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Qualia or “we or “us” or “our” refer to Qualia Labs, Inc. and its subsidiaries and affiliates.
Employee or “you” refers to all candidates, employees, separated employees, directors, officers and Board members of Qualia.

This Employee Data Privacy Notice does not apply to visitors to Qualia’s sites or users of Qualia’s services (e.g. customers). This policy applies to prospective employees (e.g. candidates or applicants or recruits), current employees, and separated employees. This policy also applies to personal information collected and used in connection with retaining and using consultants and individual contractors. This policy also applies to data collection or use wherever this policy is posted.

Personal information for purposes of this Privacy Notice means any information that (i) directly and clearly identifies an individual, or (ii) can be used in combination with other information to identify an individual. Personal information does not include such information if it is anonymous or if it has been de-identified by removing personal identifiers or through aggregation with other data.

We reserve the right to update this Employee Data Privacy Notice to reflect changes in the law or in our practices. We will make commercially reasonable efforts to alert you of any material changes. You are free to review this policy at any time.

1. Information We Collect & Use

Information You Provide To Us

• Identification data – such as your name, gender, photograph, date of birth, employee identification number
• Personal Characteristics - such as race, veteran status which are typically optional and assist us with reporting to the U.S. government on equal opportunity or disability status in relation to requests for accommodations
• Prospective Employee Biometric Data – biometric identifiers, which are individual pieces of information about you (for example: scans of facial geometry) or biometric information, which is information about you that is based on biometric identifiers and used to identify you
• Contact details – such as home address, telephone number, email addresses, for you and your emergency contacts
• Employment details – such as job title/position, office location, key dates (e.g., date of hire, date of separation), employment contracts, performance and disciplinary records, grievance procedures, time off balances and requests, compensation information.
• Educational, professional and personal background – such as academic/professional qualifications, education, CV/résumé, reference letters and interview notes, country of origin.
• Government Issued Identification Numbers – such as social security numbers (SSNs), visa numbers, drivers license numbers.
• Beneficiary & dependents information - such as marital status, information about spouse and children or designated policy beneficiaries (e.g. life insurance beneficiary), including dates of birth, SSNs.
• Financial information – such as banking details, tax information, payroll information, withholdings, court-order child support, court-ordered garnishments, salary, benefits, expenses, company allowances, stock or equity grants.
• Health information – such as information about vaccination status, short- or long-term disabilities or illnesses that you might share with People Ops or your manager, particularly in relation to any leave of absence you may need to take.
• Policies & Trainings - such as acknowledgements regarding policies or trainings, including employee handbooks, ethics and/or conflicts of interest policies, and computer and other corporate resource usage policies.
• Other information you choose to share with us – such as hobbies, social media accounts, garment size(s) etc.

Information We Generate or Collect Automatically

• Employee ID Number
• IT information – such as information related to access or use of Qualia’s computers, hardware, software, data (including Qualia Data), devices, peripherals, networks, communications systems, and physical security systems and devices (“Qualia Resources”) such as IP addresses, log files, login information, software/hardware inventories. For further information about how we process IT information, see our “Monitoring” section below.
• Clickstream data, such as web log data, referring and exit pages and URLs, platform type, number of clicks, IP address, domain names, landing pages, including pages and content viewed and the order of those pages, the amount of time spent on particular pages, actions completed, transaction types, location of transactions, tasks and workflows, time spent completing tasks and workflows, the date and time of use of the Services, the frequency of use of the Services, other usage patterns, error logs, unique identifiers, device attributes, such as operating system and browser type.
• Cookies & Related Technologies - cookies and related technologies, such as web beacons or pixels, can help websites and services tailor sites to your preferences, track your use, including the pages you visit, manage content, compile statistics about usage of services, and learn about your online activity including on other sites or services. In connection with our careers pages or presence on other platforms, such as Greenhouse, we may collect and analyze data, including the clickstream data described above, gathered in connection with cookies and related technologies.

Information We Collect from Others

• Professional Background - such as information on social or professional networks or provided by external recruiters
• Personal Background - such as credit history or criminal records checks and data where permitted by applicable law.

2. How We Use Your Personal Information

In general we use personal information for purposes of recruiting, hiring, retaining and supporting employees (current and separated) or to meet our retention and reporting requirements, and we may use tools that leverage machine learning and artificial intelligence for such purposes and requirements. Some specific uses of personal information include:

• recruiting purposes, determining eligibility for hiring, including the verification of references and qualifications and, where permitted by law, administering background checks, verifying right to work;
• administering payroll and benefits as well as processing employee work-related claims (e.g., worker compensation, insurance claims, etc.) and disability accommodation, time off and leave of absence requests;
• gathering feedback, including via surveys;
• establishing training and/or development requirements;
• reviewing work performance and determining performance requirements;
• disciplinary actions or termination;
• establishing emergency contacts and responding to emergencies;
• establishing and maintaining relationships with customers and service providers;
• complying with laws and regulations (e.g. labor and employment laws, health and safety, tax, anti-discrimination laws), under judicial authorization, or to exercise or defend legal rights;
• compiling internal directories, such as employee directories;
• to detect fraud or other types of wrongdoing;
• IT security and administration (See Monitoring section below); and
• for other legitimate purposes reasonably required for day-to-day operations, such as accounting, financial reporting and business planning.

Prospective Employee Biometric Data is collected to verify your identity for your employment candidacy and for identity fraud prevention purposes. Your Biometric Data will be destroyed or otherwise deleted from Qualia’s systems within the time period required by applicable law and regulation.

Monitoring (Limited Right of Privacy)

We reserve the right to monitor the use of our equipment, devices, computers, network, applications, software, and similar assets and resources for the safety and protection of employees, sensitive data and intellectual property. In the event such monitoring occurs, it may result in the collection of personal information about you.

Qualia physically and electronically monitors its offices. For example, we may monitor employees’ activity and presence in our offices with badge readers, sign-in sheets, and surveillance cameras. We generally do these things to prevent unauthorized access to our offices and to protect employees, authorized visitors, and our property.

Qualia may also monitor or record activity on Qualia Resources (including IT equipment and communications systems and networks), such as internet traffic, website filtering, email communications, systems or data accessed. We generally do these things to prevent and detect unauthorized access to or use of systems and data. And we may record calls and meetings with co-workers or with prospects and customers. More information on electronic monitoring is available in Qualia’s Acceptable Use Policy.

Where permitted by law, we may also carry out monitoring for other purposes such as:

• Proof of business transactions and archiving;
• Training and evaluation of employees;
• Protection of confidential information, intellectual property and other business interests;
• To investigate breaches of Qualia policies and procedures, or other unlawful or improper acts;
• For compliance with a legal obligation;
• Other legitimate purposes as permitted by applicable law.

3. Sharing - With Whom Do we Share Your Personal Information

• Service Providers - third parties who help us provide compensation, benefits and other services relevant to employing people, such as benefit plan providers, payroll support services and employee travel management services.
• Contractors, Other Qualia Companies, Customers - to support effective operations
• Other employees - to support effective operations, communications and growth
• If we go through a corporate sale, merger, reorganization, dissolution or similar event, personal information described in this Data Privacy Notice may be transferred in connection with such an event. Any acquirer or successor of Qualia may continue to use the personal information as described in this Data Privacy Notice.
• Other Potential Disclosures - We may also disclose your personal information to a third party under the following circumstances:
  • if we in good faith believe we are obligated by any applicable law, regulation, legal process or government authority;
  • where necessary to exercise, establish or defend legal rights, including to enforce our agreements and policies;
  • to protect Qualia’s rights or property;
  • to protect Qualia, other employees, our customers, or the public from harm or illegal activities;
  • to respond to an emergency which we believe in good faith requires us to disclose data to prevent harm; or
  • with your consent.

4. Security

We employ organizational and technical measures that are intended to safeguard the personal information we collect, use or store. For example, encryption at rest and role-based access controls are utilized to limit access to employee personal information. Please note that no system for transmission or storage of data is completely secure. So, while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.

5. Supplemental Privacy Notice for California Residents

This section supplements the information contained in the Qualia Employee Data Privacy Notice and applies solely to employees and contractors who are residents of the State of California, as defined in Section 17014 of Title 18 of the California Code of Regulations.

A. Information We Collect and Purposes For Which It Is Used

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“CA Personal Information”).

• Categories of CA Personal Information Collected - Section 1 describes the categories of personal information we collect.
• Purposes of Collection and Use - Section 2 describes the purposes for which we collect and use personal information.
• Categories of Sources of CA Personal Information - Section 1 describes the sources of personal information that we collect and use.
• Categories of third parties to whom Qualia discloses CA Personal Information - Section 3 describes the categories of third parties to whom we might disclose your personal information
• Retention - Qualia retains or stores CA Personal Information for as long as necessary to: achieve the purpose for which it is processed; comply with retention periods established by applicable law; resolve disputes or enforce our agreements.
• Sell or Share - We do not knowingly sell or share as defined by California’s CCPA CA Personal Information that pertains to employees.

B. Individual Rights

If you are a California resident, you may have certain rights in relation to your CA Personal Information. California law may permit you to request that we:

• Provide you the categories of CA Personal Information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting, selling, or sharing your personal information; and the categories of third-parties with whom we share CA Personal Information (as defined under CA law and if applicable) or to whom we sell CA Personal Information (as defined under CA law and if applicable).
• Stop selling your CA personal Information (if applicable)
• Stop sharing your CA Personal Information (if applicable)
• Provide access to or a copy of certain California Personal Information we process.
• Correct inaccurate CA Personal Information that we process.
• Delete certain CA Personal Information we process.

You may have the right to receive information about the financial incentives that we offer to you. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights.

Certain information may be exempt from such requests under applicable law.

C. Exercising Your Rights

If you wish to review your personal information, we recommend accessing the relevant systems, such as ADP, many of which are designed to allow you to review information and update or correct it. These systems may also support exports of your CA Personal Information.

Before satisfying a rights request Qualia may need to take steps to verify the identity of the requestor. These steps may include: requiring you to log in to the appropriate account (if applicable); confirming your possession or knowledge of certain information about our relationship with you; asking you to complete a declaration regarding your identity. If your request is submitted by an agent, Qualia may take steps to verify your identity as well as the authority of the agent, including whether the agent is registered with the California Secretary of State. If we cannot verify the identity of a requester or the authority of an individual’s agent (if applicable), we will not satisfy the request.

Exceptions to Rights Requests. CCPA sets out a number of grounds on which a business may deny a rights request. For example a request to delete may be denied if the CA Personal Information is needed to: complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relations with you or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for such activities. If there are reasonable grounds for denying a rights request, we will advise you of that fact.

If you have a request to access, correct or export your CA Personal Information that you cannot conduct yourself, please contact people@qualia.com. If you have a request to delete CA Personal Information, please contact people@qualia.com.

7. General - Concerns & Contact Info

In general we hope to process your personal information in a manner that acknowledges the sensitivity of some of the information, strives to keep it up to date and accurate, and addresses any questions or concerns you may have about your personal information. If you have a question or concern about how your personal information is processed, contact people@qualia.com.