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LEGAL

Notice at Collection for California Employees and Applicants

Effective: September 1, 2026

SkillStorm Commercial Services, LLC

SkillStorm Commercial Services, LLC ("SkillStorm," "Company," "we," or "us") collects and uses your personal information, including sensitive personal information, for recruiting, human resources, employment, training-program administration, client-engagement staffing, benefits administration, health and safety, security-clearance processing, and business-related purposes, and to comply with the law. This notice describes the categories of personal information we collect from and about California residents who apply for or express interest in employment or a training program with SkillStorm, and who become our employees, consultants, or contractors, together with the purposes for which we use it, how long we keep it, and whether we sell or share it. We are committed to properly handling the personal information collected or processed in connection with your application and employment relationship with us.

To view our full Privacy Notice for California Residents, visit www.skillstorm.com/privacy-policy/california. Our general Privacy Policy is available at www.skillstorm.com/privacy-policy.

We will not sell the personal information, including any sensitive personal information, we collect about our employees, applicants, or program candidates, or share it with third parties for cross-context behavioral advertising.

We may collect the personal information and sensitive personal information categories listed in the tables below, retain them for the indicated period, and use them for the stated business purposes. We disclose personal information to service providers (such as our applicant tracking, human resources information, payroll, benefits, and background-screening providers) under contracts that restrict their use of it, and, where you are being considered for or placed on a client engagement, to that client to the extent necessary to evaluate and support the placement, including client-required security and clearance processing.

Personal Information Categories

Personal Information CategoryRetention PeriodBusiness PurposeSold or Shared

Identifiers, such as your full name, alias, postal address, email address, telephone number, date of birth, signature, Social Security number, driver's license or state identification number, passport number, and similar information for your dependents, beneficiaries, and emergency contacts.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Recruit and process applications, including verifying identity and eligibility for employment and conducting background, drug-screening, and related checks

Evaluate and place you on client engagements, including client-required onboarding and security processing

Conduct onboarding; maintain and administer payroll and employee benefit plans, including enrollment and claims handling

Maintain personnel records and comply with record retention requirements

Provide human resources management, data maintenance, and support services; communicate with you and your emergency contacts and plan beneficiaries

Comply with applicable state and federal labor, employment, tax, benefits, workers' compensation, disability, equal employment opportunity, workplace safety, immigration, government-contracting, and related laws

Prevent unauthorized access to or use of Company and client property, including information systems, devices, networks, and data

Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy

Exercise or defend the legal rights of the Company and its employees, affiliates, clients, contractors, and agents; respond to law enforcement requests and as required by applicable law or court order

No

California Customer Records employment and personal information, such as your name, signature, Social Security number, physical description, photograph, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certifications, bank account number (for payroll direct deposit), and medical or health insurance information.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Same purposes as for the Identifiers category

No

Protected classification characteristics under California or federal law, such as age (40 or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy, and related conditions), sexual orientation, military and veteran status, or genetic information. Race, ethnicity, gender, disability, and veteran status are collected through voluntary self-identification only.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Comply with federal and state equal employment opportunity laws and, as a federal contractor, affirmative-action and reporting obligations (including EEO-1 and VETS-4212)

Verify eligibility for employment and for positions or engagements with citizenship, work-authorization, or security-clearance requirements

Review and process reasonable accommodation and leave requests

Perform workforce analytics, data analytics, and benchmarking in aggregated form

Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy

Exercise or defend the legal rights of the Company and its employees, affiliates, clients, contractors, and agents; respond to law enforcement requests and as required by applicable law or court order

No

Commercial information, such as transaction information, purchase history, and financial details.

N/A

Not collected

No

Biometric information, such as fingerprints or other physical patterns used to identify an individual.

N/A

Not collected. Any fingerprinting required for a client or government security clearance or background investigation is collected by the sponsoring agency or its vendor, not by SkillStorm.

No

Internet or other similar network activity information, including activity on Company information systems (such as internet browsing history, search history, intranet activity, email communications, stored documents, usernames, and passwords) and on communications systems (such as phone calls, call logs, voicemails, text messages, chat logs, and application use on Company-issued devices), and your interactions with our careers website, applicant tracking system, and learning platforms.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Facilitate the efficient and secure use of Company information systems and deliver training-program content and assessments

Ensure compliance with Company and client information systems policies and procedures

Comply with applicable state and federal laws and client security requirements

Prevent unauthorized access to, use, disclosure, or removal of Company and client property, records, data, and information

Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy

Exercise or defend the legal rights of the Company and its employees, affiliates, clients, contractors, and agents; respond to law enforcement requests and as required by applicable law or court order

No

Geolocation data, such as general location derived from IP address when you use Company systems. We do not collect precise geolocation.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Facilitate the secure use of Company information systems and detect unauthorized access

Comply with applicable tax and employment laws that depend on work location

No

Sensory data, such as audio, electronic, or visual information, including recorded telephone calls with our recruiters or automated calling system (where you have been notified of recording), recorded video interviews, recorded training sessions, and your photograph for identification badges.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Recruit and evaluate applicants; deliver and record training-program sessions for participant review and quality purposes; issue identification credentials

Comply with applicable state and federal laws, including workplace health and safety

Exercise or defend the legal rights of the Company and its employees, affiliates, clients, contractors, and agents; respond to law enforcement requests and as required by applicable law or court order

No

Professional or employment-related information, such as application information (the position applied for, your responses to our application questions, work history, academic and professional qualifications, certifications, references, interview notes, and any résumé you later provide), technical assessment and training-program results, background check and drug-testing results, work authorization, security clearance status and eligibility, performance and disciplinary records, salary, bonus, and other compensation data, benefit plan enrollment and claims information, leave of absence information including religious, military, and family obligations, and client-engagement assignment and evaluation records.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Recruit and process applications, including verifying eligibility for employment, background checks, and onboarding

Evaluate applicants and participants for, and place them on, training programs and client engagements; report participant progress and engagement performance to the sponsoring client as required by the engagement

Design and administer compensation, benefit plans, and programs, including leaves of absence

Maintain personnel records and comply with record retention requirements

Comply with applicable state and federal labor, employment, tax, benefits, workers' compensation, disability, equal employment opportunity, workplace safety, and government-contracting laws

Evaluate and provide feedback about job performance, facilitate working relationships, and support professional development

Prevent unauthorized access to or use of Company and client property; conduct internal audits and investigate complaints, grievances, and suspected policy violations

Exercise or defend the legal rights of the Company and its employees, affiliates, clients, contractors, and agents; respond to law enforcement requests and as required by applicable law or court order

No

Non-public education information (FERPA), such as transcripts, degrees, and vocational certifications you provide to us.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Evaluate your qualifications for hire, program admission, promotion, or transfer; verify credentials required by a client engagement

No

Inferences drawn from other personal information to create a profile or summary, such as a person's abilities, aptitudes, and characteristics.

N/A

Not collected. SkillStorm does not create profiles or inferences about applicants or employees; all hiring, admission, assignment, and compensation decisions are made by SkillStorm personnel.

No

As a general rule we retain personal information for 12 months from the last activity on your record. We keep it longer where the law requires, including the retention periods that apply to federal contractors for applicant and personnel records, to payroll and tax records, to Form I-9, to benefit-plan records, and to workplace safety and workers' compensation records, and we may keep it for a shorter period where the law so requires. At the end of the applicable period, personal information is deleted, destroyed, or deidentified.

Sensitive Personal Information Categories

While we collect information that falls within the sensitive personal information categories listed in the table below, the CCPA does not treat this information as sensitive because we do not collect or use it to infer characteristics about a person. We use it only for the purposes stated below.

Sensitive Personal Information CategoryRetention PeriodBusiness PurposeSold or Shared

Government identifiers, such as your Social Security number, driver's license, state identification card, passport and visa information, or immigration status and documentation.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Recruit and process applications, including verifying identity and eligibility for employment and conducting background and related checks

Support client- or government-required security clearance and background investigations you have authorized

Process and administer payroll, tax reporting, and employee benefit plans

Maintain personnel records and comply with record retention requirements

Comply with applicable state and federal labor, employment, tax, immigration, and government-contracting laws

Exercise or defend the legal rights of the Company and its employees, affiliates, clients, contractors, and agents; respond to law enforcement requests and as required by applicable law or court order

No

Complete account access credentials, such as usernames and passwords for Company or client systems.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Provide and secure access to Company and client information systems, devices, networks, and data

Prevent unauthorized access to or use of Company and client systems

No

Precise geolocation.

N/A

Not collected

No

Racial or ethnic origin (voluntary self-identification only).

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Comply with federal and state equal employment opportunity laws and federal-contractor affirmative-action and reporting obligations

Perform workforce analytics and benchmarking in aggregated form

Conduct internal audits and investigate complaints of discrimination

No

Citizenship or immigration information, including work authorization status.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Verify employment eligibility (Form I-9 and E-Verify where required)

Determine eligibility for positions and client engagements with citizenship, work-authorization, or security-clearance requirements

Comply with federal and state equal employment opportunity, immigration, and government-contracting laws

No

Religious or philosophical beliefs.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Review and process religious accommodation requests

Exercise or defend the legal rights of the Company and its employees, affiliates, clients, contractors, and agents; respond to law enforcement requests and as required by applicable law or court order

No

Union membership.

N/A

Not collected

No

Mail, email, or text message contents not directed to the Company, where present on Company systems.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Conduct internal audits and investigate complaints, grievances, and suspected violations of Company policy

Exercise or defend the legal rights of the Company and its employees, affiliates, clients, contractors, and agents; respond to law enforcement requests and as required by applicable law or court order

No

Genetic data.

N/A

Not collected

No

Neural data.

N/A

Not collected

No

Uniquely identifying biometric information.

N/A

Not collected

No

Health information, including job restrictions, accommodation requests, leave-related medical documentation, drug-screening results, and workplace illness and injury information.

12 months from the last activity on your record, or the longer period required by law for employment, payroll, tax, immigration, benefits, safety, or government-contracting records

Review and process disability accommodation and leave requests

Investigate and process workers' compensation claims

Administer drug-screening required for the position or client engagement

Comply with workplace health and safety laws

No

Sex life or sexual orientation information.

N/A

Not collected. (Benefit-plan claims are processed by our carriers and administrators, not by SkillStorm.)

No

SkillStorm does not use automated decision-making technology to make significant decisions about applicants or employees. Automated tools may assist with scheduling and communication, but a SkillStorm employee reviews the relevant information and makes every final decision about hiring, program admission, assignment, and compensation.

If you have any questions about this notice or need to access it in an alternative format due to a disability, please contact privacy@skillstorm.com or 904-438-3440.

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