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PRIVACY NOTICE

FRENCH - Canada   FRENCH - France   SPANISH   GERMAN    DUTCH 


PROTECTING YOUR PERSONAL INFORMATION

UKG Inc. and its respective affiliates (collectively, “UKG”, “we” and/or “us”)
are committed to protecting the privacy of the individuals who visit our website
and subpages located at https://www.ukg.com/ (the “Site”) and who use our
products and services or otherwise interact with us directly (“you”).

SCOPE

This Global Privacy Notice (“Privacy Notice”) describes UKG’s privacy practices
in connection with your use of the Site and your use of UKG products and
services offered by UKG to its customers and provided for you (collectively, our
“Services”). We provide information about the choices you have regarding the
collection or use of your personal information including similar terms as
defined by various jurisdictions, and the rights provided to you, including the
ability to access or update your personal information.

Some data protection laws distinguish between “controllers” and “processors”
when it comes to handling personal information. Although the specific terms
might vary from one jurisdiction to another, the underlying principles generally
stay consistent. The entity that determines the purpose and means of processing
of personal data is the controller. The processor is an entity that handles
personal information under the instruction of a controller without making
decisions. Depending on the scenario, UKG can be either a controller or a
processor.

This Privacy Notice applies when UKG is a controller of your personal data (when
UKG collects data directly from you). This Privacy Notice describes how UKG
processes such data, including collecting, sharing, using, retaining your
personal information, and your data subject rights.

This Privacy Notice does not apply to UKG’s data processing activities on behalf
of its enterprise customers. If you are an employee, contractor, or job
applicant of an organization that uses UKG’s products and services, please
contact your employer for any privacy related inquiries. Additionally, this
Privacy Notice does not cover:

 * UKG’s processing of personal information in connection with certain
   direct-to-consumer products and services (e.g., e-Vault) where UKG is data
   controller. For more information on UKG’s practices for these products and
   services, please see the UKG Employee Vault Notice.
 * UKG's processing of personal information as a data processor when providing
   its Services to UKG's business customers
 * For more information about biometric data and UKG’s timekeeping devices,
   click here.
 * Children and/or Minors. Our Services are neither designed nor intended for
   any users under the legal working age according to the applicable law. If you
   have any reason to believe that a user of our Site or our services is under
   the legal working age, please contact us at Privacy@ukg.com and we will take
   appropriate action.

Please refer to our ESG Program – Privacy and Data Protection page to learn more
about UKG's commitment to privacy.

 

WHAT IS PERSONAL INFORMATION?

For purposes of this Privacy Notice, “personal information” means information
collected by UKG relating to an identified or identifiable natural person and
includes similar terms as defined by various jurisdictions.

Personal information does not include non-personal data such as information that
has been aggregated, de-identified, or anonymized so that no individual natural
person can reasonably be identified.

OUR ROLE

UKG Inc is the controller of your personal information when you browse our Site
or contact us as a prospective customer of our products and services. This means
that we determine and are responsible for how your personal information is used.

If you are an end user of our products and services (“End User”), we process
your personal information as a data processor on behalf of the relevant customer
or as a subprocessor on behalf of the UKG affiliate who contracted with the
relevant customer except to the extent you are using certain direct-to-consumer
products and services (e.g., e-Vault, ). The customer will normally be your
current, past, or prospective employer. This means that the UKG customer
determines and is responsible for how your personal information is used, and we
use your personal information on behalf of the relevant customer based on their
instructions, as set out in a data processing agreement between UKG and UKG
customer.

We do, however, also use certain personal information of End Users of our
Services for our own purposes as a data controller, as described in this Privacy
Notice.

LINKS TO NON-UKG WEBSITES

For your convenience, the Site may contain links to third-party websites and/or
information. When you access those links, you leave UKG’s Site and are
redirected to a third-party website. UKG does not control third-party websites,
thus the privacy practices of third parties might differ from UKG’s privacy
practices. We do not endorse or make any representations about third-party
websites. When you share personal information with third-party websites, the
third-party processing is not covered by this Privacy Notice. We encourage you
to review the privacy policy of any website or company before sharing personal
information.

HOW UKG COLLECTS YOUR PERSONAL INFORMATION

SOURCES OF PERSONAL INFORMATION AND PERSONAL INFORMATION WE COLLECT:

UKG collects personal information from several different sources, including:

 * Directly from you as a user of our Services, including job applicants;
 * From service providers or other third parties, including our customer’s
   account administrators; and
 * Automatically from a website visitor’s visit or activity on our Services.

Please review each of the sections below to learn more about how UKG collects
personal information, and what personal information is collected.

How We Collect Personal Information

UKG collects personal information when you visit our Services and when you
choose to provide personal information. For example, we collect information when
you contact us via our Site, provide your email, phone number or other similar
contact information, such as the information that you provide when you sign up
for a webinar. Job candidates who complete an application for employment with
UKG or create a profile on this Site may also provide credentials and other
information relevant to the job application.

SourceData ElementsHow/PurposeVisitors to our Site
 * First Name;
 * Company;
 * Job Title;
 * Address;
 * Phone Number;
 * Email Address;
 * IP address, device type, unique device identification numbers, browser type,
   broad geographic location (for example, country or city-level location based
   on your public IP address), performance, and other usage and technical
   information. information about how you interact with our websites (for
   example, referring web page, pages visited, features used), emails, content,
   or other features (for example, when you open a marketing email or click on
   an embedded link, or if you watch videos on our site, or interact
   with/message using our chat function). Some of this information may be
   collected using cookies and similar tracking technology, as further explained
   in our Cookie Notice. We do not collect “sensitive personal information” as
   the term is defined by California law beyond what is necessary to provide
   your requested services. Accordingly, we do not provide a mechanism for you
   to request that we limit our use of sensitive personal information.

To fulfill the purpose(s) for which the information was collected or provided,
including to communicate with you and respond to your inquiries and requests,
and to analyze, administer and enable the use of certain Services.  

Lawful Basis: Legitimate Interest 
 

 * Understand our website visitors, their origin, and their interests to improve
   site quality and relevance through internal analytics.
 * Operate and maintain our websites, provide requested content, and display
   country-specific information.
 * Protect security and prevent misuse by tracking usage, verifying accounts,
   investigating suspicious activity, and enforcing terms and policies.

Third Parties or Publicly Available Sources (including purchased business
contact information)
 * First name
 * Last name
 * Business Email
 * Telephone number
 * Company name
 * Job level
 * Functional role
 * Business street address
 * Online identifier
 * Employment history

We use this data for our internal customer analytics, to identify prospective
customer marketing opportunities, and to improve the relevance of our Site
content and our advertising. 

We may collect or receive personal information from third parties including from
our affiliates, marketing companies, job posting websites and recruiting firms.
This data may be licensed by third parties or available publicly. 

We collect business contact information for account management purposes related
to the use of UKG software-as-a-service applications or professional services. 

Lawful Basis: Legitimate Interest 

Analytics information and to administer and enable the use of certain Services. 

Lawful Basis: Legitimate InterestDirectly from you as a user of our Services
 * First name
 * Last name
 * Business Email
 * Telephone number
 * Company name
 * Emergency contact (in some instances)
 * Dietary preferences (in some instances)
 * Health and safety information (in some instances)
 * Billing information (such as billing name, billing address, and credit card
   number)

If you register to attend a UKG-sponsored Event, we may require certain data.

Lawful Basis: Performance of Contract & Legitimate InterestVisitors to our Site
 * IP address

Our Site may include social media features, such as video links and other
functionality to demonstrate your interest in our Site and other materials and
may set a cookie to enable such functionality. This functionality may be hosted
by a third party or hosted directly on our Site. When provided or hosted by a
third party, your use and interactions with these features is at your discretion
and is governed by the privacy policy of the companies providing them. 

Lawful Basis: Legitimate InterestCustomer Account Management Information
 * First name
 * Last name
 * Business Email
 * Telephone number
 * Company name
 * Job level
 * Functional role
 * Business street address
 * Online identifier and password

We collect business contact information for account management purposes related
to the use of UKG software-as-a-service applications or professional services. 

If you use certain systems provided by UKG, we will collect data from you to
enable multifactor authentication, such as mobile number, email address, or
unique verification identifier. 

Lawful Basis: Legitimate InterestAnalytics Information from the Use of the
Services (“Usage Data”)
 * IP address
 * Mobile Phone Number
 * User Settings
 * Mobile Advertising and Other Unique Identification Numbers
 * Browser, Device and Operating System Details
 * Location information (inferred from your IP address)
 * Internet Service Provider
 * Clickstream Data
 * Cookie Data (see below)
 * Information about how you interact with and use the Services

Our Services may record information concerning the access, use, and performance
of the Services, including how often you use the application, the events that
occur within the application, aggregated usage metadata, performance data, your
IP address. We do not link the Usage Data we process to any personal information
you submit within the Services. We use Usage Data to analyze, enhance and
develop our Services.

Lawful Basis: Consent for processing of device-level data and Legitimate
interests for all other Usage Data to the extent required by lawEnd User and
Customer Feedback
 * Product feedback provided via surveys.

We may use any feedback received in relation to our Services to inform
improvements to and develop new product features and functionalities.End User
and Customer Content
 * Name;
 * Company;
 * Job Title;
 * Address;
 * Phone Number; and
 * Email Address
 * IP addresses and operating systems information (“latest account activity”
   feature).
 * All information uploaded by customers or End Users to UKG Services relating
   to End Users.

We generally only process End User and Customer Content as a data processor to
provide the Services to and on behalf of our customers. In limited instances,
where our customer (your employer) has instructed us, we may use End User and
Customer Content to analyze, enhance and develop functionalities. Where
possible, we take steps to aggregate, anonymize or de-identify such Content
prior to use by UKG as a data controller

Lawful Basis: Legitimate Interest

Cookies and Other Similar Technologies

Like many websites, UKG uses cookies and similar tracking technologies
(including for analytics, functionality, advertising, and other purposes). For
more information about the technologies, we use and how you can control these
technologies, please see our Cookie Notice.

Analytics 

We use Google Analytics and other service providers to collect and process
analytics information on our Services. For more information about how Google
uses data, please visit www.google.com/policies/privacy/partners/. You can opt
out of Google Analytics’ collection and processing of data generated by your use
of our website by going to https://tools.google.com/dlpage/gaoptout.

Other Information

If UKG collects any other personal information from you, we will explain which
personal information is collected and the purpose for its collection.

HOW UKG USES PERSONAL INFORMATION

WHY WE USE YOUR PERSONAL INFORMATION:

UKG relies on lawful bases, such as Performance of Contract or Legitimate
Interest. Additionally, we may process personal information for the following
purposes:

 * To fulfill the purpose(s) for which the information was collected or
   provided, including to communicate with you and respond to your inquiries and
   requests; 
 * To improve our Services, through testing, research, analysis and product
   development (including Usage Data and, where instructed, aggregate,
   de-identified or anonymized End User or Customer Content); 
 * To market, advertise, and promote our Services, such as to make suggestions
   and recommendations to you about products or services that may be of interest
   to you; 
 * To provide support and information about our Services via virtual assistant,
   also known as chatbot, available 24/7 on our Sites; 
 * To provide training related to the Services, such as making available
   training materials or events (whether in-person or online) for which we may
   use your personal information to provide notices and information regarding
   such training and events; 
 * For security, audit, internal investigation, and fraud prevention purposes,
   such as to prevent unauthorized access or disclosure, to maintain data
   accuracy, to protect the confidentiality, integrity, and availability of your
   personal information; to allow only the appropriate use of your personal
   information; to identify any fraudulent, harmful, unauthorized, unethical or
   illegal activity; 
 * To manage litigation, such as in connection with establishing, exercising, or
   defending our legal rights where it is necessary for our legitimate interests
   or the legitimate interests of others; 
 * To improve the content and format of our Services, including by using cookies
   and other similar technologies, such as to measure the preferences of our
   Site visitors, analyze trends, administer the Services, analyze use of the
   Services, and to gather demographic information about visitors to the Site; 
 * To allow us to better understand the functionality of our mobile
   applications, though we do not link the usage information we collect through
   the mobile applications to any personal information you submit within the
   mobile application; 
 * For other purposes for you have provided consent; 
 * To aggregate or deidentify your personal information so that the information
   can no longer be linked to you or your device and use and share such data for
   any business purpose in accordance with applicable law; and 
 * To comply with all applicable legal obligations, such as to comply with
   subpoenas and other court orders to process data where we have determined
   there is a legal requirement to do so.

No mobile information or SMS consent will be sold or shared with third parties
for marketing/promotional purposes.

WHEN UKG DISCLOSES YOUR PERSONAL INFORMATION

Please note, UKG does not sell personal information to third parties. The term
“sell” as defined by applicable laws, means disclosure of personal information
to third parties for monetary or other valuable consideration.

Please review each of the sections below to learn more about how we may share
your personal information.

AFFILIATES:

We may disclose your personal information to our Affiliates in order to
facilitate delivery of a product or service or complete a task that you
requested.

THIRD PARTIES (VENDORS/SERVICE PROVIDERS):

We may engage with third parties (vendors and/or service providers) to
facilitate delivery of a product or service (or perform certain functions such
as enhancing and/or delivering our product and service offerings); complete a
task that you requested; provide training; support product research and
development (including training AI models), conduct marketing and advertising;
operate, secure, and optimize the Services; and coordinate and work with our
partners.

We have contracts with such third parties to perform certain functions on our
behalf, and only at our direction. These third parties are bound by agreements
that contain confidentiality and other data protection terms designed to ensure
the third parties only use your personal information to the extent necessary to
provide these contracted services in accordance with our instructions (and for
the purposes we disclose).

ADDITIONAL DISCLOSURES

We may disclose your personal information as necessary to:

 * To provide customer service or technical support regarding training or
   webinars for which you register or attend; 
 * For our administration, and business operation purposes and to keep a record
   of your relationship with us; 
 * Comply with the law or with legal obligations, such as with law enforcement
   officials, government authorities or other third parties in response to a
   lawful request for information by a competent authority, if we believe
   disclosure is in accordance with, or is otherwise required by, any applicable
   law, regulation, or legal process, including to meet national security or law
   enforcement requirements; 
 * To manage litigation and conduct internal audits and investigations, such as
   to protect and defend our rights and property, investigate fraudulent or
   illegal activity, and conduct internal financial, security, or other audits; 
 * Protect against misuse or unauthorized use of our Site, products, and
   services; 
 * Protect the personal safety or property of our users or the public (among
   other things, this means that if you provide false information or attempt to
   use another’s identity, information about you may be disclosed as part of any
   investigation into your actions) 
 * In connection with, or during the negotiation of, any merger, sale of company
   assets, consolidation or restructuring, financing or acquisition of all or a
   portion of our business by or to another company, including the transfer of
   contact information and data of customers, partners, and end users; • In an
   aggregated and de-identified or anonymized form; and 
 * When we have your consent to share the information.

Other than as stated in this Privacy Notice, we will endeavor not to release
your personal information to unknown or unaffiliated third parties, and we will
not cross-reference your personal information with that of any other customer or
entity.

TRANSFERRING PERSONAL INFORMATION

INTERNATIONAL TRANSFERS

UKG agrees it will use the Standard Contractual Clauses (“SCCs”) or the UK
International Data Transfer Agreement for UKG transfers to third-party
subprocessors subject to cross border mechanisms for transfers between UKG
entities.

UKG agrees it will use the Standard Contractual Clauses (“SCCs”) or the UK
International Data Transfer Agreement for UKG transfers to third-party
subprocessors subject to cross border mechanisms for transfers between UKG
entities. For recipients in the US, UKG may also transfer personal information
to recipients who have certified to the EU-U.S. Data Privacy Framework, Swiss-US
Data Privacy Framework and the UK-U.S. Data Privacy Framework. This practice
complies with European requirements for transfers or processing of personal
information by UKG outside the EEA, Switzerland, and the UK or in a jurisdiction
other than the EEA, Switzerland, UK or other European Commission-approved
countries providing ‘adequate’ data protection. To learn more about how UKG
complies with the Schrems II caselaw, please refer to UKG’s Transfer Risk and
Impact Statement.

DATA PRIVACY FRAMEWORK

UKG and its subsidiaries comply with the EU-U.S. and the Swiss-US Data Privacy
Framework as well as the UK-U.S. Data Privacy Framework (collectively, the "Data
Privacy Framework"), including liability for onward transfers, as set forth by
the U.S. Department of Commerce regarding the collection, use, and retention of
personal information transferred from the European Union, the United Kingdom
and/or Switzerland, as applicable. UKG has certified to the Department of
Commerce that it adheres to the Data Privacy Framework Principles with respect
to such information. If there is any conflict between the terms in this notice
and the Data Privacy Framework Principles, the Data Privacy Framework Principles
shall govern. To learn more about the Data Privacy Framework program, and to
view our certification, please visit the Data Privacy Framework website and
UKG’s Data Privacy Framework Statement

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and
the Swiss-U.S. DPF, UKG commits to cooperate and comply respectively with the
advice of the panel established by the EU data protection authorities (DPAs) and
the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data
Protection and Information Commissioner (FDPIC) with regard to unresolved
complaints concerning our handling of human resources data received in reliance
on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S.
DPF in the context of the employment relationship.

Data processed: UKG provides HR management tools that our customers use for
their workforce. In providing these tools, UKG processes data our customers
submit to our services or instruct us to process on their behalf. While UKG’s
customers decide what data is processed, it typically includes information about
their employees such as contact information, scheduling, and pay slips. Purposes
of data processing: UKG processes data submitted by customers for the purpose of
providing UKG’s online services to our customers. To fulfill these purposes, UKG
may access the data to provide the services, to correct and address technical or
service problems, to respond to customer support matters, or to follow customer
instructions who submitted the data, in response to contractual requirements or
for security monitoring.

Inquiries and complaints: If you believe UKG maintains your personal data in one
of the services within the scope of our Data Privacy Framework certification,
you may direct any inquiries or complaints concerning our Data Privacy Framework
compliance to privacy@ukg.com. UKG will respond within 45 days. If you have an
unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third-party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
If neither UKG nor our dispute resolution provider resolves your complaint, you
may have the possibility to engage in binding arbitration through the Data
Privacy Framework Panel. For more information on this option, please see Annex I
of the EU-U.S. Data Privacy Framework Principles.

Third parties who may receive personal data: UKG uses a limited number of
third-party service providers to assist us in providing our services to
customers. These third-party providers offer various services, including data
storage services. These third-parties may access, process, or store personal
data in the course of providing their services. UKG maintains contracts with
these third parties restricting their access, use and disclosure of personal
data in compliance with our Data Privacy Framework obligations, including the
onward transfer provisions, and UKG remains responsible and liable if they fail
to meet those obligations and we are responsible for the event giving rise to
damage.

Your rights to access, to limit use, and to limit disclosure: EU individuals and
Swiss individuals have rights to access personal data about them, and to limit
use and disclosure of their personal data. With our Data Privacy Framework
self-certification, UKG has committed to respect those rights. Except for
MyPeopleDoc Employee Vault and Immedis Tax Services, UKG personnel have limited
ability to access data our customers submit to our services. If you wish to
request access, or to limit use, or to limit disclosure, please provide the name
of the customer who submitted your data to our services. We will refer your
request to that customer and will support them as needed in responding to your
request.

U.S. Federal Trade Commission enforcement: The Federal Trade Commission has
jurisdiction over UKG’s compliance with the Data Privacy Framework and is
subject to the investigatory and enforcement powers of The Federal Trade
Commission

Compelled disclosure: UKG may be required to disclose personal information in
response to lawful requests by public authorities, including to meet national
security or law enforcement requirements. UKG maintains transparency reports
accordingly.

AP

UKG’s privacy practices, described in this Privacy Notice, comply with the APEC
Cross Border Privacy Rules System (CBPR). The APEC CBPR system provides a
framework for organizations to ensure the protection of Personal Information
transferred among participating APEC economies. More information about the APEC
framework can be found here.

RETAINING PERSONAL INFORMATION

UKG will only retain personal information for the length of time necessary to
fulfill the purpose(s) for which the information was collected or as required or
permitted by applicable laws, (including the resolution of disputes) and in
accordance with our customer contracts.

To determine the appropriate retention period for personal information, we
consider the amount, nature, and sensitivity of the personal information, the
potential risk of harm from unauthorized use or disclosure of the personal
information, the purposes for which we process your personal information, and
whether we can achieve those purposes through other means, and the applicable
legal requirements.

When we no longer require your personal information, we will either delete or
deidentify it or, if this is not possible, we will securely store it in
accordance with this Privacy Notice and cease use of the personal information
until deletion is possible. If we deidentify your personal information (so that
it is no longer associated with you), we may retain this information for longer
periods.

DATA SUBJECT RIGHTS

In accordance with applicable law and depending on your location, you may be
entitled to exercise some or all the following rights regarding our collection,
use, and sharing of your personal information:

 * Access the personal information we maintain about you;
 * Update or correct any inaccurate or incomplete personal information about
   you;
 * Request that we delete your personal information;
 * Restrict the processing of your personal information;
 * Receive the personal information you have previously provided to UKG, in a
   machine-readable format, allowing you to transfer that personal information
   to another company at your discretion;

Not be subject to a decision based solely on automated processing, including
profiling, which produces legal effects concerning you or similarly
significantly affects you; and

 * Dispute resolution

You also have the right to object to our use of your personal information in
certain circumstances. There may be compelling reasons for continuing to process
your personal information, and we will assess and inform you if that is the
case. You can object to marketing activities for any reason.

 

EXERCISING YOUR RIGHTS

To protect your privacy and security, we take reasonable steps to verify your
identity before granting access to your personal information. Please follow the
instructions below based on your relationship with UKG and provide the requested
information to allow us to adequately address your request. We will respond to
your request within a reasonable timeframe and as otherwise required by
applicable law in your location.

If you are not a California resident and would like to request access to your
personal information or request erasure (right to be forgotten) of personal
information previously provided, please contact privacy@ukg.com.

CALIFORNIA RESIDENTS – CALIFORNIA PRIVACY NOTICE

For California residents, The California Consumer Privacy Act (“CCPA”) provides
certain privacy-related rights. If you are a California resident, please click
here to learn more about UKG’s privacy practices under the CCPA.

DO NOT TRACK

Some internet browsers may be configured to send “Do Not Track” signals to the
websites that you visit. We currently do not respond to “Do Not Track” or
similar signals. To find out more about “Do Not Track,” please click here.

UKG APPLICANTS & CANDIDATES

UKG applicants who want more information on how UKG processes applicant personal
information, please review this section.

This section applies to the processing of Personal information by UKG collected
in connection our recruitment process and with your employment application with
UKG. This section applies to individuals who apply to work at UKG or provide
services to UKG (including current employees who apply for new positions with
us) (“you" or "Individuals").

The section describes the categories of personal information we collect in
connection with the recruitment and employee onboarding process, the purposes
for which we collect that personal information, the other parties with whom we
may disclose that personal information, and how UKG protects that personal
information. This section also provides you with information about your rights
and choices with respect to your personal information, and how you can contact
us to update your personal information or make inquiries about our privacy
practices.

1. Personal information We may collect

We collect the following Personal Information about you in connection with your
employment application and as part of our recruitment process, as permitted
under applicable law:

Data CategoryReason for Processing*Immigration status and work permits (if
applicable)Check regularity of your employment statusContact information (e.g.
email address, phone, address, city, state, zip code, country)Contact
 * Identification details (e.g first name, last name)
 * Gender

Identification
 * CV/Resume
 * Desired salary (if applicable)
 * Education history
 * Results on the selection process
 * Online identifiers and website, device and mobile app usage, and similar
   information collected via automated means, such as cookies and similar
   technologies
 * Salary history (to the extent permitted by the local laws)

Process application
 * Any other information you choose to share, such as information included in
   your CV/resume and/or shared with us during the interview process
 * Tax Identification number (Country Specific)

Process application and verify your suitability for current and future potential
functions
 * Calendar availability

Scheduling
 * Employment history
 * LinkedIn profile URL, the publicly available sections of your LinkedIn
   profile if you provided to us and other professional websites you Provided to
   us
 * Results of any pre-employment testing (such as psychometric testing, credit
   history checks and other screening, subject to strict conditions, as
   permitted under applicable law)
 * Skills inventory (including by way skills of assessments you may take part of
   any application process)
 * Video/photo images or audio recordings (e.g., via virtual interviews and/or
   CCTV footage (where applicable))

Verify your suitability for current and future potential functions

*Lawful Basis for all of the above: The processing is necessary for performance
of a contract with you, as well as legitimate interest and compliance with
applicable laws and regulations.

In certain jurisdictions, and only to the extent permitted b applicable law, UKG
may process Sensitive Personal information, such as racial or ethnic origin,
health-related data (for example, disability information), religious beliefs,
and trade union membership, for the limited purposes as set out under Section 2,
below.

To the extent permitted under applicable law, UKG may receive personal
information directly from you through our Careers portal and indirectly from
third parties (e.g., former employers, educational institutions, publicly
available sources, and professional social networking sites such as LinkedIn,
online recruitment platforms, professional recruitment agencies, and government
agencies).

2. How We May Use Your Personal information

We may use your Personal information to*:

Processing Activity
 * Identify and contact you
 * Consider your application
 * Schedule and facilitate interviews
 * Determine your suitability for current and future job roles with us
 * Contact references or other individuals who may provide information about
   your employment history
 * Perform pre-employment screening and testing
 * Potentially prepare employment terms or an employment contract
 * Financial planning and budgeting
 * Engage in diversity and equal opportunity initiatives (where permitted and/or
   required under applicable law)

 * Provide reasonable workplace accommodations and safe workplace
 * Make staffing decisions
 * Enforce our policies and other legal rights
 * Improve and develop our recruitment processes (including surveys)
 * Ensure safety and security of our systems
 * Audit, research and perform analysis of our recruiting experience on our
   websites
 * Respond to inquiries, complaints or disputes
 * Perform certain data analysis regarding use of our recruiting sites and our
   recruitment programs
 * Comply with legal and other requirement

*Lawful basis for all of the above: The processing is necessary for performance
of a contract with you, as well as legitimate interest and compliance with
applicable laws and regulations.

Where we seek to review and implement measures to improve our recruitment
activities and ensure compliance with our policies such as equal opportunity
initiatives, we use aggregated data.

UKG only processes personal information for the above purposes to the extent
permitted by applicable law and, where required, only when it can rely on a
legal basis. In certain cases, such as when looking to fill a job opportunity,
we may process your personal information with assistance from automated
employment tools. However, all decisions with regards to the use of automated
employment tools also include the use of human review and/or intervention.

3. How We Share Your Personal information

We do not sell your personal information, share or otherwise disclose personal
information we collect about you, except as described in this Notice or
otherwise disclosed to you at the time the information is collected. We may
share your personal information we collect with:

We may share your Personal information we collect with:

 * Companies within the UKG group, including UKG Inc.’s affiliates globally to
   the extent that they are involved in the recruitment and/or hiring process;
 * Members of our internal departments to the extent that they are involved in
   the recruitment and/or hiring process. Company staff accessing personal
   information are required to maintain its confidentiality and to process such
   information in accordance with applicable law;
 * Third parties to the extent necessary for the recruitment and/or hiring
   process (e.g., HR hosting services, candidate relationship management
   services, recruitment agencies and background screening agencies). The
   Company enters into contractual obligations with its third-party service
   providers to provide appropriate protection of personal information.

For more information on service providers, please contact us as described in the
"How to Contact Us" section below.

We also may share personal information with our service providers who perform
services on our behalf and in relation to the purposes described in this Privacy
Notice:

 * With the consent or authorization of the Individual;
 * In the context of a sale or transfer involving all or a portion of the
   Company’s business or assets (including in the event of a reorganization,
   dissolution or liquidation);
 * In response to requests by government agencies, such as law enforcement
   agencies;
 * To protect the rights and properties of the Company;
 * If required to do so by law, regulation, or legal process (such as a court
   order or subpoena);
 * When we believe disclosure is necessary or appropriate to prevent physical
   harm to UKG employees or financial loss;
 * As part of an investigation of suspected illegal activity.

The Company enters into contractual obligations with its third-party service
providers to provide appropriate protection of Personal information.

Choosing Not to Share Your Personal information

DENIAL OF REQUESTS

UKG may deny a request submitted in accordance with the above as permitted by
applicable law in your location. UKG will endeavor to notify you regarding any
decision and reason(s) for denial in a timely manner and otherwise in accordance
with applicable law in your location.

DISPUTE RESOLUTION

In accordance with this Privacy Notice, UKG will investigate and attempt to
resolve complaints and disputes regarding the use and disclosure of your
personal information. Additionally, UKG will cooperate with governmental
authorities upon request.

Any privacy-related dispute or concern that is still unable to be resolved to
your satisfaction shall be handled in accordance with applicable dispute
resolution procedures, free of charge, through our U.S.-based third-party
dispute resolution provider TRUSTe.

We strongly encourage you to contact us directly with any complaints you may
have with regard to this Privacy Notice or our privacy practices prior to
proceeding to the arbitration procedure described above.

SECURITY

UKG utilizes physical, technical, and administrative controls and procedures
designed to safeguard the information we collect, prevent unauthorized access or
disclosure, to maintain data accuracy of your personal information, and to
restrict the processing of your personal information as set forth in this
Privacy Notice.

We utilize a variety of physical and logical access controls, firewalls,
intrusion detection and prevention systems, network and database monitoring,
anti-virus, and backup systems. We use encrypted sessions when collecting or
transferring sensitive data through our Site.

We limit access to your personal information and data to those persons who have
a specific business purpose for maintaining and processing such information. Our
employees who have been granted access to your personal information are made
aware of their responsibilities to protect the confidentiality, integrity, and
availability of that information and have been provided training and instruction
on how to do so.

For additional information regarding UKG’s commitment to cybersecurity, please
refer to UKG’s ESG – Cybersecurity page.

ENFORCEMENT AND VERIFICATION

UKG will periodically assess its operations to validate compliance with this
Privacy Notice.

We will take reasonable steps to prevent or address any unauthorized use or
disclosure of your personal information in a manner contrary to this Privacy
Notice. We hold our employees and third parties accountable for maintaining the
trust that you place in UKG.

CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice is effective November 14, 2024. UKG reserves the right to
modify or amend this Privacy Notice at any time consistent with applicable laws.
We encourage you to periodically review this page for the latest information on
our privacy practices.

CONTACT INFORMATION

At any time, you may contact UKG with questions or concerns about this Privacy
Notice at privacy@ukg.com.

Written responses may also be submitted to:

UKG Inc. 
Attention: GVP Deputy General Counsel 
900 Chelmsford St.& 
Lowell, MA 01851

Those located in the EU may contact our European representatives via email at
privacy@ukg.com. UKG Inc. EU representative is:

PeopleDoc SAS 
Attention: Data Privacy Officer 
53 rue d’Hauteville 
75010 Paris, France

UKG will respond to all correspondence within a reasonable timeframe, including
as required by applicable law.



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