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Effective Date: 12/31/2022

Privacy Notice for California Employees and Applicants

Coalition, Inc., a Delaware corporation, on behalf of itself, and any of its current and future subsidiaries and affiliates (“Company” or “We”) respects your privacy. This Privacy Notice for California Employees and Applicants (“Privacy Notice” or “Notice”) describes the types of personal information we collect about California residents who are (1) Company employees, applicants, owners, directors, officers, medical staff members and contractors (collectively, “Company Personnel”), (2) emergency contacts of Company Personnel, and (3) individuals related to Company Personnel for whom Company administers benefits (collectively with Company Personnel, “Covered Individuals”).

Company Personnel are responsible for providing this Privacy Notice to any Covered Individual whose personal information is provided to Company by our personnel. Certain terms used in this Notice have the meanings given to them in the California Consumer Privacy Act of 2018, as amended including by the California Privacy Rights Act of 2020, and its implementing regulations (the “CCPA”).

Personal Information We Collect

Company may collect the following categories of personal information about Covered Individuals:

  • Identifiers: identifiers, such as a real name, alias, postal address, unique personal identifier (e.g., a device identifier, employee number, unique pseudonym, or user alias/ID), telephone number, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, date of birth, and other similar identifiers, signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number and debit card number, and other financial information, medical information, and health insurance information

  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status

  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites or applications

  • Geolocation Data

  • Sensory Information: audio, electronic, visual, and similar information

  • Employment Information: professional or employment-related information, such as compensation, benefits and payroll information (e.g., salary-related information, tax-related information, benefits elections and details regarding leaves of absence), information relating to your position (e.g., job title and job description), performance-related information (e.g., evaluations and training), talent management information (e.g., resumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information), emergency contact information, and dependent information

  • Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)

  • Other Information: any other information you voluntarily provide to the Company

How We Use the Personal Information

We use personal information for the purpose of carrying out and supporting the Company’s Human Resources team’s (“HR”) functions and activities, including the uses described below. In addition to general HR purposes, the Purpose column also lists relevant “business purposes” as they are described in the CCPA or other commercial purposes. The Categories of Personal Information column identifies the categories of personal information that are used for each purpose.

Purposes

Categories of Personal Information

Managing work activities and personnel generally, including recruiting; performing background checks; determining suitability for employment or promotion; determining physical and/or mental fitness for work; reviewing and evaluating performance; determining eligibility for and processing salary increases, bonuses, and other incentive-based compensation; providing references; managing attendance, absences, leaves of absences, and vacations; administering payroll services; reimbursing expenses; administering health, dental, and other benefits; training and development; making travel arrangements; securing immigration statuses; monitoring staff; creating staff directories; investigating suspected misconduct or non-performance of duties; managing disciplinary matters, grievances, and terminations; reviewing staffing decisions; and providing access to facilities

Identifiers; Protected Classifications; Online Identifiers; Additional Data Subject to Cal. Civ. Activity; Geolocation Data; Sensory Information; Employment Information; Education Information

Ensuring business continuity; protecting the health and safety of our staff and others; safeguarding, monitoring, and maintaining our IT infrastructure, office equipment, facilities,

and other property; detecting or preventing theft or fraud, or attempted theft or fraud; and facilitating communication with you and your designated contacts in an emergency

Identifiers; Protected Classifications; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information

Operating and managing our IT, communications systems and facilities, and monitoring the use of these resources; performing data analytics; improving our services; allocating and managing company assets and human resources; strategic planning; project management; compiling audit trails and other reporting tools; maintaining records relating to business activities, budgeting, and financial management; managing mergers, acquisitions, sales, reorganizations or disposals and integration with business partners

Identifiers; Online Activity; Geolocation Data;

Complying with legal requirements, such as tax, record-keeping and reporting obligations; conducting audits, management and resolution of health and safety matters; complying with requests from government or other public authorities; responding to legal process such as subpoenas and court orders; pursuing legal rights and remedies; defending litigation and managing internal complaints or claims; conducting investigations; and complying with internal policies and procedures

Identifiers; Protected Classifications; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information

Performing services

Identifiers; Protected Classifications; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information

Auditing related to a current interaction with you and concurrent transactions

Identifiers; Protected Classifications; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information

Certain short-term, transient uses

Identifiers; Protected Classifications; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

Identifiers; Protected Classifications; Online Activity; Geolocation Data; Employment Information; Education Information

Debugging to identify and repair errors that impair existing intended functionality

Identifiers; Online Activity; Geolocation Data

Undertaking internal research for technological development and demonstration

Identifiers; Online Activity; Geolocation Data

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

Identifiers; Online Activity; Geolocation Data

Disclosure of Personal Information

We disclose all of the categories of personal information that we collect to the following categories of recipients:

  • Payroll and benefit providers.

  • Information technology vendors.

  • Government and law enforcement.

  • Affiliates.

  • Charitable Donation Recipients.

Sources of Personal Information

We may have obtained personal information about you from the following categories of sources:

  • Directly from you, such as when you contact us with a question.

  • From your devices.

  • Your family or friends, such as when they designate you as emergency contacts or beneficiaries.

  • Our affiliates and subsidiaries.

  • Government agencies.

  • Vendors who provide services on our behalf.

  • Online advertising services and advertising networks.

Privacy Rights

Please know that the privacy rights outlined below exercised in your role as a Covered Individual are subject to significant exceptions. We will respond to every request according to applicable law and will not retaliate or discriminate against for exercising any of your privacy rights.

  • Know: You have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.

  • Deletion: You have the right to request that we delete certain personal information we have collected from you.

  • Correct: You have the right to correct inaccurate personal information that we maintain about you.

  • Opt-Out of Sale or Share: We do not sell or share information about you in your role as a Covered Individual.

  • Limit Use and Disclosure of Sensitive Personal Information: We do not use any sensitive information about you, in your role as a Covered Individual except to facilitate the employment relationship and other compatible uses.

How Long We Retain Information

We keep personal information for specified periods of time, depending on business needs, privacy interests and the law. As a general matter, we only retain personal information for as long as it is needed or useful for accomplishing a business, legal or tax purpose. After such period, the data is deleted or fully anonymized. Personal information collected about you as a Covered Individual is generally retained while we have a relationship with you plus a period of no more than 10 years after the term of your employment, except when the retention of the data is necessary to enforce or defend our rights or comply with law.

How To Contact Us or Submit a Request

If you have any questions regarding this Privacy Notice or our privacy practices, please contact us toll-free at (302) 280-8820 or privacy@coalitioninc.comto submit a request.

Authorized Agents

You may designate an authorized agent to submit requests on your behalf. To submit a request as an authorized agent on behalf of a consumer, please contact us as described above.

Verifying Requests

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: first name, last name, month & year of birth, email address, mailing address. If you designate an authorized agent to make a request on your behalf (a) we may require

you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).