EmpireWorks - The Nation's Largest Reconstruction Company

privacy

CALIFORNIA CONSUMER PRIVACY NOTICE

FOR CALIFORNIA CONSUMERS, EMPLOYEES AND JOB APPLICANTS (CPRA)

NOTICE STATEMENT

This Privacy Notice provides you with necessary information about the personal information we collect, how this information may be used by EmpireWorks Reconstruction (the "Company"), your privacy rights and The Company’s obligations in accordance with the California Consumer Privacy Act of 2018 ("CCPA") and the California Privacy Rights Act of 2020 ("CPRA").

Scope

This Privacy Notice applies solely to natural persons residing in California ("Consumers"), and does not apply to individuals living elsewhere, businesses or other corporate entities.

Responsibilities

The Company’s General Counsel is responsible for maintaining, reviewing and updating this Privacy Notice.

Definitions

Consumer: As defined by the CCPA and CPRA, a consumer is a natural person who is a California resident, living in California for other than a temporary or transitory purpose, or individual domiciled in California.

Personal Information: Commonly referred to as Personally Identifiable Information (“PII”),

Personal Information (“PI”) may be defined under various privacy laws, but, generally, is a fact about an individual which, if combined with one or more other facts about that individual, would enable others to determine the specific person to whom the facts apply.

Sensitive Personal Information: Sensitive Personal Information (“SPI”) is a subset of PI that requires greater security protections and standards of care in handling. SPI, also known as "special categories of information", is defined as information that if lost, compromised, or disclosed could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual. Sensitive Personal Information used for direct purpose, and not for inferring characteristics of the individual, is treated as mere personal information for all CPRA purposes.

The Company: For the purposes of this Notice, we will refer to EmpireWorks Reconstruction and our associated affiliates as “the Company”, and collectively as “we”, “our”, or “us”.

1. CONSUMER RIGHTS

1.1. RIGHT TO ACCESS

You have the right to access PI which we may collect or retain about you. If requested, we shall provide you with a copy of your PI which we collect as permitted by the CCPA/CPRA. You also have the right to receive your PI in a structured and commonly used format so that it can be transferred to another entity (“data portability”).

1.2. RIGHT TO KNOW

You have the right to request that we disclose the following about your PI, as defined by the CCPA/CPRA:

• The specific PI we may collect;

• The categories of PI we may collect;

• The categories of sources from which we may collect your PI;

• The business purpose(s) for collecting or sharing your PI;

• The categories of PI we may disclose for business purposes; and

• The categories of third parties to whom we may share your PI.

1.3. RIGHT TO OPT-OUT / DO NOT SELL MY PERSONAL INFORMATION

The Company does not sell PI within the meaning of the CPRA.

1.4. RIGHT TO LIMIT USE AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

You have the right to limit how your SPI is disclosed or shared with third parties, as defined in the CPRA.

1.5. RIGHT TO DELETION

In certain circumstances, you have the right to request the erasure of your PI. Upon verifying the validity of a deletion request, we will delete your PI from our records, and instruct any service providers or third parties to delete your information, when applicable.

1.6. RIGHT TO CORRECT/RIGHT TO RECTIFICATION

In certain circumstances, you have the right to request correction of any inaccurate PI. Upon verifying the validity of a verifiable consumer correction request, we will use commercially reasonable efforts to correct your PI as directed, taking into account the nature of the PI and the purposes of maintaining your PI.

1.7. Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.

2. EXERCISING YOUR RIGHTS

If you are a California resident, you can exercise any of your rights as described in this Notice and under applicable privacy laws by using the contact information provided in this Notice. We will not discriminate against you for exercising such rights. Except as described in this Notice or provided for under applicable privacy laws, there is no charge to exercise of your legal rights.

However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may:

• Charge a reasonable fee taking in account the administrative costs of providing the

information or taking the action requested; or

• Refuse to act on the request and notify you of the reason for refusing the request.

3. VERIFYING REQUESTS

When you make a request to us, we will require your name, e-mail, phone number, and address. We will attempt to match our records based on that information.

Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm their identity.

4. PERSONAL INFORMATION (PI) WE COLLECT

We collect PI as necessary to enable us to carry out your instructions, to manage and operate our business, and to comply with our legal and regulatory obligations.

For consumers: The PI that we may collect from consumers in the course of your use of our website, may include, but is not limited to, the following:

• Your name;

• Your mailing address;

• Your contact details (such as telephone number, email address, emergency contact);

• Your online behavioral data (such as website browsing behavior, social media activity); and/or

• Your demographic information.

For employees and job applicants: The PI that we may collect in the course of your employment,

or as your potential employer, may include, but is not limited to, the following:

• Your name;

• Your mailing address;

• Your contact details (such as telephone number, email address, emergency contact);

• Your employment and educational background and other relevant applicant information; and/or

• Other PI contained in correspondence and documents which you may provide to us.

You confirm that you are authorized to provide us the PI which we shall collect on your behalf.

Where the PI relates to your family members, it is not reasonably practicable for us to provide to them the information set out in this Notice. Accordingly, where appropriate, you are responsible for providing this information to any such person.

5. SENSITIVE PERSONAL INFORMATION (SPI) WE COLLECT

We may also collect or process SPI from employees and/or job applicants as necessary to enable us to carry out your instructions, to manage and operate our business, and to comply with our legal and regulatory obligations. We do not collect or process SPI from website consumers.

For employees and job applicants, you may also supply us with, or we may receive, the following SPI:

• Financial, account or billing information, including tax identification number or social security number;

• Proof of identification, including driver's license number, or state/national governmentissued identification;

• Diversity or demographic information, including race or ethnicity, gender or gender identity, veteran or disability status;

• Information required to conduct background checks;

The Company collects SPI on the basis of one or more of the following:

• You have given explicit consent to the collection for one or more specified purposes;

• Where the collection of SPI is manifestly made public by you; and/or

• Where the collection is necessary for the establishment, exercise or defense of legal claims.

Where the collection is necessary for reasons of substantial public interest, in accordance with

applicable law, the Company may collect SPI for the following reasons:

• For the purposes of the prevention or detection of an unlawful act or for preventing fraud;

and

• For the provision of confidential advice.

The Company collects SPI for direct purposes and does not use SPI to make inferences about your characteristics. Under CPRA, SPI collected for direct purposes is treated as personal information only.

6. HOW PERSONAL INFORMATION IS COLLECTED

We collect most PI directly from you. However, we may also collect PI from the following:

• Publicly accessible sources;

• Directly from a third party for background checks;

• A third party, such as a bank, financial institution or advisor, with your consent;

• Consultants and other professionals we may engage in relation to your employment, with your consent;

• Our website, or through the use of Cookies;

• Our Information Technology (IT) systems, including:

• Online payroll management, document management and time recording systems.

7. THE PURPOSE FOR WHICH PERSONAL INFORMATION IS COLLECTED

The purposes for which The Company will collect or use your PI may include:

• To carry out our business operations and associated administration in connection with your matters or as your potential employer;

• To comply with our internal business processes and policies;

• To comply with our legal, regulatory and professional obligations;

• For operational reasons, such as improving efficiency, training and quality control;

• To prevent unauthorized access and modifications to our systems;

• For updating employee records;

• For the purpose of conducting background checks; and/or

• For marketing and sales purposes.

8. DISCLOSURE OF CONSUMER PERSONAL INFORMATION

We do not sell consumer personal information to third parties. We do not collect or sell consumer SPI to third parties.

We use a third-party service provider to collect consumer personal information. Our third-party service provider is only permitted to process the information in accordance with our instructions for our marketing and sales purposes.

The Company shall use a reasonable standard of care to store and protect from disclosure any PI collected using the principles of least-privileged access and by limiting access to PI to individuals with a 'need to know'.

9. DISCLOSURE OF EMPLOYEE PERSONAL INFORMATION

We do not sell employee and/or job applicant personal information or sensitive personal information to third parties.

PI will be retained by us as set out in The Company's policies. The Company may share employee PI under the following circumstances:

• In the event that we sell or purchase any business or assets, or if all or substantially all of The Company's assets are acquired by a third party, in which we may disclose your PI to the prospective seller or buyer of such business or assets, solely for the purpose of permitting the due diligence required to decide whether to proceed with a transaction;

• If reasonably necessary to protect the vital interests of a person or The Company;

• If we are subject to disclose or share your information in order to comply with any legal or regulatory obligation; or

• To enforce or apply our terms and conditions or to establish, exercise or defend the rights of The Company, Personnel, customers or others.

Our third-party service providers are subject to security and confidentiality obligations and are only permitted to process information for a specified, legitimate business purpose and in accordance with our instructions.

We only share your personal information with the following third parties:

• Affiliated companies as necessary to carry out the purposes for which the information

was supplied or collected; and/or

• HR system providers, including benefits and payroll providers.

10. DATA STORAGE AND SECURITY

The Company shall use a reasonable standard of care to store and protect your PI. We use appropriate physical, technical and organizational security measures and procedures to protect PI from unauthorized use, loss, alteration, destruction or modification. The Company shall retain your PI until the initial purpose for collecting and retaining such data has been satisfied. If you subsequently agree to a new or additional purpose, your PI may be retained for that.

11. RETENTION PERIOD

The Company retains consumer personal information for 90 days.

The Company retains employee personal information and sensitive personal information for four (4) years pursuant to Government Code 12946.

12. CONTACT INFORMATION

If you have any questions regarding this Notice, or any questions about your rights with respect

to your Personal Information, please contact us at:

Phone: (888) 278-8200

Website: https://empireworks.com/

E-mail: hr@nsgmail.com

Address: EmpireWorks Reconstruction

Attn: Karina Villalvazo

1682 Langley Ave

Irvine, CA 92614

13. MODIFICATIONS AND REVISIONS

We reserve the right to modify, revise, or otherwise amend this Privacy Notice at any time and in any manner. Any new version of this Notice will be posted on https://www.empireworks.com/privacy. This Notice will be reviewed annually and updated, as

necessary.

Updated: April 17, 2023