RED VENTURES’ US EMPLOYEE PRIVACY NOTICE

This Privacy Policy (“Privacy Notice”) explains how Red Ventures, LLC and our Subsidiaries and Affiliates (“Red Ventures”, “us”, “our”, or “we”) collect, use, disclose, and/or retain Personal Information. This Notice applies to all current and former job applicants, employees, contractors, or other roles within our Company.

This Privacy Notice also serves as the Notice at Collection for California residents pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).

For purposes of this notice:

• The term “Employee” refers to all current and former employees, directors, officers, Board members, job applicants, temporary staff, interns, independent contractors, consultants, and benefits recipients of Red Ventures.
• The term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.The term “Sensitive Personal Information” means information revealing racial or ethnic origin, religious or philosophical beliefs, union membership, biometrics, health, sex life or sexual orientation.

What Personal Information Do We Collect, Use and Share About You?

Most often, the Personal Information, including Sensitive Personal Information, we collect from Employees is collected directly from you. In some cases, it is collected from third parties, for example, when we perform background checks. In most circumstances, we get your consent before we collect Personal Information about you from a third party. The table below includes each of the categories and types of Personal Information we collect from and about you, and the purpose for collecting it.

Categories of Personal Information	Purpose for Collecting Personal Information
Personal Identifiers, such as your name and the names of your spouse, partner, beneficiaries, and dependents. Contact details such as home address, telephone number, email addresses, social media handles, and emergency contact details. Employee identification number, photo, and Internet Protocol address. Insurance policy numbers and bank account numbers. Signature, education, employment, employment history, other financial information, medical information, or health insurance information. Information considered sensitive such as immigration status, social security number, any information on your government identification cards, and health information such as short/long-term disabilities, particularly in relation to a leave of absence.	We use your Personal Information, including Sensitive Personal Information, primarily for the purposes of managing our employment relationship with you, and for other business purposes such as: Applicant recruiting, conducting background and reference checks, and employee on-boarding; Administering payroll and independent contractor payment processing; Benefit administration, including equity-related plans and benefits; Time entry and leave management; Expense reimbursement and management; Establishing emergency contacts and responding to emergencies; Establishing internal directories, such as employee directories and facilitating; communication between and among the company workforce; Protecting our business through security and entry to premises, systems, and processes; Training, appraisal, development, performance, and disciplinary records; Employee and staff surveys; Equal opportunity and diversity monitoring; To comply with applicable laws and legal obligations such as employment, tax, and anti-discrimination laws.
Protected Classification Characteristics, such as your age, race, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability and sex (including gender, gender identity, gender expression), sexual orientation, pregnancy or childbirth and related medical conditions, veteran, or military status, all of which are considered sensitive personal information. This information is generally collected on a voluntary consensual basis, or where it is legally required.
Internet or other similar network activity, such as email sent or received on our network or on our equipment, browsing history, search history, and information on your interaction with a website, or application.
Geolocation Information, are data derived from your device by using satellite or cell phone tower signals or exchanges to locate you within a geographic area. Internet protocol address and Multi-Factor Authentication, for security purposes, which may indicate general location.
Audio or Visual Information, such as photos, videos, voicemail, meeting recordings, or security cameras.
Biometric Information, such as fingerprint or face for access to Red Ventures laptops (optional and collected with your consent) which is considered sensitive personal information.
Professional or Employment-Related Information, such as job application details such as academic and professional qualifications, education, CV/resume, and certifications. Employment details such as job title, work location, supervisor, work schedule and status, compensation information, benefit information, training and development information, employment duration, current or past job history, and performance evaluations.
Inferences drawn from other personal information to build a profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, and aptitudes.

We do not use or disclose the above Sensitive Personal Information for purposes other than those business purposes specifically permitted by law. As a result, we do not offer a right to limit our use or disclosure of these categories.

With Whom Do We Disclose Your Personal Information?

Your Personal Information may be provided to the following categories of persons who are engaged by us that need it to provide the services for which they have been engaged.

• Our Affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).
• Service providers and contractors that process your Personal Information on our behalf to establish, manage, or terminate your employment or services.
• Third parties at your direction to fulfill requests by you with your consent such as benefit and payroll providers.
• Third parties who provide specific services to us such as travel booking.
• Third parties in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition.
• Law enforcement and other third parties to address legal obligations.

How Long Do We Retain Your Personal Information?

We retain your Personal Information so long as it is reasonably necessary for the purpose for which it was collected, compliance with our legal obligations, resolution of disputes, fraud prevention, and enforcement of our agreements.

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

In some circumstances we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information.

Upon expiration of the applicable retention period, we will securely destroy your Personal Information in accordance with applicable laws and regulations.

Your Personal Information Rights (applicable to California employees)

This section describes your rights regarding your Personal Information, as applicable under US state law We do not discriminate against California Employees who exercise their rights described in this Privacy Notice.

Request to Access Your Personal Information (Right to Know)

You have the right to request that we provide you with the following information:

• The specific pieces of your Personal Information that we have collected about you;
• The categories of your Personal Information we have collected about you;
• The categories of sources from which your Personal Information is collected;
• The business or commercial purpose for collecting, disclosing, or selling your Personal Information; and
• The categories of third parties to whom the Personal Information was disclosed or sold for a business purpose.

Our responses to a request to know will provide Personal Information collected and maintained about you since January 1, 2022, unless doing so proves impossible or would involve a disproportionate effort. There may be scenarios where we deny your request. If that occurs, we will provide you with an explanation as to why we could not provide you with all or some of your Personal Information. Please note that we are not required to provide Personal Information to you more than twice in a 12-month period.

Request to Delete Your Personal Information (Right to Request Deletion)

You have the right to request that we delete your Personal Information, under certain circumstances, subject to several exceptions. There may be scenarios where we deny your deletion request. If that occurs, we will provide you with an explanation as to why we could not delete all or some of your Personal Information.

Request to Correct Your Personal Information (Right to Request Correction)

You have the right to request correction of inaccurate Personal Information maintained by us. If you have an active account, you may make the corrections yourself. Otherwise, when we receive and confirm your request, we will correct, and direct our service providers to correct, your Personal Information in our records. As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under law, or if we determine that the contested information is more likely than not accurate, based on the totality of circumstances.

How to Submit a Request

What to Expect When you Submit a Request

We use reasonable measures to detect fraudulent requests and prevent unauthorized access to your Personal Information. To meet our obligations, we are required to verify your identity. We may need to contact you about your request, and you can choose the contact method you would like us to use.

You may designate, in writing or through a power of attorney an authorized agent to make requests on your behalf related to your Personal Information. If you use an authorized agent to submit a request, we require the agent to provide proof they are authorized to act on your behalf by submitting their registration with the California Secretary of State as well as proof that you gave the authorized agent written permission.

We will process your request within 45 days or notify you if we require additional information, require an extension, or if the request will be denied. If we require additional time beyond 45 days, we will inform you of the reason and the extension period.

Changes to this Privacy Notice

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 post the updated notice on this page and update the Notice’s effective date. Your continued use of our Redventures.com website to apply for a job and your Red Ventures accounts following the posting of changes constitutes your acceptance of such changes.

Questions