STUDS PRIVACY NOTICE FOR CALIFORNIA EMPLOYEES AND APPLICANTS

Effective Date: March 11, 2024

This Privacy Notice for California Employees and Applicants (this “Notice”) is adopted to comply with the California Consumer Privacy Act of 2018 (the “CCPA”), the California Privacy Rights Act of 2020, effective January 1, 2023 (“CPRA”) and other California privacy laws (collectively referred to in this Notice as “California Laws”), and applies to current and former employees of, and applicants for employment with, Studs. If you are an employee of or applicant for employment with Studs and you reside in California, you are entitled under the California Laws to certain information regarding your Personal Information (which includes Sensitive Personal Information as defined in the California Laws) as defined in the Studs Privacy Policy available at HTTPS://STUDS.COM/PAGES/PRIVACY-POLICY (the “Policy”) that Studs collects about you, and how we use that information, at or before the time we collect such information. Any terms defined in the California Laws have the same meaning when used in this Notice. Any terms not defined in this Notice have the meaning set forth in the Policy.

Rights under California Laws. California Laws provide applicants for employment and employees who are California residents with certain rights:

• Right to know about Personal Information collected, disclosed, shared, or sold. A California resident has the right to be informed about the information practices of a business (including the purposes for which categories of Personal Information are collected or sold, the categories of sources from which a business collects Personal Information, and categories of third parties to whom a business discloses or sells Personal Information), and the specific pieces of Personal Information (including Sensitive Personal Information) that a business holds about that resident.
• Right to request deletion of Personal Information. A California resident may request that a business delete their Personal Information.
• Correction request rights. A California resident may request that a business correct any inaccurate Personal Information (including Sensitive Personal Information) that we have about you, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.
• Right to opt-out of the sale of Personal Information. A California resident has the right to opt-out of the “sale” of their Personal Information by a business.
• Right to opt-out of sharing. A California resident has the right to opt out of the sharing of their Personal Information to a third party for cross-context behavioral advertising.
• Right to non-discrimination for exercise of consumer privacy rights. A California resident has the right not to receive discriminatory treatment by a business for the exercise of privacy rights provided by the California Laws.

The Personal Information and Sensitive Personal Information that we are collecting. For the past twelve (12) months preceding the effective date of this Notice, we have collected the following information:

• Identifiers, such as name, preferred name, government-issued identifier (e.g., Social Security number), and unique identifiers (e.g., employee ID);
• Sensitive Personal Information, such as real name, signature, SSN, physical characteristics or description, address, telephone number, driver’s license or state identification card number, passport number, birth certificate number, federal identification authorizing work in the United States, access and/or passcodes, insurance policy number, education, employment, employment history, bank account number, other financial information, medical information, or health insurance information;
• Characteristics of protected classifications under California or federal law, such as age, marital status, gender, sex, race, color, disability, citizenship, primary language, immigration status, military/veteran status, disability, request for leave, sexual orientation, and medical conditions;
• Commercial information, such as transaction information and purchase history (e.g., in connection with travel or other reimbursements or purchases from Company);
• Internet or network activity information, such as browsing history and interactions with our online systems and websites and any Personal Information that you provide while accessing the Company’s computer systems, such as personal credit card information and passwords;
• Geolocation data, such as device location from usage of the Company’s devices;
• Audio, electronic, visual, and similar information;
• Professional or employment-related information, such as work history and prior employer;
• Non-public education information; and
• Inferences drawn from any of the Personal and Sensitive Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

If you are an applicant for employment, providing Personal Information to us is voluntary. However, if you do not provide sufficient information, we may be unable to consider your application. In certain cases we may ask you for additional information for purposes of complying with applicable laws. We may also inquire about criminal records. We will do so only where permitted by applicable law.

If you are an employee, you may be required to provide certain information to Studs in order to comply with applicable law. 

Where we get your Personal Information from. The Company collects Personal Information about you from the following sources:

• You
• Prior employers, references, recruiters, job-related social media platforms;
• Third-party sources of demographic information; 
• Third-party companies, such as pre-employment screening companies and benefit companies; and 
• Claim administrators and investigators.

Depending on Studs’ interactions with you, we may collect all of the Personal Information identified above about you.

How your Personal Information is used. We may use Personal and Sensitive Personal Information:

• To operate, manage, and maintain our business;
• For hiring, retention, and employment purposes;
• To otherwise accomplish our business purposes and objectives, including, for example:
• Emergency services;
• Conducting research, analytics, and data analysis;
• Maintaining our facilities and infrastructure;
• Quality and safety assurance measures;
• Conducting risk and security controls and monitoring;
• Protecting confidential and trade secret information;
• Detecting and preventing fraud;
• Performing identity verification;
• Performing accounting, audit, and other internal functions, such as internal investigations;
• Complying with the law, legal process, and internal policies;
• Maintaining records;
• Claims processing;
• Reporting as required by state and federal laws;
• Responding to legal requests for information and subpoenas; and
• Exercising and defending legal claims.; and
• Any other purposes authorized by the California Privacy Protection Agency, California or Federal law.

We may have used Personal and Sensitive Personal Information about you for each of the above purposes.

Selling and Sharing of Personal Information. Studs does not sell or share for cross-context behavioral advertising purposes (in the past 12 months preceding the effective date of this Notice and otherwise) Personal Information of applicants for employment or employees, including any Personal Information of minors under 16 years of age. For more information about our privacy practices and policies, please review our PRIVACY POLICY.

Disclosure of Personal Information. We only disclose your information for the purposes set forth above.  In the past 12 months, we have disclosed it to: 

• You;
• Third-party companies, such as payroll and benefit companies; 
• Service providers assisting with and providing advice related to internal functions; and,
• Claim administrators and investigators. 

Sensitive Personal Information. We do not use or disclose your Sensitive Personal Information for purposes other than the limited purposes permitted by the CCPA.

Data Retention. The Company retains the information it receives about you for the periods required under applicable California and/or Federal law.

For Inquiries and/or to submit requests for information, deletion or correction. 

Please either:

(1) complete the form located here, or 

(2) call +1-877-321-3035. 

Please understand that we are only obligated to respond to verifiable consumer requests.  If we receive a request for information about you, we need to know that it is actually coming from you, or an agent who is legally authorized to act on your behalf. In order to verify a request, we may ask for certain Personal Information, including at least the name and email address of the person who is the subject of the request, and we may implement authentication procedures that are appropriate to the nature of the request. We may also use any information that we have already collected in order to verify a request. If we collect any new Personal Information (that we do not already hold for another purpose) in order to verify a request, we will only use that information to verify the request.

If you are acting as an authorized agent to make a request to know, delete, or correct on behalf of a California resident, please submit a written authorization signed by the resident with your request, and we will contact you and the resident with any further steps required to verify the resident’s identity.

For more information on Studs employment and privacy policies, please refer to the Studs Employee Handbook (including its supplement for California employees) and the Studs PRIVACY POLICY. 

Please VISIT THIS LINK to see the Studs Privacy Notice for California Residents, effective prior to March 10, 2024.