California Resident Privacy

Material Holdings, LLC, together with its subsidiaries and services
(e.g. Lieberman Research Worldwide, Interviewing Service of America;
collectively, “we,” “us” and “Material”), is committed to protecting
the privacy of all information we collect from our current,
prospective and former California-resident employees, contingent
workers, independent contractors, job candidates, vendors, clients
and/or similar business service providers engaged in business
related activities with Material (each a “California BSP”). This
California Privacy Notice (“California Privacy Notice”) applies to
California BSP Personal Information (including Sensitive Personal
Information) collected, stored, used or otherwise processed by
Material in connection with our operations and business activities
(“Data Processing Activities”). “Personal Information” and
“Sensitive Personal Information” hold the same definition provided
by the California Consumer Privacy Act a/k/a (“CCPA”). References to
Personal Information herein shall also refer to Sensitive Personal
Information when applicable under the circumstances. 

By engaging with Material in your capacity as a California BSP, you
confirm that you have read and understood the entirety of this
California Privacy Notice as well as our broader
Privacy Policy. Additionally, if you are a candidate applying to work at
Material, our
California Candidate Privacy Statement
applies as well.

Material is a marketing services and digital transformation company
focused on helping its clients better understand and more
effectively interact with their customers.  For more information
about our company and our business activities, please refer to our
company website:
www.materialplus.io.  

In connection with our business operations, we collect and process a
variety of information from California BSPs. In the vast majority of
cases, the information we collect has been provided to us by you
and/or made available with your permission.  All BSP
Information, and the manner of collection of such information is
context specific. For example, we collect Personal Information
relating to our employees and prospective employees for the purpose
of payroll, communication, verification of employment, need for
reasonable accommodations, etc. Conversely, for individuals that
work for (or with) our clients and vendors, the extent of the
information we collect is limited to business contact information,
role and other information necessary to engage in such business
activities. 

In some situations, for example if you log onto one of our physical
devices, network, and/or virtual private network (VPN), we may
employ software to identify certain systems-related information,
including IP address, device and browser type, and geographic
location, in an effort to help protect us (and you) from malicious
activity. 

Our legal basis for Processing Personal Information in most
situations is by obtaining your consent. Nevertheless, other legal
bases exist which may take precedence, including, without
limitation: 

• legitimate interest to protect the integrity of our business 
• legitimate business activity 
• to perform a contract with you, the company for which you work
  and/or third-parties related to the applicable transactions,
  and/or 
• to comply with applicable and/or prevailing, regulatory guidance
  and/or industry codes of ethics and standards.  

Whenever the legal basis relied upon for the Processing of Personal
Information is no longer reasonably necessary, we will delete such
information.  You may withdraw your consent from our Processing
activities at any time; provided that you acknowledge that in many
situations there may be a superseding legal, contractual or other
reasonable justification to maintain the information.  For
example, withdrawing your consent, may not supersede record keeping
obligations imposed under applicable laws.    

If you choose to use social media (for example, Facebook, Instagram,
Twitter, LinkedIn, or our blog) in order to contact us or find out
about our services, we may collect your public-facing profile data,
data relating to your interactions with us, and any data you post on
message boards which are relevant to our business.  Some of
this data may be Personal Information. 

We collect certain information regarding visitors to our websites,
including IP address, device and browser type, date and time of
visit, name of the visitor’s Internet service provider, state or
country from which the websites were accessed, web pages from which
the visitors linked to the websites, and behavior while on the
websites (e.g., which links were clicked on).  We may do so using
cookies, which are small files placed on your internet browser when
you visit our websites, in order to offer you a more tailored
experience in the future by, for example, understanding and
remembering your particular browsing preferences.  Occasionally,
cookies, pixels, or web beacons may be placed on our websites by
service providers or partners; we do not permit Personal Information
to be collected or accessed by these cookies, pixels, or web
beacons.  If you prefer not to receive cookies from our websites you
can disable their use in your browser settings. By doing so you may
reduce the functionality of the web pages you view and, in some
cases, be unable to take part in important online activities
concerning your engagement with us.   

Currently, our systems do not respond to browser do-not-track
signals, and do not treat such signals as “do not sell” signals
under CCPA (as defined below).   

Lastly, when visiting certain of our websites, you are provided the
option to sign up for our newsletters, white papers, ebooks, or
mailing lists, and if you do, we collect the information you supply
for use in the promotion of our own businesses to you. If you wish
to be removed from our email lists, please email us
at info@materialplus.io or, in the case of messages that are not
transactional in nature, you may use the unsubscribe feature in the
email message you received (typically located in the footer of the
message). 

Depending on how we obtain your Personal Information (as described
above), we may either be processing the data in accordance with the
instructions provided to us by the party controlling such data
and/or we may be the party in control of such data. 

Regarding data collected as part of one’s status as California BSP,
we Process data for purposes related to and in connection with the
applicable services you are providing, and our use of that
information is limited to that purpose. In some cases, this purpose
may extend to sharing Personal Information with third parties for
services that support Material’s business, operations, compliance,
etc. When doing so, the third-party use of such Personal Information
shall be subject to agreements with at least the same level of
privacy protection provided by Material and limited to the purposes
specified herein, including the references to related
notices.  

As to Personal Information we Process from (or about) our clients’
personnel, we use such information for purposes connected to
fulfilling our obligations to such client(s).  

Any Personal Information which may be collected in the Careers
sections of our websites and/or otherwise for consideration and
qualification for employment or similar engagement with Material
will be used for purposes of the consideration of such engagement
and, if engaged, used as part of the engagement.  Our data
privacy practices in that context are further specified in our
California Candidate Privacy Statement.  

Notwithstanding the category of individuals about whom Personal
Information is collected, we use multiple Safeguards (as defined
below) to protect such information. Please refer to the Information
Security Section (below) for more information.  

Material conducts business, provides services and also employs or
engages with workers across the globe. Any data we collect and
process relating to California BSPs in connection with our global
business activities may be transferred between or among two or more
countries (either within Material or between Material and a third
party) for the stated purposes referenced herein.  In all cases, we
will take appropriate measures to ensure that Personal Information
is transferred in accordance with this California Privacy Notice and
the applicable legally-provided mechanisms available to the parties
to lawfully transfer data across borders.  

Information we collect from or about visitors to our websites and/or
social media pages is used for improvement and maintenance of our
services and the preparation of reports or compilation of statistics
in order to improve our the general suite of services we offer.
 Personal Information supplied to us in connection with newsletters,
white papers, and mailing lists will remain confidential and will be
used by Material for its own marketing activities.  If you wish
to be removed from our marketing lists, please email us
at info@materialplus.io or, in the case of messages that are not
transactional in nature, you may use the unsubscribe feature in the
message you received (typically located in the footer of the
message). 

We do not “sell” (as defined by the CCPA) California BSP Personal
Information.  In addition to the data sharing activities
disclosed in this California Privacy Notice, under certain
circumstances, we may be required to release Personal Information in
response to a legal request from public authorities including to
meet national security or law enforcement requirements, or in
response to a subpoena or other legal process. 

We do not discriminate financially between those who elect to supply
their Personal Information to us and those who elect to not do so,
provided, however, that to the extent the information is required to
perform a service, complete a transaction, comply with law and/or
enforce Material business process or policy, but you decline to
consent to such collection, our ability to engage you in certain
capacities may be limited or not practicable. 

In all cases, Material will take reasonable steps to ensure the
Personal Information is accurate, complete, current and relevant and
being used only for the intended purposes. We will not process
Personal Information in a way that is incompatible with the purposes
for which it has been collected (or subsequently authorized by the
individual) without first obtaining your consent or having a
compelling legal basis for such use. 

We keep Personal Information for no longer than necessary for the
purposes for which the Personal Information is collected or
processed. The length of time we retain Personal Information for
depends on the purposes for which we collect and use it and/or as
required to comply with applicable laws and to establish, exercise
or defend our legal rights. In situations in which we do not have a
superseding requirement to retain your Personal Information, you may
request that we delete it (see section below: Your Rights As to Your
Personal Information). 

We maintain physical, electronic and procedural security measures to
help safeguard California BSP Personal Information which are
consistent with industry standards and practice and in compliance
with applicable law (our “Safeguards”). Notwithstanding the category
of individuals about whom Personal Information is collected, our
Safeguarding is designed to use commercially reasonable efforts to
protect data we process from loss, misuse, unauthorized access,
disclosure, alteration, and destruction. The specific Safeguards we
use (which may vary depending on the circumstance of the Processing
activities) include, without limitation, (1) a cybersecurity program
and data privacy program, (2) data breach incident management
procedures, (3) periodic self-assessments and third-party
assessments to address privacy and security requirements, and (4)
penetration tests.  

The technical and organization safeguards we employ meet the
applicable standards of industry practice that are relevant to our
business activities and the volume and sensitivity of data we
process. Third parties that provide us with support or services and
that may also receive California BSP Personal Information are
required by us to maintain safeguarding measures similar to ours
with respect to such information. 

California BSPs have certain rights (by law) to know certain details
or to request we take certain action regarding their Personal
Information. While such rights are widely applicable there are valid
exceptions (e.g. the information is needed to fulfill a contract or
the right being exercised is preempted by conflicting laws,
obligations and/or the rights of others).  

If you are a California BSPs, you have the right to: 

If you are a California BSPs, when applicable under the
circumstances and subject to any exceptions that may exist, you have
the right to: 

1. know what personal information we collected about you, from whom
it was collected, why it was collected, and, if sold, to whom; 

2. delete personal information collected by us; 

3. opt-out of the sale of personal information (if applicable) (or
the sharing of personal information to third parties for
cross-context behavioral advertising); 

4. non-discriminatory treatment for exercising any rights;  

5. initiate a private cause of action for data breaches; 

6. correct inaccurate personal information; and 

7. limit use and disclosure of sensitive personal information.

If you would like further information about these rights or would
like to exercise any of them, please email us
at privacyrequests@materialplus.io or call our privacy request
hotline at (888) 914-9661 (PIN: 892698). Either of these methods can
be used in the event that you wish to appeal a decision we made with
respect to a data privacy request.

By law, as well as for your protection, if you request that we take
certain actions as to Personal Information we have about you, we may
be required to (or we may reasonably believe we should) take certain
steps to verify your identity.  If we are not able to verify your
identity, we may not be able to respond to your request.  To verify
your identity, we minimally request, at point of submission of your
request, that you supply your basic contact information, as well as
the specific information at issue.  In addition, as to those rights
permitted by law to be exercisable by an authorized agent on your
behalf, in addition to verifying your identity as described above,
we require the agent to also supply written authorization from you
to act on your behalf, except where restricted by law. 

Material is subject to the investigatory and enforcement authority
of the FTC and the California Privacy Protection Agency.   

Also, as members of the
Insights Association
and
ESOMAR, we strive to model our policies according to guidelines
promulgated by those organizations.  

Our Privacy Officer is available to answer questions or for
processing a complaint at privacyrequests@materialplus.io (ATTN:
Privacy Officer).

We may update this California Privacy Notice from time to time by
posting an amended version of the statement. Please refer to this
notice regularly.  

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