We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you: Through forms you complete during the application or onboarding process, or information you provide during interviews and communications.
• Indirectly from you: Information we collect in the course of providing services to you, such as through your use of our systems and networks.
• From our clients or their agents: Through information we receive from our clients related to the services for which they engage us.
• From third-party service providers: Background check agencies, or employment verification services that interact with us in connection with onboarding requirements.
• From public sources: Information from public social media profiles or professional networking sites, if applicable.
• From government agencies: When we verify eligibility for employment or compliance with legal obligations.

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, including submitting resumes to client job requisitions and conducting onboarding screening.
• To provide you with information or services that you request from us.
• To communicate with you about your recruitment and onboarding process, including sending email and text alerts.
• To carry out our obligations and enforce our rights arising from contracts entered into between you and us, including for employment purposes.
• To operate, evaluate, and improve our business, including developing new services, managing communications, performing data analytics, and enhancing our ATS portal and HRIS/Payroll system.
• For auditing, security, and fraud prevention purposes.
• For data analysis, reporting, and service development.
• To protect the rights, property, or safety of us, our clients, or others.
• To comply with legal obligations, respond to law enforcement requests, and as required by applicable law, court order, or government regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets.

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you.
• Whether there is a legal obligation to which we are subject.
• Whether retention is advisable considering our legal position (such as statutes of limitations, litigation, or regulatory investigations).

We collect and use Sensitive Personal Information (SPI) only as necessary to perform the services or provide the goods expected by an average consumer, or for other purposes authorized by the CPRA. We do not use or disclose SPI for purposes other than those specified in the CPRA.

You have the right to limit the use and disclosure of your SPI to those purposes authorized by the CPRA. To exercise this right, please contact us using the information provided in the "Contact Information" section.

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers
• Category B: California Customer Records personal information categories
• Category C: Protected classification characteristics under California or federal law
• Category D: Sensitive Personal Information (SPI)
• Category J: Professional or employment-related information

Important Note: We do not sell personal information for monetary consideration. We also do not share personal information for cross-context behavioral advertising purposes as defined under the CPRA.

The CCPA, as amended by the CPRA, provides California residents with specific rights regarding their personal information.

Right to Access and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose:

• The categories of personal information we collected about you
• The categories of sources for the personal information
• Our business or employment purpose for collecting or selling that personal information
• The categories of third parties with whom we share that personal information
• The specific pieces of personal information we collected about you (data portability request)

Right to Correct

You have the right to request that we correct any inaccurate personal information we maintain about you.

Right to Deletion

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. We may deny your deletion request if retaining the information is necessary to:

• Complete the transaction for which the personal information was collected
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity
• Debug to identify and repair errors
• Exercise free speech or ensure the right of another consumer to exercise their free speech rights
• Comply with the California Electronic Communications Privacy Act
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest
• Enable solely internal uses that are aligned with consumer expectations
• Comply with a legal obligation

Right to Non-Discrimination

We will not retaliate against you for exercising any of your rights under the CCPA. We will not:

• Deny your employment
• Charge you with different rates for services or deny benefits
• Provide you with a different level or quality of services

To exercise your rights to access, data portability, deletion, correction or to limit the use of your sensitive personal information, please submit a verifiable consumer request to us.

Request Requirements

Your verifiable consumer request must:

• Provide sufficient information that allows us to 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

Response Timing and Format

We endeavor to respond to a verifiable consumer 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.

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

Frequency of Requests

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on the company's ADP Intranet homepage.

If you have any questions or comments about this notice, our Privacy Statement, 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: