Applicant, Employee, and Contractor Privacy Notice

Last Updated: December 8, 2023

This Privacy Notice provides limited information about how Allegiance Gold, LLC (“Allegiance,” “we,” “us,” “our”) collects, uses, and discloses Personal Information of current and former associates, contractors, and job applicants (and related beneficiaries, dependents, and emergency contacts) who reside in California.

NOTICE AT COLLECTION

Information We Collect

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

• Identifiers such as your contact information, Social Security number, driver’s license number, passport number, other government identifications, date of birth, emergency contact information or signature, Allegiance-specific identifier such as an associate number, Allegiance login information;
• Characteristics of protected classification under California or federal law such as race, ethnicity, gender, copies of citizenship and right to work information, medical condition, physical or mental disability, military, and veteran status;
• Internet or other electronic network activity information such as IP address and other online identifiers (when you use Allegiance devices, systems, websites, and other tools and services), other network activity information (such as Internet, application, and file use) of Allegiance computer systems and computing devices;
• Geolocation data such as location (including precise geolocation) when working on-site, in a vehicle owned or leased by Allegiance, or utilizing Allegiance devices or electronic resources;
• Audio, electronic, visual, thermal, olfactory, or similar information such as recordings of calls, emails, collaboration software, and other communications, security and other video footage, and photographs (which we do not use to create a biometric identifier or biometric template);
• Professional or employment-related information. We collect multiple types of employment-related information, including:
  • Financial information. We may collect financial information (such as your bank account number) to make payroll and other payments to you.
  • Compensation, benefits, withholdings, and garnishment information. We may collect and create information associated with your benefits (including beneficiaries), withholdings, garnishments, compensation, vacation and time/off balances, and similar information.
  • Work performance information. We may collect and create information associated with your work performance (such as your timecards, performance appraisals, feedback, safety records, drug test records, and disciplinary actions).
  • Prior employment and professional experience information. We may maintain Personal Information that you submitted in connection with a job application. Such information includes professional and employment-related information (such as title, resume/CV, compensation and performance review information, and background check results).
  • Claims and medical reports information. We may collect and create information associated with claims (such as workers compensation claims and unemployment claims), including related medical reports.
  • Medical and health information. We may receive health-related information when you are involved in an accident, when you provide it to us (such as when you request sick leave), or in connection with your enrollment in Allegiance’s medical insurance program.
• Education information such as academic transcripts, degrees awarded, confirmations of attendance at an educational institution, other information provided in support of the job application; and
• Personal information described in subdivision (e) of Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information above.

Some of the Personal Information listed above that we collect may be considered sensitive under California law (“Sensitive Personal Information”), including:

• Social Security number, driver’s license number, passport number, or other government identification number;
• Allegiance login information;
• Precise geolocation;
• Race, ethnicity;
• Medical and health information;

The type of Personal Information we collect about you may vary.

How We Use Information

We may use your Personal Information for business purposes, such as:

• Identifying and evaluating job applications, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
• Verifying your information and carrying out employment, background, and reference checks, subject to your consent where required by applicable law.
• Communicating with you about the recruitment process and your application.
• Verifying your eligibility for employment and, if applicable and required, supporting you with obtaining a work permit or visa.
• Keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
• Onboarding you as a new employee or contractor.
• Analyzing and improving our recruitment, application, and onboarding process and practices.
• Creating and submitting reports as required by applicable laws or regulations.
• Payroll/payment administration, including, reporting and paying taxes and other withholdings and garnishments.
• Benefits administration.
• Business management and planning.
• Processing employee work-related claims (for example, insurance claims).
• Accounting and auditing.
• Conducting performance reviews and determining performance requirements.
• Assessing qualifications for a particular job or task.
• Gathering evidence for disciplinary action or termination.
• Education, training, and development requirements.
• Facilitating business travel.
• To comply with applicable laws, regulations, corporate governance requirements, contractual obligations, and health and safety obligations.
• To measure Allegiance’s performance against diversity goals.
• To track safety efforts.
• To prevent fraud.
• To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
• To ensure physical security of our personnel, offices, stores, and equipment.
• To evaluate or facilitate business transactions such as a merger, acquisition, or asset sale.

We use Sensitive Personal Information as follows:

• Social Security Numbers and driver’s license or other government identification information, including passport numbers – to evaluate job candidates, process payroll, maintain employment records, report and pay taxes and other withholdings and garnishments, manage benefits, facilitate business travel, carry out performance reviews and evaluations, perform risk management activities (including background checks), implement and track safety efforts, respond to workers compensation claims, comply with our legal and contractual obligations, maintain the integrity of our processes, enforce rights, prevent fraud, validate your identity, and otherwise as part of typical employment-related activities.
• Allegiance login information – to permit access to Allegiance systems, devices, programs, and/or accounts and operate information security and anti-fraud program.
• Precise geolocation – for safety and security purposes, and otherwise for typical workplace and facilities monitoring.
• Race and ethnicity – to report to regulators and to measure Allegiance’s performance against diversity goals.
• Medical and health information –to implement and track safety efforts, for staffing purposes, to comply with legal and contractual obligations, and otherwise as part of typical employment-related activities.

We may also use Personal Information and/or Sensitive Personal Information as described to you at the point of collection, with your consent, or as otherwise required by applicable laws.

Third-Party Selling or Sharing

We do not sell or share (for cross-context behavioral advertising purposes) Personal Information collected in an employment context.

Data Retention

We keep your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) the length of time for which we have an ongoing relationship with you; (ii) legal requirements and best practices; and (iii) other legitimate needs for such information (e.g., to cover applicable statutes of limitations, use in connection with litigation or regulatory investigations, or use for other post-employment purposes).

If you are offered and accept employment or a contractor relationship with us, the Personal Information we collect during the application and recruitment process will become part of your employment or contractor record, and we may use it in connection with your relationship with us consistent with our policies. If you do not become an employee or contractor, or, once you are no longer an employee or contractor of us, we will retain and destroy your Personal Information in accordance with our document retention policies and applicable laws and regulations.

OTHER PRIVACY DISCLOSURES

How We Collect Information From You

In most cases, we will collect the Personal Information that we use directly from you.

Third Parties

We may collect Personal Information from third-party data sources such as employee benefit providers, medical professionals, former employers, or service providers hired to provide identity verification services or conduct background checks, drug screenings, or credit checks.

Through Allegiance-Issued or Authorized Equipment and Systems

We may collect Personal Information from our review of your use of (i) Allegiance systems such as email, project management software, and communication platforms, (ii) Allegiance-issued or authorized devices such as computers, tablets, telephones, and (iii) Allegiance-issued equipment and vehicles.

We and our service providers may record and retain your usage of, and contents within, Allegiance-authorized devices such as computers, tablets, telephones. By using such devices, you consent to our and our service providers recording and retention of your usage and the contents within. You understand that you have no expectation of privacy when using Allegiance issued or authorized devices.

From Employees or Contracts (if You are a Beneficiary or Emergency Contact)

If you are not employed by us, but receive benefits through one of our employees, are a dependent of an employee, or serve as an employee or contractor’s emergency contact, we may collect Personal Information from the employee or contractor with whom you have a relationship.

How We Disclose Information

We may disclose your Personal Information for employment-related purposes to:

• • Employees, contractors, or designated agents who require such information based on your relationship with us.
  • Service providers who require such information to help us administer our relationship with you, including entities who provide services to us or you or on our behalf. Service providers may include, but are not limited to, payroll/payment processors, benefits administration providers, professional employment organizations, background check providers, and data storage or hosting providers. These service providers may be located outside of your home jurisdiction. We do not permit our service providers to use your Personal Information for their own purposes. We only permit them to use your Personal Information for specified purposes in accordance with our instructions.
  • Third parties (excludes service providers) where required by law, to protect our rights and property and the rights of property of any related companies, during emergency situations, where necessary to protect the health or safety of persons, or in connection with a potential or actual business transaction or change in ownership.

In the past twelve months, we have disclosed the following categories of Personal Information to the following categories of third parties who are not our service providers:

• • • • Government officials: Identifiers
      • Law enforcement and courts: Identifiers
      • Parties to litigation: Identifiers

We do not sell or share (for cross-context behavioral advertising purposes) Personal Information collected in an employment context.

Data Security

We use reasonable physical, technical, and organizational security measures designed to secure your Personal Information against accidental loss and unauthorized access, use, alteration, or disclosure; however, no security measures are guaranteed to be successful. In addition, we limit access to Personal Information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Not a Contract of Employment

This Employee Privacy Notice does not create a contract for employment, compensation, hours of work, or for the provision of benefits. If you are a current employee, you are employed at-will, without any definite term or duration, and your employment with us can be terminated at any time, by either party, for any or no reason.

California Privacy Rights

If you are an applicant, employee, or independent contractor, or a beneficiary, dependent, or emergency contact of such a person, residing in California you have additional rights to access and control your Personal Information. Exemptions may apply. Privacy rights include:

Right to Know

You have the right to request twice per 12-month period that we disclose to you certain information about our collection, use, disclosure, and sale of your Personal Information over the past 12 months, including: (i) the categories or, if requested, specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose(s) for which we collected or sold your Personal Information; and (iv) the categories of Third Parties with whom we sold, shared, or disclosed your Personal Information, including the categories of Personal Information sold, share, or disclosed to each and the purposes for doing so. We are not permitted to provide access to specific pieces of Personal Information that creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver’s license numbers. We will not provide specific pieces of Personal Information unless you expressly request them.

Right to Delete

You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, or comply with legal obligations. We will retain a copy of your deletion request for at least two years as required by law.

Right to Correct

If you would like to update your information or information related to your beneficiaries, please do so by [insert instructions/link for self-update option].
If you are unable to correct Personal Information on your own and you believe it is inaccurate, you have the right to request that we correct it. When you make your request, please be sure to provide us with the specific information that you believe is inaccurate and the correct information. You should also provide us with any documentation you believe supports your proposed correction, and we will take that documentation into consideration. We will only correct the information if we determine, based on the totality of the circumstances, that your correction is more likely than not accurate. We may also choose to delete the allegedly inaccurate information instead of correcting it.

Submitting a Request

If you are a California resident and would like to exercise your rights, you may submit your request(s) by calling us at 844-790-9191 or by completing our online form.
To prevent unauthorized individuals from making rights requests, you must provide required information and/or documentation to verify your identity. We will process verified Right to Know, Right to Correct, and Right to Delete requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law.

Authorized Agent

If you are an authorized agent submitting a request for another California resident, you must provide a copy of a lawful power of attorney or written authorization from the consumer (along with proof of your identity). You will be provided options on how to provide this documentation after submitting the request. We may contact you or the consumer on whose behalf you claim to act to verify your authorization.

Non-Discrimination Notice

We will not discriminate or retaliate against any person for exercising their privacy rights under law or this Employee Privacy Policy.

Do Not Track

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Website and Services do not respond to “do not track” signals.

Changes to Privacy Notice

We reserve the right to update this Privacy Notice at any time. If such changes materially affect the Personal Information we collect or how we use your Personal Information, we will notify you.

Contact Us

If you have any questions about this Employee Privacy Policy, please contact us at:
Email: privacy@allegiancegold.com

Mailing Address:
Allegiance Gold, LLC
27001 Agoura Road
Suite 200
Calabasas, California 91301
Telephone: 844-790-9191