Privacy Notice (CA)

This privacy notice for California Residents (this “Privacy Notice”) is provided in addition to the information in any other privacy notice provided by The Skain Group L.L.C. and its affiliates (together, “TSG”, “we”, “us” or “our”) and explains how TSG collects, uses and discloses Personal Information relating to residents of the State of California (“consumers”, “you” or “your”) covered by the California Consumer Privacy Act of 2018 as amended from time to time, together with any applicable regulations (the “CCPA”).

TSG adopts this Privacy Notice to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this Privacy Notice. This Privacy Notice is effective from January 1, 2020.

This Privacy Notice does not apply to (i) TSG personnel or job applicants seeking opportunities at TSG, (ii) personnel working on behalf of business partners with whom we are conducting business, or (iii) information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.

We may amend this Privacy Notice from time to time by posting the updated Privacy Notice on our website.

1. NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We may collect the following categories of Personal Information about you online or offline:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers.

• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information.

• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status.

• Commercial Information: commercial or investment information, including financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies.

• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.

• Sensory Information: audio, electronic, visual, and similar information.

• Employment Information: professional or employment-related information.

• Education Information: ducation information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).

• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of Personal Information listed above for the purposes described in our Privacy Notice (Non-EU). In addition, we may use these categories of Personal Information for certain business or commercial purposes, as described in this table:

Purposes Categories of Personal Information

Performing Services

Auditing related to a current interaction with you and concurrent transactions

Short-term, transient use

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

Debugging to identify and repair errors that impair existing intended functionality

Undertaking internal research for technological development and demonstration

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

2. OUR PRIOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

We may have collected and used your Personal Information, as described in section 1 above, during the 12-month period prior to the effective date of this Privacy Notice. For the Personal Information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the Personal Information, (b) the categories of third parties with whom we may have shared the Personal Information, and (c) the categories of Personal Information we may have disclosed for a business purpose.

     a. Sources of Personal Information

We may have obtained Personal Information about you from various sources, as described below.

Categories of Sources of Data Collection Categories of Personal Information

From you, for example, through your use of our websites, when you send us an email, visit our facilities, or otherwise contact or communicate with us

From monitoring tools, such as cookies that track your use of our websites

Our affiliates

Vendors (e.g., background check providers), advisors and other business partners

Recruiting agencies, social media networks or publicly available sources

c. Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties for a business purpose all of the categories of Personal Information about you listed in Section 1 above.

Categories of Third Parties Categories of Personal Information

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; Education Information and Inferences

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Sensory Information; Employment Information; Education Information and Inferences

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Sensory Information; Employment Information; Education Information and Inferences

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences

c. Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties for a business purpose all of the categories of Personal Information about you listed in Section 1 above.

   d. Sale of Personal Information

TSG has not sold Personal Information in the preceding twelve (12) months. TSG does not sell Personal Information, including not selling the Personal Information of minors under 16.

3. CALIFORNIA CONSUMER PRIVACY RIGHTS

You have certain choices regarding our use and disclosure of your Personal Information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the Personal Information we have collected, used, and disclosed about you during the past 12 months.

Deletion: You have the right to request that we delete certain Personal Information we have collected from you.

How to Submit a Request: To submit an access or deletion request, call us at 800-905-3401 or submit a completed Access and Deletion Rights Request Form to dataprivacyofficer@tsg.nyc.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If you request access to or deletion of your Personal Information, we may require you to provide any of the following information: address, date of birth, unique personal identifier, nationality, telephone number, email address, CV information or details of a transaction. In addition, if you ask us to provide you with specific pieces of Personal Information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent written permission to do so, and (2) verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Privacy Notice is available in alternative formats upon request. Please contact dataprivacyofficer@tsg.nyc or 800-905-3401to request this Privacy Notice in an alternative format.

Last updated: October 2020