Applicant CCPA Notice

CALIFORNIA APPLICANT PRIVACY NOTICE

Effective date: Jan 1, 2025

This California Employee Privacy Notice (the “CA Employee Notice”) explains how the Transform Holdco LLC family of companies (“Transformco,” “our,” “we,” or “us”) Collects, uses, and discloses the Personal Information of California employees, and others who work for us (collectively, “Associates”. In this CA Employee Notice, we use the word “you” or “your” to refer to anyone within the scope of this CA Employee Notice.

As used in this CA Employee Notice, 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 an individual or household. Personal Information does not include information that is publicly available, deidentified, or aggregated. Capitalized terms defined in the CCPA that are used in this California Notice shall have the same meaning as in the CCPA.

Unless otherwise noted, the disclosures contained within this CA Employee Notice cover our activities in the prior 12 months from the effective date, as well as our current practices.

1. How and Why We Collect Your Personal Information

General Personal Information

We Collect, use and disclose Personal Information about our Associates as follows (whether we Collected a specific category of Personal Information depends on the nature of your interaction with us):

Category of Personal Information	Purposes for Collection, Use, and Disclosure
Identifiers including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers	To communicate with you To open and maintain employee records To assess your eligibility for employment To onboard and enroll you as an employee To provide compensation and benefits To comply with applicable laws and regulations To manage the security of our premises and systems
Personal Information described in Cal. Civ. Code § 1798.80(e), including your Identifiers listed above, signature, social security number, passport number, driver’s license or state identification card number, and financial information	To communicate with you To assess your eligibility for employment To open and maintain employee records To onboard and enroll you as an employee To provide compensation and benefits To comply with applicable laws and regulations To manage the security of our premises and systems
Characteristics of protected classifications under California or federal law, including but not limited to age and date of birth, marital status, race, ethnic origin, sex, gender, sexual orientation, gender identity, military or veteran status, and disability.	To comply with applicable laws and regulations To comply with U.S. Equal Employment Opportunity Commission (“EEOC”) and California Civil Rights Agency (“CCRA”) requirements, and other equal opportunity initiatives
Commercial information, including products or services purchased	To reimburse you if you have job-related expenses and seek reimbursement
Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, systems, and applications	To manage corporate information technology To monitor your compliance with our internal policies and procedures For business improvement, management, and planning To investigate security breaches and misuse of computer equipment and systems To manage the security of our premises and systems To detect and prevent fraud against you and/or us
Geolocation data, including access-control data based on employee badge swipes and location data inferred from your device IP address We may Collect precise geolocation data from certain Transformco-owned vehicles. For more information, please see the Notice Regarding Monitoring which can be found in the TechHub Help File	To manage corporate information technology To manage the security of our premises and systems To monitor your compliance with our internal policies and procedures
Audio, electronic, visual, or similar sensory information, including closed-circuit , photographs and video or audio recordings of you (for example if you answer phone calls on a recorded line) We may Collect video recordings when you are operating a Transformco-owned vehicle. For more information, please see the Notice Regarding Monitoring which can be found in the TechHub Help File	To manage job duties, evaluate performance, and operate our business To authenticate your identity To manage the security of our premises and systems To monitor your compliance with our internal policies and procedures
Professional or employment-related information, including: Recruitment information (such as skills, qualifications, references, recommendations, languages spoken, and other information included in a resume, application form, or cover letter) Background information commonly used for onboarding and security screenings, including citizenship, immigration, visa status, and work authorization information and criminal records information Motor vehicle checks and drug screening	To manage job duties, evaluate performance, and operate our business To provide compensation and benefits To comply with applicable laws and regulations To assess your eligibility for employment

Sensitive Personal Information

Sensitive Personal Information is a type of Personal Information. We Collect the following categories of Sensitive Personal Information about our Associates (whether we Collected a specific category of information depends on the nature of your interaction with us):

Precise geolocation to determine your location and movements while you are in a Transformco-owned service vehicle in order to ensure the safety and security of our services and technicians, to ensure technicians are obeying traffic laws, and to verify route information

We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

2. Sources of Personal Information

We Collect the Personal Information identified above from the following sources (whether we Collect information from a specific source depends on the nature of your interaction with us):

Directly from you. We Collect information from you during the onboarding process and throughout your interactions with us as Associates, including through our information technology systems, through technology utilized in Transformco-owned vehicles, and through our forms and processes where Associates submit information to us (e.g., expense reports, pre-employment forms, and surveys.)
Automatically when using our systems. We Collected information about you when you used our information technology services and when you accessed our facilities (e.g., video surveillance information).
Created by us. We Collected information about you that we created, such as credentials for access to our information technology systems.
Service Providers. We Collected information about you from certain Service Providers that provide information to help us run our business.
Affiliates. We disclose Personal Information among the companies within the Transformco family of companies and affiliates. We receive information to enable us to manage our business and workforce.
Other parties. We may have received information about you from other parties when necessary to manage or operate our business or to offer benefits to you.
Parties to corporate transactions. As permitted by law, we may receive Personal Information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of a business or assets.

3. Disclosures of California Employee Personal Information

We have not Sold or Shared for cross-context behavioral advertising the Personal Information of California Associates that we Collect in the context of your work with us. If you also interact with us as a Consumer, please review our California Consumer Privacy Notice here for more information about our practices in that context.

We disclosed the Personal Information described in this CA Employee Notice to Service Providers that help us run our business, manage and administer benefits, and manage our human resources activities.

We have also disclosed, or may disclose in the future, the Personal Information described in this CA Employee Notice in other circumstances when required to or permitted by law. These circumstances include:

disclosures among the companies within the Transformco family of companies and affiliates, when permitted by law, to manage employee relationships, benefits, pay and compensation, and other human resources services across the Transformco family of companies and affiliates
disclosures to provide products or services requested by Associates
disclosures required or permitted by law to defend against legal claims
to law enforcement agencies, courts, regulatory agencies and others when the disclosure is required or permitted by law, including to comply with valid legal process and
as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of our business or assets.

4. How Long We Keep Your Personal Information

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information (which includes the categories of Personal Information set forth in the charts and sections above) for as long as necessary to fulfill the purposes we Collected it for, as required to satisfy any legal, obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes we process your Personal Information for, and whether we can achieve those purposes through other means. For certain types of Personal Information we will only maintain it for a limited duration. Where Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

5. Submitting Requests Relating to Your Personal Information

You may access or correct certain Personal Information by logging into MPI and accessing your profile or account settings. You may also contact your HR representative to request access to your personnel file.

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request by calling us at 1 888-527-6415 or by email at HRCMPLY@transformco.com. Please note that, if you submit a request to know, request to delete or request to correct, you will be asked to verify your identity. You may designate an authorized agent to make a request on your behalf however, you may still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the toll-free number or email listed above.

Right to Know. You have the right to know what Personal Information we have Collected about you, which includes:

The categories of Personal Information we have Collected about you, including
1. The categories of sources from which the Personal Information was Collected
2. Our Business Purposes for Collecting Personal Information
3. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information
The specific pieces of Personal Information we have Collected about you

Right to Delete Your Personal Information. You have the right to request that we delete certain Personal Information we Collected from you, subject to certain exceptions.

Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Opt Out of Sales and Sharing of Personal Information. We do not Sell or Associate Personal Information and, therefore, we do not offer a way for you to submit such a request.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the permitted Business Purposes. For this reason, we do not treat the Sensitive Personal Information we Collect as subject to a limit use of Sensitive Personal Information request and, therefore, we do not offer a way for you to submit such a request.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate against you if you choose to exercise any of the privacy rights described above.

6. How to Contact Us

If you have any questions about how we handle your Personal Information or if you need to access this CA Employee Notice in an alternative format, please contact: HR Policy & Compliance, hrpc@transformco.com.

This CA Employee Notice is not a contract of employment and does not provide contractual rights or obligations.