CALIFORNIA APPLICANT PRIVACY NOTICE

Carpenter Co., its subsidiaries and affiliates (collectively “Carpenter,” “us,” “we,” or “our”) provide this California Applicant Privacy Notice (“Applicant Notice”) to explain our practices regarding the collection of Personal Information through our job application process, including our careers website. This Notice explains what Personal Information we collect about California applicants, why we collect it, how we use and share it, and the rights you have relating to your Personal Information under the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (the “CCPA”).

I. Personal Information We Collect About Applicants

Within the past 12 months, we collected Personal Information about job applicants as follows:

• Identifiers including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, driver’s license, or other similar identifiers.
• Personal Information described in Cal. Civ. Code § 1798.80(e), including your name, signature, address, telephone number, driver’s license or state identification card number, credit card number, debit card number, or other financial information, education, employment, employment history, and medical information
• Characteristics of protected classifications under California or federal law, including race, ethnic origin, sex, gender, military or veteran status, medical condition, disability
• Commercial information, including receipts for expenses incurred when you travel to your interview
• Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements
• Geolocation information inferred from your IP address
• Audio, electronic, visual, thermal, olfactory, or similar information, including closed-circuit images and other information collected about you should you come onto a Carpenter property; audio and video information collected through phone and video interviews
• Professional or employment-related information, including skills, qualifications, work experience, languages spoken, honors and awards, references, recommendations, and other information included in a resume, CV, application form, or cover letter; salary information; answers to behavioral or other screening questions in an application or interview; information contained in any personal webpages, social media sites, or documents you choose to share with us; information relating to professional licenses, training, disciplinary actions, and membership in professional organizations; information relating to membership in civic organizations
• Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
• Sensitive Personal Information, including:
  • Social security, driver’s license, state identification card, or passport number
  • Personal Information that reveals racial or ethnic origin, religious or philosophical beliefs, or union membership
  • Personal Information collected and analyzed concerning health (e.g., drug-screening information)

We also collect the following information about you, which does not directly fall within the categories listed in the CCPA:

• Citizenship, immigration, visa status, and work authorization information (including information from related documents, such as your passport, driver’s license, or other identification, proof of residence, and proof of authorization to work in the United States, and documents you provide with your US Citizenship and Immigration Services Form I-9)
• Criminal records information including results of background checks obtained through government agencies such as the US Federal Bureau of Investigation
• Medical examination results for those who apply for certain positions as required by federal law

Unless otherwise specified, the sources of this Personal Information, the purposes for which we use it, and the categories of persons to which we disclose it are the same as those listed for Professional or Employment-Related Information.

II. Sources From Which We Collect Personal Information

Generally, we collect the categories of Personal Information described above from the following categories of sources:

• Directly from you
• Automatically when you use our careers website or our other electronic systems
• Created by us (e.g., if we create records pertaining to you to facilitate the application process or assess your application)
• From service providers that help us to run our business (such as those that host or support our careers website, provide analytic or data storage services, or otherwise perform functions on our behalf as part of the job application process)
• From third parties, which may include background check vendors and individuals who serve as references for you, among others
• Government records

III. Purposes for Which We Use Applicant Personal Information

Generally, we use your Personal Information for the following purposes:

• To open and maintain your application records
• To assess your eligibility for employment
• To communicate with you regarding your application
• To comply with applicable laws and regulations
• To provide you with tailored recommendations, and updates
• To show you relevant ads while you are browsing the internet or using social media
• To improve our website, set default options, and provide you with a better application experience
• To manage the security of our website, premises and systems
• To detect and prevent fraud against you and/or us

We use your Sensitive Personal Information for more limited purposes, which include:

• To assess your eligibility for employment
• To comply with applicable laws and regulations
• To manage the security of our premises and systems

We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

IV. How Long We Keep Your Personal Information

We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Privacy Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which it was collected;
• Your Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
• We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.

Where your Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention practices, please contact us using the contact details below.

V. Disclosures of California Applicant Personal Information

Within the preceding 12 months, we have not sold or shared for cross-context behavioral advertising the Personal Information of California residents that we collect in relation to applications for employment at Carpenter. The chart below shows the categories of Personal Information we have disclosed to our service providers and contractors for a business or commercial purpose during the last 12 months.

Category of Personal Information	Categories of Recipients	Purposes for Disclosure
Personal Information
Identifiers Personal Information described in Cal. Civ. Code § 1798.80(e) Professional or employment-related information	Service providers that help us to run our business Data analytics providers Governmental authorities	To open and maintain your application records To assess your eligibility for employment To communicate with you regarding your application To comply with applicable laws and regulations To manage the security of our website, premises and systems To detect and prevent fraud against you and/or us
Internet or other electronic network activity information Geolocation data	Service providers that help us to run our business Data analytics providers	To facilitate your use of our website To provide you with tailored recommendations, and updates To improve our website, set default options, and provide you with a better application experience To protect the security of our website To detect and prevent fraud against you and/or us
Audio, electronic, visual, thermal, olfactory, or similar information	Service providers that help us to run our business	To manage the security of our premises and systems
Service providers that help us to run our business	To facilitate the interview process
Inferences Commercial information	Service providers that help us to run our business	To assess your eligibility for employment To manage the security of our website, premises and systems To detect and prevent fraud against you and/or us
Sensitive Personal Information
Social security, driver's license, state identification card, or passport number Personal Information that reveals racial or ethnic origin, religious or philosophical beliefs, or union membership. Personal Information collected and analyzed concerning health.	Governmental authorities	To comply with applicable laws and regulations

VI. Submitting Requests Relating to Your Personal Information

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request through our webform or call us at 833-996-1631. Please note that if you submit a request to know, request to delete, or a request to correct, you will be asked to provide 2-3 pieces of Personal Information that we will match against our records to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will need to verify your identity directly with us before we will be able to process your request.

a. Right to Know

If you are a California resident, you have the right to request more information regarding the following, to the extent applicable:

• The categories of Personal Information we have collected about you
• The categories of sources from which we collected your Personal Information
• The business or commercial purpose why we collected your Personal Information
• The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information
• The specific pieces of Personal Information we have collected about you.

b. Right to Request Deletion of Your Personal Information

You have the right to request that we delete the Personal Information we collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not to attempt to reidentify the information.

c. Right to Correct Inaccurate Personal Information

If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

d. Right to Non-Discrimination for the Exercise of Your Privacy Rights

If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us, including retaliation against you as an employee, jo b applicant, or independent contractor.

VII. How to Contact Us

If you have any questions about how Carpenter handles your Personal Information or if you need to access this notice in an alternative format or language, please contact our Human Resources Department at CCPrivacyAct@carpenter.com

Last Updated: March 2023