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Privacy Notice for California Employees

Last Updated: December 12, 2022

Generate Capital, PBC and its affiliates (“Company,” “we,” or “us”) value the trust of our job applicants and employees and endeavor to protect the privacy of their personal information. The purpose of this privacy policy (this “Policy”) is to notify California residents (“you”) of the processing of information that can reasonably be linked with them and that we collect, use, and disclose in the context of their current or former role as our employees or job applicants (“Personal Information”).

This Policy also applies to the beneficiaries of your employment benefits, such as the individuals who are on your health plan and the beneficiaries of your retirement accounts, as well as your emergency contacts. It is your responsibility to inform any such individuals about this Policy and ensure that you have the right to provide their Personal Information to us.

How We Collect Your Information

We collect Personal Information in a number of ways, for example:

  • from the information you provide to us when you interact with us before making an application to work for us, for example when you come for an interview;
  • when you submit a formal application to work for us, and provide your Personal Information in application forms, covering letters, résumés, and similar materials;
  • from third parties, for example through background screening checks, and your previous or current employers, in order to verify details about you and / or your application to work for us;
  • during the course of your employment or other engagement with us, including in the course of carrying out your employment (or equivalent) duties; and
  • in various other ways as you interact with us during your time as an employee, and afterwards, where relevant, for the various purposes set out below.

The Types of Information We Collect and Disclose to Others

The following chart details which categories of Personal Information we collect and process, as well as which categories we disclose to third parties for our operational business and employment purposes, including within the 12 months preceding the date this Policy was last updated.

Categories of Personal Information Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name, alias, postal address, unique personal identifiers, IP address that can reasonably be linked or associated with a particular individual, email address, account name, online identifiers, photos, beneficiary designations, and government-issued identifiers (e.g., Social Security number, driver’s license) Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Personal information as defined in the California customer records law, such as name, contact information, signature, passport number; medical, insurance, financial, education and employment information Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, consulting, training, expense management, medical/health, and other services; professional advisors, such as accountants, auditors , bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Protected Class Information under California or federal law, such as sex, age, gender, race, religion, national origin, disability, medical conditions, citizenship, military/veteran status, gender identity and expression, primary language, immigration status, marital status, and requests for leave Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, consulting, , medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Commercial Information, such as transaction information and purchase history, such as travel expenses, including information about corporate credit card purchases, frequent flyer rewards, and other travel-related programs and expenses Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Internet or network activity information, such as access and usage information regarding websites, applications, and systems, information about online communications, including browsing and search history, timestamp information, IP address, and access and activity logs Our affiliates; service providers that provide services such as IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Geolocation Data, such as device location, company-owned vehicle location, and approximate location derived from IP address, or GPS, Wi-Fi, or BLE tracking Our affiliates; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Audio/Video Data. Audio, electronic, visual, and similar information, such as call and video recordings, including voicemail and security camera footage, information about the use of electronic devices and systems, key card usage; photos on websites or in employee directories Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Education Information subject to the federal Family Educational Rights and Privacy Act, s, academic standing, confirmation of graduation and degree received Our affiliates; investors; capital providers; service providers that provide services such as background checks, payroll, professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Employment Information. Professional or employment-related information, such as work history and prior employer, information from reference checks, background screening information, employment application, membership in professional organizations, personnel files, personal qualifications and training, eligibility for promotions and other career-related information, work preferences, business expenses, wage and payroll information, benefit information, information on leaves of absence or PTO, performance reviews, information on internal investigations or disciplinary actions Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, characteristics, predispositions, and abilities Our affiliates; service providers that provide services such as payroll, benefits, training, expense management, medical/health, IT, and other services; professional advisors, such as accountants, auditors, bankers and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Sensitive Personal Information.

  • Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin;; citizenship or immigration status; union membership; the contents of mail, email, and text messages unless the company is the intended recipient of the communication; genetic data;
  • Personal Information collected and analyzed concerning an individual’s health;
  • Personal Information collected and analyzed concerning an individual’s sexual orientation
 Our affiliates; investors; capital providers; service providers that provide services such as payroll, benefits, training, consulting, expense management, medical/health, IT, and other services; public and governmental authorities, such as regulatory authorities and law enforcement

We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We do not sell Personal Information, and we do not share or otherwise process Personal Information for purposes of cross-context behavioral advertising, as defined under California law. We have not engaged in such activities in the 12 months preceding the date this Policy was last updated. Without limiting the foregoing, we do not sell or share the Personal Information of minors under 16 years of age.

Purposes for the Collection and Use of Personal Information

We collect and use Personal Information for the purposes of operating, managing, and maintaining our business, managing our workforce and other employment purposes, and accomplishing our business purposes and objectives, including, for example, to:

  • Plan and manage workforce activities and personnel generally, including for recruitment, employee onboarding, appropriate staffing, performance management, training and career development, payments and benefit administration, employee training, leaves and promotions;
  • Conduct workforce assessments, including determining physical or mental fitness for work and evaluating work performance;
  • Process payroll, manage wages and other awards such as stock options, stock grants, and bonuses, reimburse expenses and provide healthcare, pensions, savings plans, and other benefits;
  • Operate, maintain, monitor, and secure our facilities, equipment, systems, networks, applications, and infrastructure;
  • Manage attendance, time keeping, leaves of absence, and vacation;
  • Facilitate employee communication and workforce travel;
  • Undertake quality and safety assurance measures, protect the health and safety of our workforce and others, and conduct risk and security control and monitoring;
  • Conduct research, analytics, and data analysis, such as to assist in succession planning and to ensure business continuity, as well as to design employee retention programs and diversity initiatives;
  • Perform identity verification, accounting, budgeting, audit, and other internal functions, such as internal investigations, disciplinary matters, and handling grievances and terminations;
  • Operate and manage IT and communications systems and facilities, allocate Company assets and human resources, and undertake strategic planning and project management; and
  • Comply with law, legal process, requests from governmental or regulatory authorities, internal policies, and other requirements, such as income tax deductions, record-keeping, work permit and immigration regulations and reporting obligations, and the exercise or defense of legal claims.

Use of Sensitive Personal Information

We may use Sensitive Personal Information for purposes of performing services for our business, providing services as requested by you, and ensuring the security and integrity of our business, infrastructure and the individuals with whom we interact. This includes, without limitation, establishing and maintaining your employment relationship with us, ensuring the diversity of our workforce, complying with legal obligations, managing payroll and corporate credit card use, administering and providing benefits, and securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure.

How Long Personal Information is Kept

We retain Personal Information, including Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

  • The duration of your employment;
  • The length of time we have an ongoing relationship with you or your dependents/beneficiaries and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
  • Whether there is a legal obligation to which we are subject (for example, certain laws may require us to keep your employment records for a certain period of time); and
  • Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation, or regulatory investigations.

Individual Requests

You may, subject to applicable law, make the following requests:

  1. You may request that we disclose to you the following information covering the 12 months preceding your request:
    1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
    2. The business or commercial purpose for collecting Personal Information about you; and
    3. The categories of Personal Information about you that we disclosed and the categories of third parties to whom we disclosed such Personal Information.
  2. You may request to correct inaccuracies in your Personal Information.
  3. You may request that we delete Personal Information that we have collected from you.
  4. You may request to receive a copy of your Personal Information, including a copy of the Personal Information you provided to us in a portable format.

We will not unlawfully retaliate or discriminate against you for making a request under the CCPA.To make a privacy request, please use the privacy request form available at the bottom of our website at www.generatecapital.com or call 1 (833) 723-3264. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as first name, last name, email address and phone number, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information. We will verify and respond to your request consistent with applicable law.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Individual Requests.” As part of our verification process, we may request that the agent provide proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

Changes to this Employee Privacy Policy

We may change or update this Policy from time to time. When we do, we will communicate changes and updates to this Policy by posting the updated policy on The Grid.

Contact Us

If you have any questions about this Policy or how we process your Personal Information, you may contact the People Team at [email protected].