California Consumer Privacy Act Employment and Independent Contractor Disclosure

This California Employment and Independent Contractor Privacy Notice applies to California residents and tells you how Franklin Sports, Inc. (“Franklin Sports,” “we” or “us”) uses, shares, discloses, and retains (collectively “processes”) your personal information. We are committed to processing your personal information responsibly and in accordance with applicable laws and internal policies. For the purpose of this California specific Privacy Notice, residents include individuals who: 1) have applied or may apply for a position at Franklin Sports; 2) are current or former Franklin Sports employees; 3) are beneficiaries or emergency contacts of a current or former employee; 4) receive insurance or other benefits through a Franklin Sports employee; or 5) are independent contractors performing services for Franklin Sports (collectively, “HR Covered Individuals”). If you provide personal information of another person (e.g., beneficiary or emergency contact), then you are responsible for providing this Privacy Notice to that individual.

Certain terms used in this Notice have the meanings given to them in the California Consumer Privacy Act.Categories of Personal Information Collected

We may collect the following categories of personal information about HR Covered Individuals:

	Categories of Personal Information Collected
Category A	Identifiers, such as name, contact information, online identifiers and Social Security numbers and other government-issued ID numbers
Category B	Personal information, as defined in the California consumer records law, such as name, contact information, insurance policy number, education, employment, employment history financial information, medical information and health information¹
Category C	Characteristics of protected classifications under California or federal law,² such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and martial status
Category D.	Commercial information, such as transaction information, purchase history and financial details
Category E.³	Biometric information, such as facial recognition and fingerprints
Category F.^3,4	Internet or network activity information, such as browsing history and interactions with our website, applications or systems
Category G.^3,4	Geolocation data, such as device location
Category H.⁴	Audio, electronic, visual, and similar information, such as images and audio, video or call recordings created in connection with our business activities;
Category I.	Professional or employment-related information, such as work history and prior employer, human resources data and data necessary for benefits and related administrative services
Category J.⁴	Education information subject to the federal Family Educational Rights and Privacy Act, such as student records
Category K.	Inferences drawn from any of the Personal Information listed above to create a profile or summary above, for example, an individual’s preferences, abilities, aptitudes and characteristics

¹ This includes name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
² This include sex (including pregnancy, childbirth, breastfeeding, and related medical conditions), age (40 and over), race, color, religion or creed, ancestry, national origin, disability, medical conditions, genetic information AIDS/HIV status, martial status, sexual orientation, gender identity and expression, citizenship, primary language, immigration status, military/veteran status, political affiliation/activities, domestic violence victim status, and request for leave.
³ Only applicable where employer has selected to receive time keeping services from ADP.

Purposes for Collecting Personal Information:

Franklin Sports may use personal information of HR Covered Individuals for the following purposes:

To comply with state and federal law and regulations;
To process payroll;
To track time and attendance;
To manage workers’ compensation claims;
To administer and maintain benefits, including group health insurance;
To administer and maintain retirement service;
To manage employee performance of their job duties, including promotions, discipline, and/or termination, and to ensure compliance with Franklin Sports’ requirements, policies or procedures;
To conduct workplace investigations;
To evaluate job applicants and candidates for employment;
To obtain and verify background checks;
To grant and monitor employees’ access to secure company facilities;
To make the necessary applications to obtain visas or other permits for work-related travel
To establish a point of contact in the event of emergency;
To compile directories and telephone lists;
Assist law enforcement or respond to legal/regulatory inquiries;
Fulfill and manage orders and purchases;
Enable volunteer activities and civic engagement;
Conduct research and analysis, including focus groups and surveys;
Support diversity and inclusion initiatives;
To implement, monitor, and manage electronic security measures on devices that are used to access networks and systems (e.g., incident management);
To engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company;
To maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance;
To anonymize and/or aggregate data to perform workforce analytics, data analytics, and benchmarking;
To perform call monitoring and surveillance (e.g., CCTV);
To provide, validate, or communicate services offered by ADP directly to individuals; and
Fulfill such other business purposes as reasonably determined by Franklin Sports.

⁴ Only applicable where employer has selected to receive screening and selection services from ADP.

Retention of Personal Information

We will retain your personal information for the time period required or permitted by law or for the time reasonably necessary to achieve the purposes described in this Privacy Notice or any other notice provided at the time of collection. Retention is based on several factors, including legal requirements, statutes of limitation, and business needs.

Sources of Personal Information

Franklin Sports may obtain personal information about HR Covered Individuals from the following categories of sources:

Directly from you
Your device(s)
Other individuals, for example, in connection with hiring referrals, provision of benefits, feedback from guests or business partners
Our affiliates and subsidiaries
Service providers, contractors and other vendors who provide services on our behalf;
Internet service providers
Operating systems and platforms
Government entities
Social networks (e.g., LinkedIn, Indeed)
Data brokers (e.g., background check services)

Disclosure of Personal Information

Franklin Sports may disclose the following categories of personal information about HR Covered Individuals to the following categories of third parties. Disclosure is for business purposes related to establishing or maintaining the employment relationship.

Categories of Personal Information	Categories of Third Parties
Identifiers Personal Information Characteristics of protected classifications Commercial information Internet or other electronic network activity Geolocation data Audio, electronic, or visual information Professional or employment-related information Education information Inferences drawn from information above	Provider of software or services used to manage hiring, payroll, benefits, performance reviews and other human resources functions (e.g., ADP) Business partners, such as benefit administrators and training providers Government entities, such as regulators or courts Professional services organizations, such as auditors and law firms
Biometric information	Government entities, such as regulators or courts

We may also share the information we collect with our service providers and within Franklin Sports, which includes all our subsidiaries and affiliates.

In addition to the categories of third parties identified above, we may disclose personal information about HR Covered Individuals to third parties in connection with corporate transactions.

Franklin Sports does not share for cross-context behavioral advertising purposes or sell personal information about HR Covered Individuals, except to the extent that they have visited the franklinsports.com web site.

California Privacy Rights

If you are an HR Covered Individual, you have the following rights:

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information or categories of personal information we have collected, used, disclosed, and sold or shared about you.
- Note: If you are an applicant or current employee, certain personal information can be found in your ADP account (e.g., contact information, pay data, vacation balances, career information, learning history, etc.).
Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
- Note: If you are an applicant or current employee, you can correct certain personal information in your ADP account (e.g., address, phone, email) or through your HR representative.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
- Note: Certain personal information may not be deleted if subject to legal exceptions (e.g., legal compliance, ongoing employment)

How to Submit a Request: To submit an access, correction, or deletion request, email us at [email protected] or call us at 1-877-377-6787.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. Based on the type of HR Covered Individual request, you will be required to submit specific pieces of information. We will use this information to search our systems and determine if we have information about you. If we can locate information about you, we will fulfill your request as required by law.
If you are an authorized agent, you will be required to submit your information as well as specific pieces of information about the individual for whom you are making a request. You will also be asked to fill out a certification form confirming your information and certifying you have the right to make this request on behalf of the individual.

Non-Discrimination: Franklin Sports will not discriminate against you because you exercise your rights. For example, we will not deny you employment if you make an access request.

How To Contact Us

If you have any questions about this Privacy Notice or our privacy practices, please contact [email protected].

Last Update: June 6, 2023