PRIVACY NOTICE FOR CALIFORNIA RESIDENTS SEEKING EMPLOYMENT

INTRODUCTION

If you are a California resident who has applied for or sought employment with Europ Assistance North America (the “Company”, “we”, “us”, or “our”), this Privacy Notice for California Residents Seeking Employment (the “Privacy Notice”) applies to you (“Prospective California Employees” or “you”). Europ Assistance North America adopts this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”).

ORGANIZATIONS COVERED BY THIS PRIVACY NOTICE

Europ Assistance North America is a family of companies, including (i) GMMI, Inc., (ii) Trip Mate, Inc.,

(iii) Customized Services Administrators, Inc. (iv) Generali Global Assistance, Inc. and (v) Generali US Branch.

SCOPE OF THIS PRIVACY NOTICE

1. This Privacy Notice is intended to describe our practices as required by the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”) and other California privacy laws. Any terms defined in the CCPA/CPRA have the same meaning when used in this Privacy Notice. This Privacy Notice supplements information contained in our Privacy Policy and takes precedence with respect to Personal Information for Prospective California Employees if there is a conflict between the two.
2. In this Privacy Notice, when we talk about “Personal Information”, we mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Prospective California Employee.
3. You should be aware that Personal Information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA/CPRA’s scope, like:
  • Protected Health Information under HIPAA, information subject to the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

INFORMATION WE COLLECT FROM PROSPECTIVE CALIFORNIA EMPLOYEES

We have collected the following categories of Personal Information from Prospective California Employees within the last twelve (12) months:

USE OF PERSONAL INFORMATION

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

1. To consider or process an application for employment or to verify information provided to us in connection with the pre-employment process;
2. To effectively process expense reimbursement requests;
3. To comply with state and federal law requiring employers to maintain certain records;
4. As necessary or appropriate to protect the rights, property, or safety of us, our clients or others, including conducting appropriate security and related reviews of our systems;
5. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations, including garnishments, withholdings or similar requests or proceedings; and
6. As described to you when collecting your Personal Information or as otherwise set forth in the CCPA/CPRA. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

RIGHTS AND CHOICES UNDER THE CCPA/CPRA

• Right to Access. You have the right to access your Personal Information that we may collect or retain about you. If requested, we shall provide you with a copy of your Personal Information that we collect as permitted under the CCPA/CPRA.
• Right to Know. You have the right to request that we disclose the following about your Personal Information, as defined under the CCPA/CPRA:
  • The specific Personal Information we may collect;
  • The categories of Personal Information we may collect;
  • The categories of sources from which we may collect your Personal Information;
  • The business purpose(s) for collecting or sharing your Personal Information;
  • The categories of Personal Information we may disclose for business purposes; and
  • The categories of third parties to whom we may share your Personal Information.
• Right to Deletion.
  • You have the right to request that we delete any of your Personal Information that Company collected from you and retained, subject to certain exceptions. Any requests for deletion should be directed at legal@us.generaliglobalassistance.com.; and
  • Company may deny your deletion request for reasons permitted by the CCPA/CPRA. (i.e. if the information is excluded from the CCPA/CPRA or does not constitute Personal Information).
• Right to Opt Out. You have the right to opt out of the sale or sharing of Personal Information. If we sell any of your Personal Information, you have the right, at any time, to tell us not to sell your Personal Information. At the time this Privacy Policy was last updated, we do not sell any Personal Information. You also have the right to request that we do not share your Personal Information.
• Right to Correct. You have the right to request the correction of any Personal Information we maintain about you.
• Right to Limit Use or Disclosure of Sensitive Personal Information (“SPI”). You have the right to limit the use and disclosure of your SPI, if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services.
• Response Timing and Format. Once verified the request is from a California consumer, Company will try to respond within 45 days. If we need more time, we will tell you in writing why and how much longer we need, either by mail or electronically (based on your choice).
• Non-Discrimination. Company will not discriminate against you for choosing to exercise any of your CCPA/CPRA rights, including with respect to any Company services.

HOW WE SECURE YOUR PERSONAL INFORMATION

We use appropriate technical and organizational measures to protect the Personal Information of our Prospective California Employees. For example, we limit access to your Personal Information to members of Company’s and Company’s affiliates’ and subsidiaries’ personnel with a need to know in connection with their job duties, such as select personnel within the recruiting, human resources, finance, legal, insurance, information security and IT departments, as well as individuals evaluating you as a candidate, and for talent acquisition, human resources, and business uses.

CHANGES TO THIS PRIVACY NOTICE

We may change this Privacy Notice at any time. Please check this Privacy Notice regularly to ensure that you are aware of any changes. We may try to notify you of material changes to this Privacy Notice, which if we do so may be by sending an email notification (if you have provided your email address to us), or by other reasonable methods.

INQUIRIES OR CONCERNS?

If you have any questions about this Privacy Notice or concerns about how we manage your Personal Information, please contact the Compliance Department (contact information below). We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.

Attn: Customer Privacy Management Office
9797 Aero Drive, Suite 300
San Diego, CA 92123
Phone Number: 866-757-0010
Email: consumerprivacy@us.generaliglobalassistance.com