race/ethnicity, citizenship, gender, and disability information.

• Internet or other electronic network activity information ► including browsing history, search history, and general internet usage data).

• Audio, electronic, visual, thermal, olfactory, or other sensory information ► including photographs, audio, or footage collected in the course of video interviews, through an online applicant platform, or through a public profile.

• Professional or employment-related information ► including your title, work schedule and status, work experience, education, licensure and other credentials, and other such information you provide or that is generated during or after interviews and related activities.

• Education information ► including education history, professional qualifications, academic certificates and licenses, languages spoken, and other relevant skills.

• Inferences ► drawn from any of the information we collect, such as likelihood of your profile being a good fit with our internal team and long-term prospects with Outform.

Some of this information may be considered sensitive personal information under California law ► including your Social Security number, driver’s license, state identification card, or passport number; account log-in information; racial or ethnic origin, religious or philosophical beliefs, or union membership; information about your health (such as information to accommodate health and safety requirements, disability status and information about such disability, smoking status, and vaccination status) ; and information about your sexual orientation.

2. SOURCES OF PERSONAL INFORMATION
We may obtain your Personal Information the following sources:

• Directly from you ► such as when you complete a paper or online application (including on our dedicated online talent management platform), communicate with us in connection with your application, provide references, or participate in an interview or any aptitude test or assessment (including online). We may also collect your Personal Information when you decide to complete questionnaires, such as a satisfaction survey or a diversity and inclusion questionnaire.

• From third parties ► such as companies or individuals who direct or refer you to us (including third-party staffing or recruiting firms or individuals who suggest or identify you), as well as from publicly available sources and third-party professional social networking websites. Where permitted or otherwise authorized by law, we may also collect information received from third parties in connection with references or background checks.

We may combine and use information and make inferences from information that we receive from the various sources described in this Privacy Policy, including third party sources. We also use or disclose the combined information and inferences for the purposes identified below.

3. HOW WE USE YOUR PERSONAL INFORMATION
We use your Personal Information for the following business purposes:

• In connection with your application ► such as assessing your application, interview, and test results for suitability for the position for which you have applied or other open positions; communicating with you concerning job openings or your application; conducting pre-employment verification and screening; offering you the job position, in our discretion; notifying you of job opportunities (including from affiliates in our group, where we have shared your job application with them); and dealing with any inquiry, challenge, or request for feedback received in relation to our recruitment and hiring decisions.

• For our internal business purposes ► such as managing and improving our recruitment process (for example, enhancing our scouting and talent identification processes); enforcing our policies and rules; and operating our diversity and inclusion initiatives.

• For legal, safety or security reasons ► such as complying with legal requirements, processes, or orders; fulfilling reporting and similar requirements; complying with government inspections and other requests from government or other public authorities; pursuing legal rights and remedies; investigating and responding to claims against Outform and its customers and employees; monitoring and managing equal opportunity programs; screening and conducting background checks (as required or permitted by law); protecting our, your, our customers’, and other individuals’ safety, property or rights; addressing security and health and safety issues (including managing spread of communicable diseases) and malicious, deceptive, fraudulent, or illegal activity; ascertaining your eligibility for work; and receiving legal advice or approval.

• In connection with a corporate transaction ► such as if we acquire, or some or all of our assets are acquired by, another entity, including through a sale in connection with bankruptcy and other forms of corporate change.

• To comply with policies including monitoring and video surveillance ► including in relation to claims, disciplinary actions or legal processes or requirements and conducting investigations and incident response.

• For promotional purposes ► such as to notify you about new job openings in accordance with your preferences.

We do not collect or process sensitive personal information to infer characteristics about you.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose each type of Personal Information listed above to the following categories of third parties pursuant to the business and commercial purposes listed above:

• Service providers ► including those that provide IT services, background check vendors, and drug-screening services providers.

• Professional consultants ► including recruiters, accountants, lawyers, financial advisors, and audit firms.

• To affiliated companies ► that are owned or operated by the same corporate parent.

• To other third parties for legal purposes ► including government and law enforcement agencies, regulatory authorities, and their service providers.

We do not sell your Personal Information, and we do not share information with third parties for cross-context behavioral advertising (including Personal Information of individuals under 16 years old).

5. YOUR RIGHTS
You may have certain rights over the Personal Information we maintain about you, including:

• Right to Access: You have the right to request information about the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting the Personal Information, and to whom we have disclosed Personal Information and why.

• Right to Delete: You have the right to request that we delete Personal Information that we have collected from you subject to certain exceptions.

• Right to Correct: You have the right to request that we correct inaccurate Personal Information that we maintain about you.

• Right not to be Discriminated Against: We will not discriminate against you if you exercise your rights.

You can call us at 800-356-5775 to request to exercise the rights above. When you make a request to access or delete your information, we must first verify your identity before processing your request. We will ask for your name, e-mail address, and other information you include on your resume to match against any information we maintain about you in our systems.

You can submit requests through an agent that you have authorized in writing to act on your behalf. Your agent will need your written and signed permission that they are authorized to act on your behalf. As explained above, your agent will also need to provide information verifying your and their identity. We will still need to contact you directly to verify your identity and the request, or if any other information may be needed.

Please be aware that certain exceptions apply to the exercise of these rights and so you will not be able to exercise them in all situations.

6. SECURING AND RETAINING YOUR PERSONAL INFORMATION
Outform will take steps to protect your Personal Information against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification, regardless of the format in which it is held and will use appropriate security safeguards to provide necessary protection.

We retain your Personal Information for only as long as we need it to provide our products and services, operate our business, and comply with our legal obligations. When we decide how long to keep your Personal Information, we keep in mind the nature and sensitivity of the information, the potential harm from unauthorized use, the reasons we collected the Personal Information, and our legal obligations.

7. CHANGES
We may update this Privacy Policy from time to time. Any updated Privacy Policy will be effective when posted. Please check this Privacy Policy periodically for updates. If required by law, we will contact you directly to provide you with an updated Privacy Policy.

8. QUESTIONS
You can contact 800-356-5775 for questions about this Privacy Policy.