Security

JOB APPLICANT PRIVACY NOTICE

Last Updated: December 16, 2025

PLEASE READ THIS NOTICE CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AS WELL AS YOUR CHOICES AND RIGHTS.

INTRODUCTION

Obtelecare and its affiliates (also referred to herein as “we,” “us,” and “our”) are committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as a part of our business. We also believe in transparency, and we are committed to informing you about how we treat the data we collect and process. You may obtain an accessible version of this Notice by contacting us via the methods identified in the “Contact Us” section of this Notice.

When Does This Notice Apply? This Notice describes our practices for the personal information we receive, collect, use, share, and otherwise process in connection with your application for employment with us and our hiring process. It also describes your rights regarding your personal information. This Notice does not, however, create or form a part of any employment contract. For more information about how we process personal information in other contexts, please see our Privacy Policy. This Notice supplements and is a part of the Privacy Policy.

Further, this Policy does not apply to any information that is Protected Health Information (“PHI”), as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). We only collect, receive, maintain, use, and disclose PHI as permitted or required by applicable law, and you may learn more about how we use and disclose PHI and your rights under HIPAA by reviewing our Notice of Privacy Practices.

Our Role and Contact Information. We act as the “data controller” with respect to the information described in this Notice. Our contact information is provided at the end of this Notice.

HOW WE PROCESS PERSONAL INFORMATION

What Personal Information Do We Collect and Process? We collect and process the following personal information for the purposes described below, including in the “How Do We Share Personal Information?” “Additional HR Processing Activities” sections of this Notice. For residents of California, pursuant to the California Consumer Privacy Act, as amended (“CCPA”), we have identified the categories of personal information collected.

Category	Description and Purpose
Contact Information and Communications	We will collect your full name, address, telephone number, email address, and any other contact information that you provide to us. We will also receive your communications, including emails, with us. We process Contact Information and Communications to communicate with you, to process your application with us, and as described in the “Additional HR Processing Activities” section below. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute
Education and Professional Experience Data	You may share your résumé or Curriculum Vitae (CV) with us, which may contain information about your educational history, work history, professional experience, competencies, certifications, and skills. You may also share information in your application. We process Education and Professional Experience Data to assess and document your qualifications for the requirements of the role for which you applied, and as described in the “Additional HR Processing Activities” section below. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Professional or Employment-related Information; Education Information
Background Check Information	During the application process or when otherwise permitted by law, we will collect information from you in the form of official documentation (e.g., government-issued identification) and from third parties (e.g., references, former employers, government agencies, background check providers, credit bureaus, publicly available resources, and websites) to the fullest extent permitted by law. This may include public information gathered from social media. We process Background Check Information for background screening and vetting, to carry out our obligations under applicable law, and as described in the “Additional HR Processing Activities” section below. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Professional or Employment-related Information; Education Information; Sensitive Personal Information
Verification of Identity and Right to Work Information	At various times, we may ask you to provide your full name, date of birth, residential address, government identification number, and a copy of your government-issued photo identification. We process Verification of Identity and Right to Work Information to confirm your identity and your entitlement to work in the applicable country, to carry out our obligations under applicable law, and as described in the “Additional HR Processing Activities” section below. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Sensitive Personal Information
Expense Reimbursement Information	When you seek reimbursement for approved hiring-related travel, we will ask you to complete a form to facilitate reimbursement of any expenses you incurred, in accordance with our reimbursement policies. This information may identify your location and other activities, including how much was spent, when, and why. We process Expense Reimbursement information to facilitate reimbursements and as described in the “Additional HR Processing Activities” section below. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Commercial Information; Geolocation Data
Sensitive Information	We process certain sensitive personal information and/or “special categories” of data, such as your social security number, identification card (e.g., driver’s license, state ID card, passport), data revealing racial or ethnic origin, trade union membership, and data concerning health and safety (e.g., incident reports, workers’ compensation claims, leave requests, and requests for accommodations). We process Sensitive Information to carry out our obligations under applicable law and, where permitted by applicable law, as described in the “Additional HR Processing Activities” section below. CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Sensitive Personal Information
*Note: This list contains examples of information we may have about you, and it does not guarantee that we currently hold or have ever held this information about you.

How Do We Collect Personal Information? We will collect information from you (including in your application and interviews). We may also collect information from third parties, including references, former employers, government agencies, background check providers, credit bureaus, publicly available resources, websites, and others.

Is Personal Information Required? You may object to our collection of data, but certain information is mandatory. If you do not provide the required information, we will not be able to perform certain activities necessary to process your application for employment.

How Do We Share Personal Information? Where permitted by applicable law, we disclosed the personal information described above in the following contexts. We will only disclose your personal information where, when required by law, the recipient has provided written assurances that it will protect any personal information disclosed to it in accordance with applicable law.

Team Members. Your information will be shared internally for human resources and operational purposes. This includes members of our Human Resources team, managers, and others who participate in interviews with you.
Affiliates. We share personal information with our subsidiaries and affiliates and with their respective officers, directors, employees, and agents.
Corporate Transactions. We will disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of our company or some or all of our assets or businesses. If our business (or any component of it) is acquired by or merged with another company, your information may be transferred to the new owners.
Disclosures with Your Consent. We will disclose your information to fulfill the purposes for which it was collected, the purposes for which you provided it, and the purposes disclosed to you when you provided the information. We may also ask if you would like us to share your information with third parties who are not described elsewhere in this Notice. We will only disclose your personal information in this context with your consent.
Legal Obligations. We will, to the extent permitted by law, disclose personal information in response to subpoenas, warrants, court orders, and other legal process, and to comply with relevant laws. We also share information in order to establish and exercise our legal rights, to pursue claims, to defend against legal claims, and to investigate, prevent, and take action regarding possible illegal activities, suspected fraud, safety of person or property, and/or violations of contract.
Service Providers and Advisors. We share personal information with our and our affiliates’ contractors, service providers, insurers, debt collectors, and professional advisors (including attorneys, accountants, consultants, and auditors) that need access to the information to provide services on our behalf or perform functions for us. Among other things, the recipients help us administer the Sites, support our provision of services, send communications, store data, and assist with other legitimate purposes permitted by law. You may also interact with individuals who are independent contractors of the company, and they will receive the information you share with them.
Digital Marketing and Business Vendors. We share information, including your Device and Usage Information, with certain vendors for purposes of providing analytics and better engaging with your preferences.
Deidentified or Aggregated Data. We may share aggregated information and information that does not identify any specific individual, such as groupings of demographic data and preferences. By way of example, this information is shared for research, education, and marketing purposes.

Additional HR Processing Activities. In addition to the specific processing activities described above, we also process personal information for the following purposes:

Personnel and Human Resources Management. This includes, for example, ordinary business practices related to the establishment, maintenance, and termination of relationships; personnel management and administration (including before, during, and after your relationship with us); business management and planning; administering benefits; conducting performance reviews and disciplinary proceedings; providing training; processing work-related claims (for example, insurance and worker’s compensation claims); and addressing labor relations issues.
Operations Management. This includes, for example, the establishment, performance, and management of our business activities (such as maintaining internal networks and IT systems); operation, evaluation, and improvement of our recruiting system; accounting and auditing; preventing fraud; obtaining or maintaining insurance coverage; managing risks; and obtaining professional advice.
Security Management. This includes, for example, ensuring the security of our premises and information held by us as well as the safety of our personnel; preventing fraud; and network and information security.
Legal and Regulatory Compliance. This includes, for example, obtaining and releasing personal information as required by law or court order; maintaining records that can include personal information, such as government identifiers, information relating to sickness, leave, and retirement; and establishing, exercising, or defending legal claims, whether in court, administrative, or other proceedings.
Anonymous Data. Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you. We will process such data only in a de-identified fashion and will not attempt to re-identify such data.
Consistent Purposes. We may also process the information described above for purposes that are consistent with, related to, and/or ancillary to the purposes and uses described in this Notice for which your personal information was provided to us.

YOUR RIGHTS AND CHOICES

Depending on where you reside, you may have certain rights regarding your personal information. Please contact Human Resources if you wish to exercise or learn more about your rights under applicable law.

California

California residents can learn more about your rights under the CCPA below. All terms used in this section shall have the meanings given in the CCPA, when applicable.

CCPA Notice at Collection. We collect and process personal information as described in the “How We Process Personal Information” section of this Notice. The relevant CCPA categories for this information are indicated above. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes. This Notice relates to personal information we may collect and process in the course of your application for employment with us. For information about how we process personal information outside of this context, please see our Privacy Policy.

Data Practices During the Last 12 Months. For information about our data practices during the last 12 months, please see our Privacy Policy.

No Financial Incentives. We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your personal information.

CCPA Individual Rights. California residents have the rights described below. However, these rights do not apply in all instances and are subject to certain exceptions as a matter of law.

Right to Know. You have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold or shared and the categories of third parties to whom the personal information was sold or shared; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, selling, or sharing personal information; and (7) the categories of third parties to whom we disclose personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request unless a longer period is requested by you.

Right to Delete. You have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described herein, we will delete your personal information from our records and, as applicable, notify any service providers and contractors (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.
Right to Correct. You have a right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process the personal information. We will use commercially reasonable efforts to correct the inaccurate personal information as directed by you.
Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to limit our use and disclosure of your sensitive personal information to that use which is necessary to perform our services and provide our goods as requested by you, or as otherwise permitted by law. We only use or disclose sensitive personal information for purposes permitted by the CCPA and to which the right to limit does not apply.
Right to Opt-Out. You have the right to direct us to stop selling or sharing your personal information to third parties and to refrain from doing so in the future. For purposes of the CCPA in the context of our employment or contractual relationship with you, we do not sell or share personal information as defined under applicable law.

Submission Process. You may submit a request to exercise one of the above rights via a toll-free telephone call to 800.967.2289, or by email to legal@obhg.com. If a request is submitted in an incorrect manner or if it is deficient, we will either (1) treat the request as if it had been submitted via the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies, as applicable.

Verification Process. We are required to verify the identities of those who submit requests to exercise certain of the above rights. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, email address, mailing address, and/or telephone number. We will inform you if we cannot verify your identity.

If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our Privacy Policy.
If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.
If we cannot verify the identity of the person making a request to delete, we may deny the request.
If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor. In such cases we may not be required to comply with the request or may request additional information reasonably necessary to verify the request.

Authorized Agents. Authorized agents may submit requests via the methods identified in this Notice. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we may not require these actions with respect to confirmed guardianship, conservatorship, power of attorney, or other protective arrangement in accordance with applicable law.

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the above rights. We do not discriminate against individuals for exercising their rights under applicable law.

Appeals Process. Residents of certain states have the right to appeal a refusal to take action on a request within a reasonable time after your receipt of the decision. You may submit an appeal to a decision on your request via a toll-free telephone call to 800.967.2289 or by email to legal@obhg.com. We will inform you of any action taken or not taken in response to the appeal, along with a written explanation of the reasons in support of the response.

OTHER IMPORTANT INFORMATION

How long do we store and use your information? We will keep your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to operate our business, and to enforce our agreements. We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it. We may retain and use anonymous, de-identified, or aggregated information for as long as is permitted under applicable law. We are required by law to maintain records of certain requests submitted under applicable privacy laws (for example, the CCPA) and how we responded to such requests for at least 24 months. We only use this information for recordkeeping purposes. For more information, please contact us via the “Contact Us” details at the end of this Notice.

How do we protect your information? We have adopted security measures designed to protect the personal information under our control. From time to time, we review our security procedures to consider appropriate new technologies and methods. But no security system is perfect, and no data transmission is 100% secure. Although we strive to protect personal information, we cannot guarantee or warrant the security of any information transmitted to or from us. We cannot guarantee that your data will remain secure in all circumstances. If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

Updates and Changes. We may add to, change, update, or modify this Notice to reflect any changes to how we treat your information or in response to changes in law. If we update this Notice, we will make an updated copy of it available on our website.

CONTACT US

If you have any questions or concerns, wish to exercise your rights, or want to submit a complaint, please contact us using the information below, and we will do our best to assist you.

In Writing: Obtelecare

777 Lowndes Hill Road, Building 1

Greenville, South Carolina 29607

Attn: General Counsel

By Email: legal@obhg.com

Telephone: 800.967.2289