This California Privacy Notice/ Policy (the "Policy") supplements the Online Privacy Policies of Headlands Technologies LLC ("HT") and its affiliates (collectively, "we," "us," or "our") and provides eligible California residents with specific rights with respect to our collection, retention and use of personal information. This Policy has been adopted to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Act of 2020, effective January 1, 2023, and applies solely to residents of the State of California (collectively the "CPRA").

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, is capable of being associated with, or may reasonably be linked, directly or indirectly, with a California resident, including job applicants ("Personal Information"). In particular, we do collect and have collected in the preceding twelve (12) months, the following categories of Personal Information:

Category	Examples	Collected
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, cookies, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.	YES
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e))	A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	YES
Characteristics of protected classifications under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender, identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
Internet or other similar network activity	Browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement.	NO
Geolocation data		YES
Sensory information	Audio, surveillance, thermal, olfactory, or similar information.	YES
Professional or employment-related information	Current or past employment history, performance evaluations or professional references.	YES
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)	Records, files, documents, and other materials which contain information directly related to a student and are maintained by an educational agency or institution or by a person acting for such agency or institution.	YES
Inferences drawn from other personal information	Inferences drawn from other personal information such as a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

The CPRA also defines certain information that divulges any of the following as sensitive personal information:

Category	Examples	Collected
Government identifiers	SSN, driver's license, state identification card, or passport.	YES
Complete access credentials	User names, account numbers, and security code or password.	NO
Precise geolocation	IP address which can determine your general location.	YES
Racial or ethnic origin	Race, color, ancestry, national origin.	YES
Religious or philosophical beliefs		NO
Union membership		NO
Genetic data		NO
Mail, email, or text message contents		YES
Unique identifying biometric information		NO
Health, sex life or sexual orientation information	Health conditions (if relevant to your employment), job restrictions, workplace injury information, or health insurance policy information.	NO

USE OF PERSONAL INFORMATION

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information as part of an employment application, we will use that information to evaluate your background and credentials in considering you for employment.
• To provide you with information that you request from us.
• To maintain an accurate and up to date personnel file.
• To evaluate and identify candidates for recruitment.
• To conduct due diligence and KYC procedures.
• To meet our financial obligations.
• To facilitate employee background checks.
• To verify employment eligibility.
• To comply with regulatory requirements.
• To facilitate employee expense reimbursement.
• To provide access to office locations.
• As necessary or appropriate to protect the rights, property, or safety of us or others.
• To respond to law enforcement requests and as required by applicable law, court order, or government regulation.
• As described to you when collecting your personal information as or as otherwise set forth in the CPRA.
• To improve our websites and present their contents to you.

We will not collect additional categories of Personal Information or us the Personal Information we collected for materially different unrelated, or incompatible purposes without providing you notice.

Personal Information does not include:

• Publicly available information that is lawfully made available from federal, state, or local government records.
• Deidentified or aggregate California resident information.
• Information specifically excluded from the CPRA's scope, including:
• protected health or medical information collected by a covered entity under the Confidentiality of Medical Information Act or governed by the privacy, security, and breach notification rules under the Health Insurance Portability and Availability Act of 1996 ("HIPAA");
• personal information covered by certain other privacy laws, including the Fair Credit Reporting Act ("FCRA"), the Gramm-Leach-Bliley Act ("GLBA"), California Financial information Privacy Act ("FIPA"), and the Driver's Privacy Protection Act of 1994.

We do not and will not knowingly collect, disclose, or sell data relating to children, that is, individuals under the age of 16 years.

Any sensitive Personal Information collected or processed by the firm is not for the purpose of inferring characteristics.

RETENTION PERIOD

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our record retention policy which you can request from us by contacting us at dataprotection@headlandstech.com.

SOURCES OF PERSONAL INFORMATION

We obtain Personal Information you voluntarily provide to us when you apply for a job or otherwise contact us in the recruitment context.

We may also combine Personal Information collected from other sources with the Personal Information you provided us. For example, we may collect information from:

• Recruiters
• Prior employers (e.g., for references)
• Professional references provided to us
• Educational institutions
• Pre-employment screening services
• Publicly available sources such as your social media profiles (e.g., LinkedIn, Twitter and Facebook)
• Directly and indirectly from activity on our website. For example, website usage details collected automatically.

We do not and will not knowingly collect, disclose or sell data relating to children, that is, individuals under the age of 16 years.

DISCLOSURE OF PERSONAL INFORMATION

We may share your Personal Information to a third party for a business purposes described in this Policy, including internally with our personnel involved in the hiring process. We have shared during the past 12 months for our business purposes the categories of Personal Information listed above to the following categories of third parties:

• Our affiliates
• Service providers
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

We do not and will not sell any Personal Information. In the preceding 12 months, we have not sold any personal information.

YOUR RIGHTS

The CPRA grants California residents certain rights regarding their Personal Information. This section describes your rights under the CPRA and explains how you can exercise these rights.

Right to Access Specific Information and Data Portability

You have the right to request that we disclose which of your Personal Information we have collected or used over the past 12 months. After we receive and confirm your verifiable request, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting that Personal Information.
• The categories of third parties with whom we share your Personal Information.
• The specific pieces of information we collected about you (also called a data portability request).
• If we disclosed your Personal Information for a business purpose, we will identify the Personal Information categories that were disclosed to each category of recipient.

Right to Request Deletion or Correction of Personal Information

You have the right to request the deletion or correction of your Personal Information collected or maintained by us, subject to certain exceptions. After we receive and confirm your verifiable request, we will delete or correct, and/or we will direct our service providers to delete, your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another California resident to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Enable solely internal uses that are reasonably aligned with expectations based on your relationship with us.
7. Comply with a legal or regulatory obligation (e.g. litigation holds, document retention requirements).
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights

To exercise the rights described above, please submit a verifiable request to us by either:

• Calling us at (888) 611-4611
• Emailing us at dataprotection@headlandstech.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf (an agent), may make a verifiable request related to your Personal Information.

You may only make a verifiable request for disclosure of Personal Information collected twice within a 12-month period. The verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot 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. We will only use Personal Information provided in a verifiable request to verify the requestor's identity or authority to make the request.

Right to Access Specific Information and Data Portability

We will confirm the receipt of a request within ten business days of receiving. We aim to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA we will not:

• Deny you goods or services.
• Provide you a different level or quality of goods or services.

CHANGES TO OUR POLICY

We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post a notice on our website.

CONTACT US

If you have any questions or comments about this Policy, the ways in which we collect and use your personal information, your choices, and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Updated: April 2023