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PRIVACY POLICY

This Privacy Policy (“Policy”) describes how Paychex, Inc. and our subsidiaries
and affiliates, with its corporate offices located at 911 Panorama Trail South,
Rochester, NY 14625 (“Paychex,” “we,” “us,” or “our”), transmit, use, share and
protect business, financial, and personal information. This Policy applies to
all information provided, transmitted, or submitted to Paychex in connection
with the services provided to or on behalf of our clients (“Services”),
including on this website and mobile applications (“Site”).

Data privacy, and the privacy of the information provided, is important to us.
We use reasonable care to protect data provided to us by or on behalf of our
clients or prospective clients (“Clients”) and their workers or from visitors of
our Site (collectively “You” or “Your”) from loss, misuse, unauthorized access,
disclosure, alteration and untimely destruction. This Policy governs personal
information collected, processed, or disclosed by Paychex for its own purposes
as well as information provided to us as a service provider for our Clients. It
protects information collected online as well as offline. We may receive
personal data from our Clients about their current and/or prospective workers,
as well as workers’ dependents and/or family members as needed to provide
Services. Paychex will collect and process Your personal information as
instructed or permitted by our Clients or in accordance with this Policy.

We do not grant access to personal information except as set forth herein. We do
not share or sell personal information provided or transmitted to our Site with
any third parties for their own marketing purposes. At times, we will provide
links to other websites not affiliated with Paychex. We encourage You to be
aware when You leave our Site, and to read privacy policies regarding how third
parties may use or process Your information.


WHAT INFORMATION IS COLLECTED

We limit the information that we collect, to the information that we need to
provide our Services, to administer and improve the Site or our Services, and to
fulfill any legal and regulatory requirements.
The categories of personal information that we may collect include the
following:

 * Contact information to allow us to communicate with You or to provide the
   Services
 * Financial and bank account information as needed to provide the Services
 * Social security number, date of birth, name, address, email address, phone
   number, including mobile phone number, and other details as needed to provide
   the Services
 * Credit, debit, or payment card information if used
 * Credit or debt history regarding creditworthiness or credit history, with
   proper disclosures
 * Health and benefits information, which may include health plan numbers,
   beneficiary or dependent identification and contact information, and other
   health information as needed to provide the Services
 * Employment history and application information submitted through our
   recruiting and applicant tracking Service
 * Geolocation data, including your IP address, to provide Services or if
   geolocation Services are enabled for time and attendance tracking
 * Other personal information as needed to provide specific Services
 * Other information and documentation provided as part of Paychex’ customizable
   fields or Services, to be stored within the Site and Services, which may
   include other personal information, personal health information, and/or other
   human resource information Client seeks to collect and retain through the
   Site. Clients are responsible for the maintenance and retention of any
   information or documentation stored with Paychex’ customizable features.


HOW PERSONAL INFORMATION IS COLLECTED OR TRANSMITTED

To access or use certain information, features, or Services, You may be required
to provide personal information. Personal information is primarily collected,
submitted, and/or transmitted:

 * When a Client provides it to Paychex to facilitate the processing of the
   Services
 * From You when You utilize the Site or Services
 * From applications, forms, webinars, surveys, and other information You
   provide us
 * If You provide us with comments or suggestions, request information about our
   Services, or contact our customer service or support departments via phone,
   email, chat or other forms of communication
 * From consumer and business reporting agencies regarding Your creditworthiness
   or credit history
 * Between Paychex and third party vendors
 * From information You may provide via Social Media. For information regarding
   safe and productive participation in our social media community, view our
   Social Media Guidelines


HOW PERSONAL INFORMATION IS USED

We may use personal information to:

 1.  Facilitate current, prospective, or former employer requested Services,
     transactions, investments, distributions and/or benefits
 2.  Administer and improve our Site
 3.  Facilitate applicant tracking and recruitment
 4.  Facilitate billing and collections
 5.  Contact Clients and consumers with information on Services, new Services or
     products, or upcoming events, including via SMS or MMS text messaging if
     mobile phone number is provided for that purpose
 6.  Offer advanced analytics and insights to help Clients with business
     planning and decision making
 7.  Market our Services to Clients and consumers or for auditing our
     interactions
 8.  Detect fraud or theft or for other security purposes
 9.  Comply with legal, reporting, and regulatory requirements
 10. Maintain, manage, or service accounts
 11. Provide customer service or support
 12. Verify consumer identity as well as eligibility to receive Services,
     information, and products
 13. Research and develop technological improvements
 14. Send transactional communications as part of our Services
 15. Improve, upgrade, or enhance our Services
 16. Administer quality and safety maintenance for our Site or Services
 17. For other purposes that are compatible with this Privacy Policy or where
     permitted by applicable law
 18. In any other way we may describe when You provide the information, or for
     which You provide authorization


PARTIES WITH WHOM INFORMATION MAY BE SHARED

Information is shared to facilitate the Services requested by or on behalf of
our Clients or for our business operations. We may share information with:

 A. Our affiliates, partners, or subsidiary organizations
 B. Government agencies to fulfill legal, reporting and regulatory requirements
 C. Attorneys, accountants and auditors
 D. Credit reporting agencies to supply vendor references on Client’s behalf or
    to provide credit related Services as requested by You
 E. Our employees, affiliated companies, subsidiaries, contractors, agents and
    third-party vendors to perform Services related to your account, to offer
    additional Services, perform analysis to determine qualification to receive
    future services, collect amounts due, or for our business operations
 F. Third-party providers for services that You may sign-up for via our Site or
    Services
 G. Banking and brokerage firms to process payroll-related and/or securities
    transactions
 H. To a buyer or successor in the event of 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
 I. Credit bureaus and similar organizations, law enforcement or government
    officials. We reserve the right to release information if we are required to
    do so by law or if, in our business judgment, such disclosure is reasonably
    necessary to comply with any court order, law, or legal process, in a fraud
    investigation, an audit or examination
 J. Health and welfare providers in support of benefit Services
 K. Cloud providers, customer management platforms, security providers, and
    similar Services in connection with providing products, Services and in the
    support of daily operations
 L. Any other entity disclosed by Paychex when You provide the information, or
    for which You provide authorization


DATA RETENTION

We retain personal information for as long as necessary to provide the Services
and fulfill the transactions requested by or on behalf of Clients, or for other
essential purposes such as complying with our legal obligations, maintaining
business and financial records, resolving disputes, maintaining security,
detecting and preventing fraud and abuse, enforcing our agreements, and for any
other necessary business purpose.


BIOMETRICS – COLLECTION, TRANSMISSION, RETENTION AND DESTRUCTION

For the purposes of this Policy, “biometrics” may include an individual’s
physiological characteristics that can be used, singly or in combination with
each other or with other identifying data, to establish individual identity.
Examples of biometrics include, but are not limited to, imagery of the iris,
retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from
which an identifier template, such as a faceprint, a minutiae template, or a
voiceprint, can be extracted.

In addition, the workers of Clients that use Paychex timekeeping devices may
provide an iris, finger or facial scan as part of the timekeeping process, which
the technology converts into a mathematical, encrypted algorithm, or template.
These templates are sometimes called “biometrics.” For purposes of this Policy,
Paychex broadly includes within the term “biometrics” the templates created in
the timekeeping process and treats the templates as if they are considered
“biometrics” under applicable laws. Paychex complies with all laws applicable to
it related to the use of biometrics. Clients are solely responsible for their
own compliance with all applicable laws and regulations relating to the
collection, storage, and use of biometric information, including with respect to
Client’s use of Paychex products and Services for which Client’s workers provide
biometrics. Some details about biometrics:


BIOMETRIC COLLECTION

 * Biometrics are collected by Clients from workers using Paychex’s timekeeping
   technology
 * Some laws require employers to provide workers with notice of the use of
   biometrics in timekeeping, and to obtain worker consent
 * Paychex timekeeping devices have “notice and consent” screens that Clients
   can use to provide notice and obtain consent during the enrollment process,
   or Clients can choose to obtain consent from workers through other means.
   Newer Paychex timekeeping devices require the use of Paychex notice and
   consent screens.
 * If a Client’s worker is using biometrics to record time, Paychex will presume
   one or more of the above notices and consent processes are being followed at
   Client’s worksite
 * Note: Some applications allow the use of a smartphone device, and the device
   itself collects biometrics for access to the application. The consent process
   is part of the smartphone and is controlled by the user/worker. When
   smartphone devices are used, geolocation information may be provided to
   Client to ensure that workers are located at their appropriate work location.


BIOMETRIC TRANSMISSION AND STORAGE

 * Following collection at Client’s worksite, the resulting templates are stored
   in the timekeeping device, and are also transmitted for storage on a database
   hosted by either the Client, Paychex, or a third-party web hosting service
 * Paychex requires that reasonable care be used for transmission of biometrics
   to storage on any Paychex-hosted or third-party database
 * Paychex provides secure transmission and storage for biometrics, which use
   reasonable standards of care within Paychex’ industry, and which are the same
   as the manner in which other confidential and sensitive information is
   transmitted and stored
 * Paychex does not sell, lease, trade, or otherwise profit from biometrics
 * Paychex collects latitude and longitude coordinates from the device as part
   of the timekeeping process when geolocation services are enabled


BIOMETRIC DESTRUCTION

 * Biometric templates are and shall remain the property of Client, which is
   responsible for biometric template destruction when the biometric template is
   no longer needed, or within (1) year from Client’s last contact with a
   worker, whichever is first
 * When instructed by its Clients to destroy biometric templates, Paychex will
   promptly comply with that request
 * Paychex will destroy the biometric templates of former or inactive Clients
   who fail to destroy such data, within a reasonable time period after Paychex’
   last interaction with the Client


HOW AGGREGATED, NON-PERSONAL INFORMATION IS USED

We may collect general, non-personal, statistical information about the users of
the Site and our Services to determine information regarding the use of our Site
and general information about our Clients and Service interactions. We also use
aggregated, non-identifiable information to provide statistical data, such as in
the Paychex Small Business Jobs Index, or to provide insights to our Clients
associated with their workforce as part of our Services.


HOW COOKIES AND OTHER RELATED TECHNOLOGIES ARE USED

A “cookie” is a piece of data that our Site may provide to Your browser while
You are at our Site. The information stored in a cookie is used for user
convenience purposes, such as reducing repetitive messages, tracking helper tool
versions, and retaining user display preferences. If a user rejects the cookie,
they will be able to browse the Site but will be unable to use our online
application.
During Your interaction, a Service may automatically collect information from
Your activity or device including:

 * Computer, device, and connection information, such as browser type and
   version, operating system and other software installed on Your device, mobile
   platform and unique device identifier and other technical identifiers,
   including IP addresses, error reports and performance data
 * Usage data such as user preferences including features, settings, date and
   time stamps, and pages visited

Paychex may use third-party service providers who use cookies, web beacons, and
similar technologies to collect, transmit, or receive information from our Site
and elsewhere on the internet and use that information to provide measurement
services and target ads. You can opt-out of this information tracking using a
web browser that supports Do Not Track functionality, or by manually opting out
via sites like the Digital Advertising Alliance Consumer Choice Page.


CHILDREN UNDER 13 YEARS OF AGE

This Site is not intended for children under 13 years of age. We do not
knowingly collect and/or transmit personal information from children under 13
years of age. All dependent data needed for benefits enrollment shall be
provided by the employee/guardian and kept secure as indicated in this Policy.


SECURITY

Paychex uses reasonable care to protect the confidentiality, integrity, and
availability of Your information and we continue to invest in our award-winning
security capabilities, including personnel security and physical security;
system security, access control, and monitoring; data backup and business
continuity management; and vulnerability and intrusion detection. Specifically,
we:

 * Maintain policies and procedures covering physical and logical access to our
   workplaces, systems, and records
 * Apply physical, electronic, and procedural safeguards aligned with
   industry-recognized best practices
 * Use technology such as backups, virus detection and prevention, firewalls,
   and other computer hardware and software to protect against unauthorized
   access to or alteration of Your information
 * Encrypt sensitive information transmitted over the internet
 * Through formal approval processes, access controls, and internal auditing,
   limit our employee’s access to Client information to those who have a
   business reason to know
 * Require our employees to take information security awareness training upon
   hire and annually thereafter and apply this training to their jobs every day
 * Provide ongoing training and awareness to our employees about security best
   practices, including internal phishing simulations for education and testing
   purposes
 * Use advanced technologies for the backup and recovery of Your information
 * Monitor compliance with established policies through ongoing security risk
   assessments and internal audits

While we help protect the security and integrity of Your information through
procedures and technologies designed for this purpose, the safety and security
of Your information also depends on You. We may give You, or You may choose,
account credentials to access certain parts of our Site or Services. It is
solely Your responsibility to maintain the security and confidentiality of Your
account credentials and the information and Services accessible through Your
account and the Site. You are not permitted to share or sell Your account
credentials to any third-party, unless authorized. If You suspect fraudulent or
abusive activity relating to Your account, or if Your credentials have been
lost, stolen or compromised in any way, You should immediately change Your
potentially compromised credentials and notify Paychex and your employer.

Unfortunately, the transmission of information via the internet is not
completely secure. Although we do our best to protect Your personal information,
Paychex cannot guarantee the security of Your personal information transmitted
to us. Any transmission of personal information is at Your own risk. We are not
responsible for circumvention of any privacy settings or security measures
contained on the Site.

For additional information about our commitment to protecting the security and
integrity of Your information, please refer to our Security page.


ACCESSIBILITY

Meaningful inclusion is very important to us, including providing reasonable
accommodations for persons with disabilities. If You need assistance or have any
questions, please send them to accessibility@paychex.com.


HOW TO ACCESS AND CORRECT YOUR INFORMATION

Keeping Your information accurate and up-to-date is very important. Clients can
review or correct account information on the Site or by contacting a customer
service representative. If You have an account on the Site, You may be able to
make changes to Your information after You login to the Site using the online
tools. Changes to information regarding a worker’s dependent(s) or family
member(s) must be completed by worker and/or the worker’s employer.


CALIFORNIA CONSUMER PRIVACY RIGHTS

If You do business in California or are a consumer in California, please visit
our CCPA Privacy Policy for more information regarding our processing of Your
information. The CCPA Privacy Policy is incorporated by reference herein.


CHANGES TO THIS PRIVACY POLICY

This Policy may be revised from time to time due to legislative changes, changes
in technology, our privacy practices, or new uses of Your information not
previously disclosed in this Policy. Revisions are effective upon posting and
Your continued use of this Site or our Services will indicate Your acceptance of
those changes. Please refer to this Policy regularly.


CONTACT INFORMATION

If You have any comments, concerns or questions about this Privacy Policy,
please contact Paychex at: Privacy_Office@paychex.com.

Last Updated November 21, 2022

Paychex, Inc
911 Panorama Trail South, Rochester, NY 14625.

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