NOTICE AT COLLECTION FOR APPLICANTS RESIDING IN CALIFORNIA

In compliance with California regulations under the California Consumer Privacy Act (CCPA), Threshold Enterprises, Ltd. (the “Company”) is providing you with this Notice at Collection for Applicants Residing in California (“Notice”) to inform you about:

1. the categories of Personal Information that the Company collects about applicants who reside in California; and
2. the purposes for which the Company uses that Personal Information.

For purposes of this Notice,

“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person that the Company collects about its applicants, who reside in California, in their capacity as applicants for positions with the Company.

Assistance for Disabled Applicants

Alternative formats of this Notice are available to individuals with a disability. Please contact Phil Ray, Head of Human Resources, at phillipr@thresholdent.com for assistance.

1. Identifiers and Professional or Employment-Related Information
   1. Personal Information Collected: The Company collects identifiers and professional or employment-related information, including the following:

Identifiers: real name, nickname or alias, postal address, telephone number, e-mail address, signature, online identifier, Internet Protocol address, driver’s license number or state identification card number, and passport number.

Professional or Employment-Related Information: evaluations, business references, membership in professional organizations, professional certifications, and employment history.

1. 1. Purposes of Use:

Revised January 2021

1. Personal Information Categories from Cal. Civ. Code §1798.80(e)

The Company collects categories of Personal Information listed in Cal. Civ. Code §1798.80(e) (other than those already listed in “Identifiers,” above) as follows for the corresponding purposes listed below:

• Medical information: An employee will be asked to self-identify limits on ability to perform all of the essential functions of the position(s) for which they apply, with or without a reasonable accommodation, in order to establish fitness for duty and ability to perform essential job functions with or without reasonable accommodation.

1. Commercial Information
   1. Personal Information Collected: The Company may collect commercial information, including the following: products or services purchased, obtained, or considered.
   2. Purposes of Use: reimbursement of travel expenses.
2. Internet Or Other Similar Network Activity
   1. Personal Information Collected: The Company collects information about applicants’ use of the Internet or other similar network activity, including the following: log in/out and activity on the Company's electronic resources which includes browsing history and search history, information regarding an applicant's interaction with an Internet web site, application, or advertisement, and publicly available social media activity. For security and other lawful corporate purposes, the Company uses GPS location services, IP address tracking, logging, and other software, hardware, and measures. Usage of any digital technologies at the Company constitutes consent to these practices.
   2. Purposes of Use: to monitor use of the Company's information systems and other electronic resources or information systems, to conduct internal audits, to conduct internal investigations, and to protect the safety and security of the Company’s facilities and prevent unauthorized access to its phone, digital devices, computers, and network.
3. Sensory or Surveillance Data
   1. Personal Information Collected: The Company collects sensory or surveillance data, including the following: voicemails, and footage from video surveillance cameras.
   2. Purposes of Use: for purposes of communications, to protect the safety and security of the Company’s facilities and personnel through video surveillance, to evaluate the applicant’s suitability for employment, and to monitor compliance with Company policies.
4. Non-Public Education Information
   1. Personal Information Collected: The Company may collect education information, including the following: academic transcripts, educational discipline records, and academic counseling records.
   2. Purposes of Use: to evaluate applicants’ qualifications for employment with the Company and to conduct a pre-employment background check.
5. Background Screening Information
   1. Personal Information Collected: The Company collects background screening information, including results of the following types of background screening: personal references, business references, employment history; and educational history. Note: This Notice does not cover background screening governed by the Fair Credit Reporting Act, which is subject to other notice requirements.
   2. Purposes of Use: to evaluate applicants’ qualifications for employment with the Company.
6. Preferences
   1. Personal Information Collected: The Company collects applicant preferences information, including preferred meals, seating and other travel preferences, desired working hours, and desired working conditions.
   2. Purposes of Use: to evaluate the application for employment and for travel and event planning.

Purposes Potentially Applicable to Any of the Categories of Personal Information Listed Above

The Company also may use applicants’ Personal Information to facilitate administrative functions and information technology operations and for legal reasons and corporate transactions. These functions include, but are not limited to the following:

• to manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, strategic planning;
• to manage litigation involving the Company, and other legal disputes and inquiries and to meet legal and regulatory requirements;
• to manage licenses, permits and authorizations applicable to the Company's business operations.