EMPIRE TODAY, LLC California Job Applicant Privacy Notice

Effective Date: June 5, 2026

This California Job Applicant Privacy Notice (“Applicant Privacy Notice”) explains how Empire Today, LLC, and its wholly-owned subsidiaries (collectively, “Empire,” “we,” “us,” or “our”) collect, use, and disclose Personal Information about California job applicants (“Applicants” or “you”), including through www.empiretoday.com/careers (“Careers Site”), and the rights Applicants have under the California Consumer Privacy Act, as amended (the “CCPA”).

Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.

I. Collection, Use, and Disclosure of Applicant Personal Information

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with Applicants. Applicant Personal Information does not include information that is publicly available, de-identified, or aggregated, or other information that is exempt under the CCPA.

We may collect, use, and disclose Applicant Personal Information as described in the chart below. These examples may vary depending on the nature of your interactions with us.

Category of Applicant Personal Information	Purposes for Collection, Use, and/or Disclosure
Identifiers, such as name, alias, title, username and password for our Careers Site, telephone number, email address, mailing address, IP address, signature, social media usernames, and professional license numbers	To open and maintain your application records To communicate with you regarding your application To confirm eligibility, qualification, and background checks To comply with applicable state, federal labor, employment, equal employment opportunity, and related laws
Personal information described in Cal. Civ. Code § 1798.80(e), such as name, physical and electronic signature, address, telephone number, education, employment, employment history Some of this information overlaps with the other categories listed in this Applicant Privacy Notice.	To open and maintain your application records To communicate with you regarding your application To confirm eligibility, qualification, and background checks To comply with applicable state, federal, labor, employment, and equal employment opportunity, and related laws
Protected classification characteristics under California or federal law, such as age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, disability, marital status	To confirm eligibility, qualification, and background checks To comply with applicable state, federal labor, employment, equal employment opportunity, and related laws
Internet or other electronic network activity information, such as browser type and language, operating system, website access time, duration of visit, referring website address, browsing and search history on our websites, webpages viewed immediately before and after our websites, information related to your interactions with our websites, social media pages, emails, online chat, text message communications, and advertisements	To open and maintain your application records To communicate with you regarding your application To investigate security breaches and misuse of computer equipment and systems, and for safety and security To confirm eligibility, qualification, and background checks
Geolocation data, such as your geographic location inferred from your device IP address	To show you relevant job opportunities To investigate security breaches and misuse of computer equipment and systems, and for safety and security
Audio, electronic, visual, thermal, olfactory, or similar information, such as photographs on documents you may provide during the application process	To open and maintain your application records
Professional or employment-related information, such as: skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter; Answers to behavioral or other screening questions in an application or interview; Information contained in any websites 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.	To open and maintain your application records To confirm eligibility, qualification, and background checks To comply with applicable state, federal labor, employment, equal employment opportunity, and related laws
Non-public education information, including school(s) attended, degrees obtained, and other information relating to your education	To open and maintain your application records To confirm eligibility, qualification, and background checks To comply with applicable state, federal labor, employment, equal employment opportunity, and related laws
Inferences drawn from other personal information, such as preferences, characteristics, predispositions, behavior, or attitudes based on other personal information collected about you	To open and maintain your application records To identify potential job matches for you
Sensitive Applicant Personal Information, including social security, driver’s license, state identification card, or passport number; racial or ethnic origin; citizenship or immigration status; and information concerning your health (e.g., drug-screening information)	To assess your eligibility for employment To comply with applicable laws and regulations For tax purposes To manage the security of our premises and systems For safety and security

II. How We Disclose Applicant Personal Information

We may disclose each of the categories of Applicant Personal Information identified above for operational or business purposes, including, but not limited to:

With our affiliates, including our subsidiaries, so that those affiliates may assist us in managing the recruitment process.
With our service providers, vendors, and other providers in order for them to provide their services to us, including background check vendors, credit bureaus, data analytics providers, information technology vendors, and security providers to manage the recruitment process, operate and improve our business and Careers Site; perform auditing and quality control; communicate with you; and otherwise operate our business.
With our marketing firms and advertising partners for the purposes of ad targeting, remarketing, and customized advertising content.
To comply with any legal process; as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; as part of annual audits to our independent auditors; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; to enforce our terms and conditions; to protect our operations and our rights, privacy, safety, or property, and/or that of you or others; in connection with disciplinary actions/investigations; and to allow us to pursue available remedies or limit the damages that we may sustain.
With our insurers and professional advisers for the purposes of managing risks, obtaining professional advice, and exercising or defending against legal claims.
With parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

III. Sources of Applicant Personal Information

We may collect the Applicant Personal Information identified above from the following sources:

Directly from you during the application process and throughout your interactions with us, including through your resume or CV, your application materials, our IT systems, our company forms, and other processes where you submit information to us.
Automatically when using our electronic systems, including your usage history when you use our websites, systems, and applications.
Automatically when you visit our facilities, including through security camera footage.
From our services providers, vendors, and other providers, including human resources and information technology vendors, background check agencies, and other service providers.

We may also collect publicly available information about you, including information that is lawfully made available to the general public from federal, state, or local government records.

IV. Cookies and Tracking Technologies

For more information about how Empire, our vendors, and/or other services may use cookies, log files, web beacons, and other tracking technologies (collectively, “Cookies”) to automatically collect certain information about you when you access or use the Careers Site (“Usage Information”), please visit our Privacy Policy.

V. Selling or Sharing of Applicant Personal Information

We may sell or share for cross-context behavioral advertising the following categories of Applicant Personal Information with advertisers or analytics vendors for advertising purposes: Identifiers, Internet or Other Electronic Network Activity, and Geolocation Data. When we use the terms sell, sold, or sale, we mean for valuable consideration and not necessarily monetary value.

We offer you the ability to opt out of sales of your Personal Information and sharing of your Personal Information for Targeted Advertising as set forth in the “Right to Opt Out of Sales and Sharing of Personal Information” section below.

We do not have actual knowledge that we sell or share the Applicant Personal Information of consumers under sixteen (16) years of age.

VI. How Long We Retain Applicant Personal Information

We generally maintain Applicant Personal Information according to our retention obligations and policies, operational business purposes, and other legal and regulatory requirements. For example, the Applicant Personal Information you provide may be retained and used to consider whether your skills are suitable for other opportunities with Empire or our affiliated entities.

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

Applicant 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;
Applicant Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which it was collected;
Applicant 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 Applicant Personal Information by applicable laws or regulations.

Where Applicant Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

VII. California Privacy Rights

California residents have the right to submit certain requests relating to their Applicant Personal Information as described below. Please note that when submitting a request, you may be asked to provide information 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 still need to verify your identity directly with us before we can process the request.

To submit a request, please use our webform or call us at (866) 260-8358.

The 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 Applicant Personal Information we have collected about you, including:
1. The categories of sources from which the Applicant Personal Information was collected;
2. Our business or commercial purposes for collecting, selling, or sharing Applicant Personal Information;
3. The categories of recipients with which we shared your Applicant Personal Information;
4. The categories of Applicant Personal Information that we sold in the preceding twelve (12) months, and for each category identified, the categories of recipients to which we sold that particular category of Applicant Personal Information;
5. The categories of Applicant Personal Information that we disclosed for a business purpose in the preceding twelve (12) months, and for each category identified, the categories of recipients to which we disclosed that particular category of Applicant Personal Information.
The specific pieces of Applicant Personal Information we have collected about you.

Right to Opt Out of Sales and Sharing of Applicant Personal Information. You have the right to opt out of the sale of your Applicant Personal Information and to request that we do not share your Applicant Personal Information for cross-context behavioral advertising in the context of cookies and other tracking technologies. To opt out of the sale or sharing of your Applicant Personal Information via cookies and other tracking technologies, please click on the “Do Not Sell or Share my Personal Information” link in the footer of our Careers Site. You may also opt out of the sale or sharing of your Applicant Personal Information through an opt-out preference signal. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal.

Right to Delete. You have the right to request that we delete Applicant Personal Information we collected from you, subject to certain exceptions.

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

Right to Limit Use and Disclosure of Sensitive Applicant Personal Information. We do not use or disclose sensitive Applicant Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

Rights related to Automated Decisionmaking Technology (“ADMT”). You may have the right to opt out of and access ADMT in furtherance of significant decisions. However, we do not use automated means in furtherance of decisions that produce legal or similarly significant effects under applicable state privacy laws.

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.

IX. Contact Information

If you have any questions about this Privacy Notice, you may contact us at HR@empiretoday.com with Attention: Applicant Privacy Notice in the subject line.