California Privacy Notice for Staff Members and Job Applicants

Last Revised: January 1, 2023

1. Introduction

Snappy App, Inc. and its subsidiaries and its affiliates (“Snappy,” "us", "we," "our" and/or "Company") has issued this California Privacy Notice (this "Notice") to describe how we handlePersonal Information that we collect and process about our Staff Members and job applicants who are residents of California (collectively referred to as "you") and applying for a job at or working for Company in the United States. The term "Staff Member" includes employees and independent contractors, including contingent workers, temporary workers, and interns. This categorization is for convenience and does not demonstrate or establish any particular employee, contractor or other status.

We respect the privacy rights of individuals and are committed to handling Personal Information(defined in Section 2 below) responsibly and in accordance with applicable law. This Notice sets out the Personal Information that we collect and process about you, the purposes of the processing and the rights that you have in connection with it. The California Consumer PrivacyAct of 2018, including the California Privacy Rights Act of 2020 and any regulations promulgated thereunder (“CCPA”), provides California residents with specific rights regarding theirInformation. This Notice, which applies only to California residents, describes your rights under the CCPA, explains how you may exercise your rights, and provides an overview on the types of Personal Information we collect.

Please take the time to read and understand this Notice, which should be read in conjunction with our other corporate policies and procedures. When appropriate, we will provide a “just in time” notice or notice at collection to cover any additional processing activities not mentioned in this document. This Notice does not apply to any Personal Information that we may collect if you use the Snappy gift-giving platform to send or receive gifts, and you should instead consult theSnappy Privacy Policy for further information about our data practices in relation to the Snappy gift-giving platform.

If you have any comments or questions about this Notice, please contact us at the contact details in Section 11 below.

2. Types of Personal Information we collect

The CCPA defines “Personal Information” as information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Data that has been de-identified, anonymized, or aggregated, or that otherwise cannot reasonably be related back to a specific person, is not considered Personal Information.

In the course of your employment or engagement with Company, or when making an application for employment or engagement with Company, we may process Personal Information about you and your dependents, beneficiaries and other individuals whose Personal Information has been provided to us

The types of Personal Information we may process include, but are not limited to:

Identification data – such as your name, gender, photograph, date of birth, Staff Member IDs.
Contact details – such as home and business address, telephone/email addresses, emergency contact details.
Employment details – such as job title/position, office location, employment contract, performance and disciplinary records, grievance procedures, sickness/time-off records.
Background information – such as academic/professional qualifications, education,CV/résumé, criminal records data (for vetting purposes, where permissible and in accordance with applicable law).
Government identifiers – such as government issued ID/passport, immigration/visa status, or social security numbers.
Information on your spouse/partner and/or dependents – such as your marital status, identification and contact data about them and information relevant to any Company benefits extended to such people.
Financial information – such as bank details, tax information, withholdings, salary, benefits, expenses, company allowances, stock and equity grants.
IT information – information required to provide access to company IT systems and networks(and information collected by / through those systems) such as IP addresses, log files and login information.

Personal Information that we process may also include Sensitive Personal Information. TheCCPA’s definition of Sensitive Personal information includes social security, driver’s license, state ID, or passport number; racial or ethnic origin; union membership; biometric information; and personal information concerning health, sex life, or sexual orientation ("Sensitive Personal Information"). We may also process Sensitive Personal Information relating to you (and your spouse/partner and/or dependents) for the purposes set forth in this Notice.
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We may need to collect, or request on a voluntary disclosure basis (or involuntarily, if required by applicable law), some Sensitive Personal Information for legitimate employment-related purposes: for example, information about your racial/ethnic origin and gender for equal employment opportunity reporting purposes (in accordance with applicable law); or information about your physical or mental condition to provide work-related accommodations, health and insurance benefits to you and your dependents, or to manage absences from work.

3. Sources of Personal Information

Generally, you will have provided the information we hold about you, but there may be situations where we collect Personal Information or Sensitive Personal Information from other sources. For example, we may collect the following:

Certain background and other information from recruitment agencies, academic institutions, referees, background checking agencies and other third parties during your recruitment and/or employment/engagement.
Certain information on your performance, conduct or other information relevant to formal internal procedures (e.g., disciplinary or whistleblowing procedures), from clients or other organizations with whom you work.
Information on your training and development from external training partners and information about your experience and impressions of Company through external survey providers.
Information about your health, including your fitness to carry out work and/or any accommodations or adjustments to be considered from a health care provider (as permitted by applicable law).
Information on accidents or incidents from Company’s insurance brokers, insurers and their appointed agents, where they are involved.
Information on tax payable from tax authorities and Company’s appointed payroll agents and tax/financial advisers.
Information collected through Company’s IT systems and other devices.
Information about your entitlement to participate in, or receive payments or benefits under, any insurance or pension plan or program provided by Company, from the relevant benefit provider or its appointed agent.
Information from publicly available sources (e.g. news sources and/or from social media platforms) in connection with any investigation or formal procedure concerning the same (for instance, for the investigation of an allegation that a Staff Member has breached our rules on social media use or conduct generally).
Information that we receive from a court or other government agency requiring us to comply with wage garnishment orders.

4. Purposes for Processing Personal Information

(i) Recruitment purposes

If you are applying for a role at Company, then we collect and use your Personal Information primarily for recruitment purposes – in particular, to determine your qualifications for employment or engagement as an independent contractor and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying out reference checks or background checks (where applicable) and to generally manage the hiring process and communicate with you about it. We also collect and use your Sensitive Personal Information such as: your social security, driver’s license, state ID, or passport number, your racial/ethnic origin and gender for equal employment opportunity reporting purposes (in accordance with applicable law); or information about your physical or mental condition to provide work-related accommodations that may be necessary in the hiring process.

If you are accepted for a role at Company, the information collected during the recruitment process may form part of your ongoing Staff Member record.

If you are not successful, we may still keep your application for internal reporting and to allow us to consider you for other suitable openings within the Company in the future.

(ii) Employment or work-related purposes

Once you become a Company Staff Member, we may collect and use your Personal Information for the purpose of managing our employment or working relationship with you – for example, your employment records and contract information if you have a contract (so we can manage our employment relationship with you), your bank account and salary details (so we can pay you),your equity grants (for stock and benefits plans administration), if any, and details of your spouse3and dependents (for emergency contact, tax and benefits purposes). We also collect and use your Sensitive Personal Information such as: your social security, driver’s license, state ID, or passport number, your racial/ethnic origin and gender for equal employment opportunity reporting purposes (in accordance with applicable law); or information about your physical or mental condition to provide work-related accommodations.

We may process our Staff Members' Personal Information through a Professional EmployerOrganization (“PEO”) or other human resources system ("HR System"), which provides tools that help us to administer HR and Staff Member compensation and benefits. This will involve maintaining your Personal Information in, or transferring it to, our PEO or HR System provider's servers in the United States. Company may host these servers or utilize third party servers.

(iii) The Company’s global directory

We maintain a global directory of Staff Members that contains your professional contact details(such as your name, location, photo, job title and contact details). This information will be available to everyone in the Company’s global group of companies to facilitate global cooperation, communication and teamwork.

(iv) Other legitimate business purposes

We may also collect and use Personal Information when it is necessary for other legitimate purposes, such as:

to help us conduct our business more effectively and efficiently – for example, for general HR resourcing, reporting or analytics, IT security/management, business continuity purposes, accounting purposes, or financial planning;
to investigate violations of law or breaches of our own internal policies and more generally to protect the rights and interests of Company’s group, our employees, applicants and others.For instance, we may monitor your browsing or communications activity or location when using our devices or systems, if we suspect that you have been involved in phishing scams, fraudulent activity or activities in competition with or inconsistent with your work for theCompany.
to help secure our networks and systems from unauthorized access, scams, and malicious code. For instance, we may monitor and review electronic mail communications sent or received using Company issued devices or accounts, or stored on or using such a device or account. We may also monitor and record each website visit, each chat session, newsgroup post, e-mail message, and each file transfer into and out of our systems and networks.Company may monitor this activity at any time, and, to the extent permitted by laws, users of our networks and systems should not expect privacy when using these systems and devices.
in accordance with any personal device policy in effect. For instance, we may deploy security software on your personal device that monitors URLs for phishing risks and other security threats.
to foster diversity, inclusion, and a welcoming work culture.

Company may use video cameras and recording equipment for its premises, offices, and facilitates, and stores information captured by this equipment, in order to secure its networks, systems, and property, and may monitor access and use of its systems using this equipment.

Company may also require you to enable your device, whether personal or issued byCompany, to recognize facial or fingerprint IDs. Your biometric information will be stored on the device itself, and the Company will never transfer this data to its servers or to any third party. With respect to your personal device, this means that Company will never collect your biometric information. For company-issued devices, we will only store biometric information on the basis of your explicit consent, and only for the period of time that such device is issued to you.

(v) Law-related and other purposes

We also may retain and use your Personal Information where we consider it necessary for complying with laws and regulations, including collecting and disclosing Staff Member PersonalInformation as required by law (e.g., for tax, health and safety, anti-discrimination and other employment laws), under judicial authorization, to protect your vital interests (or those of another person), or to exercise or defend the legal rights of the Company global group of companies.

5. Who we share your Personal Information with

We take care to allow access to Personal Information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate business purpose or other lawful ground for accessing it. Whenever we permit a third party to access PersonalInformation, we will implement appropriate measures designed to ensure the information is used in a manner consistent with this Notice.

(i) Transfers to other group companies

As mentioned above, we may share your Personal Information with other members of theCompany group around the world in order to administer human resources, Staff Member compensation and benefits at an international level on the HR System, as well as for other legitimate business purposes such as IT services/security, tax and accounting, and general business management.

(ii) Transfers to third party service providers

In addition, we may make certain Personal Information available to third parties who provide services to us. We do so on a "need to know basis" and in accordance with applicable data privacy laws.

For example, some of this information will be made available to:

our benefit/reward plans service providers (including retirement plan and medical insurance providers);
service providers who provide us with payroll, tax and expense administration support services;
providers of our HR Platform, including our recruitment platform;
service providers who provide, support and maintain our IT, security, and communications infrastructure (including for data storage purposes) and/or provide business continuity services;
service providers who assist in the coordination and provision of relocation, travel and/or travel permit services (in connection with work-related travel);
service providers who provide services in relation to staff training and/or qualifications and staff surveys, vendors hosting events, etc; and
auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under a contractual prohibition of using the Personal Information for any other purpose.

(iii) Transfers to other third parties

We may also disclose Personal Information to third parties on other lawful grounds, including:

Where you have provided your consent;
To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant;
In response to lawful requests by public authorities (including for tax, immigration, health and safety, national security or law enforcement purposes);
As necessary to establish, exercise or defend against potential, threatened or actual legal claims;
Where necessary to protect your vital interests or those of another person; and/or
In connection with the sale, assignment or other transfer of all or part of our business.

We do not sell the Personal Information we collect from and about you as described in Sections2-4

6. Summary of Personal Information Collection, Use and Disclosure

In the past 12 months, we have collected some or all of the categories of Personal Information described in the table below, which further describes the business or commercial purpose(s) for which the Personal Information was collected and the entities to whom such information has been disclosed within the last 12 months.

7. Your California privacy rights

(i) Right to Know

As a California consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure, or sale of your personal information over the past 12months. Once we receive and confirm your verifiable consumer request, and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:

The categories of Personal Information that we have collected about you.
The categories of sources from which the Personal Information is collected.
Our business or commercial purpose for collection, use, or disclosure of that Personal Information.
The categories of third parties with whom we sell or share that personal information.

(ii) Right to Data Portability
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You have the right to request a copy of Personal Information we have collected and maintained about you in the past 12 months. The CCPA allows you to request this information from us up to twice during a 12-month period. We will provide our response in a readily usable (in most cases, electronic) format.

(iii) Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your8Personal Information from our records unless an exception applies. For example, we may deny your deletion request if retention of the Personal Information is:

Necessary to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
Reasonably anticipated within the context of your employment or engagement, or application for employment, with us;
For solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
Necessary to comply with a legal obligation; or
Otherwise necessary for internal use in a lawful manner that is compatible with the context in which you provided the Personal Information.

(iv) Right to Correct

You have the right to request the correction of any Personal Information we maintain about you.

(v) Right to Limit the Use or Disclosure of Sensitive Personal Information

You have the right to limit the use or disclosure of your Sensitive Personal Information (“SPI”) if we are using your SPI beyond what is reasonable and proportionate within the context of your relationship with us as an employee or job applicant. You can make a request for us to limit the use or disclosure of your SPI by emailing us at privacy@snappy.com.

(vi) Right to Nondiscrimination

You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights.

8. Exercising your California Privacy Rights

To exercise the rights described above, please submit a request to us by clicking here, or contacting us at privacy@snappy.com or +1 (833)-649-3151.

After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that it is not a fraudulent request. In order to verify your identity, we will request, at a minimum, that you provide your name, email address, phone number, address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request.

Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your Personal Information. If you are making a request as the authorized agent of aCalifornia consumer, we will ask that you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf.

We will make every effort to respond to your request within 45 days from when you contacted us.If you have a complex request, the CCPA allows us up to 90 days to respond. We may contact9you within 45 days from the date you contacted us to inform you if we need more time to respond.

9. Data retention periods

Personal Information will be stored in accordance with applicable laws and kept as long asCompany has an ongoing legitimate business need to carry out the purposes described in thisNotice or as otherwise required by applicable law. Generally this means your PersonalInformation will be retained until the end or your employment, employment application, or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries, comply with regulatory obligations, or to deal with any legal matters (e.g.judicial or disciplinary actions), document the proper deductions during and on termination of your employment or work relationship (e.g. to tax authorities), or to provide you with ongoing pensions or other benefits.

10. Updates to this Notice

This Notice may be updated periodically to reflect changes in our privacy practices. In such cases, we will indicate at the top of the Notice when it was most recently updated, and if we make a material change, we will inform you, for example, on our intranet or by company-wide email. We encourage you to check back periodically in order to ensure you are aware of the most recent version of this Notice. Please note that Company does not discriminate against those who exercise their rights under applicable data protection laws.

11. Contact details

If you have any questions, comments, or complaints about how we use your information, or would like to exercise any rights that you may have under the CCPA, please address any questions or requests relating to this Notice to privacy@snappy.com or alternatively, you can raise any concerns with Snappy’s People Team. If you have disabilities, you may access this notice in an alternative format by contacting privacy@snappy.com.

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