Last Updated: December 10, 2024

This Employee, Contractor, and Applicant Privacy Notice (“CA Notice”) applies solely to those who reside in the State of California and are a job applicant to, an employee of, owner of, director of, officer of, or a contractor (“consumers” or “you”) of Spectrum Equity Management, L.P., Spectrum Management Equity, Inc. or their affiliates (collectively referred to as “Spectrum,” “we,” “us” or “our”). This CA Notice describes how we collect, use, and share HR-related personal information of consumers when we act as a “business” as defined under the California Consumer Privacy Act (“CCPA”), and their rights with respect to their personal information. For purposes of this Notice, “personal information” has the meaning given under the CCPA but does not include information exempted from the CCPA.

This CA Notice applies to Spectrum’s processing of your personal information as an employee, owner, director, officer, contractor, or job applicant and does not cover your use of Spectrum’s services outside of your regular employment, of your role as a contractor, of your board, ownership, or management position, or of the job application process. If you use Spectrum’s website and services, please see the Spectrum’s general website privacy policy for additional information.

This CA Notice does not apply to the privacy practices of third parties, including third-party job boards where our job openings may be posted, recruitment websites, or Spectrum portfolio companies. Please review the applicable privacy notice provided by those third parties for information about their privacy practices.

This CA Notice does not create or form part of any contract for employment or otherwise. If you are a contractor receiving this CA Notice, it is not intended to create an employment relationship between Spectrum and you.

Categories of Personal Information We Collect

Depending on how you interact with us and whether you are an applicant, employee, owner, director, officer, or contractor, we may collect, and in the twelve (12) months preceding the “Last Updated” date of this CA Notice may have collected, the following categories of personal information about you and, if applicable, your dependents and beneficiaries. Please note that the following list of examples is intended to be illustrative and not exhaustive:

Categories of Personal Information Collected

Category: Identifiers
Examples:

• Name (including first name, middle name or initial, and last name)
• Email address (may include personal and work)
• Home address
• Business address
• IP address
• Device ID or device name
• Personal phone number
• Business phone number
• Social Security Number
• Online identifiers
• Employee ID
• Visa status

Category: Protected classification information
Examples:

• Marital status
• Age / date of birth
• Disability information (relating to any accommodations you request)
• Veteran or military status
• Race or ethnicity
• Sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions or events)
• National origin
• Citizenship
• Sexual orientation
• First generation status (e.g., college, financial)

Category: Biometric information
Examples:

• Biometric information that may be requested as applicable to your role, such as fingerprints collected to satisfy a legal obligation

Category: Internet/electronic activity
Examples:

• Information about your use of, and the content and communications that you store on or send and receive through, our devices, internal networks, information and communications systems, applications, or databases, including time of use, files accessed or downloaded, or other information relating to your activity, usage, or device
• General location information, such as general geographic location based on the log data we or third-party providers collect
• Records of text messages sent or received, where applicable if we are required to retain these records for our legal obligations

Category: Audio, electronic, visual, thermal, olfactory, or similar information
Examples:

• Information about your access to our physical offices (e.g., badge scans or security camera footage)

Category: Professional/employment related information
Examples:

• Resumes/CVs
• Social media profile information, such as LinkedIn profile and the information you make available on it, including past experiences and education
• Interview and assessment responses, such as responses to case studies or model exercises, or to surveys or personality assessments that we request
• Academic data (e.g., GPA, transcripts, expected graduation year)
• Career planning information (e.g., geographic preferences for office location)
• Language(s) spoken
• References (including contact information and relationship)
• Relationship(s) with existing employees (for applicants), if applicable
• Background checks, including reports and records of consent
• Emergency contacts (including name, phone number, and relationship)
• Dependents and beneficiaries
• Employment information such as hire date, location, business unit, department, job title, salary, standard hours, restrictions or accommodations, termination date, and other related information
• Performance-related information, such as performance reviews and disciplinary records
• Employment eligibility information, such as visa information or Form I-9
• Bank direct deposit and payroll information
• Retirement plans, life insurance, health insurance, or other benefits information, including account details, information needed for enrollment, use, or maintenance, and information about beneficiaries and dependents

Category: Education information
Examples:

• Transcripts, course records, or other information that you provide or have sent to us

Category: Inferences drawn from personal information

• Profiles reflecting your personal characteristics, abilities or aptitudes used in connection with performance reviews or job application vetting, such as an employee personality profile if you complete a personality assessment

Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, if you agree to provide the information as part of the application process and through your role as an employee, owner, director, officer, or a contractor of Spectrum.
• Third-party sources. For example, from a reference supplied by you, information that you provided to a job board to apply for a position, background check providers and other employment service providers, public social media profiles and other publicly available sources, or employment agencies and recruiters.
• Automatic collection. For example, personal information is automatically collected when we monitor our IT and communications systems, devices, equipment and applications, including through manual review and automated tools such as security software, spam filtering, audit logs, and other means. We also monitor our physical premises, including by using security cameras and badge scans.

Purposes of the Collection and Use of Personal Information

We may use, and in the twelve (12) months preceding the “Last Updated” date of this CA Notice have used, the personal information we collect for one or more of the following business purposes within the context of your role as a job applicant to, an employee of, owner of, director of, officer of, or a contractor of Spectrum, or as otherwise described in this CA Notice or at the point of collection:

• To evaluate you as a possible employee, owner, director, officer, or contractor for Spectrum or its portfolio companies.
• To manage the performance of job duties.
• To fulfill or meet the reason you provided the information. For example, if you share your bank account number, we will use that information to process your compensation.
• To comply with our health, safety, compliance, and fraud-prevention obligations.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations or investigations.
• To establish, exercise, or defend legal claims.
• To authorize, grant, administer, monitor, and terminate access to or use of company systems, facilities, records, property, and infrastructure.
• To manage business travel (e.g., car service/rentals, flights, hotels) and personnel expenses (e.g., reimbursement, corporate credit card).
• o effectively process payroll and in connection with incentive equity grants.
• To administer and maintain employee benefit plans including group health plans, 401(k) plans and other welfare and retirement plans and perquisites.
• To operate, maintain and protect the security of our network systems and devices.
• To protect our proprietary and confidential information and intellectual property.
• To prevent, mitigate, investigate and respond to security and other incidents.
• For business continuity (such as monitoring business-related emails following an employee’s departure).
• In the event of a merger, acquisition, disposition of all or substantially all of the relevant assets of the business, bankruptcy, or similar event (including due diligence related thereto).
• To create anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business and for other lawful business purposes.
• As described to you when collecting your personal information.
• As otherwise authorized or required by applicable law.

Disclosure of Personal Information

We may disclose, and in the in the preceding twelve (12) months may have disclosed each of the categories of personal information described above with other parties as necessary for the business purposes described above, including the following persons or entities:

• Affiliates. Our subsidiaries, and other affiliates, for purposes consistent with this CA Notice or to operate shared infrastructure, systems, and technology.
• Service providers. Companies that provide us with services that help us manage the recruiting process and operate our business, such as job boards (e.g., Getro), recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), recruitment analytics, benefit administrators, compensation, payroll, and tax providers.
• Business contacts and other external audiences. We may share employee personal information with current and prospective partners and other business contacts with whom we share your Spectrum bio, which may be shared on our website or in other publicly available marketing materials and communications as part of our business activities.
• Government authorities, law enforcement and others. Under certain circumstances, we may be required to disclose your personal information to government authorities, law enforcement, courts, and others if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). We may also disclose your personal information when we believe in good faith that disclosure is necessary for the protection, safety, fraud prevention, or compliance purposes described in the “Use of Personal Information” section above.
• Business transaction participants. Parties to transactions and potential transactions whereby we sell, transfer, or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
• Professional advisors. Lawyers, immigration advisors, and other outside professional advisors.
• Customers and business partners. Customers, other companies, and individuals with whom Spectrum does business or is exploring a business relationship.

We do not “sell,” and in the preceding twelve (12) months have not “sold” any of the categories of personal information above to third parties for monetary or other valuable consideration within the meaning of the CCPA. Further, we do not “share,” and in the preceding twelve (12) months have not “shared” any of the categories of personal information above for purposes of cross-context behavioral advertising within the meaning of the CCPA.

Retention of Personal Information

Except as explained below, we retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this CA Notice or a related and compatible purpose consistent a reasonable person’s expectation, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.

We will retain application information for applicants beyond consideration of the immediate position for which the application is submitted in case future positions or opportunities become available at Spectrum or at a Spectrum Equity portfolio company. Application information for successful applicants becomes part of the applicant’s employment file and is treated accordingly.

Sensitive Personal Information

The following personal information elements, which are also identified above, may be classified as “sensitive” under the CCPA: Social Security number, racial or ethnic origin, citizenship or immigration status, or work-related accounts and passwords.

To the extent that we collect sensitive personal information, we only use or disclose it for purposes permitted under the CCPA (e.g., to perform HR activities such as payroll and benefits or for compliance and safety purposes). We do not collect or use sensitive personal information for the purpose of inferring characteristics about you.

Your California Privacy Rights

Under the CCPA, subject to certain exceptions you have the right to request the following with respect to your personal information:

Right to Know. You have the right to request that we disclose the following:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The business or commercial purpose for collecting, selling, or sharing that personal information (if applicable);
• The categories of third parties to whom we disclose that personal information; and
• The specific pieces of personal information we have collected about you.

Right to Delete. You have the right to request that we delete personal information collected from you.

Right to Correct. You can ask us to correct inaccurate personal information that we maintain about you.

Right to Nondiscrimination. You have a right not to receive retaliatory or discriminatory treatment for exercising any of the rights described above.

Please note, these rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

To submit a request, please contact us at 1-415-464-4600 or by emailing us at compliance@spectrumequity.com.

We may need to confirm your identity to process your requests. In addition, consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Changes to Our Privacy Notice

Spectrum recognizes that protecting your personal information is an ongoing responsibility and so it will update this CA Notice as it undertakes new practices involving your personal information. We reserve the right to amend this CA Notice at our discretion and at any time. Any changes will become effective when we post the revised CA Notice on our website at www.spectrumequity.com.

Your Obligations

It is your responsibility to ensure that information you submit does not violate any third party’s rights.

You should keep your personal information on file with Spectrum up to date and inform us of any significant changes to it.

Contact Information

If you have any questions or comments about this CA Notice or the ways in which Spectrum collects and uses your personal information described here, please do not hesitate to contact us by phone: 1-415-464-4600 or email: compliance@spectrumequity.com.