Privacy Notice to Employees, Job Applicants and Contractors
California Consumer Privacy Act (CCPA)

 

I. Scope and Overview

Open Healthcare US and/or any affiliated entities (collectively, “OHUS”) hereby adopt this California Employee Privacy Notice (this “Notice”) pursuant to the California Consumer Privacy Act (“CCPA”), as amended, and any terms defined in the CCPA shall have the same meaning when used in this Notice. This Notice applies to all employees, job applicants and independent contractors and outsourced staff, both current and former, who are residents of the State of California (“You” or “Consumer”).

OHUS is committed to protecting the privacy and security of Your personal information as defined in the CCPA (“Personal Information”). This Notice describes how OHUS and its subsidiaries, affiliates, and other related entities (collectively, “OHUS”, “We” or “Us”) collect and process Your Personal Information during Your employment or contractual relationship with Us.

OHUS will only process Your Personal Information in accordance with this Notice unless otherwise required by applicable law. OHUS will take necessary steps to ensure that Personal Information collected is adequate, relevant, not excessive, and processed for limited purposes.

 

II. Collection of Personal Information

OHUS may collect, store, and process Personal Information self-disclosed by You, such as on job applications, publicly available professional social media platforms, employee onboarding documentation, employee timekeeping and payroll documentation, employee benefits documentation, employee requests for leaves of absence, employee requests for use of paid sick leave or other paid time off, employee requests for accommodation, employee performance reviews and self-assessments, employee requests, such as for reimbursements or from services we provide to You such as health and welfare benefits, and information provided during communications between You and OHUS.

Personal Information may also be collected indirectly from You, such as monitoring information that Your work computer or mobile device/application transmits.

Examples of Personal Information collected for the purpose of administering the job application, employment or contractual relationship with You and to the extent permitted under applicable law include, but not limited to:

· Name and contact data. Your name, employee identification number, email address, mailing address, phone number, photo, beneficiary and emergency contact details, and other similar contact data.

· Demographic data. Your date of birth and gender as well as more sensitive personal data (also known as special category data) including information relating to racial and ethnic origin, religious, political or philosophical beliefs, trade union membership or information about Your health, disabilities, sexual orientation, gender identity, and transgender status. OHUS may also ask about Your parental status and military status.

· National identifiers. Your national ID/passport, citizenship status, residency and work permit status, social security number, or other taxpayer/government identification number.

· Employment details. Your job title/position, account credentials, office location and/or remote working location, employment contract, offer letter, hire date, termination date, performance history and disciplinary records, hours worked, badge activity information, training records, leave of absence, sick time, and vacation/holiday records.

· Spouse’s/partner’s and dependents’ information. Your spouse and dependents’ first and last names, dates of birth, and contact details.

· Background information. Your academic and professional qualifications, education, CV/Resume, credit history and criminal records data.

· Video, voice and image. We may collect and use Your video, voice and image data, subject to the requirements of local law, internal policy, and any consultation requirements with worker representatives (where appropriate).

· Financial information. Your bank account details, tax information, salary, retirement account information, company allowances and other information necessary to administer payroll, taxes, benefits, and equity and incentive compensation.

· Learning and Skills Data. Your educational background, licenses, certifications, completed trainings.

· Travel information, such as, loyalty programs numbers; dates; hotel names and locations; and travel routes and departures, stops, and destination points.

· Personal vehicle information, such as license plate number, color, year, make, and model.

· Workplace, Device, Usage, and Content data. Application and communication data (such as data from company devices, software and mobile applications used for business purposes) including emails sent and received, calendar entries, to-do items, instant messages, technical data and information (containing only limited identifiers, if any personal data at all).

· Inferences. Inferences to create a profile reflecting Your personal characteristics (such as work history and experience), abilities, and aptitudes.

· Sensitive Personal Information. OHUS may collect certain “sensitive” or “special categories” of Personal Information (“Sensitive Personal Information”). To support legal and business activities, and as permitted by law, OHUS may collect Sensitive Personal Information as part of our employment relationship with You. Additional examples of Sensitive Personal Data that we may collect include:

    ○ government issued identifiers, such as social security information, driver’s license, state identification card, or passport number;
    ○ account log-in in combination with a security or access code, password, or credentials that allow access to an account;
    ○ precise geolocation;
    ○ sensitive demographic information such as racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership;
    ○ biometric information (where used for the purpose of uniquely identifying You);
    ○ medical or health information (such as information necessary to provide an accommodation related to Your health and insurance enrollment information);
    ○ information relating to sex life (such as reproductive health and maternal care to provide applicable benefits) or sexual orientation (to comply with our legal obligations related to anti-discrimination requirements);
    ○ in certain locations, such as California, the content of Your communications where OHUS is not the intended recipient.

Personal Information does not include: (i) publicly available information from government records, (ii) information that a business has a reasonable basis to believe is lawfully made available to the general public by the employee or from widely distributed media, (iii) information made available by a person to whom the employee has disclosed the information if the employee has not restricted the information to a specific audience, and (iv) de-identified or aggregated information.

In addition to collecting Personal Information from You (directly or indirectly), we obtain Personal Information about You from sources other than You, including:

· Inference data that we generate or derive about You from personal data we process about You.
· References provided by or about you, including from former and current employers.
· Third parties or public sources (e.g. information from public professional networking sources, such as Your LinkedIn profile, for recruitment purposes).
· Our vendors and other providers, such as when we conduct lawful background screenings, to the extent permitted by law, through a third-party vendor who provides us information about Your past education, employment, credit and/or criminal history.
· Insurance and benefit providers
· Travel partners (e.g., travel agents and portals, car-hire service, and ride share companies)
· Corporate transactions (e.g. as part of an acquisition, merger, divestment, etc.)

Additionally, if there is an investigation of an incident involving employees, we may obtain information relevant to the incident from external sources including private parties, law enforcement or news sources and public social media posts.

 

III. Use of Personal Data

OHUS will only process Your Personal Information where applicable law permits or requires it, including where the processing is necessary for the performance of OHUS’ employment contract with You, where the processing is necessary to comply with applicable legal obligations that applies to OHUS as Your employer, or to protect legitimate business interest of OHUS pertaining to Your employment thereof, or with Your consent where applicable law requires such consent. OHUS may use Your Personal Information for the following legitimate business purposes and for any other purposes of carrying on the employment/contractual relationship with You:

· Conducting interviews and communicate with You regarding your candidacy for Your employment or independent contract relationship with OHUS;
· Conducting pre-employment screening and background checks;
· Administration (including payroll and benefits administration) and management of employment or working relationship;
· Business management, operations and planning;
· Processing work-related claims (ex. insurance claims, mileage and expenses reimbursement claims);
· Accounting and auditing, including examination by third party auditors;
· Conducting performance reviews;
· Assessing qualification for position, job or task;
· Gathering evidence for disciplinary action or termination;
· Creating and submitting reports as required by applicable laws or regulations;
· Education, training, and development requirements;
· Health and benefits administration services;
· Managing, monitoring, protecting, and improving OHUS facilities, including, company buildings, parking, rooms, other physical spaces (including measures for health and safety of persons using OHUS facilities, operating security systems such as CCTV);
· Managing, monitoring, protecting, and improving OHUS systems (e.g. activities related to managing, monitoring, protecting, and improving our information systems, services, networks, applications, devices and other assets, infrastructure, technology, and resources (“Systems”), including managing, measuring, assessing, and protecting unauthorized access and use of confidential data or Systems; human and machine review of data to train AI models; and other activities to improve business operations, security, manager capability, and the employee/contractor/job applicant experience)
· Complying with workplace health and safety regulations;
· Complying with company policies and all applicable local, state, and federal law, regulations, ordinances, guidelines, and orders;
· Equal opportunity assessment and accommodations;
· Corporate transactions, including sale, acquisition, merger of OHUS

If OHUS needs to process Your Personal Information for other purposes, OHUS will notify You and, if required by applicable law, seek Your consent.

 

IV. Data Sharing

OHUS will only disclose Your Personal Information to third parties where required by applicable law or to our employees, contractors, designated agents, or third party service providers who require such information to assist OHUS with its legitimate business need, including third party service providers who provide services to OHUS or on OHUS’ behalf. These third party service providers may be located outside of the State of California.

OHUS require all its third party service providers, by written contract, to implement appropriate measures to protect Your Personal Information consistent with OHUS’ policies. OHUS do not permit its third party service providers to process Your Personal Information for their own purposes, and the permission is limited to the extent required to provide their services to OHUS, and only to carry out the purpose for which OHUS’ disclosed Your Personal Information to them. Third party service providers are not permitted to use Your Personal Information for any other purpose and in any manner that would constitute a violation of any federal, state or local regulations.

OHUS may also disclose Your Personal Information for the following additional purposes where permitted or required by applicable law:

· To OHUS’ affiliates, for the purposes set out in this Notice and as necessary to perform OHUS’ employment contract with You;
· To carry out the purposes of our Personal Information processing as described above;
· To enable third parties to provide services on behalf of OHUS;
· To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or other court orders. When such disclosure is required, OHUS will take reasonable steps to ensure that OHUS will disclose only minimum Personal Information necessary for the specific purpose and circumstances;
· To seek legal advice from external lawyers and advice from other external professionals such as accountants, management consultants, etc.;
· During emergency situations or where necessary to protect the safety of persons;
· In connection with a corporate transaction or proceeding, including the sale, assignment or other transfer of all or part of our business (such as a potential or actual purchaser and its legal/professional advisers) and integration activities related to a corporate transaction, including where we are the purchaser; or
· Otherwise in accordance with Your consent.

We do not sell Your Personal Information, and we do not share Your Personal Information for purposes of cross context behavioral advertising. We do not sell or share for cross-context behavioral advertising information about individuals we know are under age 16.

 

V. Data Retention

Except as otherwise permitted or required by applicable law or regulation, OHUS will only retain Your Personal Information for as long as necessary to fulfill the purposes OHUS collected it for, as required to satisfy any laws or regulations governed by various regulatory bodies, legal, accounting, or other reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, OHUS will consider its statutory obligations, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, and whether OHUS can achieve such purposes through other means.

At the end of the retention period, OHUS will delete or anonymize Your Personal Information so that it can no longer be associated with You. OHUS may continue to use anonymous and de-identified data for any legitimate business purposes without further notice to You or Your consent.

Once You are no longer in employment or contractual relationship with OHUS, OHUS will retain and securely destroy Your Personal Information in accordance with OHUS’ document retention policy and applicable laws and regulations.

 

VI. Rights to Know, Right to Delete and Right to Correct

It is important that Your Personal Information is accurate and current. Please keep Your Personal Information updated if Your Personal Information changes during Your employment or contractual relationship with OHUS.

You may have the right to know and request that we disclose the following information:

· The categories of Personal Information we collected about them and the categories of sources from which we collected such Personal Information;
· The specific pieces of Personal Information we collected about them for the applicable time period;
· The business or commercial purpose for collecting, disclosing, or selling or sharing Personal Information about them;
· The categories of Personal Information about them that we sold or shared and the categories of third parties to whom we sold or shared that Personal Information; and
· The categories of Personal Information about them that we otherwise disclosed and the categories of external parties with whom we disclosed that Personal Information.

You have the right to request access to, correct, and delete the Personal Information that OHUS holds about You, subject to all applicable laws. You have the right to be free from unlawful discrimination for exercising Your rights under the CCPA.

To make a request for the disclosures described above, or the deletion or correction of your Personal Information described above, please contact us as provided in Section IX below. Upon request, OHUS will take commercially reasonable efforts to correct Your Personal Information.

OHUS may request specific information from You to confirm and verify Your identity in order to process Your right to access, correct and delete Your Personal Information request. Applicable law may allow or require OHUS to refuse to provide You with access to some or all of the Personal Information that OHUS holds about You, or OHUS may have destroyed, deleted, or made Your Personal Information anonymous accordance with OHUS’ record retention obligations and practices. If OHUS cannot comply with Your request, OHUS will inform You the reasons why, subject to any legal or regulatory restrictions.

If OHUS denies Your request to correct Personal Information collected concerning Your health, You may provide a written statement, limited to 250 words per alleged inaccurate piece of Personal Information, and request that the statement be made part of Your record. Upon receipt of such a statement from You, OHUS will include it with Your record.

If You would like, You may designate an authorized individual or agent to make a request on Your behalf. OHUS will deny requests that do not evidence sufficient proof of authorization from You. To verify that an authorized individual or agent has authority to act for You, OHUS may require a copy of a power of attorney or require that You provide the authorized agent with written permission and verify Your own identity with OHUS.

 

VII. Right to Limit Use and Disclosure of Sensitive Personal Information

As used herein, the “Sensitive Personal Information” has the same meaning as set forth in the CPRA Section 1798.140(ae), as amended. See Section II above for more details on Sensitive Personal Information. Sensitive Personal Information does not include information that is publicly available. You have the right to request that OHUS limit the use of Your sensitive personal information for specific purposes by contacting OHUS in writing as specified below in Section IX.

 

VIII. Right to Opt Out

OHUS does not sell Personal Information to any third party for monetary consideration. However, sharing Personal Information with third party for purposes stated in this Notice may be considered “selling” under applicable laws. Therefore, You may opt out from sharing Personal Information by contacting OHUS in writing.

 

IX. Contact Us

To exercise any foregoing rights or for any questions about OHUS’ processing of Your Personal Information, please contact OHUS by:

a) Calling HR Office at (562) 945-1220
b) Submitting Your questions online using the OHUS Privacy Rights Exercise Portal at https://hq.ohc.global/en/privacy
c) Submitting Your questions and request to the HR Office email at privacy@ohcus.com
d) Write us at:
[Privacy Rights Request]
OHUS Human Resources Office
Attn: HR
1487 W. 178th St.,
Gardena, CA 90248

Please note, only You or someone legally authorized to act on Your behalf may make a verifiable request related to Your Personal Information. To designate an authorized agent, please submit appropriate designation letter with Your identifiable personal information and signature to OHUS. Please note, OHUS cannot respond to Your request if OHUS cannot verify Your identity or if OHUS does not receive proper documentation supporting / evidencing authorization to make request on Your behalf. OHUS will only use Your identifiable personal information to verify the requestor’s identity or the requestor’s authority to make the request.

Please allow 45 days to respond Your request. If more time is needed, You will be notified in writing.

 

X. Future Updates

OHUS urges You to check the terms of this Notice for periodic updates. OHUS reserves the right to amend this Notice in order to reflect its legal and business obligations. In the event that any material or substantive changes are necessary, You will be notified by posting the updated Privacy Policy on OHUS’ website.

Adopted
Revised February 10, 2026