Pathway Capital Management, LP

Job Applicant Privacy Notice

Last Updated: June 30, 2020

For a number of business reasons, Pathway Capital Management, LP and its affiliates (collectively, “Pathway” “we,” “our,” or “us”) is required to collect certain personal identifying information from job applicants, employees, officers and contractors as well as former employees, officers, and contractors (collectively, the “workforce” or “you”) in the course of our recruitment, hiring and termination process, and in accordance with federal, state and local laws.

This Privacy Notice applies to the portion of our workforce who reside in the State of California only. For more information about how we collect information from consumers, please refer to: https://pathwaycapital.com/privacy-policy/

California Consumer Privacy Act (CCPA) Rights

Starting January 1, 2020, California residents have new privacy rights to their personal information. Businesses are required to inform members of the categories of personal information they collect and the purposes for which the categories will be used, at or before the point of collection.

What Information Do We Collect?

We collect the following categories of personal information:

• Identifiers, such as name, parents’ surnames prior to marriage, alias, home address, email address(es), telephone number(s) and other similar identifiers.
• Visual and audio information, such as on-site security cameras, video and audio recordings.
• Professional or employment-related information, such as pre-hire documents (such as job application, Curriculum Vitae/resumé, current and previous employment details, background check information and candidate evaluation(s)).
• Education information, including information about an employee’s educational background such as school records, school(s) attended, dates attended, degree(s) earned and transcripts that is not publicly available.
• Inferences, including any information drawn from any of the personal information categories referenced above to create a profile about an employee reflecting the employee’s characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

We may also collect additional information that you choose to provide to us during the interview process.

In addition, where relevant to the recruitment process, including where necessary to accommodate any disability needs or to comply with some regulatory requirements, we may also have the need to process some characteristics of protected classifications under California or federal law. This may include:

• Race, skin color
• Ancestry, citizenship status, national origin (including languages used and proficiency)
• Religion, creed, political affiliations or activities
• Age (40 and above)
• Disability, mental and physical
• Medical condition (such as genetic characteristics or request for family care leave, pregnancy disability leave or leave for an employee’s own serious health condition)
• Sex, gender (including pregnancy, childbirth, breastfeeding or related medical conditions)
• Sexual orientation, gender identity, gender expression
• Religion (including religious dress and grooming practices)
• Marital status
• Military or veteran status

How Do We Use Your Personal Information?

We may use or disclose the personal information we collect from you for one or more of the following purposes:

1. 1. To process your application, including to identify and contact you;
   2. To determine whether you have the professional skills, expertise, and experience for the position applied for;
   3. To verify employment with an outside entity;
   4. If you are offered a position with us, to verify the Personal Information provided including your identity, address, right to work, employment history and academic background and other background screening purposes including, where allowed by law, criminal record checks and sanctions screening checks;
   5. To provide you with information about future job vacancies, if you would like us to send you such notifications, which may include using data analytics to match your profile against vacant positions; and
   6. To accommodate your disability needs.

We may collect additional categories of personal information for other business-related purposes and/or use personal information collected for additional purposes, upon prior written notice to you.

Security of Your Personal Data

We employ security measures and technologies, such as password protection, encryption and physical locks, etc., to prevent the unauthorized access and disclosure of your personal information.

This Privacy Notice is effective as of the date noted above.

We welcome your questions, comments, and concerns about privacy. You may contact Human Resources at HR@pathwaycapital.com for any additional questions.