Worksite Employee Privacy Policy

Contents

1. Scope of this Policy
2. Collection of Personal Information and Sensitive Personal Information
3. What Sensitive Personal Information We Collect
4. Sources of Personal Information
5. To Whom We Disclose Personal Information
6. Reasons Why We Collect, Use, Retain, and Disclose Personal Information
7. Retention of Personal Information
8. Third-Party Vendors
9. Business Transfers
10. Compliance With Law and Safety
11. Passwords
12. Worksite Employees and Their Family Members, Dependents, and Beneficiaries Under the Age of 16
13. How We Protect the Information That We Collect
14. Rights Under the CCPA and CPRA
15. Consent to Terms and Conditions
16. Changes to Our Privacy Policy
17. Individuals With Disabilities
18. Questions About the Policy

Scope of this Policy

CoAdvantage Corporation (“CoAdvantage”) or the “Company” or “we”) has developed this Privacy Policy out of respect for the privacy of the worksite employees of our customers and their family members, dependents, and beneficiaries. Your employer (“Worksite Employer”) has entered into an agreement with the Company under which we provide Professional Employer Organization (“PEO”) services to the Worksite Employer. The PEO services provided by the Company typically include payroll processing, workers' compensation coverage, and other services and/or benefits as may be selected by your Worksite Employer. As a worksite employee, you remain an employee of the Worksite Employer. The Company is not a joint employer with your Worksite Employer, and this Privacy Policy does not and cannot be interpreted to create an employment relationship between you and the Company.

This Policy describes the personal information we collect, both online and offline, for what purposes we use and disclose it, how long we retain it, and whether we sell it or share it for cross-context behavioral advertising purposes (we don't by the way). We will collect some information from you, including information about your family members, dependents, and beneficiaries, for various purposes as detailed in this Privacy Policy during the course of the Company providing services to your Worksite Employer.

This Privacy Policy applies only to information collected, used, or disclosed by the Company in the course of providing services to your employer. It does not apply to other contexts, including when accessing our website or inquiring about or applying for a job with CoAdvantage, and with respect to our own employees. Our Online Privacy Policydescribes our data collection and use practices when you visit our public-facing website or engage in transactions with the Company in other capacities (as a client or customer); our Job Applicants Privacy Policy applies to data collected in the process of inquiring about or applying for a job with CoAdvantage; and our Employee Privacy Policy applies to our collection of data from or about our employees and their family members, dependents, and beneficiaries.

Collection of Personal Information and Sensitive Personal Information

In the last 12 months, we have collected the following categories of personal information from or about worksite employees and their family members, dependents, and beneficiaries. For each category of information, we identify below the categories of third parties, service providers, and contractors to whom we have disclosed the information in the last 12 months. The examples provided for each category are not intended to be an exhaustive list or an indication of all specific pieces of information we collect from or about you in each category, but rather the examples are to provide you a meaningful understanding of the types of information that may be collected within each category.

Category	Personal Identifiers
Examples	Name, alias, social security number, date of birth, driver's license or state identification card number, passport number, permanent resident alien card number, alien registration number, employment authorization document number, school ID, voter's registration card number, U.S. military card number, draft record, military dependent ID number, native American tribal document number, school record, report card, clinic, doctor or hospital record, day-care or nursery school record, birth certificate, certifications of report of birth document, U.S. citizen ID card number, worksite employee ID number, professional license number.
Disclosed in Last 12 Months To	Financial institutions Government agencies Credit and consumer reporting agencies Benefits administrators and vendors, including third party administrators, 401K administrators, workers' compensation and unemployment administrators, and wellness vendors Insurance carriers, administrators, and brokers Employee tracking and talent management systems Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer IT, cybersecurity, and privacy vendors and consultants

Category	Contact Information
Examples	Home, postal or mailing address, email address, home phone number, cell phone number, emergency contact number.
Disclosed in Last 12 Months To	Financial institutions Government agencies Benefits administrators and vendors, including third party administrators, 401K administrators, workers' compensation and unemployment administrators, and wellness vendors Insurance carriers, administrators, and brokers Employee tracking and talent management systems Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer IT, cybersecurity, and privacy vendors and consultants

Category	Account Information
Examples	Username and password for access to Company accounts, systems, and any required security or access code, password, or credentials allowing access to your Company accounts.
Disclosed in Last 12 Months To	IT, cybersecurity, and privacy vendors and consultants

Category	Visual, Audio, or Video Recordings
Examples	Photos, images, audio recordings, video recordings, or any necessary evidence for workers compensation claims.
Disclosed in Last 12 Months To	Government agencies Benefits administrators and vendors, including third party administrators, 401K administrators, workers' compensation and unemployment administrators, and wellness vendors Insurance carriers, administrators, and brokers Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer

Category	Protected Classifications
Examples	Race, ethnicity, national origin, citizenship or immigration status, sex, gender, sexual orientation, gender identity, religious or philosophical beliefs, age, physical or mental disability, medical condition, veteran or military status, familial status, language, or union membership.
Disclosed in Last 12 Months To	Government agencies Benefits administrators and vendors, including third party administrators, 401K administrators, workers' compensation and unemployment administrators, and wellness vendors Insurance carriers, administrators, and brokers Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Employee tracking and talent management systems Your Worksite Employer

Category	Physical Characteristics or Description
Examples	Information on your driver'''s license (such as eye color, hair color, height, weight), as well as information collected to the extent relevant for workplace investigations.
Disclosed in Last 12 Months To	Government agencies Benefits administrators and vendors, including third party administrators, 401K administrators, workers' compensation and unemployment administrators, and wellness vendors Insurance carriers, administrators, and brokers Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer

Category	Financial Information
Examples	Bank account number for direct deposit, and worksite employee's personal credit card number, debit card number, or other financial account information.
Disclosed in Last 12 Months To	Financial institutions Government agencies Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS)

Category	Pre-Hire Information
Examples	Information provided in your job application or resume, information gathered as part of background screening and reference checks, pre-hire drug test results, information recorded in job interview notes by persons conducting job interviews for the Company's customer (Worksite Employer), information contained in candidate evaluation records and assessments, information in work product samples you provided, voluntary disclosures by you, and Wage Opportunity Tax Credit (WOTC) information.
Disclosed in Last 12 Months To	Financial institutions Government agencies Insurance carriers, administrators, and brokers Employee tracking and talent management systems Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer Credit and consumer reporting agencies

Category	Employment History
Examples	Information regarding prior job experience, positions held, and when permitted by applicable law your salary history or expectations.
Disclosed in Last 12 Months To	Government agencies Employee tracking and talent management systems Insurance carriers, administrators, and brokers Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer Credit and consumer reporting agencies

Category	Education Information
Examples	Information contained in your resume regarding educational history and information in transcripts or records of degrees and vocational certifications obtained.
Disclosed in Last 12 Months To	Government agencies Employee tracking and talent management systems Insurance carriers, administrators, and brokers Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer Credit and consumer reporting agencies

Category	Professional or Employment-Related Information
Examples	Information contained in your personnel file and in other employment documents and records, including information in new hire or onboarding records, I-9 forms, tax forms, time and attendance records, non-medical leave of absence records, workplace injury and safety records, performance evaluations, disciplinary records, investigatory records, training records, licensing and certification records, compensation and health benefits records, pension, retirement and 401(k) records, COBRA notifications, business expense records, and payroll records.
Disclosed in Last 12 Months To	Financial institutions Government agencies Benefits administrators and vendors, including third party administrators, 401K administrators, workers' compensation and unemployment administrators, and wellness vendors Insurance carriers, administrators, and brokers Employee tracking and talent management systems Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer Communications providers/vendors Credit and consumer reporting agencies

Category	Travel Information
Examples	Information regarding business travel, vacation, and personal travel plans.
Disclosed in Last 12 Months To	Government agencies Benefits administrators and vendors, including third party administrators, 401K administrators, workers' compensation and unemployment administrators, and wellness vendors Insurance carriers, administrators, and brokers Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer

Category	Family Information
Examples	Contact information for family members listed as emergency contacts, contact information for dependents and other dependent information.
Disclosed in Last 12 Months To	Government agencies Benefits administrators and vendors, including third party administrators, 401K administrators, workers' compensation and unemployment administrators, and wellness vendors Insurance carriers, administrators, and brokers Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer

Category	Medical and Health Information
Examples	Medical information contained in such documents as doctor's notes for absences or work restrictions, medical leave of absence records, requests for accommodation, interactive process records, ergonomic assessment and accommodation records, and correspondence with you and your medical or mental health provider(s) regarding any request for accommodation or medical leave of absence, as well as information in post-hire drug test results, and information related to symptoms, exposure, contact tracing, diagnosis, testing, or vaccination for infectious diseases (e.g., COVID-19), pandemics, or other public health emergency. This includes medical information and health benefits information for dependents and beneficiaries.
Disclosed in Last 12 Months To	Government agencies Benefits administrators and vendors, including third party administrators, 401K administrators, workers' compensation and unemployment administrators, and wellness vendors Insurance carriers, administrators, and brokers Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer

Category	Internet, Network, and Computer Activity
Examples	Internet or other electronic network activity information related to usage of Company networks, servers, intranet, or shared drives, including system and file access logs, security clearance level, browsing history, search history, and usage history.
Disclosed in Last 12 Months To	Government agencies Employee tracking and talent management systems Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Communications providers/vendors Your Worksite Employer IT, cybersecurity, and privacy vendors and consultants

Category	Mobile Device Security Information
Examples	Data identifying worksite employee devices accessing Company networks and systems, including cell phone make, model, and serial number, cell phone number, and cell phone provider.
Disclosed in Last 12 Months To	Government agencies Employee tracking and talent management systems Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Communications providers/vendors Your Worksite Employer IT, cybersecurity, and privacy vendors and consultants

Category	Online Portal and Mobile App Access and Usage Information
Examples	Username and password or worksite employee's account on Company-controlled and managed systems, apps, and online portals, account history, usage history, file access logs, and security clearance level.
Disclosed in Last 12 Months To	Government agencies Employee tracking and talent management systems Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Communications providers/vendors Your Worksite Employer IT, cybersecurity, and privacy vendors and consultants

Category	Geolocation Data
Examples	IP address and/or GPS location (latitude & longitude) recorded in timekeeping applications on cell phones that worksite employees use to clock in and out and that log the geographic location at which each time entry was made.
Disclosed in Last 12 Months To	Government agencies Employee tracking and talent management systems Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Communications providers/vendors Your Worksite Employer IT, cybersecurity, and privacy vendors and consultants

Category	System Access Records
Examples	Information identifying which worksite employees accessed security Company systems and networks and at what times using their login credentials, or other security access method.
Disclosed in Last 12 Months To	Government agencies Employee tracking and talent management systems Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS) Your Worksite Employer IT, cybersecurity, and privacy vendors and consultants

What Sensitive Personal Information We Collect

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information we may collect from or about worksite employees:

1. Personal Identifiers (social security number, driver's license or state identification card number, passport number)
2. Account Information (your Company account log-in, in combination with any required security or access code, password, or credentials allowing access to the account)
3. Protected Classifications (racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, union membership, or sexual orientation)
4. Medical and Health Information
5. Geolocation Data (IP address and/or GPS location, latitude & longitude)

Personal information does not include:

• Publicly available information from government records.
• Information that a business has a reasonable basis to believe is lawfully made available to the general public by the worksite employee or from widely distributed media.
• Information made available by a person to whom the worksite employee has disclosed the information if the worksite employee has not restricted the information to a specific audience.
• De-identified or aggregated information.

Sources of Personal Information

We may collect your personal information from the following sources:

• You, the worksite employee, when you voluntarily submit information
• Company systems, networks, software applications, and databases you log into or use in the course of performing your job, including from vendors the Company engages to manage or host such systems, networks, applications or databases
• Government agencies
• Insurance carriers, administrators, and brokers
• Credit and consumer reporting agencies
• Drug testing and physical testing providers and vendors
• HR support vendors, including administrators of benefits, leaves of absence, workers' compensation, unemployment claims, payroll, timekeeping, expense management, and training platforms
• Social media platforms
• Recruiters
• Staffing agencies
• Personal references and former Worksite Employers
• Other worksite employees, contractors, vendors, and customers based on your interactions with them
• Our affiliates, including parent, subsidiary, or sister companies

To Whom We Disclose Personal Information

We may disclose your personal information to the following categories of service providers, contractors or third parties:

• Financial institutions
• Government agencies
• Credit and consumer reporting agencies
• Benefits administrators and vendors, including third party administrators, 401K administrators, workers' compensation and unemployment administrators, insurance brokers, and wellness vendors
• Insurance carriers, administrators, and brokers
• Employee tracking and talent management systems
• Payroll processors, timekeeping vendors, and vendors providing services for purposes of our human resources information system (HRIS)
• Communications providers/vendors
• Your Worksite Employer
• IT, cybersecurity, and privacy vendors and consultants
• Our affiliates, including parent, subsidiary, or sister companies

Reasons Why We Collect, Use, Retain, and Disclose Personal Information

We may collect and disclose your personal information for any of the following business purposes:

1. To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to become a worksite employee, we will use that Personal Information in connection with your employment with your Worksite Employer or your relationship with us.
2. To assist the Company's customer (the Worksite Employer) to comply with local, state, and federal law and regulations requiring maintenance of certain records (such as immigration compliance records, travel records, personnel files, wage and hour records, payroll records, accident or safety records, and tax records).
3. To comply with local, state, and federal law and regulations that apply to the Company.
4. To manage and process payroll.
5. To validate a worksite employee's identity for payroll and timekeeping purposes.
6. To maintain commercial insurance policies and coverages, including for workers' compensation and other liability insurance.
7. To manage workers' compensation claims.
8. To administer, manage, and maintain group health insurance benefits, 401K and/or retirement plans, and other Company benefits and perks.
9. To provide Human Resources best practices consulting services to the Company's customer (the Worksite Employer), including the following topics:
10. Worksite Employer's management of worksite employees.
11. Workplace investigations (such as investigations of workplace accidents or injuries, harassment, or other misconduct).
12. Worksite Employer's evaluation of job applicants and candidates for employment or promotions.
13. Information gathered through background checks on job applicants and worksite employees and to verify worksite employment references.
14. Worksite Employer's decisions regarding a worksite employee's employment, including decisions to hire, terminate, promote, demote, transfer, suspend or discipline.
    1. To communicate with worksite employees regarding employment-related administrative matters such as upcoming benefits enrollment deadlines, action items, availability of W2s, and other alerts and notifications.
    2. To implement, monitor, and manage electronic security measures on Company networks, software applications or systems, including managing and securing online portal CoAdQuantum, CoAdEnroll, and CoAd360, as well as on worksite employee devices that are used to access Company networks, software applications or systems.
    3. To engage in corporate transactions requiring review or disclosure of worksite employee records subject to non-disclosure agreements, such as for evaluating potential mergers and acquisitions of the Company.
    4. To assist in communications with an employee's family or other contacts in case of emergency or other necessary circumstance.
    5. To assist the Company's customer (the Worksite Employer) to promote and foster diversity, equity, and inclusion in the workplace.
    6. To evaluate, assess, and manage the Company's business relationship with vendors, service providers, and contractors that provide services to the Company.
    7. To improve user experience on Company computers, networks, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
    8. To detect security incidents involving potentially unauthorized access to and/or disclosure of Personal Information or other confidential information, including proprietary or trade secret information and third-party information that the Company receives under conditions of confidentiality or subject to privacy rights.
    9. To protect against malicious or illegal activity and prosecute those responsible.
    10. To prevent identity theft.
    11. To verify and respond to consumer requests under applicable consumer privacy laws.

We do NOT and will not sell your personal information in exchange for monetary or other valuable consideration. We do not share your personal information for cross-context behavioral advertising.

We do NOT and will not use or disclose your sensitive personal information for any purposes that give rise to a right to limit the use or disclosure of your sensitive personal information under the California Consumer Privacy Act (CCPA), if it applies and you are a California resident.

Retention of Personal Information

CoAdvantage will retain and use your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. The user account will remain active until responsible contracting company has either disabled the account or termination of service contract with CoAdvantage.

Third-Party Vendors

We may use other companies and individuals to perform certain functions on our behalf. Examples include administering e-mail and payroll services. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose.

Business Transfers

In the event we sell or transfer a particular portion of our business assets, worksite employee information may be one of the business assets transferred as part of the transaction. If substantially all of our assets are acquired, employee information may be transferred as part of the acquisition.

Compliance With Law and Safety

We may disclose specific personal and/or sensitive personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect worksite employees or the public.

Passwords

The personal data record created through your registration for your various Company accounts, including to access timekeeping and payroll applications, can only be accessed with the unique password associated with those records. To protect the integrity of the information contained in those records, you should not disclose or otherwise reveal your passwords to third parties.

Worksite Employees and Their Family Members, Dependents, and Beneficiaries Under the Age of 16

We do not knowingly sell or share the personal information of worksite employees or any of their family members, dependents or beneficiaries under 16 years of age.

How We Protect the Information That We Collect

The protection of the information that we collect about worksite employees is of the utmost importance to us and we take every reasonable measure to ensure that protection, including:

• We use commercially reasonable tools and techniques to protect against unauthorized access to our systems.
• We restrict access to private information to those who need such access in the course of their duties for us.

Rights Under the CCPA and CPRA

This section of the Privacy Policy applies only to California residents. If you are a California resident, you have the following rights pursuant to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

1. Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected, shared or sold about you, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we disclose or have disclosed your personal information;
2. Right to Access. The right to request, up to 2 times in a 12-month period, that we provide you access to or disclose to you the specific pieces of personal information we have collected about you;
3. Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we have collected from you, subject to certain exceptions;
4. Right to Correct. The right to request that we correct inaccurate personal information (to the extent such an inaccuracy exists) that we maintain about you;
5. The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and
6. The right to not be discriminated or retaliated against for exercising any of the above rights.

You Can Submit Any of the Above Types of Requests by Any of the Options Below:

1. Submit an online request on our website by filling out this Request Form.
2. Call our privacy toll-free line at (800) 868-1016.

How We Will Verify That it is Really You Submitting the Request:

If you are a California resident, when you submit a Right to Know, Right to Access, Right to Delete, or Right to Correct request through one of the methods provided above, we will ask you to provide some information in order to verify your identity and respond to your request. Specifically, we will ask you to verify information that can be used to link your identity to particular information in our possession, which depends on the nature of your relationship and interaction with us.

Responding to your Right to Know, Right to Access, Right to Delete, and Right to Correct Requests

Upon receiving a verifiable request from a California resident, we will confirm receipt of the request no later than 10 business days after receiving it. We endeavor to respond to a verifiable request within forty-five (45) calendar days of its receipt. If we require more time (up to an additional 45 calendar days, or 90 calendar days total from the date we receive your request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

For a request to correct inaccurate personal information, we will accept, review, and consider any documentation that you provide, and we may require that you provide documentation to rebut our own documentation that the personal information is accurate. You should make a good-faith effort to provide us with all necessarily information at the time that you make the request to correct. We may deny a request to correct if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive. If we deny your request to correct, we shall inform you of our decision not to comply and provide an explanation as to why we cannot comply with a request, if applicable.

If You Have an Authorized Agent:

If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf. To do so, you must either (a) execute a valid, verifiable, and notarized power of attorney, or (b) provide other written, signed authorization that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf. We will also contact you and ask you for information to verify your own identity directly and not through your authorized agent. We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that they have been authorized by you to act on your behalf.

Consent to Terms and Conditions

By onboarding as a worksite employee of a Worksite Employer who has contracted with CoAdvantage Corporation, you consent to all terms and conditions expressed in this Privacy Policy.

Changes to Our Privacy Policy

As our services evolve and we perceive the need or desirability of using personal information collected in other ways, we may from time to time amend this Privacy Policy. We encourage you to check the CoAdQuantum or CoAd360 frequently to see the current Privacy Policy in effect and any changes that may have been made to them. If we make material changes to this Policy, we will post the revised Policy and the revised effective date on the CoAdQuantum or CoAd360. Please check back here periodically or contact us at the address listed at the end of this Policy.

Individuals With Disabilities

This Policy is in a form that is or will be made accessible to individuals with disabilities.

Questions About the Policy

If you have any questions about this Privacy Policy, please contact us at privacy@CoAdvantage.com or call 800-868-1016.

**This Policy was last updated May, 2025.