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NOTICE REGARDING THE COLLECTION AND USE OF PERSONAL INFORMATION

PTOE Corporation and its affiliates (collectively, the “Company”) collect and use personal information for legitimate business purposes. These purposes include communicating with you, handling administrative tasks related to your application, employment, or services with the Company, complying with legal obligations, and addressing legal or compliance issues involving you or the Company.
This Notice (“Notice”) outlines how we collect, store, disclose, and process your personal information in accordance with applicable privacy laws, including but not limited to the California Privacy Rights Act (“CPRA”), the UK Data Protection Act (“DPA”), and the EU General Data Protection Regulation 2016/679 (“GDPR”).
Please read this Notice carefully, along with any other relevant notices provided when we collect or process your personal information, to understand how and why we use such information.
The Company reserves the right to update this Notice from time to time. If significant changes occur, we will provide an updated notice. Modifications may include changes in the types of data we collect or adjustments to our processing practices. We may also notify you separately about certain processing activities.
We retain the right to amend this Notice at our discretion, at any time.
If you have any questions regarding this Notice, please contact us at: [email protected].

PERSONAL INFORMATION WE COLLECT AND HOW IT IS USED

Most of the personal information we hold has been provided by you directly. However, some information may come from internal sources such as your manager, or from external sources like employment agencies, background check providers, medical professionals, or governmental authorities. We only use your personal information when permitted by law, as described in this Notice. Typically, we use your personal information under the following circumstances:
  • To fulfill obligations under a contract: 
For example, an agreement related to your employment or services provided to the Company.
  • To comply with legal requirements: 
Such as tax, legal, or regulatory obligations.
  • To fulfill obligations under a contract: 
Where these interests do not override your rights and interests.
  • To protect vital interests:
For example, to prevent serious harm to an individual’s health, safety, or public health.
  • To meet employment-related legal obligations:
Including those related to equal opportunities, occupational health, or pension schemes.
  • For the assessment of working capacity:
Relevant to employment or legal claims.
The following table outlines the categories of personal information we typically collect, the purposes for collection, and the legal grounds that justify the use of such information:

Category of Personal Information Collected

Examples

Business Purpose for Collection of Personal Information

Legal Grounds for Processing

Identifiers

Your name (including any nickname or alias you have used), signature, postal address, telephone number, mobile number, unique personal identifier, online identifier, Internet Protocol address, e-mail address, account name, Social Security number, driver’s license or identification number, passport number, or other similar identifiers, education, work history, information on your resume, CV, or bio, awards, certifications, recognitions, professional licenses

Identification and evaluation, job application identification, job application evaluation, communications, payroll and benefit administration, relocation, travel administration, security, legal issues/compliance

– Agreement relating to the performance of your work for or with the Company

– Our legitimate interests
– Compliance with legal obligations

Benefits, payroll, security and emergency contact information

Insurance policy number, bank account number, federal and state tax credits claims, credit card number, debit card number, or any other financial information, medical information, health insurance information, beneficiary information, physical characteristics, description, photographs, video, emergency contact name, emergency contact information and telephone number

Payroll and benefit administration, relocation, travel administration, legal issues/compliance, emergency response, security

– Agreement relating to the performance of your work for or with the Company

– Our legitimate interests
– Compliance with legal obligations

Protected characteristics under California or federal law

Race, color, ancestry, national origin, citizenship, religion or creed, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, marital status, age, medical condition, physical or mental disability, genetic information (including familial genetic information), veteran or military status

Benefit administration, legal issues/compliance, government related security clearance

– Agreement relating to the performance of your work for or with the Company

– Compliance with legal obligations

Category of Personal Information Collected

Examples

Business Purpose for Collection of Personal Information

Legal Grounds for Processing

 

activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data

security clearance, ergonomic or accommodation evaluations, secured computer or electronic access

performance of your work for or with the Company

– Our legitimate interests
– Compliance with legal obligations

Internet, computer, or other similar network activity

Use of the Company’s computer system, browsing history, search history, information regarding interaction with a website, application, or advertisement, email, instant messaging, or voicemail messages

Information technology administration, work supervision, investigations, communications, performance evaluation, compliance with Company policies and procedures, discipline, legal issues/compliance

– Agreement relating to the performance of your work for or with the Company

– Our legitimate interests
– Compliance with legal obligations

Geolocation data

Physical location or movements

Security monitoring, site access, company travel including vehicles, VPN, government assignment locations

– Agreement relating to the performance of your work for or with the Company

– Our legitimate interests
– Compliance with legal obligations

Sensory data

Audio, electronic, visual or similar information

Fitness for duty exams, operations center and surveillance recording, phone recording for benefits and facilities emergencies

– Agreement relating to the performance of your work for or with the Company

– Our legitimate interests
– Compliance with legal obligations

Professional or work-related information

Current or past job history or performance, conduct, performance evaluations

Evaluation and advancement, investigations, discipline, legal issues/compliance

– Agreement relating to the performance of your work for or with the Company

– Our legitimate interests
– Compliance with legal obligations

MONITORING

Non-public education information
Education records directly related to an applicant, or current or former employee, maintained by the Background check education – Our legitimate verification, tuition interests reimbursement program, job, Company or party acting on its behalf, such as grades, transcripts, student financial information related credentials certifications, legal issues/compliance. Compliance with legal obligations.

Category of Personal Information Collected

Examples

Business Purpose for Collection of Personal Information

Legal Grounds for Processing

 

 

 

 

Sensitive Personal Information

Social Security, driver’s license, state identification card, or passport number, proof of US work authorization (such as green card), account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health, sex life or sexual orientation.

Identity verification, employment and benefits administration, vendor oversight, security detection, protection and enforcement, compliance with law.

– Agreement relating to the performance of your work for or with the Company

– Our legitimate interests
– Compliance with legal obligations

– Carrying out the obligations and exercising our rights as your employer

Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Evaluation and advancement, legal issues/compliance

– Our legitimate interests
– Compliance with legal obligations

MONITORING OF ACCESS TO COMPANY SYSTEMS

The Company may monitor your access to and use of our systems, as permitted by applicable laws. This may include, for example, monitoring telephone, voicemail, email, internet, computer usage, websites visited, work email inbox, and log files of your computer. Monitoring may occur where you have agreed to it or where it is necessary for our legitimate interests (or those of a third party). The purposes of such monitoring may include, but are not limited to:
  • Ensuring compliance with company policies, rules, and principles.
  • Preventing unlawful or defamatory actions.
  • Retrieving lost messages.
  • Protecting the Company’s economic, commercial, and financial interests.
  • Ensuring the safety and proper functioning of the Company’s IT systems, including cost control and physical protection of equipment.
  • Complying with legal obligations or assisting in investigations of alleged wrongdoing.

RETENTION OF PERSONAL INFORMATION

Personal information will be retained for as long as necessary to comply with applicable laws or fulfill legal obligations. We may retain records for as long as required by law, for a period consented to by you, or for purposes outlined in this Notice. At the end of the retention period, we will take appropriate steps to delete or anonymize your personal information. Any physical records, such as printouts or hard copies, will be permanently destroyed.

DISCLOSURE OF PERSONAL INFORMATION

We will not sell, rent, share, or transfer your personal information to third parties, either within your jurisdiction or internationally, except as described in this Notice or unless you provide prior consent. We may share personal information in the following situations:

  • Third-party service providers:
We may share personal information with third-party vendors, service providers, or subcontractors who assist with services like payroll, pension administration, benefits, accounting, legal services, and IT. These third parties are contractually bound to protect your privacy.
  • Business transactions:
In connection with a merger, acquisition, or sale of all or part of our business, we may share your personal information with third parties involved in the transaction. We will aim to anonymize data before the transaction, and after the transaction, we will share personal information as required by the terms of the deal.
  • Advisors:
We may share personal information with auditors, legal advisors, and other professional service providers under confidentiality obligations.
  • Law enforcement:
We may disclose personal information to government authorities or third parties when required by law, such as in response to a subpoena, court order, or for law enforcement investigations. We may also disclose personal information if necessary to protect the Company’s rights or in response to potential legal claims.
  • Other third parties:
We may share personal information with other third parties for specific purposes, ensuring that privacy protections are in place, such as requiring third parties to handle data according to our instructions or anonymizing the data before sharing.

INTERNATIONAL TRANSFERS AND STORAGE

Your personal information may be stored and processed in the United States, where our servers are located, and/or in other locations where our central database is operated. When transferring personal information internationally, we will take necessary steps to ensure its protection, including using standard contractual clauses or data transfer agreements. If you are located in the UK, Switzerland, or the European Economic Area (EEA), we may store your personal information outside of these regions. In such cases, we will ensure that your data is transferred securely and in compliance with applicable laws.

YOUR RIGHTS AS A DATA SUBJECT

Depending on your location, you may have the following rights regarding your personal information:
  • Access:
You may request confirmation as to whether we process your personal information and access data we hold about you, including the purposes of processing, recipients, and retention period.
  • Correction:
You may request corrections to inaccurate personal information.
  • Erasure:
You may request deletion of your personal information, subject to legal exceptions.
  • Restriction of processing:
You may request to restrict the processing of your personal information.
  • Data transfer:
You may request the transfer of your personal information to another party where feasible.
  • Objectionr:
You may object to the processing of your personal information on legitimate grounds.
  • Withdraw consent:
If processing is based on your consent, you may withdraw consent at any time.
If you believe the Company has not adhered to its obligations under this Notice or applicable law, you have the right to lodge a complaint with the relevant supervisory authority.

CALIFORNIA RESIDENTS' RIGHTS

If you are a California resident, you have the following additional rights:
  • Access:
The right to request information about the personal information we collect, including categories, sources, and third parties with whom it is shared.
  • Opt-Out:
The right to request that we do not sell your personal information or share it for behavioral marketing purposes.
  • Deletion:
The right to request the deletion of your personal information, with certain exceptions.
  • Non-Discrimination:
We will not discriminate against you for exercising any of the above rights.
To exercise these rights, or for any questions, please contact us at: [email protected].
Effective Date: March 15, 2025
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