JOB APPLICANT PRIVACY NOTICE

Effective date: April 1, 2024

1. Overview
We recognize the importance of your privacy and maintaining the confidentiality of your personally identifiable information (“Personal Information”). This Job Applicant Privacy Notice (“Privacy Notice” or “Notice”) describes how Hearts on Fire Company, LLC and its affiliates (“HOF“, “we”, “us” or “our”) may collect, use, disclose, protect and retain Personal Information about you in connection with recruitment and pre-employment activities (including recruitment activities of individuals being considered for rendering contracted services to HOF in an individual capacity (“independent contractors”)).

2. Categories of Personal Information We Collect
In the past twelve months, and generally during the course of your pre-employment relationship with us, we may collect or may have collected the following types of professional and educational Personal Information about you to generally administer our recruitment and pre-employment activities (as further described below):
• Personal identification and communication information: name, phone number, mailing address, email address, social security number (which may also be considered sensitive personal information) and other taxpayer/government identification number, date of birth, gender, and residency and work permit status.
• Application-related information: curriculum vitae (CV), cover letter, employment history, education history, qualifications and skills, reference contact information, name of referrer, position preferences, willingness to relocate, desired salary, interests and aspirations, background screening information if relevant and bank account information if we reimburse expenses.
• Interview Information: Notes collected by interviewers and other professional assessment information.
• Pre-employment Screening: If we offer you a job, we may collect additional background information such as criminal history and eligibility information (as permitted by law).
• Device Information and Other Unique Identifiers: Device identifier, internet protocol (IP) address, or similar unique identifiers (to the extent you apply through or otherwise interact with the HOF careers portal).
• Sensitive personal information: social security number, driver’s license number, racial or ethnic origin, personal affiliations, information about your health (including where required, drug screening results) and disabilities where we need to make any reasonable accommodations, equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief, and/or criminal history.
In many instances, providing the Sensitive Personal Information listed above is voluntary and may not be a requirement for employment. If you decide not to share such information with us, not doing so will not impact your application. Note however that the collection of some of the categories of information above are required to process your application.

3. Sources of Collection
We collect most of the aforementioned information from you directly. For example, data is collected through our recruitment portal on HOF’s official website and CVs; from correspondence with you; or through interviews, meetings or other assessments. We also collect some information about you from third-party recruitment portals (e.g., LinkedIn, Indeed), other people (e.g. recruiters, referrals), your referees or organizations (e.g., from LinkedIn if you choose to connect us with your LinkedIn profile; where applicable, we also collect data from our third-party background screening provider during the pre-employment screening process).
If you provide to us any Personal Information relating to third parties, such as your reference(s), it is your responsibility to ensure that information you submit does not violate any third party’s rights and that you have obtained approval from that individual to provide information to us.

4. Why We Collect, Use and Store this Personal Information
We use your Personal Information and sensitive personal information for the following business purposes (“Processing Purposes”) associated with the administration of your application and our general business operations:
• To process your application, make informed decisions on recruitment and assess your suitability for the role, communicate with you about your application, respond to your inquiries and schedule interviews, and reimburse you for any agreed expenses incurred in the application process;
• To contact you about future career opportunities at HOF ;
• To improve our recruitment processes by analyzing your Personal Information and compare it to past recruitment processes;
• To verify the information provided by you and to carry out appropriate pre-employment background checks;
• To protect our business interests and legal rights, including, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes and ethics and compliance reporting requirements;
• To analyze and monitor the diversity of the workforce in accordance with applicable laws including, for example, compliance with equal opportunity employment laws; and
• To comply with legal, regulatory and other requirements under applicable laws.

5. How We Disclose Your Personal Information
Personal Information will primarily be processed by employees in our Human Resources, IT and finance departments. Your Personal Information may also be shared with or transferred as follows:
• Within HOF. We may disclose Personal Information to HOF’s group companies, including our ultimate holding company, our subsidiaries and corporate affiliates, joint ventures, and other companies under common control of our ultimate holding company for recruitment purposes.
• Service Providers. As part of normal business operations, HOF may disclose Personal Information to companies providing services, such as technology services including hosting, maintenance, administration and analysis, as well as other agencies, under contract to HOF as part of the recruitment process.
• Government Entities, Regulators or External Advisors. HOF may disclose Personal Information to government agencies and regulators external advisors (e.g., lawyers, accountants, and auditors), courts and other tribunals, and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws. Business Transactions. In the event of mergers, reorganizations or similar corporate restructuring activities, we may disclose information to our advisers and any prospective purchaser’s adviser and the new owners of the business. In some instances, this may include your Personal Information.
• Other Disclosures with Your Consent. We may ask if you would like us to disclose your Personal Information with other unaffiliated third parties who are not described elsewhere in this Privacy Notice.

6. Your Choices and Rights
If you are a resident of California, you may have certain rights regarding your Personal Information. The rights available to you depend on our reason for processing your Personal Information and the requirements of applicable law. Specifically, you may have the following rights:
• Access and portability: You have the right to request access to Personal Information we hold about you. Specifically, you have the right to request access to information about the categories of Personal Information concerned and categories of recipients to whom the Personal Information has been or will be disclosed, and the sources from which we receive that Personal Information among other information. You generally have the right to receive this Personal Information, in a structured, commonly used, and machine-readable format so you can transmit this Personal Information to another entity.
• Correction: You have the right to request correction of inaccurate Personal Information we may have about you.
• Deletion: You have the right to request that we delete your Personal Information.
• Opt out of the sale or sharing of Personal Information: We do not currently, nor have we in the preceding 12 months, sold or shared (in this context, share means use of your Personal Information for cross-contextual behavioral advertising ) your Personal Information. We do not knowingly sell or share the Personal Information of individuals under the age of 16.
• Online Tracking. Some web browsers incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. Not all browsers offer a DNT option and there is currently no industry consensus for how to recognize or respond to a DNT signal. We will endeavor to recognize commercially recognized opt out signals (e.g., Global Privacy Control). Recognition of this signal will only take place with respect to the device and/or browser that communicates the signal.
• Automated processing: Under certain circumstances, you have the right to object to a significant decision based solely on automated processing (i.e., without human intervention ) unless that decision is required or authorized by law. We do not presently engage in automated processing without human intervention.
• Non-discrimination: We do not discriminate against applicants who exercise any of their rights described in this Privacy Notice, nor do we retaliate against applicants who exercise these rights. However, we may require the use of your Personal Information to administer your pre-employment relationship with us. Therefore, in some instances, we may not be able to process your request.
• Restriction of processing of sensitive personal information. You have the right to request the restriction of processing of your sensitive personal information. At the current time, however, we do not use or disclose sensitive personal information for purposes other than those expressed in this Notice or otherwise permitted by applicable law, and these uses cannot be limited under California law.
If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law. Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request.
A person authorized to act on your behalf may make a verifiable request related to your Personal Information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.
Your verifiable request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
To exercise your rights, please contact us as stated in the “Contact Us” section of this Privacy Notice.

7. How Long We Retain Your Personal Information
HOF will retain your Personal Information, including sensitive personal information, only for as long as it is necessary to fulfill the above-mentioned Processing Purposes, or as required to comply with applicable legal requirements. Even when the recruitment and pre-employment screening activities are complete, we may need to keep your information longer because of a legal action, or an investigation involving HOF.

8. Confidentiality and Security
We maintain appropriate technical and organizational measures designed to protect against unauthorized or unlawful processing of Personal Information and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage to Personal Information.

9. Contact Us
If you have questions about this Privacy Notice or wish to contact us for any reason in relation to our Personal Information processing, please contact us via email talent@heartsonfire.com.