Teamshares Inc. California Personnel Privacy Notice

Last Updated: 08/14/2023

Teamshares Inc. and its affiliates (collectively, “Teamshares,” “we,” “us,” or “our”) respect your privacy. This California Personnel Privacy Notice (“Notice”) applies to Personal Information that we collect as a Business from or about our current and former employees, applicants, contractors, consultants, stockholders, directors, and officers who are California residents (collectively, “you,” or “personnel”) in the context of their employment or other similar relationship with us.

For the purposes of this Notice, “Personal Information” and other capitalized terms not otherwise defined in this Notice have the meanings provided in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

• Publicly available, as defined by the CCPA.
• Deidentified or aggregated.
• Otherwise excluded from the scope of the CCPA.

Collection of Personal Information

In the preceding twelve months since this Notice was last updated, we have collected Personal Information from the following categories of sources:

• You
• Your devices directly
• Affiliates
• Publicly available databases

Collection and Disclosure of Personal Information

The chart below provides the categories of Personal Information and Sensitive Personal Information (as defined by the CCPA) we have collected, or disclosed for a business purpose, or sold or “shared” (for cross-context behavioral advertising purposes) in the preceding twelve months since this Notice was last updated. The examples of Personal Information and Sensitive Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information and Sensitive Personal Information associated with each category.

Disclosure of Personal Information

In the preceding twelve months since this Notice was last updated, we have disclosed Personal Information to the following categories of third parties:

• Vendors: Vendors and service providers. Personal Information we disclosed: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Characteristics of Protected Classifications under California or Federal Law, Internet or Other Electronic Network Activity Information, Geolocation Data, Sensory Information, Professional or Employment-Related Information, Inferences Drawn from Personal Information, Sensitive Personal Information (Identifiers), Sensitive Personal Information (Log-In and Financial Information), Sensitive Personal Information (Contents of Communications), Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Health), and Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Sex Life or Sexual Orientation)
• Affiliates: Our affiliate companies. Personal Information we disclosed: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Characteristics of Protected Classifications under California or Federal Law, Internet or Other Electronic Network Activity Information, Geolocation Data, Sensory Information, Professional or Employment-Related Information, Inferences Drawn from Personal Information, Sensitive Personal Information (Identifiers), Sensitive Personal Information (Log-In and Financial Information), Sensitive Personal Information (Group Membership), Sensitive Personal Information (Contents of Communications), Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Health), and Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Sex Life or Sexual Orientation)
• Third Parties as Legally Required: Third parties as required by law and similar disclosures. Personal Information we disclosed: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Characteristics of Protected Classifications under California or Federal Law, Internet or Other Electronic Network Activity Information, Geolocation Data, Sensory Information, Professional or Employment-Related Information, Inferences Drawn from Personal Information, Sensitive Personal Information (Identifiers), Sensitive Personal Information (Log-In and Financial Information), Sensitive Personal Information (Contents of Communications), Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Health), and Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Sex Life or Sexual Orientation)
• Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information. Personal Information we disclosed: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Characteristics of Protected Classifications under California or Federal Law, Internet or Other Electronic Network Activity Information, Geolocation Data, Sensory Information, Professional or Employment-Related Information, Inferences Drawn from Personal Information, Sensitive Personal Information (Identifiers), Sensitive Personal Information (Log-In and Financial Information), Sensitive Personal Information (Contents of Communications), Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Health), and Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Sex Life or Sexual Orientation)

Use of Personal Information

We collect, use, or disclose your Personal Information in accordance with the specific business purposes below:

• Recruitment: To receive, evaluate, and process job applications, verify your information and conduct background checks, as permitted by law, communicate with you about the recruitment process and your application, schedule interviews, and improve the recruitment process.
• HR Operations: To fulfill your employment agreement, manage employee onboarding, promotions, transfers, and secondments, manage HR related claims and litigation, provide trainings, performance reviews, and evaluations, manage business and travel expenses, and create reports for workforce planning, such as headcount and employee turnover.
• Payroll and Benefits: To administer pay and benefits, process business and travel expense reimbursements, calculate tax and social security withholdings, comply with wage garnishment orders, and process leaves.
• IT and Security: To provide IT and security support, manage IT resources and provisions of new IT applications, manage log-in credentials, monitor IT systems and networks for suspicious activity, detect intrusions, and monitor and control access to facilities to protect us, our personnel, and property.
• Legal and Compliance: To comply with legal obligations regarding HR analytics, including requests from government statistics services, process conflict of interest reporting, process employee work-related claims such as worker compensation or insurance claims ensure compliance with our employee policies and security requirements gather evidence for and to support any internal investigations, litigation, disciplinary action, termination, or related activities, protect, enforce, and defend the legal rights, privacy, safety, or property of us and our employees, agents, and contractors, protect against fraud and manage risk, and comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
• Acquisition or Merger: To manage acquisitions, mergers, and reorganizations or sale of some or all of a company.
• Other Business Purposes: For other purposes that you would reasonably expect, or for which we provide specific Notice at the time the information is collected.

Data Retention

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods for each category of Personal Information include:

• The length of time we have an ongoing relationship with you and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
• Whether there is a legal obligation to which we are subject that requires us to retain information for, or delete information after, a certain period of time; and
• The length of time we use the information to detect and prevent fraud and security incidents.

Your California Privacy Rights

If you are a California resident, you may exercise the following rights:

• Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected or disclosed by us; (2) purposes for which categories of Personal Information are collected by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties to whom we disclosed Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.
• Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
• Right to Correct. You have the right to correct inaccurate Personal Information that we maintain about you.
• Verification. Requests for access to, deletion, or correction of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access, deletion, or correction request, please follow the instructions provided in our response to your request.
• Right to Opt Out. In some circumstances, you may opt out of the sale or sharing (for cross-context behavioral advertising purposes) of your Personal Information. We do not sell or share (for cross-context behavioral advertising purposes) your Personal Information.
• Right to Limit Use and Disclosure of Sensitive Personal Information. In some circumstances, you may limit our use and disclosure of your Sensitive Personal Information. We do not use or disclose your Sensitive Personal Information for purposes other than the limited purposes permitted by the CCPA.
• Right of No Retaliation. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations, including if you are an employee, applicant, or independent contractor of our business.

Submit Requests

To exercise your rights under the CCPA, send an email via our Contact Information section.

Authorizing an Agent

If you are acting as an authorized agent to make a request to know, delete, correct, or opt out on behalf of a California resident, send an email via our Contact Information section below and attach a written authorization signed by the resident.

Contact Information.

If you have any questions, comments, or concerns about this notice or our processing activities, please email us at support@teamshares.com or write to us at:

Teamshares Inc.

214 Sullivan Street, Suite 6B

NY, NY 10012

We will make an effort to reply within a reasonably timeframe. Please feel free to reach out to us at any time.