ATTENDANCE ON DEMAND PRIVACY POLICY

This policy is effective December 23, 2022.

Your privacy is important to Attendance on Demand, Inc. (“Attendance on Demand”) Please read the following carefully to understand our policies and practices regarding your personal information and how we treat it.

The policy applies to (1) our website and mobile applications (“Site”), (2) the products or services offered on or through the Site (“Services”), and (3) communication between you and us, whether it be by email, text message, chat or other electronic means of communication. By interacting with the Site, Services or communicating with us through the Site or Services, you agree to this policy. This policy may be changed at any time and without advanced notice. Your continued use of the Site or Services is deemed to be acceptance of such changes. Please check the policy occasionally for updates. The effective date at the top of this policy will be updated if any changes are made.

Personal Information Collected

Attendance on Demand collects and manages information for business contacts, such as marketing contacts and website visitors, differently from employment information necessary for the workforce management services we deliver to our clients. The following sections describe this information and how it is used.

Business Contact Information

To access the Services, you may be asked to provide information that allows you to be identified as a particular person (“Personal Data”). We collect certain types of Personal Data when you register for a white paper, contact us, or visit us at a trade show. This Personal Data may include:

• Your name
• Your company
• Your company's address
• Your phone number
• Your email address

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this policy, including without limitation, your acknowledgement and agreement that such Personal Data may be transferred from your current location to offices and servers of Attendance on Demand and/or those third party providers with whom we have a relationship, including analytics and distribution partners (“Service Providers”), and to our affiliates, employees and contractors located in the United States and other countries.

Site Monitoring

Attendance on Demand, or its Service Providers may send a cookie to your computer or use web beacons to gather statistical information when you visit our site. Neither cookies nor web beacons personally identify you.

A cookie is a piece of data that a website can send to your browser, which is then stored on your computer as an anonymous tag that identifies your computer. When a visitor accesses certain pages on the Site an anonymous notice of that visit is generated which may be processed by us or by our Service Providers. Web beacons work in conjunction with cookies to let us know what portions of the Site are of interest to you and to help us provide you with tailored information from our Site. We use the information primarily to provide you with a personalized Internet experience that delivers information, resources, and services that are most relevant and helpful to you.

If you never provide us with Personal Data, then your visits - despite us using cookies or web beacons - are anonymous. We don't know the actual person linked with the cookie or web beacon.

If you do provide Personal Data, then we are capable of linking your Personal Data with your cookie, then gather the visits with web beacons and understand how you personally have acted when visiting the Site.

Browsers can be set to accept or reject cookies or notify you when a cookie is being sent. If you turn off cookies, web beacon technology will still detect anonymous visits, but the notices they generate cannot be associated with other anonymous information or Personal Data and are disregarded.

“Do Not Track” is a preference you can set in your web browser to let websites you visit know that you do not want them collecting information about you. This is an optional feature that each website may choose to respond or not respond to when requests are received. At this time, this Site does not respond to Do Not Track or other similar signals.

Third-party vendors, including Google (www.google.com/policies/privacy/partners/) and Facebook, show Attendance on Demand ads on sites across the Internet. Third-party vendors, including Google, may use cookies and/or web beacons to serve ads based on past visits to our website. You may be able to opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.

Employment-Related Information

We provide workforce management services to employers. If your employer uses our Services, we may receive and process Personal Data that identifies you and is related to the work you do or your use of our Site or Services.

Such Personal Data may be transferred from your work location to offices and servers of Attendance on Demand and/or those third party providers with whom we have a relationship, including Service Providers, and to our affiliates, employees and contractors located in the United States and other countries.

If you have questions about your employment-related data, contact your employer.

How We May Use Your Information

Business Contact Information

We will only use and disclose your Personal Data and other information collected on our Site or through our Services in the following ways:

1. For the reasons or purposes for which you gave it to us or with your consent.
2. To our employees, contractors, affiliates, business partners and Service Providers relating to the Services offered on or through the Site or in associate with the Services, each of these entities is under contractual obligations to protect the confidentiality of such information.
3. To administer our Site and Services, including to operate, maintain, and provide to you the features and functionality of our Services.
4. For marketing purposes, including to personalize your experience and to deliver custom content, products and Services relevant to your interests.
5. To address and remedy any inquiries or complaints made by or about you related to our Services.
6. To recognize you and remember your information when you return to our Site or Services.
7. Pursuant to applicable law or regulation or in response to a subpoena or an order of a court or government agency.
8. To establish, exercise, or defend against legal claims, including to protect the safety of an individual or to protect Attendance on Demand's rights and/or property.
9. To help maintain the safety, security, and integrity of our Site, Services, technology assets, and business.
10. To a parent, subsidiary, or affiliate of Attendance on Demand: (i) in the event of a reorganization or restructuring, or (ii) for use and processing in accordance with this policy.
11. In connection with a change of ownership or control, including, without limitation, a merger or an acquisition of any or all of Attendance on Demand's business assets.

Employment-Related Information

If we receive or collect information about you in the context of providing workforce management Services to your employer, we use, process, and disclose this information only to provide such Services. We do not sell Personal Information or share it for marketing purposes.

At the direction or with the permission of your employer, we may disclose Personal Information to our Service Providers and other third parties, such as affiliates supporting our Services, payroll processors, or ACA filing providers. These parties are contractually obligated to use Personal Information only in providing services and to protect its confidentiality. We will also disclose personal data when required to do so by law, such as in response to a subpoena.

If you have questions about your employment-related data, contact your employer.

Privacy Policies of Third Parties

This policy only addresses the use and disclosure of information by Attendance on Demand. Other websites, application and platforms may be accessible through this Site or Services and have their own privacy policies and data collection, use and disclosure practices. Our affiliates and business partners have their own privacy policies too. We encourage you to familiarize yourself with the privacy policies provided by all third parties prior to providing them with information.

Children Under 13

We do not intentionally collect information from children under 13 on the Site and the Site and Services are not intended or designed for use by children under 13. If you are aware that a child under 13 has provided us with information and notify us at privacy@attendanceondemand.com and we shall promptly remove such information.

Updating Your Information

If we receive and use your Personal Information in the context of providing services to your employer, contact your employer to correct or update this information.

If we collect and use your Personal Information in any other context, you can opt-out or unsubscribe using a link at the bottom of our email communications. You can update or correct your information by emailing us at privacy@attendanceondemand.com.

Notice to Residents of California

Personal Information Related to Employment

Attendance on Demand is a service provider to employers who may be subject to California privacy laws, such as the California Consumer Privacy Act (“CCPA”), including amendments and authority promulgated thereunder.

We receive Personal Information from and about you for a variety of purposes. To learn more about the types of Personal Information we collect, the sources from which we collect or receive Personal Information, and the purposes for which we use this information, please see the rest of this policy.

We have received the following categories of consumer (employee) Personal Information within the last twelve (12) months:

California Rights and Choices

CCPA provides California residents with certain rights regarding their Personal Information (subject to certain limitations at law). The following paragraphs describe these CCPA rights. If we receive your Personal Information through your employer's use of our Services, contact your employer to exercise these rights.

Right to Access and Portability

California residents have the right to request disclosure of certain information about the collection and use of Personal Information over the last twelve (12) months. Once your employer receives and confirms your verifiable consumer request, we will assist, at their request, in disclosing to you the following:

• The categories of Personal Information collected
• The categories of sources for the Personal Information collected Our business or commercial purpose for collecting Personal Information
• The categories of third parties with whom we share that Personal Information
• The specific pieces of Personal Information collected about you (also called a data portability request)
• If we disclose your Personal Information for a business purpose, identifying the Personal Information categories disclosed.

Right to Deletion

The CCPA allows California residents the right to request the deletion of any Personal Information that we collect and retain, subject to certain exceptions.

A request may be denied if retaining the information is necessary to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity
• Debug products to identify and repair errors that impair existing intended functionality
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
• Enable solely internal uses that are reasonably aligned with consumer expectations
• Comply with a legal obligation and requests from law enforcement agencies
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Right to Opt-Out of the Sale of Your Information

We do not currently sell data, as it is defined in the CCPA and we restrict our service providers from doing so. We have also not sold Personal Information in the preceding twelve (12) months.

Request Submissions

To exercise the access and deletion rights under the CCPA as described above, please submit your request to your employer.

Verifiable Consumer Requests

A verifiable consumer request may be submitted by a California resident or a person registered with the California Secretary of State that is authorized to act on your behalf. Requests for access can only be made twice during a twelve (12) month period. Requests for access and deletion must:

• Detail sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Your employer cannot respond to your request or provide you with Personal Information if your identity or authority to make the request cannot be verified.

Timeframe for Responding to Requests

We will respond to requests from your employer within forty-five (45) days of receipt. The period of response may be extended to sixty (60) or ninety (90) days if more time is required. In that event, we will inform your employer of the reason and extension period in writing.

Fee

We do not charge individuals a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

No Discrimination

The CCPA prohibits a business from discriminating against California residents for exercising the rights outlined above.

No Financial Incentive

We do not offer any financial incentives or price or service differences in an attempt to influence a resident's decision whether or not to exercise a right afforded to the consumer under the CCPA.

Authorized Agent

A California resident may use an authorized agent to submit an access request or a request to delete.

Other Personal Information Rights

If you want to exercise any rights relating to your Personal Information that your place of residence provides (and that are applicable to our Site or Service), you should contact us by email privacy@attendanceondemand.com or by postal mail: Attention: Privacy, Attendance on Demand, 22300 Haggerty Road, Northville, MI 48167. We may request verification of your residency and identification before honoring requests.

Notice to Residents of Countries Outside the United States

Attendance on Demand is headquartered in the United States of America. Your Personal Information may be accessed by or transferred to the United States or to our affiliates or third parties elsewhere in the world. By providing us with your Personal Information, you consent to this transfer. We use commercial reasonable measures to protect the privacy of your Personal Information, regardless of where it is processed or stored.

BIOMETRIC INFORMATION POLICY

Attendance on Demand, Inc. hosts data for customers using its labor management services. When customers use biometric time clocks, finger or hand templates (“Templates”) are also stored. Some states, including Illinois and Texas, have statutes governing biometric information. Templates are digitally-converted representations of geometric measurements of the hand or fingerprint. Templates may or may not be deemed to be biometric information under such statutes. Attendance on Demand;s policy is designed to protect and store the Templates in accordance with applicable standards and biometric information laws.

Storage of Biometric Data

Templates are stored in time clocks and in the customer's Attendance on Demand database. They can be deleted at the time clock, with authorized access, and through the Attendance on Demand service by an authorized system user. Templates are included in production backups of Attendance on Demand customer databases. Attendance on Demand will not sell, lease, trade, or otherwise profit from an individual's Templates and shall only disclose, re-disclose or disseminate an individual's Templates with necessary consents or as may be required by law.

Routine Maintenance of Biometric Data

Customers are responsible for complying with applicable standards and laws. For example, under the Illinois law, customers must delete an individual's biometric data when the initial purpose for collecting or obtaining the data has been satisfied or within three years of the individual's last interaction with the customer, whichever occurs first. When an employment relationship ends, the customer terminates the employee through the Attendance on Demand service by changing the employee's status. The customer should also delete the Template when the employee's status is set to Terminated. This causes the Template to be deleted from the Attendance on Demand database and the time clock (at the time clock's next synchronization).

Maintenance and Storage of Backups and Archives

Backups of active customer databases are automated and take place on an incremental hourly, daily, weekly and quarterly basis. These production backups are kept for a maximum of one year. After one year, they are destroyed.

Authorized support personnel from Attendance on Demand, Inc. may occasionally backup or copy a system for the purposes of testing and troubleshooting. It is Attendance on Demand's policy that these backups be deleted when they are no longer needed. As a precaution, all manual backups are destroyed after one year.

Attendance on Demand, Inc. archives databases of clients that are no longer using the Attendance on Demand service. As part of the archive process, all Templates are deleted.

Security of Biometric Information

Attendance on Demand, Inc. takes great care with all employee data, including Templates and such care is within the reasonable standard of care for this industry. Attendance on Demand stores, transmits, and protects the Templates in a manner that is the same or more protective than it stores, transmits, and protects other confidential or sensitive information. Templates are transmitted with encryption. Access to employee information is protected through access rights and password authorization. Biometric information cannot be imported or exported from the system. In addition, Attendance on Demand's hosting environment and backup storage are protected from unauthorized access by physical and digital security measures.

This Attendance on Demand, Inc. Biometric Information Policy should not be construed as legal advice. Contact your legal counsel for clarification and/or advice regarding this and other state laws and regulations.

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