Privacy Notice for California Company Employees Contractors and Applicants

Effective Date: January 1, 2020

This Privacy Notice is for California employees (“Notice), contractors and applicants and sets forth our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”). This document is to supplement ZAGG’s Privacy Policy to its customers located on ZAGG.com. This Notice only applies to individuals residing in the State of California who are considered “Consumers” under the CCPA and for whom we collect “Personal Information” as described in the CCPA. Under the CCPA, California Residents who are job applicants, employees or contractors of ZAGG qualify as Consumers. For purposes of this Notice, when we refer to Consumers, we mean you to the extent you are a California employee, employee applicant or contractor.

What information do we process?

As your employer or potential employer, we need to keep and process certain information about you for normal employment and HR management purposes, to comply with our legal obligations and, where necessary, to protect our legitimate business interests. We will collect and process information from you during the recruitment process, during our employment relationship and following the termination of our employment relationship.

Personal Information is normally obtained directly from you. In certain circumstances, we obtain it indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things. There are also instances where it is necessary to obtain Personal Information from internal third parties, e.g. your line manager, or from external third parties, e.g. references from previous employers, recruiters, consumer reporting agencies for employment background checks etc.

The categories of Personal Information we collect are set out in more detail in the appendix to this notice. Personal information does not include de-identified or aggregated consumer information.

How do we use your information?

The information we collect from or about you will be used for management and administrative purposes. We keep it and use it to enable us to run our business, manage our employment or potential employment relationship with you effectively, and lawfully and appropriately protect employees’ (and prospective employees’) rights and interests. This includes the following use of your information:

• to enable us to manage your recruitment and onboarding process
• to enable us to manage your employment or potential employment to support and respond to your inquiries
• to maintain your contact information, including altering your details across relevant entities within ZAGG (for example personal, other employment and transferring roles), and to include contact details for your dependents and other designees as provided by you in case of personal or business emergency
• to contact you and inform you about benefits or other information pertaining to your employment or potential employment, and to administer a range of medical, dental, vision, retirement, disability and other benefits for you and your beneficiaries
• to provide employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration
• to enable us to pay and reimburse for expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus and commission payments to individuals, and stock option payments
• to conduct performance reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff re-structuring
• to monitor work-related licenses and credentials, including provisioning software licenses for use in the course of an employee’s work-related responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies
• to administer international (or inter-state) assignments, including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration and filing obligations, and addressing health requirements
• to monitor and ensure your eligibility to work in the U.S., which means monitoring and ensuring compliance of employees’ ability to work in the U.S
• to enable healthcare-related services, including conducting pre-employment drug screenings and employment-related medical screenings for return to work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs of employees to plan and provide appropriate services, including operation of sickness policies and procedures
• to facilitate better working environment, which includes conducting staff surveys, providing senior management information about other employees, and conducting training
• to ensure a healthy, safe and efficient working environment, which includes ZAGG’s actions relating to disciplinary actions, and code of conduct processes and investigations
• to maintain the safety, security and integrity of our systems, databases and other technology assets and our business
• to comply with legal and regulatory obligations, government regulatory request, court order or other law enforcement requests
• to pursue our legitimate interests and protect our legal position in the event of legal proceedings against the company
• as described to you whenever collecting your personal information or as otherwise set forth in the CCPA or subsequently agreed to by you

Where there is a need to process your Personal Information for a purpose other than those set out in the appendix or otherwise outlined to you, we will inform you of this.

How is your information shared?

Your information may be disclosed to third parties where it is required, necessary or beneficial by virtue of your employment or potential employment. For example, we pass on certain information to our external payroll provider, retirement and health insurance providers, consumer reporting agencies for employment background checks, compensation experts in connection with a compensation survey or with third parties to manage a required accommodation in connection with your employment.

More detailed information on how we share your Personal Information is set out in the appendix.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, ZAGG Inc has disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers
• Category B: California Customer Records personal information categories
• Category C: Protected classification characteristics under California or federal law
• Category F: Internet or Network Activity
• Category G: Geolocation Data
• Category H: Audiovisual Information
• Category I: Professional or Employment Information
• Category J: Education Information as defined by the Family Education Rights Privacy Act
• Category K: Inferences Drawn

In the preceding twelve (12) months, we have not sold or leased any personal information. ZAGG does not sell or lease personal information.

What happens if you do not provide us with your information?

In some cases, you may decline to provide us with your Personal Information. However, if we believe that we require relevant information to effectively and properly manage our employment relationship, we may not be able to continue our employment relationship with you if you decline to provide us with that Personal Information.

Further information

If you have any questions or comments about this notice, please do not hesitate to contact privacy@zagg.com or reach out to your Human Resources representative.

Review

ZAGG Inc. reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post a revised notice online and update the notice’s Effective Date above. We encourage you to check this link frequently to see the current privacy notice in effect and any changes that may have been made to them.

Appendix