California Resident Privacy Notice For Personnel and Business Service Providers

Public Version:
Published Date: Feb 19, 2026

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, 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, and the right to not be retaliated against, 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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