CCPA

EFFECTIVE DATE: MARCH 31, 2024

CCPA Notice at Collection and Privacy Policy for California Employees and Applicants

The Flex Company is committed to protecting your privacy. The information that you provide to The Flex Company (sometimes referred to as “we”, “us”, “our”, or “Flex”) is utilized in order for us to (among other things) consider you for employment, retain you as an employee and to maintain employment records.

This Notice to California Employees and Job Applicants (“Notice”) applies to our offline and online data collection practices, including when you submit personal data for purposes of applying for and/or becoming a valued employee at The Flex Company (“Flex”), and in the course of your employment with Flex, pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not an employee or job applicant who is a California resident, this Notice does not apply to you.

This Notice serves as our “Notice of Collection” under the CPRA.

YOUR CONSENT

This Notice may be revised from time to time for any reason. If this Notice changes, the revised Notice will include a new effective date, and we will notify you of such changes by posting the revised policy.

You should read this entire Notice before submitting information, including personal information, to us in any form. Whenever you submit personal information to us, you consent to the collection, use, disclosure, transfer, and storage of that information in accordance with this Notice.

All personal information may be used for the purposes stated in this Notice. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form.

COLLECTION OF PERSONAL INFORMATION

Flex collects Personal Information and Sensitive Personal Information from you when you choose to voluntarily provide it for purposes of employment with Flex or applying for employment with Flex for the business purposes listed in the chart below. We are committed to properly handling the personal information collected or processed in connection with your employment relationship with us.

We will not sell the personal information, including any sensitive personal information, we collect about our employees or applicants for employment or share it with third parties for cross-context behavioral advertising.

We may collect the personal information and sensitive personal information categories listed in the tables below. The tables also list, for each category, our expected retention period and collection and use purposes/and whether we sell the information or share it with third parties for cross-context behavioral advertising.

Personal Information Category	Retention Period	Business Purpose	Sold or Shared
Identifiers, such as your full name, contact information, gender, date of birth, signature, Social Security number, driver's license or state identification numbers, and similar information for your dependents and beneficiaries.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks Conduct employee onboarding Maintain and administer payroll and employee benefit plans, including enrollment and claims handling Maintain personnel records and complying with record retention requirements Provide employees with human resources management services and employee data maintenance and support services Communicate with employees and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data Ensure employee productivity and adherence to Company policies Conduct internal audits and investigate complaints, grievances, and suspected violations of Firm policy Respond to law enforcement requests and as required by applicable law or court order Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents	No
California Customer Records employment and personal information, such as your name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certifications, bank account number, credit card number, debit card number, or any other financial, medical or health insurance information.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Same purposes as for identifiers category	No
Protected classification characteristics under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information).	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Comply with federal and state equal employment opportunity laws Design, implement, and promote the Company's diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits, grievances, and suspected violations of Company policy Exercise or defend the legal rights of the Company and its employees	No
Commercial information, such as transaction information, purchase history, and financial details.	N/A	N/A	Not collected
Biometric information, such as facial recognition, fingerprints, iris or retina scans, keystroke, or other physical patterns, and certain wellness metrics.	N/A	N/A	Not collected
Internet or other similar network activity information, including all activity on the Company's information systems (such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames, and passwords) and all activity on communications systems (such as phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an employee's use of company-issued devices).	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Facilitate the efficient and secure use of Company information systems Ensure compliance with Company information systems policies and procedures. Comply with applicable state and federal laws Prevent unauthorized access to, use, or disclosure or removal of the Company's property, records, data, and information Enhance employee productivity Conduct internal audits and investigate complaints, grievances, and suspected violations of Firm policy Exercise or defend the legal rights of the Company and its employees	No
Geolocation data, such as the time and physical location related to use of an internet website, application, or device, and GPS location data from mobile devices of employees who participate in our vehicle reimbursement program.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Improve safety of employees, customers, and the public regarding use of the Company property and equipment Prevent unauthorized access, use, or loss of the Company property Improve efficiency, logistics, and supply chain management Ensure employee productivity and adherence to the Company's policies Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company's policy	No
Sensory and surveillance data, such as COVID-19 related temperature checks and call monitoring and video surveillance.	N/A	N/A	Not collected
Professional or employment-related information, such as employment application information (work history, academic and professional qualifications, educational records, references, and interview notes, background check, drug testing results, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, leave of absence information including religious, military and family obligations, health data concerning employee and their family members.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Recruit and process employment applications, including verifying eligibility for employment, background checks, and onboarding Design and administer employee benefit plans and programs, including for leaves of absence. Maintain personnel records and comply with record retention requirements. Communicate with employees and their emergency contacts and plan beneficiaries. Comply with applicable state and federal labor, employment, tax, benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws. Prevent unauthorized access to or use of the Company's property, including its information systems, electronic devices, network, and data. Ensure employee productivity and adherence to the Company policies. Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company policy. Evaluate and provide useful feedback about job performance, facilitate better working relationships, and for employee professional development Exercise or defend the legal rights of the Company and its employees	No
Non-public education information, such as education records, degrees and vocational certifications obtained, report cards, and transcripts.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Evaluate an individual's appropriateness for hire, or promotion or transfer to a new position at the Company.	No
Inferences drawn from other personal information to create a profile or summary, for example, an individual's preferences, abilities, aptitudes, and characteristics.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Engage in human capital analytics, including to identify correlations about individuals and job success, analyze data to improve retention and productivity, and analyze employee preferences to inform human resources policies and procedures Conduct applicant reference checks to assist in hiring decisions	No

Sensitive personal information is a subtype of personal information consisting of specific information categories. We may collect or use information that falls within the sensitive personal information categories listed in the table below to infer characteristics about a person.

Sensitive Personal Information Category	Retention Period	Business Purpose	Sold or Shared
Government identifiers, such as your Social Security number, driver's license, state identification card, passport and visa information, and immigration status and documentation.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Recruit and process employment applications, including verify eligibility for employment and conducting background and related checks Process and administer payroll and employee benefit plans, including enrollment and claims handling Maintain personnel records and comply with record retention requirements Provide employees with human resources management services and employee data maintenance and support services Communicate with employees and their emergency contacts and plan beneficiaries Comply with applicable state and federal labor, employment, tax benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and related laws Prevent unauthorized access to or use of the Company property, including information systems, electronic devices, network, and data Respond to law enforcement requests and as required by applicable law or court order	No
Complete account access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password.	N/A	N/A	Not collected
Precise geolocation, such as physical access to a Company office location, or the location of a delivery, sales, or other employee in the field.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Improve safety of employees, customers, and the public regarding use of the Company property and equipment Prevent unauthorized access, use, or loss of the Company property Improve efficiency, logistics, and supply chain management Ensure employee productivity and adherence to the Company's policies Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company's policy Exercise or defend the legal rights of the Company and its employees	No
Racial or ethnic origin.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Comply with federal and state equal employment opportunity laws Design, implement, and promote the Company's diversity and inclusion programs Perform workforce analytics, data analytics, and benchmarking Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy	No
Religious or philosophical beliefs.	N/A	N/A	Not collected
Union membership.	N/A	N/A	Not collected
Mail, email, or text messages contents not directed to the Company.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Conduct internal audits and investigate complaints, grievances, and suspected violations of the Company policy Exercise or defend the legal rights of the Company and its employees, customers, contractors, and agents	No
Genetic data.	N/A	N/A	Not collected
Unique identifying biometric information.	N/A	N/A	Not collected
Health information, including job restrictions and workplace illness and injury information.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Investigate and process workers' compensation claims Process health insurance claims Conduct and process employment testing Ensure equal access to retirement programs and fertility planning by same-sex spouses Ensure equal family leave policies and insurance for transgender surgeries	No
Sexual/sexual orientation information.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.	Process health insurance claims Ensure equal access to retirement programs and fertility planning by same-sex spouses Ensure equal family leave policies and insurance for transgender surgeries	No

In addition to the terms set forth in Flex’s Notice of Collection and full privacy policy set forth at https://flexfits.com/pages/privacy-policy, the following additional privacy policy applies to employees and applicants based in California.

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED OR DISCLOSED

Personal Information Collected
In the past 12 months, we have collected the categories of personal information about California employees and job applicants as described in the Notice of Collection.

Information Sold or Shared
We have not sold personal information about California employees or job applicants in the past 12 months. However, we have disclosed the following categories of personal information about California employees and job applicants for a business or commercial purpose in the preceding 12 months:

IP address, device ID, browser type, domain names, access times and dates, pages viewed, one or more cookies that may uniquely identify your browser, referring website addresses, what applications are run on your company issued device, files downloaded, opened, and created using company managed equipment, geolocation of laptops and mobile devices which contain company data, and any personal information entered into any company controlled system, including company email.
Name, job title, mailing address, right to work for I-9 verification, phone number, date of birth, gender, names and relationships of dependents, emergency contact information, credit check, background check, resume with professional, employment and educational background, language proficiency, beneficiary designations, garnishment notices from tax agencies, proof of identification, health information, diversity information and EEO data collection.

YOUR RIGHTS
Information about your rights to know or delete, right to correct, right to non-discrimination are set forth in our full privacy policy set forth at https://flexfits.com/pages/privacy-policy.

CONTACT FOR MORE INFORMATION
For information and questions about the use of your personal information or this Employee Notice or your rights under California law, you may contact Human Resources at people@flexfits.com.

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