Barbier Security Group 

Employee Privacy Policy Notice 

Barbier Security Group (“BSG”) provides this Privacy Notice which applies to California resident employees, employee applicants, owners, directors, officers, or contractors of BSG, including as applicable, those individuals’ emergency contacts and beneficiaries. This Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”). Please note, there may be additional or different privacy notices or disclosures that govern our use of your personal information beyond the CCPA. Where collection, use, and disclosure of personal information is subject to the CCPA, this Privacy Notice shall prevail. For collection, use, and disclosure of personal information beyond the CCPA, those separate and relevant privacy notices and disclosures shall prevail. Any terms defined in the CCPA have the same meaning when used in this notice. 

Pursuant to the CCPA, we provide the following details regarding the categories of  Personal Information we have collected or disclosed within the preceding twelve (12)  months: 

We collected the following categories of Personal Information: 

• Identifiers, such as name and government-issued identifier (e.g., Social  Security number); 

• Personal information, as defined in the California safeguards law, including  without limitation, name, signature, SSN, physical characteristics or  description, address, telephone number, passport number, driver’s license or  state identification card number, insurance policy number, education,  employment, employment history, bank account number, credit card number,  debit card number, or any other financial information, medical information, or  health insurance information; 

• Characteristics of protected classifications under California or federal law,  including without limitation, age, gender, medical conditions, marital status,  sex (including pregnancy, childbirth, breastfeeding, and related medical  conditions), race, color, religion or creed, ancestry, national origin, disability,  genetic information, AIDS/HIV status, sexual orientation, gender identity and  expression, citizenship, primary language, immigration status, military/veteran  status, political affiliation/activities, domestic violence victim status, and  request for leave; 

• Biometric information, such as face scans, fingerprints and voiceprints;

• Internet or network activity information, such as browsing history and  interactions with our websites; 

• Geolocation data, such as device location; 

• Audio, electronic, visual and similar information, such as call and video  recordings; 

• Professional or employment-related information, such as work history and  prior employer;

• Education information subject to the federal Family Educational Rights and  Privacy Act, such as student records and directory information; and

• Inferences drawn from any of the Personal Information listed above to create a  profile or summary about, for example, an individual’s preferences and  characteristics. 

We collected this Personal Information directly from employees, employee applicants, owners, directors, officers, and/or contractors. We also collected Personal Information  about our employees’ and other individuals’ emergency contacts and beneficiaries from  such employees or other individuals. 

We may use this Personal Information to operate, manage, and maintain our business,  for our employment purposes, and to otherwise accomplish our business purposes and  objectives. Our business purposes and objectives include, for example, developing and improving our services and programs for our employees; conducting research, analytics, and data analysis; maintaining our facilities and infrastructure; undertaking  quality and safety assurance measures; conducting risk and security controls and  monitoring; detecting and preventing fraud; performing identity verification; performing  accounting, audit, and other internal functions, such as internal investigations;  complying with law, legal process, and internal policies; maintaining records; and  exercising and defending legal claims. Specifically, we may use this information in  some of the following ways, though this is not an all-inclusive list: 

• To Recruit Employees, including to conduct employment-related background  screening and checks. 

• To Administer Benefits, such as medical, dental, optical, commuter, and  retirement benefits, including recording and processing eligibility of dependents,  absence and leave monitoring, insurance and accident management, and  provision of online total reward information and statements. 

• To Pay and Reimburse for Expenses, including salary administration, payroll  management, payment of expenses, administering other compensation-related payments, including assigning amounts of bonus payments to individuals,  administration of departmental bonus pools, and administration of stock option  payments. 

• To Conduct Performance-Related Reviews, including performance appraisals,  career planning, skills monitoring, job moves, promotions, and staff re structuring. 

• To Monitor Work-Related Licenses and Credentials, including provisioning  software licenses for use in the course of an employee’s work-related responsibilities, ensuring compliance, training, examination, and other  requirements are met with applicable regulatory bodies.

• To Provide Our Employees with Human Resources Management  Services, including providing employee data maintenance and support services,  administration of separation of employment, approvals and authorization  procedures, administration and handling of employee claims, and travel  administration. 

• To Administer International Assignments, including relocation services,  documenting assignment terms and conditions, obtaining relevant immigration  documents, initiating vendor services, fulfilling home/host country tax  administration and filing obligations, addressing health requirements and  populating the BSG global system. 

• To Maintain Your Contact Information, including altering your details across  relevant entities within the Lever group of companies (for example personal,  other employment and transferring roles). 

• To Assist You in Case of Emergency, including maintenance of contact details  for you, and your dependents in case of personal or business emergency. 

• To Monitor Eligibility to Work in the U.S., which means monitoring and ensuring  compliance of employees’ ability to work in the U.S. 

• To Conduct Healthcare-Related Services, including conducting pre-employment  and employment-related medical screenings for return-to-work processes and  medical case management needs; determining medical suitability for particular  tasks; identifying health needs of employees to plan and provide appropriate  services, including operation of sickness policies and procedures; and providing  guidance on fitness for travel and fitness for expatriation. 

• To Facilitate Better Working Environment, which includes conducting staff  surveys, providing senior management information about other employees, and  conducting training. 

• To Ensure a Safe and Efficient Working Environment, which includes Lever  actions relating to disciplinary actions, and code of conduct processes and  investigations. 

• To Maintain Security on Company Websites, which includes hosting and  maintenance of computer systems and infrastructure; management of BSG’s  software and hardware computer assets; systems testing, such as development  of new systems and end-user testing of computer systems; training; and  monitoring email and Internet access.

To Comply with Applicable Law or Regulatory Requirements, such as legal (state and  federal) and internal company reporting obligations, including headcount, management  information, demographic and Health, Safety, Security, and Environmental reporting. 

We may also disclose the following Personal Information to third parties, such as our  service providers and affiliates, for our operational business purposes: 

• Identifiers, such as name and government-issued identifier (e.g., Social  Security number); 

• Personal information, as defined in the California safeguards law, including  without limitation, name, signature, SSN, physical characteristics or  description, address, telephone number, passport number, driver’s license or  state identification card number, insurance policy number, education,  employment, employment history, bank account number, credit card number,  debit card number, or any other financial information, medical information, or  health insurance information; 

• Characteristics of protected classifications under California or federal law,  including without limitation, age, gender, medical conditions, marital status,  sex (including pregnancy, childbirth, breastfeeding, and related medical  conditions), race, color, religion or creed, ancestry, national origin, disability,  genetic information, AIDS/HIV status, sexual orientation, gender identity and  expression, citizenship, primary language, immigration status, military/veteran  status, political affiliation/activities, domestic violence victim status, and  request for leave; 

• Commercial information, such as transaction information and purchase  history; 

• Biometric information, such as fingerprints and voiceprints; 

• Internet or network activity information, such as browsing history and  interactions with our websites; 

• Geolocation data, such as device location; 

• Audio, electronic, visual and similar information, such as call and video  recordings; 

• Professional or employment-related information, such as work history and  prior employer; 

• Education information subject to the federal Family Educational Rights and  Privacy Act, such as student records and directory information; and • Inferences drawn from any of the Personal Information listed above to create a  profile or summary about, for example, an individual’s preferences and  characteristics. 

We have not “sold” Personal Information for purposes of the CCPA 

For purposes of this CCPA Notice, “sold” or “sale” means the disclosure of Personal  Information for monetary or other valuable consideration but does not include, for  example, the transfer of Personal Information as an asset that is part of a merger,  bankruptcy, or other disposition of all or any portion of our business.

Your Rights and Choices  

You may request that we:  

• Disclose to you the following information covering the 12 months preceding your  request: 

o The categories of Personal Information we collected about you and the  categories of sources from which we collected such Personal Information; o The specific Personal Information we collected about you; 

o The business or commercial purpose for collecting (if applicable) Personal  Information about you; and, 

o The categories of Personal Information about you that we otherwise  shared or disclosed, and the categories of third parties with whom we  shared or to whom we disclosed such Personal Information (if applicable).  

• Delete Personal Information we collected from you. However, BSG has the right  to maintain Personal Information, despite a deletion request, when retention of  the information is reasonably necessary for the business or necessary in order to  comply with a legal obligation. 

To exercise your rights under the CCPA, you must submit a “verifiable employee request.” Only you, or your authorized agent, may make a verifiable employee request  related to your personal information. You may also make a verifiable employee request  on behalf of your minor child.  

A verifiable employee request must provide sufficient information that allows us to  reasonably verify you are the person about whom we collected personal information or  an authorized representative. We will request, for example, the submission of your first  and last name, address, date of birth. If we cannot verify your identity or authority to  make the request, we will not be able to fulfill your request. The information provided for  verification will only be used for that purpose.  

You can request access to your personal information or have your information deleted.  To exercise your rights under the CCPA, please submit a request via email at  HR@Barbiersecurity.com or telephone at 415-747-8473. 

If you’ve already submitted a request and want to know the status, please submit a  request via email at HR@Barbiersecurity.com or telephone at 415-747-8473.  

If you are an authorized agent and would like to make a request on behalf of a  California Resident, please submit a request via email at HR@Barbiersecurity.com or  telephone at 415-747-8473. 

Non-Discrimination and Other Rights

You have the right to be free from unlawful discrimination, retaliation, and/or  harassment for exercising your rights under the CCPA.  

Changes to Our Privacy Notice  

We reserve the right to amend this privacy notice at our discretion and at any time.  When we make changes to this privacy notice, we will post the updated notice on the  website and update the notice’s effective date.  

Contact Information  

You can contact us with your questions, comments, rights requests, and other CCPA related inquiries:  

• Call 415-747-8473 

For privacy concerns, please contact the Privacy Officer at:  415-747-8473 

Effective Date:  This Privacy Notice for California consumers is effective August 4, 2023.