Last Updated: June 28, 2023

This California Applicant Privacy Notice (“Applicant Notice”) describes our information practices relating to applicants and candidates for employment with Cargomatic Inc. (“Cargomatic,” “we,” “our,” “us,” or the “Company”) who are California residents (each an “Applicant” or “you”). This Applicant Notice is intended to satisfy the requirements of the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020), and its implementing regulations (collectively the “CCPA”).

TABLE OF CONTENTS
1. Scope and Relation to Other Policies
2. What Personal Information Do We Collect?
3. Sources of Personal Information
4. Why Do We Collect Personal Information?
5. Disclosure of Personal Information
6. How Long Do We Retain Personal Information?
7. Security
8. How You Can Update Your Personal Information
9. Your California Privacy Rights
10. Changes to This Applicant Notice
11. Contact Us

1. Scope and Relation to Other Policies

This Applicant Notice applies to any information we collect about our Applicants that identifies, relates to, describes, is reasonably capable of being associated, or could reasonably be linked, directly or indirectly, with an individual (“Personal Information”). Our information practices may vary depending upon certain circumstances, such as the location or role for which you are applying.

This Applicant Notice does not address or apply to our information practices that are not subject to the CCPA, such as:

• Publicly Available Information. Information that is lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience.
• Deidentified Information. Information that is deidentified in accordance with applicable laws.
• Aggregated Information. Information that relates to a group from which individual identities have been removed.
• Protected Health Information. Information governed by the Health Insurance Portability and Accountability Act or California Confidentiality of Medical Information Act.
• Activities Covered by the Fair Credit Reporting Act. This includes information we receive from consumer reporting agencies that are subject to the Fair Credit Reporting Act, e.g., information contained in background check reports we obtain as part of our vetting process.

This Notice also does not apply to the Personal Information we collect from our customers, contractors, employees, or our Applicants in the context of their personal use of our products and services, which are subject to different notices. For additional information on our general privacy practices, please visit our Website Privacy Policy.

We may provide Applicants additional notices about our information practices that are covered by other laws (e.g., if we conduct a background check).

2. What Personal Information Do We Collect?

The following identifies the categories of Personal Information we may collect about Applicants (and have collected in the prior 12 months), as enumerated by the CCPA.

• Identifiers. Such as real name, alias, job title, address, unique personal identifier, online identifier, email address, date of birth, social security number, driver’s license number, and other government identifiers.
• Characteristics of Protected Classifications. Such as age (40 years or older), race, ancestry, national origin, citizenship, physical or mental disability, sex, veteran or military status, and other characteristics of protected classifications under California or federal law.
• Internet or Other Electric Network Activity Information. Such as information about applicants’ interaction with our portals, website, applications, or advertisements, including, but not limited to, browsing history, clickstream data, and search history.
• Geolocation Data. Such as information contained in driver logs.
• Audio, Electric, Visual, or Similar Information. Such as information collected via call recordings, recorded meetings, videos, photographs, and video footage to secure our offices and premises.
• Employment-Related Information. Such as previous positions held, skills and experience, job duties, certifications, and licenses.
• Education Information. Such as education records, including grades, transcripts, student disciplinary records, or any other related information you chose to provide.
• Sensitive Personal Information. Such as your social security number, driver’s license number, race or ethnic origin, medical condition, and physical or mental disability.
• Inferences and Preferences. Such as inferences and preferences reflecting an Applicant’s preferences, characteristics, attitudes, behaviors, and abilities.

3. Sources of Personal Information

We generally collect the categories of Personal Information identified above from the following categories of sources:

• Directly from you;
• From recruiters and recruiting platforms;
• From publicly available information and sources;
• From former employers (with your prior permission);
• From our service providers, representatives, and agents; and
• From any references you provide.

4. Why Do We Collect Personal Information?

We generally collect Personal Information as reasonably necessary for the following business or commercial purposes, as permitted by applicable laws:

• Recruiting and Hiring. We use Personal Information from your application and collected through the interview process to evaluate your qualifications and eligibility for employment. This includes identifying Applicants, scheduling interviews, conducting background checks, evaluating qualifications, extending offers, communicating with Applicants, maintaining Applicant information for future consideration, and supporting our equal opportunity employment practices.
• Defending and Protecting Rights. We use Personal Information to protect and defend our rights and interests and those of third parties, including to manage and respond to Applicant and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, including without limitation, Cargomatic’s trade secrets and other intellectual property, and protecting the rights, property, and reputation of Cargomatic and its workforce, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
• Compliance with Legal Obligations. We use Personal Information to comply with applicable legal obligations (such as determining hiring eligibility or responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions, and guidance.

We may use Personal Information for other business or commercial purposes depending on the context, but we will provide you with additional notice (and, if necessary, obtain your consent) prior to doing so.

5. Disclosure of Personal Information

A. Purposes for Disclosing Personal Information

We may disclose the categories of Personal Information identified in Section 2 for the following business purposes.

• To Evaluate Your Application/Candidacy. We may disclose Personal Information when it is necessary to provide services you request and where it is necessary to identify Applicants, schedule interviews, and otherwise evaluate your qualifications and eligibility for employment.
• To Enforce Rights. We may disclose Personal Information if required to do so by law, to protect our rights, property, or the safety of others, or where we have a legitimate interest in doing so.

B. Categories of Recipients

We may disclose Personal Information to the following categories of recipients:

• Affiliates and Business Partners. We may disclose Personal Information to our affiliates and business partners where necessary to evaluate your candidacy for employment or for business operations purposes.
• Service Providers. We may disclose Personal Information to our service providers who perform services on our behalf, such as recruiters or recruitment platform providers. Our service providers are required to take appropriate security measures to protect your Personal Information in line with our policies and are not permitted to use Personal Information for their own purposes.
• Government Entities and Agencies. To comply with our legal obligations and where otherwise required by law, we may disclose the following categories of Personal Information to applicable regulatory and government entities: identifiers, characteristics of protected classifications, and employment-related information.
• Data Analytics Providers. To evaluate the effectiveness of our applicant portal, we may disclose the following categories of Personal Information to data analytics providers: identifiers and internet and network activity information.
• Operating Systems and Platforms. If you sign in through Apple ID or LinkedIn to apply for a position with us, we may disclose the following categories of Personal Information to operating systems and platforms, such as Apple iOS or LinkedIn: identifiers.
• Social Networks. If we have an ongoing working relationship with you during the application process, we may disclose the following categories of Personal Information to various social media sites to promote the fact our company is working with you: identifiers.
• Other Parties With Your Consent. Personal Information may also be disclosed to a third party but only at your request and with your consent.

6. How Long Do We Retain Personal Information?

We store your Personal Information for as long as needed, or permitted, based on the reason why we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions that require data retention (e.g., issued any legal holds or otherwise need to preserve data).

Rather than delete your Personal Information, we may also deidentify it in accordance with the CCPA, by removing identifying details. Where we have committed to maintaining and using Personal Information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.

7. Security

Cargomatic takes reasonable and appropriate administrative, technical, and physical measures designed to protect the Personal Information we collect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

Please be aware that despite our efforts, no data security measures can guarantee security. You should take steps to protect against unauthorized access to your passwords and login details.

8. How You Can Update Your Personal Information

It is important that the information contained in our records is both accurate and current. If your Personal Information changes during the interview process, you can use these self-help tools to update your Personal Information.

9. Your California Privacy Rights

A. Applicant Privacy Rights

If you are a California resident, you may have additional rights regarding your Personal Information under the CCPA. These rights are subject to certain exemptions and exclusions, and include:

Right to Know/Access. You have the right to request:

• The categories of Personal Information we collected about you;
• The sources from which we have collected that Personal Information;
• Our business or commercial purpose for collecting, selling, or sharing that Personal Information;
• The categories of third parties to whom we have disclosed that Personal Information; and
• A copy of the specific pieces of Personal Information we have collected.

Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information.

Right to Delete. You have the right to request deletion of Personal Information that we have collected from you. Note, however, that we are unable to delete Personal Information if we are required to maintain it to comply with applicable laws.

Right to Limit Use and Disclosure. Subject to certain conditions and exceptions, you may have the right to limit the use and disclosure of “Sensitive Personal Information,” as defined under the CPRA. However, we do not engage in activities triggering this right.

Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

We do not sell or share (as defined under the CCPA) the Personal Information we collect from Employees and we do not have actual knowledge that we sell or share the Personal Information of individuals under 16 years of age.

B. Exercising Your California Privacy Rights

To exercise any of these CCPA rights, please use one of the following methods:

• Email: ccpa@cargomatic.com
• Phone: (866) 513-2343

Please indicate you are exercising your “CCPA rights.” Cargomatic will need to confirm your identity before fulfilling the request, so please provide us with your full name, the email address you used to communicate with us, and your address. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we will deny the request and will explain the basis for the denial.

You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf. We may also ask you directly to verify that you have authorized your authorized agent to act on your behalf.

10. Changes to This Applicant Notice

This Applicant Notice is reviewed and updated periodically consistent with applicable law and to ensure it accurately describes our information practices and procedures. When we update this Applicant Notice, we will also revise the “Last Updated” date at the top of this document.

11. Contact Us

If you have questions or concerns regarding this Applicant Notice or the handling of your Personal Information, please contact us at:

ccpa@cargomatic.com

Attn: Chief People Officer
211 East Ocean Blvd., Suite 350
Long Beach, CA 90802