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PRIVACY POLICY

Last Updated: 11/27/2024

Introduction. Elwood Staffing (“Company,” “us,” or “we”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (the "Policy"). This Policy informs our customers, employees, applicants, and visitors to Elwood Staffing's website (this “Site”) about our practices for collecting, using, maintaining, protecting, and disclosing certain data we collect through this Site as well as information we collect directly from you over the phone, via email, text message, or through computer or mobile software applications, when you visit our branches, or through other offline channels. In some cases, we may provide additional data privacy notices specific to certain services, practices, or regions. Those terms are to be read in conjunction with this Policy. This Policy does not apply to information collected by any third party through any application or content (including advertising or job ads) that may link to or be accessible from or through the Site.

Please read this Policy carefully. By accessing or visiting the Site or otherwise providing your Personal Information, you indicate your understanding that the collection, use, disclosure, and retention of your Personal Information is subject to the terms of this Policy and our Terms of Use, Except as otherwise noted, any capitalized terms not defined in the Policy have the meaning set forth in the Terms of Use. If you do not consent to the collection, use, disclosure, and retention of your Personal Information as described in this Policy, please do not provide us with such information.

Changes to this Policy. We reserve the right to change this Policy at any time. In the event we make material change(s) to the Policy, we will provide notice through the Site. Changes will be effective immediately upon posting to the Site and will apply to your use of the Site or submission of information after the “effective date” listed above. You understand and agree that your continued use of the Site or submission of information after the effective date means that the collection, use, and sharing of your Personal Information is subject to the updated Policy. Except to the extent we obtain your consent or as permitted or required by applicable law, we will handle your Personal Information collected through the Site in accordance with the terms of the Policy in effect at the time of such collection.

Information We Collect. As described below, we may collect or have collected in the preceding 12 months the following categories of Personal Information (“PI” or “Personal Information”). We may add to the categories of PI we collect and the purpose(s) we collect and use it. In those cases, we will inform and update this section of the Policy.

• Identifiers and Contact Information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, signatures, account names, dates of birth, bank account information, citizenship and country of residence, as well as your login credentials (like username and password) if you create an online account. For clients or prospective clients, your business name and contact information.
• Protected Classification Information. This category includes characteristics of protected classifications under California or federal law such as your age, ethnicity, gender, disability status and veteran status, where we are required to or permitted to do so by law.
• Commercial Information. This category includes, without limitation, products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Education Information. This category includes, without limitation, information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
• Internet or Other Electronic Network Activity Information. This category includes, without limitation, browsing history, search history, or a consumer's interactions with a website, application, or advertisement, your IP address, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform information when you are visiting our Site or using our IT systems.
• Geolocation Data. This category includes, without limitation, location information collected when using one of our apps, devices, or an application or device of a third party service provider or client to the extent such information is shared with us.
• Audio, Electronic, Visual or Similar Information. This category includes, without limitation, information collected from voicemail messages and/or by video camera, photos you provide to us or that you make publicly available on the internet (for example LinkedIn or social media websites); your image on video if you elect to do a video interview, and your image from a security camera if you visit a location with security camera footage.
• Biometric Information. This category includes, without limitation, an individual's physiological, biological, or behavioral characteristics used or intended for use – singly or in combination with each other or with other identifying data – to establish individual identity.
• Professional and Employment-Related Information. This category includes, without limitation, information regarding job applications, onboarding for payroll and benefits, as needed for evaluating performance and eligibility; your resume or C.V., employment history or education history; certifications and professional license information; language proficiencies; security clearance information or work authorization (for example citizenship information and proof of government issued identification); professional association memberships; volunteer activities; work-related skills and skills assessment information; and other relevant information (such as your photograph, interview notes and personal data included in a cover letter as part of the application process).
• Sensitive Personal Information. This category includes:
• Social Security, driver's license, state identification card, or passport number;
• log-in, financial account in combination with any required security or access code, password, or credentials allowing access to an account;
• precise geolocation;
• racial or ethnic origin;
• content of mail, email, and text messages (unless we are the intended recipient of the communication);
• biometric information;
• health information
• Consumer Profile. This category includes information drawn from any of the categories above to create a profile about a consumer reflecting the consumer's preferences, characteristics, and behaviors.
• Compensation and Benefits Information. This may include salary information (where permitted by applicable law), recurring payments and benefits, and dependents' names, addresses, dates of birth, and Social Security Numbers provided for purposes of benefits administration.
• Job or Position Information. For applicants or employees, this may include information such as your employment interests, desired compensation and shift, and desired work location. For clients or prospective clients, job titles, requirements, and wage information.
• Health and Safety Information. This may include health conditions relevant to your employment, workplace illness and injury information, and health insurance policy information.

Sources of Information. We may collect your Personal Information from the following sources:

• Directly from you. when you apply for a position or request a candidate, when you provide information through email, telephone, text message, mail, or other communications, when you visit our office locations, or when you provide it to us in any other way.
• From third parties. We also collect Personal Information about you from third party sources, such as through social media platforms, our clients, your references, news sources, and background check providers or other service providers.
• Through Automatic Data Collection Practices. As you navigate through and interact with our Site, we may compile statistical information concerning your usage of the Site through analytics services, such as those provided by Google Analytics.

Automatic Data Collection Practices. Our Site automatically collects certain non-identifiable information regarding users of the Site. Examples of such information include the internet protocol (IP) address of your computer, the IP address of your internet service provider, the date and time you access the Site and the sections or pages of the Site you visit. In the course of providing our services, we may also collect information related to your cellular service provider, the type of cellular phone you use, and unique device identifiers. This non-identifiable information is used for administration purposes and to improve the Site and services we provide. Non-identifiable information may be disclosed to others and archived for future use. The technologies we use for automatic data collection may include:

• Cookies  (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, and other traffic data. We use the information for security purposes, to recognize your device, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Site to enhance its functionality, understand how it is used and assist us with resolving questions about it. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
• Web Beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Analytics. We use third-party analytics such as Google Analytics on the Site. Google Analytics uses cookies and similar technologies and IP address to collect and analyze information about use of the Services and report on activities and trends. Google Analytics may also collect information regarding the use of other websites, apps and online resources. You can learn about Google's practices by going to www.google.com/policies/privacy/partners/, and opt out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Embedded Content and Social Media Widgets. The Site contains embedded content (e.g., videos) and Social Media Widgets (e.g., LinkedIn). Embedded content may place third party cookies on your device that track your online activity to enhance your experience or assess the success of their application. Social Media Widgets allow us to integrate social media functions into the Site. We have no direct control over the information these cookies collect; please refer to the applicable third party's website privacy policy for additional information.

IMPORTANT: By using the Site, you consent to the processing of any Personal Information for the analytics purposes and functions described above.

Do Not Track. “Do Not Track” is a privacy preference you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. Our Site is not configured to detect and respond to Do Not Track signals from a user's computer. We do not track individual consumer's online activities over time and across different Internet websites or online services when the consumer uses our Site.

How We Use Your Personal Information. In general, we will use the Personal Information we collect about you only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in this Policy. For example, we may use your information:

• To Operate Our Site. We may use your Personal Information to enable use of this Site, provide you with information or services, or to manage and administer the Site.
• For Internal Use. We may use your Personal Information to operate our business, including for
• providing you products or services;
• managing our contracts and agreements;
• in connection with recruiting, processing your application or assessing prospective employment including conducting background checks and drug testing where permitted by applicable law;
• managing our employment relationship including for onboarding, timekeeping, payroll, employee benefits, training and development, employee job performance (including reviews, promotions, discipline, and termination), and expenses reports;
• development, creation, maintenance, and security of online employee accounts;
• reaching emergency contacts when needed;
• workers' compensation and unemployment claims management;
• other human resources purposes;
• conducting internal audits and workplace investigations;
• engaging in corporate transactions requiring review of employee records;
• maintaining commercial insurance policies and coverages;
• equal opportunity monitoring or affirmative action programs;
• managing your profile;
• reviewing, improving, and monitoring our website, applications, online services, and overall user experience;
• providing customization to meet specific needs;
• assessing trends, interests, and demands of clients, applicants and employees;
• carrying out our obligations and enforcing our rights, including those arising from any contracts entered into between you and us, including for billing, payment, and collections;
• conducting research and for the development of the Site and the services and products we provide; and
• performing workforce analytics, data analytics, and benchmarking.
• To Communicate with You. We may use your Personal Information to respond to your requests for information relating to our services, staffing and HR solutions or employment opportunities; to communicate with you, including sending messages about the availability of our Site, security, or other product or service-related issues. (You may change your communication preferences at any time by contacting us at [insert]. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.) We may also send you administrative or account-related information to keep you updated about your account and the Site. Such communications may include information about Policy updates, confirmations of your account actions or transactions, security updates or tips, or other relevant transaction-related information. Site-related communications are not promotional in nature.
• To Provide Support Services. We may use your Personal Information to provide support services and engage in quality control activities concerning our services.
• To Enforce Compliance with Our Agreements or Policies. When you access or use our Site, you are bound to our Policy. To ensure compliance, we may process your Personal Information in connection with monitoring, investigating, preventing, and mitigating prohibited, illicit or illegal activities on our Site. We may also process your Personal Information to investigate, prevent or mitigate violations of our internal terms, agreements or policies; enforce our agreements with third parties and business partners; and for other purposes related to the services we provide to you, operation of our business, or your application for or employment with us or our clients.
• To Ensure the Security of the Services. We may process your Personal Information as necessary or appropriate to protect the rights, property, security, and safety of our employees, applicants, and clients, our information systems, and the public. Keeping you safe requires us to process your Personal Information, such as your device information, activity information, and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
• To Maintain Legal and Regulatory Compliance. Our business is subject to certain laws and regulations which may require us to process your Personal Information. We may also use your Personal Information to respond to law enforcement requests, as required by applicable law, court order, or governmental regulations, and for other lawful processes or public safety purposes.
• To Engage in Marketing Activities. We may process your contact information or information about your interactions with us to send you direct marketing via e-mail, messaging, phone or social media (you may opt-out of receiving future marketing communications at any time), keep you updated about the Site and our business; and provide you with information about events or other materials.
• Other Purposes. We may use your Personal Information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

Disclosure of Your information. In general, we will not disclose your Personal Information except with your consent and as described in this Policy. We may disclose your Personal Information for the same reasons that we may use it and as described in this Policy, which includes disclosing it to our affiliates and non-affiliates as we deem necessary to carry out those purposes. We endeavor to choose affiliates and non-affiliates whose standards for the protection of data match ours.

The following chart describes the categories of Personal Information we may collect about you and for each category, the categories of third parties to whom we may disclose or have disclosed Personal Information to within the last 12 months. In addition to the third parties and purposes listed in the chart below, we may disclose or have disclosed within the last 12 months all of the below categories of Personal Information to:

1. Potential buyers, successors, or third parties in preparation for or as part of any contemplated transaction to sell all or part of our business, subject to appropriate confidentiality and non-disclosure agreements.
2. Government agencies and legal service providers in order to comply with the law and in the course of providing our products and services, defend against claims made against us, or in the context of responding to a government agency or investigatory request.

Terms of Service for SMS (text) Communication.  If you choose to opt-in to receive text messages from Elwood Staffing, you may receive text messages related to job opportunities, referral contests or other marketing campaigns, information about your application status, onboarding materials, and other employment-related updates. We do NOT share information obtained as part of the SMS consent process, including your opt-in consent and your phone number, with third parties. If you consent to receive text messages, message and data rates may apply. You can opt-out at any time by texting, “STOP.” For assistance, text “HELP,” contact your local Elwood Staffing branch office, email privacy@elwoodstaffing.com, or visit our Privacy Policy and Terms of Use.

Safeguarding Personal Information. Elwood Staffing is committed to protecting the Personal Information you share with us. Elwood Staffing endeavors to use appropriate physical, technical, organizational and administrative security measures to help protect your Personal Information from unauthorized access, use, or disclosure.

The Site uses reasonable and appropriate security measures designed to protect against the loss, misuse and alteration of the information under our control. However, no system for safeguarding personal or other information is 100% secure and, although we have taken steps to protect your Personal Information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with Personal Information. No data transmission over the Internet can be guaranteed to be absolutely secure and you do so at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Links to Third Parties' Sites and Integrations. We may provide links to websites or resources outside of our Site for your informational purposes only. We may also provide links to third-party integrations. Third party integrations are websites or platforms that synchronize with our Site to provide you with additional functionality, tools, or services such as maps, sending requested information, etc.

You acknowledge and agree we are not responsible for the availability of third-party sites, resources, or integrations and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through, or provided by such sites, resources, or integrations. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of Personal Information that you provide, or that is collected by, such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.

Accessing and Correcting Your Information. If you have created an account, you can review and change your Personal Information by logging into your account. You may also contact your local Elwood Staffing branch office for assistance in accessing your account, correcting or deleting any Personal Information you have provided to us.

Information of Children. The Site is not directed to children as the products and services on this Site are intended for persons 18 years of age and older. The Company does not knowingly collect, use or disclose any Personal Data from children. If you are concerned about your child's use of the Site, you may use web-filtering technology to supervise or limit access to the Site.

Your Choices. You have the right to limit the information you provide us. If you choose not to provide us certain information we request, however, we may be unable to provide you access to certain of our services and/or content.

In accessing or using our services, you may be asked for your email address, phone or mobile number to allow communication with you regarding immediate or future job opportunities. Whether you opt to provide us that information is entirely up to you. However, we may not be able to assist you with your staffing or employment needs if you choose not to provide us with sufficient Personal Information.

We may use your email address, phone or text to send you information about our company or employment opportunities or services that fit your profile. Additionally, we may use your email address and other information you provide us to send you promotional or informational messages from time to time. You can opt out of this communication at any time. We will not sell or provide your email address or Personal Information to third parties without your consent.

Retention. We keep your Personal Information (including Sensitive Personal Information) for as long as reasonably necessary in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you or our client; (ii) as required by a legal obligation to which we are subject to (for example, certain laws require us to keep certain records for a specific period of time beyond the end of our ongoing relationship before we can delete them); (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations); (iv) and, other legitimate business needs.

We may delete Personal Information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, we may delete Personal Information from our database at any time and without providing any reason.

We may also retain your Personal Information in a deidentified or aggregated form so that it can no longer be associated with you.

Applicable law. This Policy is governed by the internal substantive laws of Indiana, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Policy shall lie exclusively with the state and federal courts within Indiana. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.

CALIFORNIA RESIDENTS

This section applies only to California residents and supplements and amends the information contained in the Policy. The other provisions of the Policy continue to apply, except as modified in this California section.

California Consumer Privacy Act. The following provisions describe our policies and practices regarding the collection, use, and disclosure of Personal Information we obtain about California residents through online (i.e., the Site) and offline channels (e.g., phone and email conversations, when you visit our locations or attend our events, or through our authorized services providers).

Any terms defined in the CCPA have the same meaning when utilized in this section. All other provisions of the Policy continue to apply except as modified herein. Please read this section carefully before using the Site or otherwise submitting information to us. By accessing or visiting the Site, or submitting Personal Information to us, you indicate your understanding that the collection, use, and sharing of your information is subject to the Policy, terms of this section and our Terms of Use.

We do not sell or share Personal Information of California residents, as those terms are defined by the CCPA, nor do we have actual knowledge that we have sold or shared the Personal Information of minors under the age of 16 .

We do not use or disclose your Sensitive Personal Information for purposes that, with limited exceptions, are not necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, to perform the services set forth in paragraphs (2), (4), (5), and (8) of subdivision (e) of Section 1798.140, or as authorized by regulations adopted pursuant to subparagraph (C) of paragraph (19) of subdivision (a) of Section 1798.185 .

Consumer Rights. California residents have the following rights with respect to the Personal Information we collect about them subject to certain exceptions.

Right to Know About Personal Information Collected or Disclosed. The Policy discloses our current practices as they relate to how we collect, use and disclose Personal Information. As a California resident, you have the right to request that we disclose additional information as it relates to our data collection activities during the preceding 12 months. To the extent applicable, you have the right to know:

• the categories of Personal Information we have collected about you
• the categories of sources from which we collected the Personal Information
• the business or commercial purpose for collecting, selling, or sharing Personal Information, if applicable
• the categories of Personal Information we sold or disclosed for a business purpose
• the categories of third parties to whom we sold or disclosed Personal Information
• the specific pieces of Personal Information we have collected about you

Upon receipt of a verifiable consumer request and as required by the CCPA, we will provide a response to your requests. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to Personal Information collected on and after January 1, 2022, and to the extent expressly required by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by us.

Right to Delete. You have the right to request that we delete Personal Information we collected or maintain about you, subject to certain exceptions. Upon receipt of a verifiable request, we will delete and direct any service providers, contractors and third parties to whom we disclosed your Personal Information, to delete your Personal Information.

We are not required to comply with deletion requests if we, or our service providers, contractors, or third parties need the subject information in order to:

• Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.
• Help to ensure security and integrity to the extent the use of the consumer's Personal Information is reasonably necessary and proportionate for those purposes.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when the Company's deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
• Comply with a legal obligation.
• Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Request Correction. You have the right, subject to certain limitations, to request that we correct any inaccurate Personal Information we maintain about you. Upon receipt of a verifiable consumer request, and as required by the CCPA, we will take appropriate steps to respond to your request.

Right to Non-Discrimination for the Exercise of Privacy Rights. We will not discriminate against you for exercising any of your rights under the CCPA. This includes but is not limited to: (A) denying you goods or services; (B) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (C) providing you with a different level or quality of goods or services; or (D) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Employees, applicants, and independent contractors have the right not to be retaliated against for exercising any of their rights under the CCPA.

Submitting Consumer Rights Requests

How to submit. To submit a California consumer rights request, please contact us by calling 888.505.3015 or emailing privacy@elwoodstaffing.com.

Verifiable Requests. We reserve the right to only respond to verifiable consumer requests to Know, Delete, or Correct. A verifiable consumer request is one made by any individual who is:

• the consumer who is the subject of the request,
• a consumer on behalf of the consumer's minor child, or
• the authorized agent of the consumer.

To verify your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information which we will only use to verify your identity, and for security or fraud-prevention purposes. Making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond.

Authorized Agents. You may authorize a natural person or a business (the Agent) to submit a request on your behalf. The Agent must provide signed permission to submit the request, and you must either (i) verify your own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. These steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

We may not be able to respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Our response. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.

We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to Personal Information collected on and after January 1, 2022, and to the extent expressly permitted by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not be impossible or require a disproportionate effort by us. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.

Fees. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request.

Contact Us. If you have any questions or comments about this Policy, the ways in which Elwood Staffing collects and uses your information, your choices and rights regarding such use, please contact us at:

Phone: 888.505.3015

Email: privacy@elwoodstaffing.com

Elwood Staffing Services, Inc.

Attn: General Counsel

PO Box 1024

Columbus, IN 47201