Disclosure to Worksite and Internal Employees Pursuant to the California Consumer Privacy Act (CCPA)

CoAdvantage may collect, receive, maintain, and use the Personal Information of current and former worksite employees for the following business purposes:

1. Complying with state and federal law and regulations requiring maintenance of certain records (records related to immigration, personnel matters, wages and payroll, accidents and safety, employer and employee taxes, benefits, insurance, unemployment, garnishments, and leaves of absence);
2. processing payroll;
3. maintaining commercial insurance policies and coverages, including for workers' compensation and other liability insurance;
4. managing workers' compensation claims;
5. administering and maintaining group health insurance benefits and products, 401K and/or retirement plans;
6. communicating with worksite employees regarding employment-related matters such as upcoming benefits enrollment deadlines, action items, availability of W2s, and other alerts and notifications; and
7. providing Human Resources best practices consulting services and tools to the Company’s customer (the worksite employer) to assist them in engaging in the following, tasks, including but not limited to:
   1. worksite employer’s management of worksite employees;
   2. workplace investigations (such as investigations of workplace accidents or injuries, harassment, or other misconduct);
   3. customer’s evaluation of job applicants and candidates for employment or promotions;
   4. information gathered through background checks on job applicants and employees;
   5. customer’s decisions to hire, terminate, promote, demote, transfer, suspend or discipline.
8. Managing and securing online portals CoAd360 and CoAdQuantum or mobile application to which worksite employees may have access for purposes of receiving and providing employment-related information, including maintaining information on who accessed the portal or application and their activity, detecting security incidents, debugging to identify and repair errors that impair existing intended functionality of the portal or application, and protecting against malicious or illegal activity.

The Company may collect, receive, and maintain the following categories of Personal Information of worksite employees for the above business purposes as referenced by number:

CATEGORY	EXAMPLES	BUSINESS PURPOSE
Personal Identifiers	Name, alias, postal or mailing address, email address, telephone number, social security number, driver’s license or state identification card number, passport number	1, 2, 3, 4, 5, 6, 7a.-7.e, 8
Physical Characteristics or Description	Eye color, hair color, hair style, height, weight, built, tattoos, piercings	4, 6, 7.b
Financial Information	Bank account number for direct deposit, credit card number, debit card number, or other financial account information	1, 2
Protected Classifications	Race, ethnicity, national origin, sex, gender, sexual orientation, gender identity, religion, age , disability, medical or mental condition, military status, familial status, language	1, 4, 5, 7.b
Pre-Hire Information	Job application, resume, background check results, drug test results, job interview notes, and candidate evaluation records	1, 2, 6, 7.b, 7.c, 7.d, 7.e
Professional or Employment-Related Information	Personnel file, new hire or onboarding records, I-9 forms, tax forms, time and attendance records, non-medical leave of absence records, workplace injury and safety records, performance evaluations, disciplinary records, training records, licensing and certification records, compensation and health benefits records, and payroll information and records	1, 2, 3, 4, 5, 6, 7a.-7.e, 8
Medical and Health Information	Doctor’s notes for absences or work restrictions, medical leave of absence records, requests for accommodation, interactive process records, and correspondence with employee and his/her medical or mental health provider(s) regarding any request for accommodation or medical leave of absence, as well as post-hire drug test results	1, 3, 4, 5, 7.a, 7.b, 7.e
Education Information	Information from resumes regarding educational history; transcripts or records of degrees and vocational certifications obtained	1, 7.a, 7.b, 7.c, 7.e
Online Portal and Mobile App Access and Usage Information	Username and password, account history, usage history, file access logs, and security clearance level	1, 6, 8