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PRIVACY AND COOKIE POLICIES

GLOBAL PRIVACY NOTICE

This privacy notice explains how we use personal data (“data”).

We always strive to make our privacy notice easy to understand and fully
inclusive. If you have any questions after reading this notice you can contact:

1. your local SThree business and brand.
2. The SThree Global Data Protection Officer by emailing dpo@sthree.com or
writing to The Data Protection Officer, SThree Plc, 75 King William Street,
EC4N 7BE London, UK
3. The SThree’s EU Data Protection Representative by emailing dpo@sthree.com
or in writing to The Data Protection Representative, SThree GmbH, Querstraße
7 , 60322 Frankfurt am Main, Germany.

For DATA SUBJECT ACCESS REQUEST Please use one of the above methods of contact
us. This will ensure we can act quickly on your request.

WHO ARE WE?

SThree plc and its subsidiaries (SThree Group) brings skilled people together to
build the future through its global house of specialist recruitment brands.).

SThree Group, offer products and services through its house of brands in the
following countries:

These brands include:

Austria

SThree Austria GmbH

- Computer Futures

Belgium

SThree Belgium NV/SA

- Progressive Recruitment

SThree Services NV/SA

- Real Staffing Group

Computer Futures Solutions NV

- Computer Futures

- JP Gray

- Global Enterprise Partners

Huxley Associates Belgium NV

- Huxley Associates

Germany

SThree GmbH

- Computer Futures

- Huxley Associates

- Progressive Recruitment

- Real Staffing Group

Madison Black

SThree Temp Experts GmbH

- Global Enterprise Partners

France

SThree SAS

- Computer Futures

- Huxley Associates

- Progressive Recruitment

- Real Staffing Group

Hong Kong

SThree Limited

- Huxley Associates

Ireland

SThree Staffing Ireland Limited

- Computer Futures

- Real Staffing Group

Japan

SThree K.K

- Computer Futures

- Real Staffing Group

- Huxley

- Progressive Recruitment

Luxembourg

SThree s.a.r.l

- Huxley

Netherlands

SThree Holdings B.V. and
SThree Interim Services B.V.

- Computer Futures

- Progressive Recruitment

- Real Staffing Group

- JP Gray

- Global Enterprise Partners

Madison Black

Huxley B.V.

- Huxley

Singapore

SThree Pte Limited

- Huxley Associates

- Progressive Global Energy

- Real Staffing Group

Spain

SThree Business Services Ibérica, SL

- Huxley Associates

Switzerland

SThree Switzerland GmbH

- Computer Futures

- Huxley Associates

- Real Staffing Group

UAE

Huxley Associates Global Limited

- Huxley Associates

UAE

Progressive Global Energy Limited

- Progressive Global Energy

SThree Partnership LLP

- Computer Futures

- Huxley Associates

- Progressive

- Real Staffing Group

- Global Enterprise Partners

- Newington International

USA

Specialist Staffing Solutions Inc.

- Computer Futures

- Huxley Associates

- Global Enterprise Partners

- Progressive Global Energy

- Real Staffing Group

USA

Newington International Inc

- Newington International

USA

Specialist Staffing Services, Inc.

- Specialist Staffing Services

WHO IS THE DATA CONTROLLER?

SThree PLC is the data controller and its subsidiaries its data processors.

SThree PLC’s EU representative is , SThree GmbH, Querstraße 7 , 60322 Frankfurt
am Main, Germany.

HOW DO WE USE PERSONAL DATA?

You may interact with us for a variety of different reasons. Each reason may
require different processing of your personal data.

To help you find the right information, we have structured this notice based on
the type of interaction you have with us.

We do not sell Personal Data we collect and process about you.

Candidate – SThree job opportunity

If you apply for a job at SThree or one of SThree’s clients (opportunity to
either perform an assignment at the client working for your own service company,
as a sole trader, an employee of a management company, or for a permanent
position) we will process your personal data to determine the suitability of
your skills and experience in relation to the specific role. This may include
interviews, and skills assessments. We may undertake background screening to
verify your eligibility to work in a particular location, to check your
credentials and qualifications. We process your personal data on the basis of
preparation of contract or because of legal requirements. We may also undertake
a formal background check with your explicit and freely given consent where we
have no other lawful basis.

We typically collect your name, address, date of birth, citizenship, social
security number, other government issued identification number, driver’s licence
details, email address, contact phone number, ethnicity (where required by law
or with your expressed and freely given consent, where we are allowed under
local law to ask), qualifications, and job experience.

Note that some of our clients are legally required to undertake formal
background checks including criminal background checks above and beyond those
checks SThree undertakes. Where that is the case, the client is the data
controller and SThree the data processor. If a client requires a background
check to be performed we will inform you at the time about this requirement and
about the client’s data protection notice.

We may also process your personal data to comply with laws and regulation that
applies to us. This includes screening against economic and trade sanction lists
issued by countries and intergovernmental organisations such as the UN.

We may reach out to any individual you have named as a reference on your
CV/resume or provided later in the application process. You must ensure that any
individual your provide has agreed to us contacting them to discuss your
credentials and qualifications.

We may also take notes during an interview process to assist in the selection
phase of the application process. These notes may contain personal details you
have mentioned during the interview.

If you are successful in your application we will keep the information collected
during the recruitment process and add this to your placement file. We will
continue to process your personal information as an SThree Employee in line with
our Employee data privacy notice or as an independent contractor.

If you are not successful in the application process we may keep personal data
we collected during the recruitment process to evidence we complied with legal
requirements such as non-discrimination laws. We will keep the data for as long
as required to comply with these legal requirements.

We may also keep your personal data to enable us to inform you about other
relevant positions that fits your skills and qualifications.

In searching for a suitable opportunities for you, we may include your profile,
in a de-identified manner to clients and organisations we believe may have an
interest. We typically include several de-identified profiles when reaching out
to clients or other organisations. The information we send out will be
sufficient for the recipient to understand your general skillset. We do this
under the lawful basis of legitimate interest. If the client is interested in
your profile we will contact you and discuss the opportunity. If you decide you
are interested in having further conversations we will ask for your consent to
send your full CV including your name and contact details to the prospective
client.

We will keep your personal data for the purpose of finding you a suitable
opportunity until you request us to delete your personal data (see below
regarding your rights) and we have a legal obligation to honour your request.

If we have had no meaningful contact in the last 2 years we will remove your
personal data from our active database. Your personal data will be moved to an
archive for a maximum of an additional 3 years before deleted.

We may retain your personal data for longer if required by applicable local
laws.

Employees within SThree

Please refer to the detail information available on SThree’s intranet site.

Employees – working with SThree's clients

If you are hired as an employee to work exclusively on assignments with SThree's
clients we will process your personal data the same way as described above under
title ‘Candidate – SThree job opportunity’. We will also share your skills and
expertise with our clients. You may also be requested to be interviewed directly
by the client. If so, any personal data you share with the client will be
processed by the client directly under its data protection policy and notice.

We may, where we are allowed under local law and in agreement with the client
require you to provide geolocation data. The data may be collected by SThree and
shared with the Client or directly by the client, and is collected to ensure
compliance with contract as well as for safety and security reasons. Geolocation
data may be collected using our issued devices such as laptops or mobile phones.
We may also collect geolocation data where we have provided you with a vehicle
using the geolocation functionality provided by such vehicle.

Processing of geolocation data is a requirement under the contract or by law.
However, in some circumstances this may be optional and will only be collected
with your expressed and freely given consent. A consent you can withdraw at
anytime.

During the assignment we will collect further information about your working
hours through timesheets, any matters raised by the client about your conduct or
other matters relevant to your assignment.

Independent contractors

Where you have successfully been paired with an SThree client to perform an
assignment as an independent contractor, we will collect and process personal
data in relation to the hours worked, any matters raised by the client in
relation to the assignment. We do so to enable performance of contract, and
comply with relevant laws.

We may where we are allowed under local law and in agreement with the client
require you to provide geolocation data. The data will be shared with the client
and is collected to ensure compliance with contract as well as for safety and
security reasons. Geolocation data may be collected using our issued devices
such as laptops or mobile phones. We may also collect geolocation data where we
have provided you with a vehicle using the geolocation functionality provided by
such vehicle. This will be a requirement under the contract or by law. However,
in some circumstances this may be optional and will only be collected with your
expressed and freely given consent. A consent you can withdraw at anytime.

Note: If your services are provided via a legal entity such as a management
company or your own personal service company, we will have a legal agreement in
place with said company to enable services to be delivered to the end client.
Part of that agreement will cover the lawful processing of, and transfer of your
personal data from said company to us and where required shared with the end
client. Any processing of your personal data by your service company or the
management company through whom you are employed is their responsibility and you
should refer to their data protection notice and policy.

Social media including job sites

If you engage with us through social media or other online fora we will process
your personal data to engage with you to address any questions you may have
raised through direct messaging functionality, other functionalities provided by
the social media platform to connect with us around job opportunities and other
related services.

We are also actively looking for talent using social media. We may contact you
via social media if we find your profile of interest in matching you with one of
our clients, have a relevant opportunity, see if you may be interested in future
opportunities or where we believe we may be able to provide services to the
benefit of your organisation .

We may collect name, email address, contact phone number, and Profile URL.

We will process your personal data on the basis of legitimate interest, and only
to the extent allowed by other applicable laws such as local marketing laws.

We may also provide options in local markets to join our own social media
members’ only area. If you decide to join such member area we will process your
personal information to enable interaction between you as a member, other
members and us, understand your activities and tailor content, and moderate
conversations. We will process your personal information on the basis of
legitimate interest.

Please note, joining a member only area on a social network typically require
you to set up or have a personal account with the social network independent of
our member area. The social media platform will dictate the terms and conditions
of such account and it will determine the purpose and means of processing your
personal data, acting as an independent data controller. We do not have any say
in this. Please refer to the social media platform’s own privacy notice.

If we process your personal data on the basis of legitimate interests, we will
keep your personal data until you request us to delete (see above regarding your
rights) and we have a legal obligation to honour your request. If we have had no
meaningful contact in the last 2 years we will remove your personal data from
our active database. Your personal data will then be moved to an archive for a
maximum of an additional 3 years before deleted.

We may retain your personal data for longer periods of time if required by
applicable local laws.

Reference - Candidate

If you have been named by one of the candidate as a reference, we will contact
you to verify candidate’s qualifications, experience and character. We request
that the candidate only name a reference where the reference has agreed to being
contacted by us. We will process your personal information on the basis of
legitimate interests.

We will typically collect, through the candidate your name, email address, a
contact phone number, professional details such as title, current employer, and
position.

We will retain your personal data for the duration of the hiring process, and if
the candidate is successful for the duration of the assignment. We may need to
keep your personal data for longer to comply with contractual obligations to
which the candidate is a party, or comply with applicable local laws.

Receiving your personal data through a third party

We may receive your information from a third party who provides such information
as part of their paid or non-paid services. We will processing your personal
data on the lawful basis of legitimate interest to conduct marketing insight
research and seek to establish whether there are business opportunities working
with you and/or your organisation. We will connect with you as soon as possible
and always within 30 days to let you know we have obtained your personal data
and from where. We will also, where allowed under local law, market our services
to you. If we are unable to reach you within 30 days your personal data will be
deleted.

If we connect and unless you object to us processing your personal data any
further, keep your personal data until you request us to delete (see below
regarding your rights) and we have a legal obligation to honour your request. If
we have had no meaningful contact in the last 2 years we will remove your
personal data from our active database. Your personal data will then be moved to
an archive for a maximum of an additional 3 years before deleted.

We may retain your personal data for longer if required by applicable local
laws.

Clients

We will process limited personal data in relation to our relationship with your
organisation to enable us to provide our services under agreed contract,
including invoicing. Personal data we collect will include your name, business
email address, business phone number, invoice address. We may use your personal
data for regular communication, invite you to events, discuss other service or
product opportunities.

We will retain your personal data for the duration of the contract or as
required by specific contractual clauses, such as audit clauses which may
survive the termination of the contract. We may also be required to keep your
personal data for longer to comply with applicable local laws.

Vendors

If you provide goods or services to SThree and you are the designated contact,
we will process your personal data to ensure performance of contract, whether
that is a written or verbal contract. Personal data we collect will include your
name, business email address, and business phone number. We may use your
personal data for regular communication, invite you to events, discuss other
service or product opportunities, or respond to invoices.

Associate Programme

We may offer you the opportunity to work with us in securing new opportunities
with our clients, including developing proposals, attend client meetings and
present. We will process your personal data to enter into a contract with you,
to execute such contract, communicate with you regarding our arrangement and
opportunities, invite you to events, and discuss other products and services.

Personal data we collect will include your name, email address, phone number.

Website visitor

We may collect your personal data when you visit our website and request further
information about our business through for example filling out a form. This
includes your name, email address, contact phone number. We will process your
personal data to ensure we can respond to your request and retain your personal
data for additional communication about our products and services.

We will process your personal data under the lawful basis of legitimate interest
unless local law does not allow. If not allowed we will seek your consent.
Regardless, you can always opt out of further communication by either object to
further processing or withdraw your consent. You can do this by unsubscribing to
our written communication through a link provided within the communication, or
if we are calling you, simply inform us during the call.

We may also use cookies or other tracking technology which places a text file
onto your device, such as your laptop or smartphone. This helps us track your
interactions with our website. You can read more about this in our cookie
section further down in this notice.

If we process your personal data on the basis of consent, we will keep your
personal data until you withdraw your consent.

We may retain your personal data for longer periods of time if required by
applicable local laws.

General Business Inquiry

If you contact us via email, telephone, text message, post, at seminars, web
conferences or any other way to obtain more information about us or have a
specific question, we will process your personal data provided to respond to
your request. We may keep your personal data for further correspondence with
you. We collect your name, email address, phone number. We may also collect your
business address, home address. We will process your personal data under the
lawful basis of legitimate interest or in some instances on the basis of
consent.

If we process your personal data on the basis of consent, we will keep your
personal data until you withdraw your consent.

If we process your personal data on the basis of legitimate interests, we will
keep your personal data until you request us to delete (see below regarding your
rights) and we have a legal obligation to honour your request. If we have had no
meaningful contact in the last 2 years we will remove your personal data from
our active database. Your personal data will then be moved to an archive for a
maximum of an additional 3 years before deleted.

We may retain your personal data for longer periods of time if required by
applicable local laws.

Transfer of personal data

As a global company, we have centralised operating systems where we host the
majority of our data including our client and candidate data, marketing data,
financial data and HR data.

The operating systems are hosted in a cloud solution which is based in the UK.
Transfer of your personal data from your country of residence to our UK cloud
solution is protected by our internal data transfer agreement which is based
upon the European Commission’s Standard Contractual Clauses with local
amendments to comply with all relevant and applicable data protection laws on
transfer of personal data.

We may also transfer your personal data to our clients or third party vendors to
fulfil our services to you and to our clients. Such transfer is governed by our
contract between the client or third party vendor and us to ensure your personal
data is protected to equivalent standard to that where you reside.

Where we transfer EU or UK residence personal data to countries which do not
have or meet the EU or UK standard set by the EU Commission or UK authority, we
will include appropriate language in our contracts to ensure EU and/or UK
standard is still met. We typically do this by applying contractual language
approved by the EU Commission and/or the UK authority.

For non-EU/UK residence we will provide equivalent protection of personal data
as those rights in your country of residence by applying the same or similar set
of contractual language to that of the EU/UK clauses or specific clauses as
required under local law.

Examples of transfer to other parties:

Example 1 - Sending your CV and contact details to a client for a job
interview.

Please note that when the client uses the CV and contact details to prepare and
conduct the interview, they will use your personal data in a way they believe is
necessary for the interview. They act independently of SThree, as a data
controller. Please ask the client for their data protection notice and/or policy
if you have questions about how they process your personal data.

Example 2 - Sharing and comparing your personal data with a job board or a
social media provider.

Where you have consented sharing your personal data from a job board or a social
media platform, we will receive your personal data from that job board or social
media platform. We may over the course of holding your personal data ask the job
board or social media platform to validate the accuracy so that we are always
keeping the most up to date personal data on our records. Personal data we will
receive include name, current employer, position, profile URL, email and contact
phone number.

YOUR RIGHTS

We will honour all our legal obligations towards you.

We will, where you have a legal right to, upon your request:

* Provide you a copy of your personal data we hold. Please note, to protect
other individuals we may need to remove or obfuscate parts of the information
we provide you with.
* Update your personal data.
* Delete your personal data. Please note, we may not always be able to delete
any or all of your personal data. We will inform you if this is the case and
why.
* Restrict or suspend processing of your personal data.
* Manually review and explain the outcome of any automated decisions made about
you.

If you live in a country where the above rights are not available to you by law,
we will still consider and may at our sole discretion honour your request.

We may request that you provide additional and sufficient evidence to establish
your identity before we can look into your request.

We will respond to you within a month unless we have a legal obligation to
respond quicker.

If you wish to use any of your rights please contact us at dpo@sthree.com

You can also contact us in writing through one of the addresses you find at the
top of the notice.

29.2.2024, 17:02:04
Arabic (Saudi Arabia)Deutsch日本語 (にほんご)FrançaisአማርኛNederlandsEspañolEnglish
(British)

USE OF COOKIES AND OTHER SIMILAR TRACKING TECHNOLOGY

Cookies are small text files that are placed on your computer by websites that
you visit. They are widely used in order to make websites work, or work more
efficiently, as well as to provide information to the owners of the site. The
table below explains the cookies we use and why.

The type of cookies that we use are:

Reason

Purpose

Necessary

These cookies are necessary for the website to function and cannot be switched
off in our systems. They are usually only set in response to actions made by you
which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms. You can set your browser to block
or alert you about these cookies, but some parts of the site will not then work.
These cookies do not store any personally identifiable information.

Performance

These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site. All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.

Functional

These cookies enable the website to provide enhanced functionality and
personalisation. They may be set by us or by third party providers whose
services we have added to our pages. If you do not allow these cookies then some
or all of these services may not function properly.

Targeting

These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant adverts on other sites. They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
advertising.

When you visit our websites you will be asked to consent to the use of cookies.
You can always decide to only accept use of necessary cookies. Once you decide
what cookies to allow, that setting is saved. This setting is remembered by a
unique cookie which is a considered necessary cookie to comply with your cookie
requirements.

HOW DO I CHANGE MY COOKIE SETTINGS?

You can always change your cookie preferences by clicking on the cookie setting
icon appearing on all our websites.

This will however only adjust your preference going forward. Any cookies placed
on your device as per your earlier selection will remain for the duration of
their lifespan.

To remove existing cookies you can use the capabilities provided in your choice
of Browser.

To find out more about cookies, including how to see what cookies have been set,
visit www.aboutcookies.org or www.allaboutcookies.org.

Find out how to manage cookies on popular browsers:

* Google Chrome
* Microsoft Edge
* Mozilla Firefox
* Microsoft Internet Explorer
* Opera
* Apple Safari

To find information relating to other browsers, visit the browser developer's
website.

CALIFORNIA PRIVACY POLICY

Specialist Staffing Solutions, Inc. and Specialist Staffing Services, Inc.
("Company") takes your privacy seriously. We want you to know how we collect,
use, share, and protect your personal information.

Assistance For The Disabled

Alternative formats of this Privacy Policy are available to individuals with a
disability. Please contact resolutiondesk@sthree.com for assistance.

This Privacy Policy Explains:

1. How we collect the personal information of California Consumers

2. How we share the personal information of California Consumers

3. California privacy rights

SCOPE

What is personal information?

For purposes of this California Privacy Policy, “personal information” means
information that identifies, relates to, describes, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a
particular consumer or household.

Whose Personal Information Is Covered By This Policy?

This California Privacy Policy applies to the Personal Information provided to
the Company by residents of the State of California (“California Consumers”).

Whose Personal Information Is Not Covered By This Privacy Policy?

“Consumer” does not include the Company’s employees, job applicants, owners,
directors, officers, or contract workers (collectively, “HR individuals”), or
the emergency contacts of HR individuals or the dependents or spouses who
receive Company benefits by virtue of their relationship to an HR individual in
their capacities as HR individuals or emergency contacts, dependents, or
spouses. “Consumer” also does not include employees or other agents of a
business engaged in a transaction with the Company in their capacities as
employees or agents of that business.

What Personal Information Does This Privacy Policy Cover?

This Privacy Policy applies to all Personal Information of California Consumers
that we collect both online and offline. Unless we inform you otherwise, this
section also serves as our “notice at collection” by informing you of your
Personal Information to be collected in the future and the purposes for its use.

1. HOW WE COLLECT THE PERSONAL INFORMATION OF CALIFORNIA CONSUMERS

Of Personal Information Collected In The Last 12 MonthsSources Of That Personal
InformationBusiness Purposes And Commercial Purposes For Collecting That
Personal InformationIdentifiers, including: real name, postal address, Internet
Protocol address, email address, social media handles, telephone number(s).The
California consumer himself or herselfTo communicate with California
ConsumersFor identity verificationDetecting security incidents, protecting
against malicious, deceptive, fraudulent, or illegal activity, and prosecuting
those responsible for that activityDebugging to identify and repair errors that
impair existing intended functionality.Communications about Placement
OpportunitiesTo meet legal and regulatory compliance requirementsCharacteristics
of protected classifications of California Consumers under California or federal
law, including: sex, age.The California consumer himself or herselfFor the
Company’s diversity and inclusion purposesFor identity verificationTo meet legal
and regulatory compliance requirementsNon-public education information,
including: grade point average.The California consumer himself or herselfTo
provide California Consumers with information about job opportunities that match
their experience and level of educationTo facilitate the placement or
recruitment of California ConsumersInternet or other electronic network activity
information, including: pages visited on the Company’s website and links
clicked.Automated technologies in the websiteDetecting security incidents,
protecting against malicious, deceptive, fraudulent, or illegal activity, and
prosecuting those responsible for that activityDebugging to identify and repair
errors that impair existing intended functionalityProfessional or
employment-related information, including: employment history and professional
license information.The California consumer himself or herselfTo provide
California Consumers with information about job opportunities that match their
experience and level of educationTo facilitate the placement or recruitment of
California Consumers with potential employer

2. HOW WE SHARE THE PERSONAL INFORMATION OF CALIFORNIA CONSUMERS

Sale of Personal Information: In the last 12 months, the Company has NOT sold
California Consumers’ personal information. The Company does not sell the
personal information of minors under 16 years of age.

Categories Of Personal Information Collected In The Last 12 MonthsCategories Of
Third Parties With Which Company Shared That Personal InformationWhether Company
Disclosed That Personal Information For A Business Purpose Or A Commercial
PurposeFor all categories: The Company discloses personal information to
government agencies, law enforcement, and other parties as required by law and
as necessary to protect the rights, property, or safety of the Company, its
subsidiaries or affiliates, employees, customers, and users.Identifiers Entities
that use the Company’s services, including the Company’s placement and
recruitment servicesYesService Providers, including the Company’s (a) website
hosting provider, and (b) data analytics providers, and (c) applicant tracking
system providerCharacteristics of protected classifications under California or
federal law, Entities that use the Company’s services, including the Company’s
placement and recruitment servicesYesNon-public education informationEntities
that use the Company’s services, including the Company’s placement and
recruitment servicesYesInternet or other electronic network activity
informationService Providers, including the Company’s (a) website hosting
provider, and (b) data analytics providers.YesProfessional or employment-related
informationEntities that use the Company’s services, including the Company’s
placement and recruitment servicesYes

3. YOUR CALIFORNIA PRIVACY RIGHTS AND HOW TO EXERCISE THEM

a. Your California Privacy Rights

Right to Know: California Consumers have the right to submit a verifiable
request to know what personal information Company collects, uses, discloses, and
sells (the Company did not sell California Consumers’ personal information
during the past 12 months).

Right To Delete: California Consumers have the right to submit a verifiable
request for deletion of their personal information that the Company has
collected or maintains.

Right to Opt Out of Sale: California Consumers have the right to opt out of the
sale of their personal information. California Consumers under the age of 16
must opt in to the sale of their personal information, or their parent or
guardian must opt in on their behalf. As noted above, the Company did not sell
California Consumers’ personal information during the past 12 months.

b. How to Exercise Your Rights

The Company will respond to requests in accordance with applicable law if it can
verify the identity of the individual submitting the request. California
Consumers can exercise their rights to know and to delete in the following ways:

Contact (833)920-0233

Email us at DPO@sthree.com

c. How We Will Verify Your Request:

The processes that we follow to verify your identity when you make a request to
know or a request to delete are described below. The relevant process depends on
how and why the request is submitted.

The verification process that we follow will depend on the nature of your
request as described below:

1. Requests To Know Categories Or Purposes: If you request to know the
categories of Personal Information collected, sources, sales, or the
Company’s business or commercial purposes for use of your Personal
Information, we will match at least two data points that you provide with
your request to know, or in response to our request for verification
information, against information about you we already have in our records
and that we have determined to be reliable for purposes of verifying your
identity. Examples of relevant data points include your mobile phone number,
your zip code, or information about products or services that you have
purchased from us.
2. Requests To Know Specific Pieces Of Personal Information: We will match at
least three data points that you provide with your request to know, or in
response to our request for verification information, against information
that we already have about you in our records and that we have determined to
be reliable for purposes of verifying your identity. In addition, we will
require you to sign a declaration under penalty of perjury that you are the
California consumer whose personal information is the subject of the
request.
3. Requests To Delete Personal Information: Our process for verifying your
identity will depend on the sensitivity (as determined by the Company) of
the personal information that you ask us to delete. For less sensitive
personal information, we will require a match of two data points as
described in Point No. 1, above. For more sensitive personal information, we
will require a match of three data points and a signed declaration as
described in Point No. 2, above.

We have implemented the following additional procedures when verifying the
identity of requestors:

1. If we cannot verify your identity based on the processes described above, we
may ask you for additional verification information. If we do so, we will
permanently delete the verification information that you provide promptly
after we have completed the verification process. We will not use that
information for any purpose other than verification.
2. If we cannot verify your identity to a sufficient level of certainty to
respond to your request, we will let you know promptly and explain why we
cannot verify your identity.

d. Authorized Agents

You may designate an authorized agent to exercise your right to know or your
right to delete by submitting to us a completed “Authorized Agent Designation”
form. You can obtain the designation form by contacting us at
resolutiondesk@sthree.com.

If an authorized agent submits a request to know or a request to delete on your
behalf, the authorized agent must submit with the request either (a) a power of
attorney that is valid under California law, or (b) a document signed by you
that authorizes the authorized agent to submit the request on your behalf. In
addition, we may ask you to follow the applicable process described above for
verifying your identity.

e. Company’s Non-Discrimination Policy

California Consumers have the right not to be subject to discriminatory
treatment by the Company for exercising their privacy rights under the
California Consumer Privacy Act, and the Company will not discriminate on that
basis. However, the Company may charge a California consumer a different price
or rate or provide a different level or quality of goods or services if the
difference is reasonably related to the value provided to the California
Consumer by the consumer’s personal information. If the Company does so, it will
provide consumers with any legally required notice.

For More Information

For questions or concerns about the Company’s privacy policies and practices,
please contact us at resolutiondesk@sthree.com.

10.5.2024, 13:27:08
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