Effective Date: 05/04/22

Scope

This Privacy Notice applies to applicants and prospective employees (collectively, “Applicants”) and employees, contractors, contingent and other personnel (collectively, “Workers”) whose personal information Primary Kids, Inc. may collect and process in the course of its Human Resources Operations, from submission of an application, throughout the course of an individual’s tenure the Company, and following such employment or services (collectively, the “Human Resources Operations”).

The terms “Primary,” “we,” “us,” and “our” include Primary Kids, Inc. and its affiliates and subsidiaries. This Privacy Notice explains the kinds of information we may collect, how we intend to use and share that information, and how you may be able to opt-out of a use or correct or change such information.

Personal Information We Collect

Primary collects personal information from Applicants and Workers as described below.

Personal Information We Collect from You Directly. We may collect the following personal information that you provide to us:

• Profile/Demographic Information. Name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, employment history, education, professional qualifications, salary information, financial information related to credit checks, bank details for payroll, information that may be recorded on a resume/CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect sensitive personal information such as details of health and disability, including medical information, health insurance information, mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race or veteran status, which helps us achieve our diversity goals.

• Communications with Us. We may collect personal information such as personal contact information when an Applicant or Worker communicates with us, for example to inquire about employee benefits.

• Posting on Intra-Company Sites. Primary may offer intra-company accessible sites, pages, messaging channels, blogs, or forums (“Intra-Company Sites”). Primary and other individuals who use the Intra-Company Sites may collect the information you submit or make available through these sites. If you choose to submit content to any public area of the Intra-Company Sites, such content will be considered “public” and will not be subject to the privacy protections set forth herein.

Personal Information We Collect Automatically.

• Use of Primary Information Technology Systems and Networks. Primary may collect certain information automatically through the course of your employment or services, such as your Internet protocol (IP) address, inferred location based on your IP address or activities, device identifiers associated with your computer or device, mobile carrier and related information, activity logs, and other information about activities you engage in on Primary property, equipment, accounts, systems and networks. Primary may monitor and review Workers’ uses of Primary equipment, accounts, information technology systems and networks, including its phone networks, computer networks, including those used to access the Internet, videoconferencing systems and other company-provided electronic communications tools. Primary may access and review electronic files, messages, and emails sent or stored on its information technology systems, including accounts, computers and devices provided to Workers.

Please note that you have no expectation of privacy while at Primary premises or using Primary information technology systems, networks, and electronic communication tools. Please also note that this Privacy Notice does not establish, and should not be construed to mean, that all Workers will have access to, or will participate in, the systems, networks, data, programs and other business activities described in this Privacy Notice.

• Surveys. From time to time, we may ask you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information. All information collected from your participation in our surveys is provided by you voluntarily.

• Contests. Occasionally, Primary may run contests. We ask those who participate to provide information relevant to the contest, which may include personal information.

Information from Other Sources. We may collect or receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, where permitted by law, we may conduct background and credit checks on you prior to your employment with Primary.

Miscellaneous Information. We may receive or collect other miscellaneous information (for example, information you choose to disclose during the interview process, whether in oral or written form, opinions generated during the interview process, and information provided to us during performance reviews).

How Primary Uses Your Information

We process personal information for a variety of business purposes including:

• To assess your suitability, aptitude, skills, qualifications, and interests for employment with or provide services to Primary;

• To communicate with you about the application process and/or your application;

• To assist you with obtaining an immigration visa or work permit (where required and requested by you);

• To take steps at your request prior to entering into a relationship with you (for example, after we have sent you an offer, to process certain personal information to enter into and commence employment);

• Workflow management, including assigning, managing and administering projects;

• Human Resources Operations administration and communication;

• Payroll and the provision of benefits;

• Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;

• To pursue our legitimate interests (for example, fraud prevention, network and information security, disclosure to affiliated organizations for administrative tasks, Worker monitoring for safety or management, whistleblowing schemes, enforcement of legal claims, and research purposes);

• Job grading activities;

• Performance and Worker development management;

• Organizational development and succession planning;

• Benefits and personnel administration;

• Absence management;

• Helpdesk and IT support services;

• Internal and/or external or governmental compliance investigations;

• Internal or external audits;

• Where it is necessary for the establishment, exercise or defense of legal claims;

• Diversity and inclusion initiatives;

• Restructuring and relocation;

• Emergency contacts and services;

• Worker safety;

• To comply with our legal obligations;

• Processing of Worker expenses and travel charges;

• Acquisitions, divestitures, and integrations; and

• As you otherwise agree or consent.

How We Disclose Your Information

We may share your information as described in this Privacy Notice (e.g., with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust personal information include service providers for: (i) maintaining our Human Resources Operations; and (ii) the provision of IT and related services.

Affiliates and Subsidiaries. Primary may share personal information with our affiliates and subsidiaries for our and our affiliates’ and subsidiaries’ internal business purposes.

Displaying to Other Individuals. When you post content to the Intra-Company Site(s), other individuals may be able to see some information about you, such as your name and/or picture in addition to the content you post. While we expect all Workers to follow Primary’s Employee Handbook, we are not responsible for practices of the individuals who view and use your information.

Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal processes, such as court orders or subpoenas; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation or prosecution of suspected or actual illegal activity.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another entity, your information may be transferred as part of such a transaction as permitted by law and/or contract.

International Data Transfers

All information collected via or by Primary may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States, in order to carry out our Human Resources Operations. We endeavor to safeguard your information consistent with the requirements of applicable laws.

Your Choices

In some instances, you may have the ability to opt out of certain uses and disclosures of your personal information.

For more information on the choices you may have and how to exercise them, please contact us as set forth below.

Individual Rights in Personal Information

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction of inaccurate, untrue or incomplete personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by Primary, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, Primary will take steps to verify your identity before fulfilling your request.

Data Retention

Primary retains the personal information we receive as described in this Privacy Notice for as long as necessary to fulfill the purpose(s) for which it was collected, carry out our Human Resources Operations, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

Third Party Websites/Applications

Various resources and sites at Primary may contain links to third party websites/applications and other websites/applications may reference or link to Primary. These third-party services are not controlled by us. We encourage Applicants and Workers to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Changes To Our Privacy Notice and Practices

We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue your employment with or services to the Primary after the new Privacy Notice takes effect. If at any point you do not agree to any portion of the Privacy Notice in effect, you must immediately contact Human Resources.

CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, please contact Primary by email at hr@primary.com.