Last Revised: January 1, 2023

1. Introduction

Snappy App, Inc. and its subsidiaries and its affiliates (“Snappy,” "us", "we," "our" and/or "Company") has issued this California Privacy Notice (this "Notice") to describe how we handlePersonal Information that we collect and process about our Staff Members and job applicants who are residents of California (collectively referred to as "you") and applying for a job at or working for Company in the United States. The term "Staff Member" includes employees and independent contractors, including contingent workers, temporary workers, and interns. This categorization is for convenience and does not demonstrate or establish any particular employee, contractor or other status.We respect the privacy rights of individuals and are committed to handling Personal Information(defined in Section 2 below) responsibly and in accordance with applicable law. This Notice sets out the Personal Information that we collect and process about you, the purposes of the processing and the rights that you have in connection with it. The California Consumer PrivacyAct of 2018, including the California Privacy Rights Act of 2020 and any regulations promulgated thereunder (“CCPA”), provides California residents with specific rights regarding theirInformation. This Notice, which applies only to California residents, describes your rights under the CCPA, explains how you may exercise your rights, and provides an overview on the types of Personal Information we collect.Please take the time to read and understand this Notice, which should be read in conjunction with our other corporate policies and procedures. When appropriate, we will provide a “just in time” notice or notice at collection to cover any additional processing activities not mentioned in this document. This Notice does not apply to any Personal Information that we may collect if you use the Snappy gift-giving platform to send or receive gifts, and you should instead consult theSnappy Privacy Policy for further information about our data practices in relation to the Snappy gift-giving platform.If you have any comments or questions about this Notice, please contact us at the contact details in Section 11 below.

2. Types of Personal Information we collect

The CCPA defines “Personal Information” as information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Data that has been de-identified, anonymized, or aggregated, or that otherwise cannot reasonably be related back to a specific person, is not considered Personal Information.In the course of your employment or engagement with Company, or when making an application for employment or engagement with Company, we may process Personal Information about you and your dependents, beneficiaries and other individuals whose Personal Information has been provided to usThe types of Personal Information we may process include, but are not limited to:

• Identification data – such as your name, gender, photograph, date of birth, Staff Member IDs.
• Contact details – such as home and business address, telephone/email addresses, emergency contact details.
• Employment details – such as job title/position, office location, employment contract, performance and disciplinary records, grievance procedures, sickness/time-off records.
• Background information – such as academic/professional qualifications, education,CV/résumé, criminal records data (for vetting purposes, where permissible and in accordance with applicable law).
• Government identifiers – such as government issued ID/passport, immigration/visa status, or social security numbers.
• Information on your spouse/partner and/or dependents – such as your marital status, identification and contact data about them and information relevant to any Company benefits extended to such people.
• Financial information – such as bank details, tax information, withholdings, salary, benefits, expenses, company allowances, stock and equity grants.
• IT information – information required to provide access to company IT systems and networks(and information collected by / through those systems) such as IP addresses, log files and login information.

Personal Information that we process may also include Sensitive Personal Information. TheCCPA’s definition of Sensitive Personal information includes social security, driver’s license, state ID, or passport number; racial or ethnic origin; union membership; biometric information; and personal information concerning health, sex life, or sexual orientation ("Sensitive Personal Information"). We may also process Sensitive Personal Information relating to you (and your spouse/partner and/or dependents) for the purposes set forth in this Notice.‍We may need to collect, or request on a voluntary disclosure basis (or involuntarily, if required by applicable law), some Sensitive Personal Information for legitimate employment-related purposes: for example, information about your racial/ethnic origin and gender for equal employment opportunity reporting purposes (in accordance with applicable law); or information about your physical or mental condition to provide work-related accommodations, health and insurance benefits to you and your dependents, or to manage absences from work.

3. Sources of Personal Information

Generally, you will have provided the information we hold about you, but there may be situations where we collect Personal Information or Sensitive Personal Information from other sources. For example, we may collect the following:

• Certain background and other information from recruitment agencies, academic institutions, referees, background checking agencies and other third parties during your recruitment and/or employment/engagement.
• Certain information on your performance, conduct or other information relevant to formal internal procedures (e.g., disciplinary or whistleblowing procedures), from clients or other organizations with whom you work.
• Information on your training and development from external training partners and information about your experience and impressions of Company through external survey providers.
• Information about your health, including your fitness to carry out work and/or any accommodations or adjustments to be considered from a health care provider (as permitted by applicable law).