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California Candidate Privacy Notice Regarding Use of Personal Information

May 9, 2023

As your prospective employer, Material Security, Inc. (“Material,” “We,” “Us,” or “Our”) collects, uses and discloses personal information (“Personal Information”) relating to you (“You” or “Your”) for employment-related purposes both before, during, and after Our consideration of Your candidacy for employment with Material. We are committed to ensuring that Your Personal Information will be handled in accordance with all applicable data privacy laws. Data privacy laws generally require that individuals be informed of (and, under certain circumstances, consent to) the processing of their Personal Information and of sharing of the information with third parties for employment-related business purposes. This California Candidate Privacy Notice (“Notice”) is intended to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, effective January 1, 2023 (collectively the “CPRA”) and applies solely to employment candidates who reside in the State of California (“Job Candidate(s)”).

Personal Information We Collect:

This section sets forth the categories of Personal Information We may collect about You when You inquire about and/or apply for employment at Material. In particular, We have collected the following categories of Personal Information in the preceding twelve (12) months from one or more Job Candidates:

Personal Identifiers, such as name, date of birth, government identification information such as driver’s license number or other identification card number, postal address, email address, and personal contact details.
Personal Information Categories listed in California Customer Records Statute, such as name, address, telephone number, personal financial information (e.g., bank account and routing number for the purpose of direct deposit), health insurance information, which may include emergency contact details and family information including beneficiary and dependent details, and educational background or employment history (including references, work history and proof of work eligibility). Some Personal Information included in this category may overlap with other categories listed in this Notice.
Characteristics of protected classifications or sensitive Personal Information under California or federal law, such as gender, information about Your citizenship and/or nationality, Union membership, medical or health information and/or Your racial or ethnic origin.
Professional or employment-related information, such as salary and benefits-related information, information held for employment-law and health and safety purposes, management or organizational assessments.
Publicly Available and Assessment information, such as Your information from publicly available sources, including online, that We believe is relevant to Your application or a potential future application (e.g. Your LinkedIn profile); and/or information related to any assessment You may take as part of the interview screening process.

Sources of Personal Information

We collect Personal Information about You from a variety of sources, including:

Personal Information You provide to Us directly;
Personal Information from public sources (such as public social media profiles on LinkedIn); and/or
Personal Information from other third parties (such as prior employers, professional references, pre-employment and background check services).

We may combine information that We receive from the various sources described in this Notice, including third party sources and public sources, and use or disclose it for the purposes set forth in this Notice.

How We Use Your Personal Information

Your information will be used by Material for the purposes of carrying out its application and recruitment process which includes:

Assessing Your skills, qualifications and interests with respect to career opportunities at Material;
Verifying Your information and carrying out reference checks and/or conducting background checks (where applicable) if You are offered a role with Us;
Communications with You about the recruitment process and/or Your application(s), including, in appropriate cases, informing You of other potential career opportunities at Material;
Creating and/or submitting reports as required under any local laws and/or regulations, where applicable;
Where requested by You, assisting You with obtaining an immigration visa or work permit where required;
Making improvements to Material’s application and/or recruitment process including improving diversity in recruitment practices;
Complying with applicable laws, regulations, legal processes or enforceable governmental requests; and/or,
Proactively conducting research about Your educational and professional background and skills and contacting You if We think You would be suitable for a role with Us.
As part of Our commitment to equal opportunity employment, We may process information regarding Your membership in various organizations to support Our diversity and inclusion efforts. This may include associating participant membership with sensitive and/or demographic information.

We will also use Your information to protect the rights and property of Material, Our customers, applicants, candidates, employees or the public as required or permitted by law.

If You are offered and accept employment with Material, the information collected during the application and recruitment process will become part of Your employment record.

Sharing Personal Information of Job Candidates

We share Your Personal Information within Material as part of Our regular reporting activities on Our performance, in the context of a business reorganization, for system maintenance support and hosting of data.

We may disclose Your Personal Information to third parties, including third party service providers rendering services on Material’s behalf. Common examples of third party service providers are payroll processors, recruiting services vendors and platforms, and companies providing other support services to Material with respect to employment with Material. We also may send Your Personal Information to companies We have contracted with to operate various information systems or to process certain transactions (e.g., payroll services providers, background check service providers, and cloud storage providers).

We will also share Your Personal Information with other third parties if We have Your consent (for example if You have given Us permission to contact Your references), or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of Material, Our customers, applicants, candidates, employees or the public or as otherwise required by law.

We may share Your Personal Information with regulatory authorities (including tax authorities), government agencies, parties (including Material’s legal or other advisors) in legal proceedings involving Material or, potentially, third parties with whom Material may merge with or acquire in future. These third parties and Material entities may be located in jurisdictions whose data privacy laws may not be equivalent to data privacy laws in Your own country of residence. Such transfers or disclosures will be made within the scope of applicable laws.

We may also share Your information:

During emergency situations or where necessary to protect the safety of persons;
Where the Personal Information is publicly available; and,
If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction.

Data Transfer

We hold Your Personal Information in the United States, where Material is headquartered. From time to time, We may be required to transfer Your Personal Information across borders and internationally for the purposes set forth above. When We do so, We will ensure that such transfers ensure that an appropriate level of protection is given to Your information.

Data Security

We have implemented appropriate physical, technical and organizational security measures designed to secure Your personal data against accidental loss and unauthorized access, use, alteration or disclosure. In addition, We limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business purpose for such access.

Data Retention

Material will retain Your Personal Information for as long as is necessary, or for such longer period as may be required by law, or to satisfy a legitimate business purpose. Records that are no longer needed are either deidentified (and the deidentified information may be retained) or securely destroyed.

Please note that these periods may be extended where reasonably necessary (for example where We are required to do so by law or by a regulator).

Updates or Requests Related to Your Personal Information

You may have certain rights in connection with Your Personal Information. For example You may access, review and update Your Personal Information by emailing legal@material.security. Additionally, where You have provided Your consent to the collection, processing or transfer of Your personal data, You may have the legal right to withdraw Your consent under certain circumstances. Please note, Your rights vary by jurisdiction, and for various legal reasons, We may not be able to comply with Your request (e.g., Material may have a legal obligation to retain the data).

We will not discriminate against You because of choices and requests You make in connection with Your Personal Information.

If You have other requests about Your Personal Information please contact legal@material.security.

Conflicts

Nothing in the Notice is meant to vest in a Job Candidate any greater rights than they may have under applicable data protection laws, employment contract or employment handbook. This Notice is not intended to replace other notices provided by Material in accordance with national laws and regulations. In the event of any conflict between notices required by local law and this Notice, any notices required by local law will control.

Changes

We reserve the right to amend this Notice from time to time and encourage You to periodically review this Notice.

Questions about Material’s Use of Your Personal Information

If You have a concern or a question about how We process Your Personal Information, You should contact legal@material.security.