LEGAL INFORMATION

Lytx, Inc. Global Human Resources Privacy Statement

Last Updated: September 15^th, 2025

This Privacy Statement describes how we collect, use, and disclose personal information related to our applicants, current and former employees (“employees”), independent contractors, consultants and other workers (collectively with employees “workers”), corporate directors, and beneficiaries and emergency contacts (collectively, “you”).

This Privacy Statement applies to Lytx, Inc. and to our controlled affiliates and subsidiaries (“Lytx”, “we”, “our” or “us”). A Lytx entity may collect or process personal information on behalf of another Lytx entity. If a candidate is hired or contracted for employment, any personal information collected under a previous privacy notice will be subject to this Privacy Statement.

This Privacy Statement is not intended to create any rights beyond those that exist by virtue of applicable privacy and data protection law. California applicants and workers can find specific disclosures, including “Notice at Collection” details about how we collect, use, disclose, sell or share, and retain personal information in the “California Privacy Rights” section below.

What Personal Information Do We Collect?

We collect Personal Information about you from different sources and in various ways during employment or contract with us, including information you provide directly, information collected automatically, information from third-party data sources, and data we infer or generate from other data. Personal information we process about includes:

Personal Information Categories and Examples	Categories of Workers
Contact information and identifiers, such as first and last name, online identifiers, account and usernames, aliases, IP address, email addresses, home and postal addresses, telephone numbers, signatures, employee ID number, and government identifiers described in the sensitive personal information category below	Applicants, Employees, Independent contractors, Emergency contacts, Beneficiaries
Demographic data, such as age (including date of birth), gender, marital status, spouse and dependents, military service, characteristics of protected classifications under applicable law, and sensitive demographic information, described in the sensitive personal information category below.	Applicants, Employees, Beneficiaries
Content of business communications, such as through our employee and IT support programs (for example, we record sales, customer and technical support calls) as well as records of communications via our email service provider, internal website, forms, audio and video recordings, surveys, business applications, chat features, and other channels.	Applicants, Employees, Independent contractors
Professional and employment-related information, such as: Work permit status and mobility information, such as immigration, residency, and related information, remote work status, and relocation information; Professional and background information, such as resumes/CVs, references, recommendations, academic and education background and qualifications, work skills and experience, professional certifications and registrations, language capabilities, training courses attended, work and salary history, information provide for and results of background checks [which include credit history and criminal background checks], results of drug and alcohol testing, health screenings or certifications, and driving and vehicle licensing and history, inferences from other data we collect for purposes other than creating a profile, including using automated means to generate information about your likely preferences or other characteristics (“inferences”); Education Information (U.S. Candidates, only), that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99) Employment and performance information, such as date of hire or contract, title, employment status, transfers and promotions, salary and rewards, training, performance appraisals/assessments, absences and reasons for absences, badge activity information, work schedules, job assignments, hours worked, attendance, time tracking information, communications, documents, files, or forms generated as part of your employment, letters of appreciation and commendation, grievances or disciplinary matters, and resignation or termination of employment; Compensation, payroll and tax information, such as pay rate, payroll amounts or deductions, hours or time worked, commission amounts, equity or stock grants, bonuses paid, banking and other financial institution details (for direct deposit), insurance and benefits payments, and information related to reimbursement of business expenses (such as credit card information, travel details and expenses, etc.); Travel information, such as loyalty programs numbers; dates and length of travel; hotel names and locations; and travel routes and departures, stops, and destination points; Personal vehicle information, such as license plate number, color, year, make, and model.	Applicants, Employees, Independent contractors
Benefits Information Benefits coverage details, such as information for determining benefits and cost estimation, (which may require information about gender, age, birthdate, marital status, and personal information of spouse and dependents); Benefits administration information, such as types of benefits used, time off requests (e.g., sick and personal leave, vacation requests) and reasons, retirement account information, and insurance;	Applicants, Employees, Beneficiaries
Emergency contact information, such as contact information related to your spouse or next of kin and your relationship to the employee.	Emergency contacts
Audio, electronic, visual, thermal, olfactory, or similar information, including facial images and voice information, such as photos, video recordings (including CCTV ), voice recordings, and sensor data such as our badge readers.	Applicants, Employees, Independent contractors
Approximate Geolocation and Location data, such as your approximate location based on an IP address or device identifier, office location, conference room booking locations, travel location information described above, company vehicle movements, movement within a Lytx-managed property to enable real-time directions and information related to Lytx and authorized third party services (e.g., building maps, tech support location, nearby restaurants or services).	Applicants, Employees, Independent contractors
Social media data, such as public profiles, posts, likes, and replies	Applicants, Employees, independent contractors
Internet or other electronic network activity, including analytics or monitoring data, including as related to internal or external communications and access to and use of our devices, systems, wi-fi, internet service, internal and external websites, equipment, applications, databases, network resources, and infrastructure (collectively, our “Systems”); and personal devices used to connect to our Systems; including usernames; passwords; system log data such as IP address, browser type, and language, device information, access times, and referring website addresses; information collected through web beacons, like cookie IDs; information collected through mobile apps, like mobile device IDs; usage data, such as time spent on our Systems, features used, and actions taken in our Systems, including page views, links clicked, and documents downloaded; contents, header, metadata, delivery and access information for voice calls, voicemail, emails, chats, messaging, documents, and other communications, data, and files stored or transmitted through our Systems. Please see our “Acceptable Use and Access Policy” posted on our employee intranet, LytxLync, to learn more about how we use personal information collected via these technologies.	Applicants, Employees, Independent contractors
Inferences drawn from personal information to create a profile reflecting your preferences, characteristics, behavior and attitudes,	Applicants, Employees, Independent contractors
Other information provided by you or as necessary for our legitimate human resources, business, security, or safety-related purpose(s)	Applicants, Employees, Independent contractors
Sensitive Personal Information government issued identifiers, such as Social Security information, driver’s license, government identification card, or passport number; account log-in in combination with a security or access code, password, or credentials that allow access to an account; sensitive demographic information such as racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; biometric information where used for the purpose of uniquely identifying you, such as to verify your identity to permit access to our offices or where features of our internal services permit you use biometric data to log into your device or identify meeting participants, where permitted by our internal policies and local law; health information, such as information necessary to provide health accommodations or time off, or to administer voluntary employee wellness programs; information relating to sex life (such as reproductive health and maternal care to provide applicable benefits) or sexual orientation (such as to support our diversity, equity, and inclusion programs) in certain locations, including California, the content of your mail, email, and text messages where we are not the intended recipient of the communication, as governed by our policies, e.g., our Acceptable Use and Access Policy	Applicants, Employees, Independent contractors

Sources of Personal Information

We collect personal information from a variety of sources, including as described in this Human Resources Privacy Statement and as follows:

Directly or automatically collected from you
Collected from or about you during the employment relationship or contract, including via feedback forms, surveys, or internal or external communications
Inferences that we may derive about you from the information we collect
Service providers (e.g., expense reimbursement services, recruiters)
Insurance and benefits providers
Training providers
Travel partners (e.g., travel agents and portals, transportation services)
Background check services
Online sources including social networks and recruiting sites (e.g., LinkedIn)
Open government databases and other public sources
Cookies and similar technologies used on devices we provide to you

Our Use of Personal Information

We use personal information that we collect in a variety of ways, as described in this Human Resources Privacy Statement and as follows:

Purposes of Use	Categories of Personal Information
Recruiting and hiring decisions	Contact information and identifiers, demographic data, content of business communications, work permit status and mobility information, professional and background information, benefits eligibility information, travel information, personal vehicle information, social media data, education information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, internet and other electronic network activity information, biometric information, inferences to create a profile, sensitive personal information
Information verification and background checks (if relevant and where permitted by local law)	Contact information and identifiers, demographic data, content of business communications, work permit status and mobility information, professional and background information, benefits eligibility information, travel information, personal vehicle information, social media data, education information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, internet and other electronic network activity information, biometric information, inferences to create a profile, sensitive personal information
Benefits eligibility determination	Contact information and identifiers, demographic data, content of business communications, work permit status and mobility information, professional and background information, benefits eligibility information, travel information, personal vehicle information, social media data, education information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, internet and other electronic network activity information, biometric information, inferences to create a profile, sensitive personal information
New hire onboarding: including to maintain and improve our recruitment and onboarding procedures, measure and analyze our technology used for recruiting and onboarding purposes, onboard new employees and to comply with applicable laws	Contact information and identifiers, demographic data, work permit status and mobility information, professional and background information, emergency contact information, sensitive personal information
Payroll and compensation	Contact information and identifiers, demographic data, content of business communications, professional and background information, compensation, payroll and tax information, travel information, personal vehicle information, benefits information, sensitive personal information
Benefits enrollment and administration	Contact information and identifiers, demographic data, content of business communications, compensation, payroll, and tax information, travel information, benefits information, geolocation and location data, internet and other electronic network activity information, sensitive personal information
Career planning and development	Contact information and identifiers, demographic data, content of business communications, work permit status and mobility information, professional and background information, employment and performance information, compensation, payroll and tax information, travel information, personal vehicle information, education information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, social media data, internet and other electronic network activity information, inferences, sensitive personal information
Training and coaching	Contact information and identifiers, demographic data, content of business communications, employment and performance information, compensation, payroll and tax information, travel information, education information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, social media data, internet and other electronic network activity information, inferences, sensitive personal information
Performance management and review: including to manage the employment relationship and enable and support career planning and development, performance reviews, investigations, disciplinary action, employee support, and legal compliance	Contact information and identifiers, demographic data, content of business communications, work permit status and mobility information, professional and background information, employment and performance information, compensation, payroll and tax information, travel information, personal vehicle information, benefits information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, social media data, internet and other electronic network activity information, biometric information, inferences, sensitive personal information
Emergency contact or notification	Contact information and identifiers; benefits information; benefits administration information; geolocation or location information; inferences to create a profile; sensitive personal information
Equal employment opportunity analysis, reporting, legal disclosures	Contact information and identifiers; demographic information, content of business communications, permit status and mobility information, professional and background information, employment and performance information, compensation, payroll and tax information sensitive personal information
Legal and policy compliance administration and enforcement, including for the purpose of anti-discrimination laws and government reporting obligations	Contact information and identifiers, demographic data, content of business communications, work permit status and mobility information, professional and background information, employment and performance information, compensation, payroll and tax information, education information, travel information, personal vehicle information, benefits information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, social media data, internet and other electronic network activity information, biometric information, inferences, sensitive personal information
Employee support services, employee wellness programs Disciplinary matters and investigations Managing, monitoring, protecting, and improving our physical spaces, such as our campus, parking, buildings, office space, conference rooms, facilities, catering and café services, including monitoring and administering building occupancy and campus parking and transportation; operating and monitoring physical security systems, such as CCTV, badge entry systems, and guest logs; registering personal vehicles and logging exit and entry times; and emergency notification services Managing and improving employee and workplace efficiency and effectiveness Legal and policy compliance administration and enforcement, including monitoring access and use of Company Systems Research and improvement of our Systems, processes, products, services, and technology	Contact information and identifiers, demographic data, content of business communications, work permit status and mobility information, professional and background information, employment and performance information, compensation, payroll and tax information, travel information, personal vehicle information, benefits information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, social media data, internet and other electronic network activity information, biometric information, inferences, sensitive personal information
Managing, monitoring, protecting, and improving our Systems, assets, and resources, including managing and protecting unauthorized access and use of company, employee and customer data, devices, systems, and infrastructure; and protecting our Systems from intrusions	Contact information and identifiers, demographic data, content of business communications, work permit status and mobility information, professional employment related information, benefits information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, social media data, internet and other electronic network activity information, biometric information, inferences, sensitive personal information
Communications and collaboration	Contact information and identifiers, demographic data, content of business communications, professional and employment-related information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, social media data, internet and other electronic network activity information, biometric information, inferences, sensitive personal information
Travel and expense reimbursement	Contact information and identifiers, demographic data, content of business communications, work permit status and mobility information, travel information, personal vehicle information, geolocation and location data, inferences drawn from other personal information
Personalization to understand your preferences to enhance your employee experience	Contact information and identifiers; content of business communications; employment-related information; travel information; internet or other electronic network activity; inferences
Using automated decision-making systems to identify trends, monitor and secure our Systems and offices, and data, training and coaching	Contact information and identifiers, demographic data, content of business communications, work permit status and mobility information, professional and background information, employment and performance information, compensation, payroll and tax information, benefits information, benefits administration information, travel information, personal vehicle information, education information, audio, electronic, visual, thermal, olfactory, or similar information, geolocation and location data, social media data, internet and other electronic network activity information, biometric information, inferences, sensitive personal information

For our workers in the UK, EU, and Switzerland, we rely on the following legal bases to process personal information:

Performance of a Contract:

Recruitment
New hire onboarding
Payroll and compensation
Benefits enrollment and administration
Performance management and review
Employee support services
Travel and expense reimbursement

Compliance with a Legal Obligation:

Equal employment opportunities analysis, reporting, legal disclosures
Legal and policy compliance administration and enforcement, including for the purpose of anti-discrimination laws and government reporting obligations

Vital Interest:

Emergency contact notification

Legitimate Interest:

Career planning and development
Training and coaching
Disciplinary matters and investigations
Managing, monitoring, protecting, and improving our Systems, assets, and resources
Managing, monitoring, protecting, and improving our physical spaces
Managing and improving employee and workplace efficiency and effectiveness
Communication and collaboration
Personalization to understand your preferences and enhance your employee experience
Using automated decision making systems to identify trends, monitor and secure our Systems, offices, and data
Legal and policy compliance administration and enforcement, including monitoring access and use of Company Systems
Research and improvement of our Systems, processes, products, services, and technology

In limited circumstances, we may also rely on consent where appropriate and either permitted or not prohibited under applicable law, such as where you choose to use biometric features on our managed devices to log in to your device.

Retention of Personal Information

We retain personal information in accordance with our obligations under applicable labor and employment law and as otherwise required to meet our legal obligations, and as necessary to administer and carry out the employment relationship and our post-employment obligations.

Disclosure of Personal Information

We may disclose your personal information with the following categories of recipients for the purposes described in this Statement or, if required by law, with your consent:

Category of Recipient and Purpose for Disclosure	Categories of Disclosed Personal Information
Our Subsidiaries and Affiliates For example, we may share business processes and common data systems with our subsidiaries and affiliates.	Contact information and identifiers Demographic data Professional and employment-related information: Benefits information Emergency contact information Audio, electronic, visual, thermal, olfactory, or similar information Geolocation and location data Social media data Internet or other electronic network activity Biometric information Inferences Other information Sensitive personal information
Vendors Working on Our Behalf For example, companies we've hired to provide recruiting, HR IT systems, including our HR record management system, background check services, payroll, benefits, travel & expense reimbursement, and administrative services; education and training services providers, communications providers (including those that record or store communications); providers to detect fraudulent, deceptive, or illegal activity, measure and analyze the use of our systems, network, and devices, and protect and secure our systems and services.	Contact information and identifiers Demographic data Professional and employment-related information Passport information Benefits information
Independent Third Parties For example, benefits partners to facilitate benefits administration (e.g., health and insurance providers), emergency services (where necessary), and with third-party providers of products and services to support our business (e.g., travel agents, corporate credit providers), or other companies that you direct us to share data with. To the extent that we provide Personal Information to such third parties, your Personal Information is governed by their privacy statements.	Contact information and identifiers Benefits information Sensitive personal information
Parties to a Corporate Transaction or Proceeding For example, we may disclose, sell, or otherwise transfer some or all of our assets, including workforce information, in connection with a merger, financing, acquisition, reorganization, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.	Contact information and identifiers Demographic data Professional and employment-related information: Benefits information
The General Public For example, we may provide features or services that permit you to publicly display and disclose certain Personal Information, such as your name or username, profile or directory information, or other Personal Information that you choose to disclose.	Contact information and identifiers
Law Enforcement and Those with Legal Necessity We will access, process, transfer, disclose, and preserve Personal to: comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; operate and maintain the security of our Systems, including to prevent or stop an attack on our computer systems or networks; protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies; or act in urgent circumstances such as protecting the health or personal safety of an employee, worker, agent, customer, user of our services, or member of the public.	Contact information and identifiers Demographic data Professional and employment-related information: Benefits information Emergency contact information Audio, electronic, visual, thermal, olfactory, or similar information Geolocation and location data Social media data Internet or other electronic network activity Biometric information Inferences Other information Sensitive personal information

This Privacy Statement applies only to Lytx’s collection and use of your personal information in connection with prospective, current or former employment. This Privacy Statement does not apply to independent third-party services to which Lytx does not control nor have access to your information. For example, information you provide directly to a benefits provider, such as your health care provider or financial institution, is not subject to this Privacy Statement. Such third-party services are governed by their own privacy statements and policies.

Data collected from or about you may be used and disclosed in a de-identified or aggregated form, that is, as a statistical measure, and not in a form that would reasonably allow anyone to identify you. Along with using this data in aggregate form ourselves, we may disclose this aggregated information in accordance with our obligations under applicable privacy and data protection laws.

Data Transfer and Location

Personal information we collect may be processed and stored in the United States or in any other country in which we or our affiliates, subsidiaries, agents, or providers maintain facilities, some of which have not been found by the local data protection regulators, such as the European Commission, to have an adequate level of data protection. When we transfer personal information to a country outside the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we protect that information in accordance with applicable law, such as the General Data Protection Regulation (GDPR) and applicable EEA, UK, and Swiss data protection laws.

If you have a question related to our processing of personal information, you may contact us as indicated below. For complaints that cannot be resolved directly we will cooperate with the relevant Data Protection Authority to resolve any issues.

Your Privacy Rights

Under certain local, state, federal, and international laws, you may have additional privacy and data protection rights related to the processing of your personal information.

European Economic Area, UK, and Swiss Worker Data Protection Rights

If our processing of personal information about you is subject to European Union, UK, or Swiss data protection law, you have certain rights with respect to that information:

You can request access to, and rectification or erasure of, personal information;
If any automated processing of personal information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal information in a usable and portable format;
If the processing of personal information is based on your consent, you can withdraw consent at any time for future processing;
You can object to, or obtain a restriction of, the processing of personal information under certain circumstances; and
For residents of France, you can send us specific instructions regarding the use of your data after your death.

To exercise one or more of these rights, please use the contact information provided in the “Exercising Your Rights” section below. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

California Privacy Rights

The California Consumer Privacy Act of 2018, Civil Code section 1798.100 et seq as amended, including by the California Privacy Rights Act of 2020 (“CCPA”), provides California workers with the following rights concerning the information we process about you:

Right to Receive Notice at Collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this statement by clicking on the above links.

Right to Know. You have a right to request that we disclose the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, sale, or sharing of such personal information. Note that we have provided much of this information in this Statement.

Right to Request Correction. You have the right to request correction of inaccurate personal information.

Right to Request Deletion. You also have a right to request that we delete personal information under certain circumstances, subject to lawful exceptions.

Right to Opt-Out. You have a right to opt-out from the “sale” or “sharing” of personal information, each of which are defined under CCPA. Note that we do not “sell” or “share” personal information as defined by the CCPA and have not done so in the past 12 months. We do not knowingly sell the personal information of minors under 16 years of age.

Right to Limit Use and Disclosure of Sensitive Personal Information. Where we use or disclose sensitive personal information to infer individual characteristics or for purposes other than those described by CCPA, you have a right to request that we limit our use and disclosure of such sensitive personal information.

We do not use or disclose sensitive personal information for purposes of inferring individual characteristics or for additional purposes.

Right to Notice. You have a right to receive notice of our personal information collection, use, retention, and disclosure practices at or before collection of personal information,

Right to Non-Discrimination. You have a right to not be discriminated against for exercising these rights set out in the CCPA.

Exercising Your Rights

To make a request to exercise your rights, or other privacy request, inquiry, or complaint, you may contact Lytx’s Chief Privacy Officer via one of the following methods:

Email: privacy@lytx.com
Telephone: 888-837-4339
By mail: 9785 Towne Centre Drive, San Diego, California 92121

If you are in the EU, in addition to the above methods, you may contact our European Data Protection Officer (EDPO):

By using EDPO’s online request form: https://edpo.com/gdpr-data-request
By mail to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

If you are in the UK, in addition to the above methods, you may contact our UK Representative, EDPO UK Ltd.:

by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
by mail to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent to provide or delete specific pieces of information, we will require the agent to provide proof that you have authorized the agent to act on your behalf, and we may need you to verify your identity directly with us.

Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. For current employees and independent contractors (or your agent), we will verify your request by asking you to send it from the email address associated with your employee log-in or by requiring any other information we determine is necessary to verify your identity. For all others, we will verify your request by requesting that you (or your agent) submit your name and email address, as well as confirm access to such email address from your email account, to process your request. We may require you to provide more information to verify your account.

When Will Lytx Update This Privacy Statement?

We may occasionally update this Privacy Statement to reflect our privacy practices or changes as required by law. If we make material changes to this Privacy Statement, or in how we process personal information, we will provide notice (or obtain consent) as may be required by law regarding such changes.

What if I Have Additional Questions?

If you have any questions about this Privacy Statement or would like to obtain a copy in a different accessible format, please contact us directly by e-mail at privacy@lytx.com. If you prefer to contact us by mail, please send any communications to:

Lytx, Inc.
9785 Towne Centre Drive
San Diego, California 92121
Attn: Chief Privacy Officer