Employee Privacy Statement

Please take the time to read the following information carefully so that you fully understand our views and practices regarding your personal data and how we will use it.

EFFECTIVE AS OF JANUARY 1, 2023
Version [1.0]

Introduction

We at Relyance Inc. (collectively, “Relyance”, “we” “our” or “us”) are committed to protecting your personal data. This Employee Privacy Statement (“Employee Privacy Statement”) applies to all of our employees, directors, Board members, contractors, interns, and job applicants. It will help you understand how we collect, use, and protect your personal data.

It is important that you read this Employee Privacy Statement together with any other privacy statements, notices, or fair processing notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Employee Privacy Statement supplements other notices and is not intended to override them.

Information on how we collect personal data from those who visit our website www.relyance.ai (“Website”) or use our software platform is captured in our general Privacy Statement (https://www.relyance.ai/privacy-statement).

Personal Data We Collect From You

We may collect personal data from you, and process different types of personal data, depending on whether you are part of Relyance’s workforce or applying for a job with us. The personal data we process may also vary depending on your location, as well as applicable local laws and regulations.

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Personal Data Types

We may collect and process the following personal data types:

Identification data
- Examples include name, date of birth, government identifiers, employee identification number, and photograph.
Contact data
- Examples include home address, telephone, email addresses, and emergency contact details.
Hiring data
- Examples include Information related to applicant qualifications, past employment, interview notes, references, immigration status and documentation, residency permits and visas, national ID/passport, and other official documentation in support of authentication or eligibility for employment (e.g., Form I-9 in the US).
Employment data
- Examples include information related to your qualifications, your role at Relyance, job description, role changes, resignation/termination, resume/CV, location, employment contracts, performance and disciplinary records, academic/professional qualifications, criminal records data, immigration status and documentation, occupational health assessments, residency permits and visas, national ID/passport, and training.
Benefits data
- Examples include information related to employment benefits we provide to you (e.g., e.g., spouse and dependent information, health information, vacation, leaves of absence, and accommodations information).
Performance and management data
- Examples include information related to performance evaluations or reviews, disciplinary actions and grievances, as well as training and development plans.
Financial data
- Examples include banking details, tax information, payroll information, withholdings, salary, expenses, company allowances, commission, as well as stock and equity grants.
Systems and asset use data
- Examples include information required to provide access to Relyance’s electronic systems, networks, applications, equipment, devices, software, and means of communication operated and managed by us (e.g., IP addresses, log files, login information, software/hardware inventories, internal communications and video and audio recordings, and information collected from our employees by internal Relyance applications (such as employee communications tools and platforms)). This also includes asset allocation data, data used for security and business continuity purposes, and information required to use Relyance sites.
Demographic data
- Examples include date of birth, gender, race/ethnicity, sexual orientation, veteran status, disability, as well as information relating to other demographic categories.
Other information you choose to share with Relyance

Personal Data Sources

We collect personal information directly from you voluntarily provide to us during the application process or when you otherwise contact us. We may also automatically collect certain information, such as IP addresses and device identifiers.

We may combine personal information you voluntarily provide to us with information we collect from other sources, such as:

Recruiters;
Prior employers and professional references;
Educational institutions;
Pre-employment screening and background check services;
Credentialing and licensing organizations;
Publicly available sources, such as public social media profiles on LinkedIn, Twitter or Facebook; and
Other sources as directed by you

We will only use this data for the reasons we originally collected it and if we need to use the data for another legitimate business reason, we will notify you directly and get your permission where required. If we ask you to provide personal data not described above, the reason for doing so will be made clear to you at the point we collect it.

How We Use Your Personal Data

We use your personal data to communicate with you and to conduct necessary business operations.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. For an explanation as to how such processing for the new purpose is compatible with the original purpose, please contact us.

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Why we process your personal data

We process your personal data for the following:

Purpose		Data categories we process
Hiring	We process job applicant personal data during the hiring process to determine suitability and eligibility for a role. This includes creating an applicant profile, conducting/scheduling interviews, verifying qualifications, administering background checks, establishing your right to work in a specific jurisdiction, and communicating with you in the process.	Identification data, Contact data, Hiring data
Compensation and Benefits	We use this information to administer payroll, expense reimbursement, manage corporate charge accounts, bonuses, taxes, benefits, as well as process work-related claims (e.g., worker compensation, insurance claims, expense and travel management) and leaves of absence.	Identification data, Contact data, Employment data, Benefits data, Financial data
Training	We use this information to help us manage and track employment-related training and other development opportunities.	Employment data
Performance Reviews	We use this information to review your work performance, and to help determine your work performance requirements and career development needs.	Identification data, Contact data, Employment data, Performance and management data, Financial data
Legal Requirements	We use this information to comply with laws and regulations, as well as legal processes (e.g. responding to subpoenas or court orders), and to respond to legal claims, resolve disputes, enforce our legal rights contained in employment or other contracts and comply with legal or regulatory recordkeeping requirements.	Identification data, Contact data, Employment data, Hiring data, Benefits data, Performance and management data, Financial data, Systems and asset use data, Demographic data
HR Management	We use this information to provide general HR management services, including managing employee on-boarding, termination and separation, travel administration and return-to-work screening (including any medical screening as required or permitted by applicable law)	Identification data, Contact data, Employment data, Hiring data, Benefits data, Financial data, Systems and asset data, Performance and management data, Other information you share with us
Contacts	We use this information internally to compile employee directories or send documents or items to home addresses.	Identification data, Contact data, Employment data
Security & IT	We use this information to maintain the security of our electronic systems, networks, applications, equipment, devices, software, means of communication operated and managed by us, assets, manage our general operations and assets, and provide services to you as necessary for your job description.	Identification data, Contact data, Employment data, Hiring data, Systems and asset data
Emergencies	We use this information to help us establish emergency contacts for you and respond to and manage emergencies, crises, and business continuity	Identification data, Contact data, Benefits data
Investigations and Disciplinary Actions	We use this information when necessary to investigate and support decisions on disciplinary actions or terminations, manage grievances, or to detect fraud or other wrongdoing.	Identification data, Contact data, Employment data, Benefits data, Financial data, Systems and asset data
Workplace DEI	We use this information as necessary to help us understand the diversity of our workforce and to support core business diversity, equity, and inclusion initiatives. In some circumstances, we may also need to use this data to comply with local laws. We generally collect this information on a voluntary consensual basis; you are not required to provide it unless it is necessary for us to comply with a legal obligation. We will not share this data without your permission unless we are legally required to do so.	Demographic data
Day-to-Day Business Operations	We may use this information for other legitimate purposes that are reasonably required for Relyance’s day-to-day operations (e.g., managing employee relationships, enforce our policies, protect the rights or employees, accounting, financial reporting, business analytics, employee surveys, operational and strategic business planning, mergers and acquisitions, real estate management, business travel, and expense management)	Identification data, Contact data, Employment data, Hiring data, Benefits data, Financial data, Systems and asset data, Other information you share with usIdentification data, Contact data, Employment data, Hiring data, Benefits data, Financial data, Systems and asset data, Other information you share with us

Who we share your personal data with

We will not sell your personal data, nor will we offer financial incentives associated with our collection, use, or disclosure of your personal information. We may share your data with third parties (but only the minimum amount they need) in the following instances:

our employees and contractors, but their use shall be limited to the performance of their duties and in line with the reason for processing, in furtherance of establishing, managing, or terminating your employment with Relyance;
consultants and advisors, to see professional advice (e.g., legal advice, accountant advice, management advice)
service providers we engage (under contract) to provide services to you on behalf of Relyance, such as:
- recruiters
- pre-employment screening service providers
- financial investment providers
- insurance providers
- benefits providers and administrators (e.g., healthcare providers)
- payroll processors
in the event of the sale, acquisition or merger of some or all of our assets, if your personal data is part of the transferred assets; we will notify you in the event of such an occurrence, as well as any choices you may have regarding your personal data
government authorities or law enforcement, as we believe necessary and appropriate to respond to a lawful order such as a subpoena or comply with other applicable law. We may also disclose your personal data to government agencies in order to protect or enforce our legal rights, or protect, investigate, or deter against fraudulent, unethical, or illegal activity.
other 3^rd parties with your consent OR 1) to protect our rights, 2) to protect Relyance, our customers, or the public from harm, and 3) to respond to an emergency which we believe in good faith requires us to share your data to prevent harm.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third party service providers to use your personal data for their own purposes, and only permit them to process your personal data for specified purposes in accordance with our instructions.

Our legal basis for processing your personal data

Relyance will only use your personal data when we have a valid legal basis to do so. Depending on the circumstance, we may use your data with your consent, or rely on the fact that the processing is necessary for us to carry out our employment contract with you, to comply with or legal obligations, exercise our rights, or to comply with law. To the extent we ask you to provide personal data to comply with applicable laws or regulations, or to perform a contract with you, will make this clear to you at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data). If we collect and use your personal data in reliance on our legitimate interests (or those of a third party) that are not listed in the table above, we will make those legitimate interests clear to you at the relevant time.

We consider and try to balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

How long we retain your personal data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes set forth in this Employee Privacy Statement or as otherwise required by law, after which time it is destroyed in accordance with our data retention policies. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

International data transfers

In order to operate our business we may transfer your personal data between different countries. The applicable data protection laws of those jurisdictions may differ from the data protection laws of your country and, in some cases, may not be as protective. If we transfer your personal data outside your country, we will ensure a similar degree of protection is afforded to it as the data protection laws of your country.

How We Protect Your Data

We are committed to securely maintaining your personal data.

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We implement appropriate technical and organizational safeguards, including encryption and de-identification where appropriate, to protect your personal data against accidental loss or unauthorized access or disclosure. We choose our security measures based on the risks presented by how we use your personal data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your Privacy Rights

We respect your rights to control your personal data.

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Your rights as a California resident

Under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”), California residents have certain rights around our collection, use, and sharing of their personal information.

You may have the right to request we:

Provide details about the categories and specific personal data types we collect about you, including where we collect it, who we share it with, and how we use it;
Provide you access to your personal data we have collected;
Correct inaccurate personal information;
Limit disclosure or use of your sensitive personal information; and
Delete the personal data we have about you.

We will not discriminate against you for exercising your privacy rights. However, in certain circumstances we cannot grant your request, for example, if we are required to retain your data to comply with law, or to enforce our legal rights.

Your rights as a European Economic Area or United Kingdom citizen

You may have the right to:

Access your personal data and receive information about our processing of it;
Ask us to correct any inaccuracies in your personal data we possess or to complete incomplete personal data we possess about you;
Ask us to delete your personal data in certain circumstances;
Ask us to restrict processing personal data to merely storing in certain circumstances;
Object to us processing your personal data for direct marketing purposes;
Challenge our processing of your personal data which has been justified on the basis of our legitimate interests;
Transfer your data to another online service provider in certain circumstances;
Not be subjected to automated decision making (including profiling) in certain circumstances; and
Withdraw consent you previously gave us to use your personal data (where we process your personal data based on your consent).

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive; alternatively, we may refuse to comply with the request in such circumstances.

If you would like to exercise any of these rights, please contact us. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This security measure is designed to prevent the disclosure of personal data to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one calendar month (starting from the day we receive your request). Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you believe we used your personal data in a way we have not disclosed to you, please contact us as soon as possible so we may address your concerns. You also have the right to complain to the relevant supervisory authority in the UK or your country of residence in the European Economic Area.

Changes to this Employee Privacy Statement

We may revise this Employee Privacy Statement from time to time at our discretion and will post notifications of any changes to our Website. We encourage you to periodically review this Employee Privacy Statement to stay updated on our privacy practices.

How You Can Contact Us

If you have any questions about this Employee Privacy Statement or how we collect and use your personal data, or would like to exercise any of your privacy rights, please contact:

Data Protection Lead

Address: 1900 South Norfolk Street, Suite 350, San Mateo, CA 94403

Email: Privacy@Relyance.AI