Notice for Job Applicants Residing in California

In compliance with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act, collectively California Privacy Laws, Listrak Inc. (“Listrak”) is providing you with this Notice for Job Applicants (“Notice”) to inform you about:

1. The categories and types of Personal Data Listrak collects about applicants who reside in California;
2. The purposes for which Listrak uses your Personal Data;
3. Sources of Your Personal Data;
4. How We May Disclose Your Personal Data; and
5. Listrak’s Retention Period for Personal Data.

“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular applicant.

Alternative formats of this Notice are available to individuals with a disability. Please contact hr@listrak.com for assistance.

Personal Data We Collect

In the course of applying for a position with Listrak, we may collect the following categories and types of Personal Data. Personal Data may be used for the following identified purposes during the application process, prior to onboarding as an employee:

Other Purposes Potentially Applicable to Any Categories of Personal Data Listed Above

Listrak may also use applicants’ Personal Data to facilitate administrative functions, information technology operations, corporate transactions, and for legal reasons. These functions may include:

• To manage litigation and other legal disputes and inquiries involving Listrak, and to meet legal and regulatory requirements;
• In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Listrak or any of its subsidiaries or affiliates; and
• To manage licenses, permits and authorizations applicable to Listrak’s business operations.

Information Provided About Other Individuals

If you provide us with Personal Data of a reference or any other individual as a part of your application, it is your responsibility to inform them of this Notice and obtain consent from that individual prior to providing the information to Listrak.

Sources of Your Personal Data

During the application process, Listrak may collect Personal Data about you from the following sources:

• You, for example, in your job application, forms you fill out for us, assessments you complete, surveys you complete, and any information you provide us during the course of your application and interview process.
• Vendors and service providers, for example, recruiters.
• Third parties, for example, job references, affiliated companies, professional employer organizations or staffing agencies.
• Public internet sources, for example, social media, job boards, public profiles, and other public online sources.
• Public records, for example, court records and credentialing and licensing organizations.
• Automated technologies on Listrak’s electronic resources, for example, to track logins and activity on Listrak’s careers page.
• Surveillance/recording technologies installed by Listrak, for example, video surveillance in common areas of Listrak facilities, voicemail technologies, webcams, and audio/video recording technologies with consent to the extent required by law.
• Government or administrative agencies, for example, law enforcement or public health authorities.
• Acquired companies, if Listrak acquired your employer, Listrak might collect Personal Data from that employer.

How We May Disclose Your Personal Data

On occasion, Listrak may have legitimate business need to disclose your Personal Data for one of the businesses purposes listed above. Listrak may disclose your Personal Data to the following:

• Service providers and contractors: Listrak discloses your Personal Data to service providers and subcontractors for the purposes above to assist us in our recruiting efforts and in meeting our business needs and legal obligations.
• Government or administrative agencies: These may include, for example:
  • Equal Employment Opportunity Commission as required for reporting.
  • California Department of Fair Employment and Housing as required to response to employment claims and charges.
  • Law enforcement in the event of criminal investigations.
• Required Disclosures: We may be required to disclose Personal Data in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
• Legal Compliance and Protections: We may disclose Personal Data when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Listrak, our clients, or others.

Listrak has not sold or shared Personal Data as defined or contemplated by the California Privacy Laws.

Retention Period

Listrak will retain Personal Data for the period necessary to fulfill the purposes outlined in this Notice and in accordance with our Records Retention Schedule unless a longer retention period is required or permitted by law. Please note, the information collected about you during the job application process may become part of your personnel file and may used to administer the employment relationship and for related reporting and recordkeeping purposes should you be hired by Listrak.

Changes to this Notice

As required by California Privacy Laws, Listrak will review and revise this Notice on an annual basis. Updates to this Notice will be posted on Listrak’s job applicant site.

Additional information regarding Listrak’s Privacy Policy may be found in the California supplement to the Listrak Employee Handbook.

California Consumer Privacy Rights

As a California Consumer, you have the following rights:

• Right to Know: California Consumers have a right to submit a verified request for information from Listrak regarding the specific pieces of Personal Data Listrak collects and discloses for business purposes about the consumer.
• Right to Delete: In certain circumstances, you have the right to submit a verified request asking we delete your Personal Data. Please note that the right to request deletion is subject to certain exceptions.
• Right to Correct Inaccurate Information: You have the right to submit a verifiable request for the correction of inaccurate Personal Data maintained by Listrak, taking into account the nature of the Personal Data and the purposes of processing the Personal Data.
• Right to Non-Discrimination: Listrak will not discriminate against California Consumers for exercising their rights under the CCPA.

Listrak does not offer financial incentives or price or service differences in exchange for the retention of a California Consumer’s Personal Data.

How to Submit a Verifiable Request

Listrak will respond to requests from California Consumers in accordance with California Privacy Laws if we can verify the identity of the individual submitting the request. California Consumers can exercise these rights by contacting (717) 625-6975or by email at hr@listrak.com. Listrak uses a tiered approach for verification of California Consumers. Listrak will match pieces of information contained in the request with information already held by the company. Where the request involves Sensitive Personal Data, more data points will be required to match information maintained by the company.

Please note, we may not be able to comply with your request if we are unable to confirm your identity or connect the information you submit in your request with Personal Data in our possession. Therefore, you should include information you have previously submitted to Listrak for the verification process. If we are unable to verify you, we may request additional information.

If you have questions on how to submit a verified request, please contact hr@listrak.com.

Authorized Agent

You may designate an Authorized Agent to submit a request to delete, request to correct, or a request to know on your behalf. For Listrak to respond to a request from an Authorized Agent, Listrak may:

• Request a copy of the written permission granting the Authorized Agent to make such a request on your behalf;
• Request confirmation from you that your authorized the agent to make the request on your behalf; or
• Request that you directly verify your own identity