NOTICE TO CALIFORNIA APPLICANTS

The California Privacy Notice is effective as of March 11, 2024

This notice applies only to California residents who are applying for a position with American Financial Integrity of California, Inc. and/or any of its affiliated entities (collectively, the "Company") as an employee or independent contractor ("California Applicants"). This California Applicant Privacy Notice sets forth the disclosures and rights for California Applicants regarding their Personal Information, as required by the California Consumer Privacy Act of 2018 ("CCPA") as amended by the California Privacy Rights Act of 2020, and any implementing regulations adopted thereunder. Terms (including defined capitalized terms) used in this California Applicant Privacy Notice have the same meanings given in the CCPA and the associated regulations, unless otherwise defined.

The California Applicant Privacy Notice covers “Personal Information” collected from California Applicants. When we refer to “Personal Information,” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or is otherwise defined or regulated as personal information under California law. Note that we may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code (“hash”). We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification process satisfies legal requirements. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.

EXERCISING YOUR CALIFORNIA RIGHTS

California Applicants have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you ("Right to Know"); (2) that we delete the Personal Information we collect from you ("Right to Delete"); (3) that we correct inaccurate Personal Information we hold about you ("Right to Correct"), all subject to the meanings and exceptions set forth in the CCPA. More information on each of these rights is below.

Verifying Your Requests

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. We may ask you to log in to your applicant portal account. We may also ask that you provide us with information, beyond your full name, in order to verify your identity and fulfill your request. We will only use any such information to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.

Authorized Agents

If you are an authorized representative submitting a request on a California Applicant's behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf.

The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may, but are not required, to submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer's identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the California Applicant to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the California Applicant's behalf, we may deny the request.

Right to Know, Delete, and Correct

To exercise your Right to Know, Delete, or Correct please submit your request by emailing us at employeerelations@pls247.com and include the type of request you would like to exercise (Know, Delete, and/or Correct) or by calling us at 833-665-0018.

In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the California Applicant whose Personal Information is the subject of the request. We will not provide you specific pieces of information that include the Personal Information of other persons, nor will we disclose certain pieces of information that the law requires us not to or that we determine is a high security risk, including your social security number, driver's license number, financial account number, health insurance or medical information number, account passwords, security questions and answers, or unique biometric data, as applicable.

Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.

Right to Limit the Use and Disclosure of Sensitive Personal Information

As disclosed in the chart below, we may collect certain information in connection with your application for a position with us that is considered Sensitive Personal Information under California law. Under the CCPA, a business must only provide the Right to Limit the Use and Disclosure of Sensitive Personal Information when sensitive personal information is collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions, pursuant to California Civil Code § 1798.121. Our use and disclosure of applicants' Sensitive Personal Information is not used for such purposes and/or falls within this list of exceptions and we therefore do not offer such opt-out right at this time.

Do Not Sell or Share

Company does not sell, or share for cross-context behavioral advertising, the Personal Information or Sensitive Personal Information of its applicants.

Data Retention

We will retain all categories of personal information described in this California Privacy Notice in line with our internal data retention practices, considering the time period reasonably necessary to: process your application; exercise the choices and rights you have requested; comply with our contractual obligation; and comply with legal and regulatory requirements. If you are offered and accept a job with Company, the Personal Information we collected during the application and recruitment process will become part of your personnel record, and we may use it in connection with your working relationship with Company consistent with our personnel privacy policy.

In determining how long we retain your Personal Information, we take into account our legal and regulatory obligations (such as legal requirements to retain your information, financial reporting obligations, and equal opportunity or anti-discrimination reporting obligations), the nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, and whether we may need to retain the Personal Information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes and/or enforce our agreements.

Security of Your Personal Information

We have adopted commercially reasonable security procedures and practices designed to protect your Personal Information in our possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction. You are also responsible for preventing unauthorized access to your Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have accessed your account.

Applicants Younger than 18

Company does not hire employees younger than 18 years of age. We therefore do not knowingly sell, or share for cross-context behavioral advertising the Personal Information of applicants younger than 18 years of age.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

California Applicants have the right to not receive discriminatory treatment for exercising their CCPA rights. We will not discriminate against you for exercising your CCPA rights.

Changes to this Policy

To the extent allowed by applicable law, we reserve the right to change this policy at any time without prior notice. If we make material changes to our policy, we will update the effective date and post a notice to our online website and applicant portals where this policy is displayed. We may also provide notice to you in other ways, such as through contact information you have provided, and provide you with the ability to opt-in or opt-out of the changes as required by law.

PERSONAL INFORMATION WE COLLECT

The Personal Information we collect about you will depend upon your application, how you interact with us, and how your application progresses through our hiring process. Accordingly, we may not collect all of the below information about you.

In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA.

Category of Personal Information Collected Categories of Sources from which the Information was Collected Business or Commercial Purpose(s) for which Information is Collected Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose
Identifiers

We may collect this type of information from:

  • You;
  • Other Company employees;
  • Cookies and Tracking Technologies;
  • Third party applicant portals and similar business partners.

We may use this type of information for:

  • Collect and process employment applications, including confirming eligibility and qualifications for employment, background and related checks, as necessary.
  • Process employee referrals;
  • Communication with you;
  • Design, implement, and promote the commitment to diversity and inclusion;
  • Compliance with legal obligations, including health and safety requirements, requests for information from government agencies, and security investigations

We may disclose this type of information to:

  • Service Providers;
  • Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition;
  • Third parties or affiliated companies when you agree to or direct that we share your information with them;
  • Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).
Professional or Employment Information
(for example, information you provide to us during the recruitment process, such as information from your resume)

We may collect this type of information from:

  • You;
  • Other Company employees;
  • Cookies and Tracking Technologies;
  • Third party applicant portals and similar business partners.

We may use this type of information for:

  • Collect and process employment applications, including confirming eligibility and qualifications for employment, background and related checks, as necessary.
  • Communication with you;
  • Statistical and analytical purposes;
  • Compliance with legal obligations, including health and safety requirements, requests for information from government agencies, and security investigations

We may disclose this type of information to:

  • Service Providers;
  • Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition;
  • Third parties or affiliated companies when you agree to or direct that we share your information with them;
  • Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).
Education Information

We may collect this type of information from:

  • You;
  • Cookies and Tracking Technologies;
  • Third party applicant portals and similar business partners.

We may use this type of information for:

  • Collect and process employment applications, including confirming eligibility and qualifications for employment, background and related checks, as necessary.
  • Statistical and analytical purposes;
  • Compliance with legal obligations, including health and safety requirements, requests for information from government agencies, and security investigations

We may disclose this type of information to:

  • Service Providers;
  • Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition;
  • Third parties or affiliated companies when you agree to or direct that we share your information with them;
  • Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).
Audio or Visual Information
(for example, your photograph if submitted as part of your resume)

We may collect this type of information from:

  • You;
  • Third party applicant portals and similar business partners.

We may use this type of information for:

  • Collect and process employment applications, including confirming eligibility and qualifications for employment, background and related checks, as necessary.
  • Compliance with legal obligations, including health and safety requirements, requests for information from government agencies, and security investigations

We may disclose this type of information to:

  • Service Providers;
  • Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition;
  • Third parties or affiliated companies when you agree to or direct that we share your information with them;
  • Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).
Internet or other electronic network activity information

We may collect this type of information from:

  • Cookies and tracking technologies;
  • Third-party career portals and other business partners

We may use this type of information to:

  • Administer our applications, software, and systems;
  • Prevent fraud and enforce Company policies;
  • Run analytics and for other statistical purposes;
  • Comply with legal obligations, including health and safety requirements, requests for information from government agencies, and security investigations

We may disclose this type of information to:

  • Service Providers;
  • Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition;
  • Third parties or affiliated companies when you agree to or direct that we share your information with them;
  • Other third parties (including government agencies) as required by law or in connection with court proceedings.
Inferences drawn from any of the information identified above to create a profile about You

We may draw these inferences ourselves.

We may use this type of information for:

  • Collect and process employment applications, including confirming eligibility and qualifications for employment, background and related checks, as necessary.
  • Design, implement, and promote the commitment to diversity and inclusion;
  • Statistical and analytical purposes

We may disclose this type of information to:

  • Service Providers;
  • Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition;
  • Third parties or affiliated companies when you agree to or direct that we share your information with them;
  • Other third parties (including government agencies) as required by law or in connection with court proceedings.
Sensitive Personal Information

We may collect the following information:

  • Identification numbers such as your social security number, driver's license number or passport number;
  • Your citizenship or immigration status;
  • Information concerning health (such as symptoms, tests results, and other indicators of exposure to COVID-19, vaccination information, fitness for duty, drug test reports, leave of absence information)

We may collect this type of information from:

  • You
  • Service Providers

We may use this type of information for:

  • Compliance with our legal obligations, including reporting obligations to and other requests for information from government agencies.

We may disclose this type of information to:

  • Service Providers (including our background check vendors and tax vendors);
  • Third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders);
  • Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition.