Effective Date: 6/1/2024

This Privacy Policy (“Policy”) for employees and applicants who reside in California (collectively “consumers” or “you”) is adopted by Rivo Holdings, LLC (“Rivo” or “company” or “we” or “us” or “our”) and sets forth how Rivo uses your personal information for human resources, employment, benefits administration, health and safety, legal and compliance, and for business-related purposes. This Policy is adopted to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) both as amended, and any terms defined therein have the same meaning when used in this Policy.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

· Publicly available information from government records.

· Deidentified or aggregated consumer information.

· Information excluded from the CCPA’s scope, such as:

o Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA); or

o Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A 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.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years 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 or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

YES

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a webiste, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

YES

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

We obtain the categories of personal information listed above from the following categories of sources:

· Directly from you. For example, from forms or applications you complete.

· Indirectly from you. For example, from observing your actions on our Website or through our electronic systems.

· From third parties, such as former employers, credit reporting agencies, educational institutions, recruiters and staffing agencies, references, benefits providers, financial institutions, internet service and data analytics providers, medical professionals, authentication providers, and other business partners.

· From our affiliates.

· From governmental agencies.

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

· To fulfill or meet the reason you provided the information.

· For any reasons set forth in the company employee handbook.

· To review and process your job application or assess qualifications for a particular job, role, or task, for background check purposes, and to verify eligibility for work.

· For business planning and business management purposes, including any diversity and inclusion initiatives.

· To provide, maintain, support, personalize, and develop our website, products, and services.

· To administer employee payroll and benefits and process work-related claims (i.e. insurance, workers’ compensation, etc.).

· For education, training, and development purposes.

· To conduct performance reviews and determine performance requirements.

· For call monitoring, quality assurance, surveillance, and fraud prevention, to conduct investigations, and for disciplinary purposes.

· For accounting, auditing, and insurance purposes.

· To disqualify you from eligibility from consideration for any loan products offered by any entities affiliated with, supported by, or working with Rivo.

· For health and welfare purposes, such as any wellness program.

· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulation.

· As described to you when collecting your personal information or as otherwise set forth in the CCPA.

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users and consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we have collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing of Personal Information

We disclose the above categories of personal information to third parties for business purposes or as required or permitted by law. We only make these disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. Third-parties with whom we disclose personal information include:

· Our affiliates and subsidiaries.

· Our employees, contractors, agents, and third-party service providers who assist us with administering the employment relationship with you. This includes, but is not limited to, payroll processors, benefits administration providers, financial institutions, reporting agencies, data storage and hosting providers, and software and application developers. These third-party service providers may be located outside of California.

· Governmental or regulatory authorities, as required by law.

We have not sold Personal Information in the twelve (12) months preceding the Effective Date of this Policy.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “Right to Know”). Once we receive your request and confirm your identity (See Exercising Your Rights to Know or Delete), we will disclose to you the categories of personal information we collected about you, the categories of sources for the personal information we collected about you, our business or commercial purpose for collecting that personal information, and the specific pieces of personal information we collected about you (also called a data portability request). Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, deleted, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot comply with your request, we will inform you of the reasons why subject to any legal or regulatory restrictions.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform any agreement with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

· Calling us at: 619-436-4937

· Emailing us at: [email protected]

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at [email protected].

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that, in our reasonable opinion, is readily useable and should allow you to transmit the information from one entity to another without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out Rights

We do not sell the personal information of employees, applicants, or minors we actually know are less than 16 years of age.

Changes to our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will provide you with a new Privacy Policy or post within the ADP Workforce Now or comparable platform and provide you notice that a new notice has been posted.

Contact Information

If you have any questions or comments about this notice, the ways in which Rivo collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 619-436-4937

Email: [email protected]

Postal Address:

Rivo Holdings LLC

530 B. Street Suite 2300

San Diego, CA 92101

If you need to access this Policy in an alternative format due to having a disability, please contact us at 619-436-4937 or via email at [email protected].