AS Solution (“we,” “our” or “us”) California Applicant Privacy Notice

PURPOSE OF THIS NOTICE: This California Applicant Privacy Notice (the “Notice”) describes how we collect and use certain personal information relating to job applicants and candidates for positions with us who are California residents (“Applicants”). This Notice is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”). We may provide Applicants additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check or extend an employment offer).

SCOPE OF THIS NOTICE: This Notice applies to the personal information that we collect from and about Applicants, for reviewing, assessing, considering, managing, storing or processing their applications or otherwise considering them for a position with us.

What is personal information? In this Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

Are our practices the same for all Applicants? The categories of personal information we collect and our use of personal information may vary depending upon the position for which you are applying.

CATEGORIES OF PERSONAL INFORMATION COLLECTED: Generally, we may collect the following categories of personal information about Applicants:

  • Name, Contact Info and other Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier, telephone number, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
  • Protected Classifications: characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
  • Audio/Visual Data: audio, electronic, visual, thermal, olfactory, or similar information such as CCTV images and photographs, and audio recordings (e.g., recorded meetings/interviews).
  • Employment History: professional or employment-related information.
  • Education Information: information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
  • Profiles and Inferences: inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Biometric Information: In some instances, we collect fingerprints, which may be considered biometric information.
  • Usage Data: internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.
  • Geolocation Data: precise geographic location information about a particular individual or device. PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION: Generally, we

    may use the above categories of personal information for the following purposes:

• Management of Job Applications, Recruiting and Hiring. To review, assess, recruit, consider or otherwise manage applicants, candidates and job applications, including:
o Schedulingandconductinginterviews
o Identifying candidates, including by working with external recruiters

o Reviewing, assessing and verifying information provided; to conduct criminal and background checks; and to otherwise screen or evaluate an Applicant’s qualifications, suitability and relevant characteristics

o Extending offers, negotiating the terms of offers, and assessing salary and compensation matters

o Satisfying legal and regulatory obligations
o CommunicatingwithApplicantsregardingtheirapplicationsandaboutothersimilarposition(s)

for which they may be interested
o MaintainingApplicantpersonalinformationforfutureconsideration o Supporting our equal opportunity employment policy and practices

• Security and Monitoring. To monitor and secure our resources, network, premises and assets, including:

o Monitoringfor,preventing,andinvestigatingsuspectedorallegedmisconductorviolationsof work rules

o Monitoring for, preventing, investigating and responding to security and privacy incidents
o Providing and managing access to physical and technical access controls
o Monitoringactivities,accessandusetoensurethesecurityandfunctioningofoursystemsand

o Securing our offices, premises and physical assets, including through the use of electronic

access systems and video monitoring

  • Auditing, reporting corporate governance, and internal operations. Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administering our records retention program.
  • M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions, such as mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions.
  • Defending and Protecting Rights. To protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
  • Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions, and guidance.

    CONTACTING US ABOUT THIS NOTICE: If you have any questions or concerns regarding our use of personal information as described in this Notice, please contact

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