Privacy Notice For California Consumers (Company Employees)

Last Revised: January 1, 2025

This Privacy Notice for California Consumers (Company Employees) supplements the information contained in our and applies solely to all employees, employee applicants, owners, directors, officers and contractors of London Properties, Ltd. who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) and any terms defined in the CCPA and CPRA have the same meaning when used in this notice. As used throughout this notice London Properties, Ltd. is referred to as "we," "us," or "our company."

The Employee Privacy Notice applies only to individuals residing in the State of California who are considered "Consumers" under the CCPA and CPRA and from whom we collect "Personal Information" as described in the CCPA and CPRA ("Consumers"). We provide you this notice because under the CCPA and CPRA, California Residents who are job applicants, employees, or contractors of a Business qualify as Consumers. For purposes of this Employee Privacy Notice, when we refer to Consumers, we mean you to the extent you are a California employee, employee applicant, or independent contractor.

Information We Collect

We may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, in physical locations, through the mail, and/or over the telephone. More specifically, London Properties, Ltd. may collect the following categories of Personal Information from California job applicants, employees, or independent contractors, which will depend on the particular Business Purpose (described in the How We Use Personal Information below) for which we collect it:

Personal Information does not include de-identified or aggregated consumer information. London Properties, Ltd. obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or services we provide you.
• 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.
• Third parties, including recruiters who submit your information to us for an employment position that may interest you and consumer reporting agencies for employment background checks.

How We Use Personal Information

We may use or disclose the personal information we collect from you or about you to do one or more of the following:

• To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job or become an employee, we will use that personal information in connection with your employment or potential employment.
• To contact you and to inform you about benefits or information relating to your employment or potential employment.
• To provide, support, personalize, and develop our website and services relating to your employment or potential employment.
• To create, maintain, customize, and secure your information or account with us.
• To process your requests or transactions and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our systems, App or Website, services, databases and other technology assets, and business.
• For research, analysis, and business development, including to develop and improve our business processes, Website and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA or subsequently agreed to by you.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of London Properties, Ltd. assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by London Properties, Ltd. about our Consumers is among the assets transferred.

How We Share Personal Information

London Properties, Ltd. may disclose your personal information to a third party for a business purpose, including to our service providers.

We disclose and share your personal information with the following categories of third parties:

• Service providers.
• Third parties with whom you direct us to share your personal information.
• Third parties as part of our employment process such as consumer reporting agencies for employment background checks.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, London Properties, Ltd. 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 other similar network activity.
• Category G: Geolocation data.
• Category H: Sensory data.
• Category I: Professional or employment-related information.
• Category K: Inferences drawn from other personal information.

Sale of Personal Information

In the preceding twelve (12) months, London Properties, Ltd. has not sold personal information of job applicants, employees or independent contractors.

Your Rights and Choices

If you are a California resident, you have certain rights regarding your personal information under the CCPA and CPRA. This section describes your CCPA and CPRA rights and explains how to exercise those rights.

Access to Specific Information

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. You must make a verifiable consumer request as described below. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources from which we collected your personal information.
• Our business or commercial purpose for collecting or selling your personal information.
• The categories of third parties with whom we share your personal information.
• The specific pieces of personal information we collected about you.
• If we sold or disclosed your personal information for a business purpose, we will provide two separate lists disclosing the following:
• The categories of personal information that we disclosed about you for a business purpose.
• The categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category of personal information for each third party to whom the personal information was sold.

If we deliver the information to you electronically, then the information will be portable and to the extent technically feasible, in a readily usable format that allows you to transmit it to another entity without hindrance.

Deletion Request Rights

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. You must make a verifiable consumer request as described below. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Comply with any federal, state or local laws.
• Comply with a civil, criminal or regulatory inquiry, investigation, subpoena or summons by federal, state or local authorities.
• Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider or third party reasonable and in good faith believes may violate federal, state or local law.
• Exercise or defend legal claims.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided it.

How to Exercise Your Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling toll free at 800-U-R-MOVED
• Emailing [email protected]

You may also make a request on behalf of your minor child. You may only make a request for access to or disclosure of your personal information twice within a 12-month period. The request 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 are unable to verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create a user account with us to make a request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. If you provide us with personal information in your request, we will only use it to verify the requestor's identity or authority to make the request.

Response Timing and Format

We will try to respond to your request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. But the extension period will be no more than an additional 45 days.

We will deliver our written response by mail or electronically, at your option. 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.

If we deliver the information to you electronically, then the information will be portable and to the extent technically feasible, in a readily usable format that allows you to transmit it to another entity without hindrance.

We do not charge a fee to process or respond to your 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 or Sharing Opt-Out Rights

You have the right to direct us to not sell or share your personal information at any time (the "right to opt-out").

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following link: DO NOT SELL MY PERSONAL INFORMATION on www.londonproperties.com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing: [email protected]

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Automated Decision-Making Opt-Out Rights

You have the right to opt out of the use of automated decision-making technology in the event we begin using such technology. We have not used automated decision-making technology during the preceding 12 months.

Right to Correct Inaccurate Personal Information

You have the right to direct us to correct personal information that is inaccurate. We will use commercially reasonable efforts to correct inaccurate personal information upon receipt of your request. Please refer to "How to Exercise Your Access and Deletion Rights" above for instructions on how to submit your request.

Right to Limit use and Disclosure of Sensitive Personal Information

You have the right to limit the use and disclosure of sensitive personal information to the extent allowed by CCPA and CPRA. Sensitive personal information includes but is not limited to the following: social security number, driver's license number, state identification card number, passport number, account log-in, financial account number, debit or credit card number, password, security code, geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, contents of mail, email or text messages unless the business is the intended recipient of the communication, genetic data, citizenship or immigration status, etc. This right only applies to the use of sensitive personal information other than what would be reasonably expected by an average employee. Please refer to "How to Exercise Your Access and Deletion Rights" above for instructions on how to submit your request.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA and CPRA rights.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their direct marketing purposes.

Security of Personal Information

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure.

Retention of Personal Information

We will store personal information of job applicants, employees and independent contractors in accordance with applicable laws or regulatory requirements and retain data for as long as necessary to fulfill the purposes for which the personal data was collected.

Changes to our Employee Privacy Notice

London Properties, Ltd. 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 the updated notice on our website and update the notice's Last Revised Date above.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 800-U-R-MOVED
Website:
Email: [email protected]
Postal Address:
London Properties, Ltd.
Attn: Patrick Conner
6442 N. Maroa Ave.
Fresno, CA 93704