Employee Privacy notice

1. Introduction and Scope

In this Privacy Notice, we describe how MG LLC d/b/a TRANZACT, a Delaware limited liability company, and each of our affiliated and subsidiary companies (individually and collectively, “TRANZACT,” “we,” or “us”) collect, use, disclose, process, and protect Personal Information about our employees, job applicants and candidates for employment with TRANZACT (collectively “you” or “your”).

For purposes of this Notice, “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 our employees, job applicants, or candidates. This may include information collected from you when you access a job description or submit your resume on the TRANZACT website, application information such as employment history and educational records, and government issued identifiers.

This Privacy Notice does not address or apply to our handling of:

• Personal Information collected from you in your capacity as a consumer;
• Publicly available information made lawfully available by state or federal governments;
• Personal Information that is subject to an exemption under Section1798.145(c) – (f) of the CCPA (such as protected health information that is subject to HIPAA or the California Medical Information Act, and non-public information subject to the Gramm Leach Bliley Act or the California Financial Information Privacy Act);
• Personal Information about individuals acting for or on behalf of another company, to the extent the information relates to our transactions with such company, products or services that we receive from or provide to such company, or associated communications or transactions.

For information on our collection, use, and disclosure of the Personal Information of consumers, please visit our consumer Privacy Notice.

2. Notice at Collection of Personal Information

Categories of Personal Information We Collect:
Generally, we collect the below categories of Personal Information about employees, job applicants, and candidates.

Name, Contact Info and Other Identifiers: Identifiers may include, but are not limited to:

• Personal Details: Name, alias, employee identification number, work and home contact details (email, phone numbers, physical address), language(s) spoken, sex, gender, date of birth, nationality, place of birth, state identification card, national identification number, passport number, social security number, driver’s license, marital/civil partnership status, domestic partners, dependents, disability, emergency contact information, health, insurance and benefits details, vehicle data, and IP address.
• I-9 Documentation Required: Passport data, details of residency or work permit.
• System and Application Access Data: Information required to access company systems and applications, which may include, but may not be limited to, such as System ID, LAN ID, email account, instant messaging account, employee ID, manager employee ID, system credentials, employee status, office location previous company details.

Protected Classifications: Characteristics of protected classifications (including those under California or federal law) such as:

• Nationality and citizenship information, as well as residency and work permit details;
• Medical information and disability information; and/or
• Information we may collect as part of any diversity and inclusion efforts including, but not limited to, race, ethnicity, color, sex, gender, sexual orientation, age, religion, national origin, disability, and citizenship status. This data is collected only if we are authorized by applicable law to do so and subject to implementing appropriate safeguards as required by applicable law.

Usage Data: Internet or other electronic network activity information including, but not limited to, browsing history, search history, email activity, and information regarding a user’s interaction with a system, website, or application. This includes:

• Information about your use of the TRANZACT website, including to submit a job application;
• Access logs and usage details regarding activities on TRANZACT’s network, systems and devices, including but not limited to website and browsing history;
• Physical access logs and call logs; and/or
• Electronic content produced using TRANZACT systems.

Biometric Information: Physiological, biological or behavioral characteristics including information pertaining to an individual's deoxyribonucleic acid (DNA), that is used or intended to be used, singly or in combination with each other or with other identifying data, which is used to establish individual identity, for the purposes of uniquely identifying someone. These data are collected only if we are authorized by applicable law to do so and subject to implementing appropriate safeguards as required by applicable law.

Geolocation Data: Precise geographic location information about a particular TRANZACT device.

Audio, Video and Other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information. This includes:

• Employee photograph;
• CCTV footage and photographs; and/or
• Call recordings and other audio recordings (e.g., recorded meetings and webinars).

Employment History: Professional or employment-related information. This includes, but is not limited to:

• Compensation and Payroll: Base salary, bonus, benefits, compensation type, salary step within assigned grade, details on stock options, stock grants and other awards, currency, pay frequency, effective date of current compensation, salary reviews, banking details, working time records (including vacation and other absence records, leave status, hours worked and department standard hours), pay data and termination date.
• Position: Description of current position, job title, corporate status, management category, job code, salary plan, pay grade or level, job function(s) and sub function(s), company name and code (legal employer entity), branch/unit/department, location, employment status and type, full-time/part-time, terms of employment, employment contract, work history, hire/re-hire and termination date(s) and reason, length of service, retirement eligibility, promotions and disciplinary records, date of transfers, and reporting manager(s) information.
• Talent Acquisition and Talent Management Information: Professional qualifications, language and other relevant skills, certification, certification expiration dates, information necessary to complete a background check and/or licensure application, details on performance management ratings, development programs planned and attended, e-learning programs, performance and development reviews, willingness to relocate, driver’s license information, and information used to populate employee biographies.
• Management Records: Details of any shares of common stock or directorships.

Education Information: Information about education history or background, including but not limited to:

• Degrees, certificates or other training completed, schools attended and relevant dates; and/or
• Details contained in letters of application and resume/CV, previous employment background.

Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile about an employee reflecting their preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Logins and Account Access Information: Information which reveals account login, financial account, debit or credit card in combination with any required security or access code, password or credential allowing access.

Sensitive Information: We may collect certain types of information that are considered sensitive data or sensitive personal information (or special categories of data) under applicable law, such as health/medical information, place of birth, trade union membership information, social security numbers and other government identifiers, religion, and race or ethnicity. We collect this information for specific purposes, such as health/medical information in order to accommodate a disability or illness and to provide benefits; and Personal Information such as sex, gender, race or ethnicity in order to comply with legal obligations and internal policies relating to anti-discrimination.

We only use sensitive information for permissible business purposes, such as work and benefits eligibility, payroll, administering benefits, and monitoring our equal opportunity practices. We do not use or disclose sensitive information for the purpose of inferring characteristics about you.

The Business and Commercial Purposes for Which We May Collect, Use, Transfer and Disclose Personal Information:

• Managing Workforce. Managing work activities and personnel generally, including recruitment, appraisals, performance management, promotions and succession planning, rehiring, administering salary, and payment administration and reviews, wages and other awards such as stock options, stock grants and bonuses, healthcare, pensions and savings plans, training, leave, managing sickness leave, promotions, transfers, secondments, honoring other contractual benefits, providing employment references, loans, performing workforce analysis and planning, performing employee surveys, performing background checks, managing disciplinary matters, grievances and terminations, reviewing employment decisions, making business travel arrangements, managing business expenses and reimbursements, planning and monitoring of training requirements and career development activities and skills, and creating and maintaining one or more internal employee directories.
• Communications and Emergencies. Facilitating communication with you, ensuring business continuity, providing references, protecting the health and safety of employees and others, safeguarding IT infrastructure, office equipment and other property, facilitating communication with you and/or your nominated contacts in an emergency.
• Business Operations. Operating and managing the IT and communications systems, ensuring the security of Company systems, networks and information, managing product and service development, improving products and services, managing company assets, allocating company assets and human resources, strategic planning, project management, business continuity, compilation of audit trails and other reporting tools, maintaining records relating to business activities, budgeting, financial management and reporting, communications, managing mergers, acquisitions, sales, re-organizations or disposals and integration with purchaser, enhancing services.
• Targeted Advertising. When you access the TRANZACT website or career portal, we, along with our third party partners, data analytics providers, advertising technology vendors, and social media platforms may collect and use your Personal Information to serve you interest-based advertising.
• Compliance. Complying with legal and other requirements and otherwise protecting the company’s legal interests, such as income tax and national insurance deductions, record-keeping and reporting obligations, conducting audits, reporting corporate governance, compliance with government inspections and other requests from government or other public authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, for the purpose of observing our legal obligations, which include preventing business transactions with restricted parties and complying with relevant global trade control laws, defending litigation and managing any internal complaints or claims, conducting investigations and complying with internal policies and procedures.
• Monitoring. Monitoring compliance with internal policies and Code of Business Conduct, monitoring activity in public places by CCTV and monitoring of telephone, email, Internet, instant messaging and other company resources as detailed in our policies and permitted by applicable law, regulation and any applicable works council agreements.
• Complying with record keeping requirements. Complying with record keeping requirements, including retention requirements mandated by statute or governmental regulatory agencies in the geographies where we do business, as defined in our agreements, or per client instructions.

Sale of Personal Information

On our website and career portal, we or our third-party partners may use advertising or analytics technologies that collect your Personal Information, including to analyze use of the portal or to display interest-based advertising on our website or across the internet. We may “sell” or “share” the Personal Information (as these terms are defined in California law) for marketing and advertising purposes to business partners and third parties, such as data analytics providers, advertising technology vendors, third-party advertising networks, and social media networks.

We do not knowingly sell or share Personal Information about persons under the age of 18. Please click on the Your Privacy Choices link located in the footer of the home page at www.tranzact.net to opt out of the sale or sharing of your Personal Information, including targeted advertising. You may also choose to enable online, where available, a universal tool that automatically communicates your opt out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt-out.

Retention

We will keep your Personal Information for as long as you remain employed by us, and for a period of 10 years thereafter subject to applicable legal requirements. We will only retain your Personal Information after this time if we are required to do so to comply with the law, or if there are outstanding or, where allowed by law, reasonably anticipated claims or complaints that will reasonably require your Personal Information to be retained. For additional details, please review our Records Management Policy. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

We may de-identify or aggregate Personal Information so that it will no longer be considered Personal Information and disclose such information to other parties for purposes consistent with those described in this Notice.

3. Sources of Personal Information

Information collected directly from you. We normally collect your Personal Information directly from you, for example, when you apply for a job with us, when you commence your role, and from time to time throughout your employment when we ask you to provide information. We may be required as a consequence of our relationship with you as your employer, or by law, to collect certain Personal Information about you. Failure to provide this information may prevent or delay the fulfillment of our obligations as an employer. We will inform you at the time your information is collected whether certain information is compulsory and the consequences of the failure to provide such information.

Information collected automatically. When you visit our website and career portal, we or our third-party advertising and analytics partners and service providers may collect browsing history, site usage data, and other information regarding your online activity automatically through a variety of technologies, such as cookies, tags, SDKs or scripts.

Information collected from third parties. We may receive Personal Information from other sources, including:

• background check information from employment screening agencies or publicly available registers (as allowed by law), or references obtained during recruitment;
• publicly available professional profiles on websites or social media (e.g., LinkedIn); and
• information about your performance or conduct from other employees, clients, or service providers you work with who may provide feedback about you or participate in performance evaluations or reviews.

Combined Information. We may combine Personal Information that we receive from the various sources described above. We use, disclose, and protect combined Personal Information as described in this Privacy Policy.

4. Monitoring tools, profiling and automated decision-making

Some of the technology we use to protect company confidential information and ensure compliance with company policies monitors employee IT usage and employee communications and may automatically filter, record or block the sending of communications, or flag certain communications for further review, subject to applicable law. For further information on this, please contact privacy@tranzact.net.

5. Use and Disclosure of Personal Information

We generally disclose your Personal Information with our staff and human resources personnel on a need to know basis, including your managers and their designees, personnel in management, HR, IT, Compliance, Legal, Finance and Accounting and Internal Audit to the extent that it is legally necessary. We may also disclose each category of your Personal Information that we collect to the following categories of recipients:

• Professional Advisors. Accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors in all of the countries in which we operate.
• Service Providers. Companies that provide products and services to us such as recruitment, onboarding, payroll, pension scheme, benefits providers; human resources services, performance management, training, expense management, IT systems suppliers and support; third parties assisting with equity compensation programs, credit card companies, medical or health practitioners, trade bodies and associations, and other service providers.
• Affiliates. We may disclose your Personal Information with our affiliated companies for purposes set forth in this Notice.
• Advertising and Analytics Providers. As described in Section 2 (above), when you access the TRANZACT website or career portal, we or our third-party partners may collect and “sell” or “share” your Personal Information for marketing or analytics purposes to business partners and third parties, such as data analytics providers, advertising technology vendors, third-party advertising networks, and social media networks.

In certain circumstances, we may disclose each category of your Personal Information to:

• Competent Governmental, Regulatory, and Public Authorities. We may disclose your Personal Information to government and law enforcement authorities, in each case to comply with legal or regulatory obligations or requests.
• Relevant Third Parties as Part of a Corporate Transaction. In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your Personal Information to certain third parties, such as the acquiring entity and its advisers.
• Other Third Parties. Additionally, we will disclose your Personal Information as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your Personal Information for other reasons that we will describe at the time of information collection or prior to disclosing your information.

All personnel within TRANZACT will generally have access to your business contact information such as name, position, telephone number, postal address, email address and photograph. We may provide a third party, such as a potential supplier or customer with a means of contacting you in the normal course of business by providing your business contact details (phone, email), title, or other relevant information.

6. California Privacy Rights

If you are an employee, job applicant, or job candidate residing in California, you are entitled to the following privacy rights, subject to applicable exceptions:

• Request to Know. California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of Personal Information that we have collected, used, disclosed and sold about them and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their Personal Information, including the:
  • categories of Personal Information collected;
  • categories of sources of Personal Information;
  • business and/or commercial purposes for collecting and selling Personal Information;
  • categories of third parties with whom we have shared Personal Information;
  • categories of Personal Information that we have sold in the preceding 12 months, and for each category identified, the categories of third parties to which we sold that particular category of information; and
  • categories of Personal Information disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information.

California residents may make a Request to Know up to twice every 12 months. We will respond to verifiable requests received from California residents as required by law.

• Request to Correct. California residents have the right to request that we correct inaccurate Personal Information that we maintain.
• Request to Delete. California residents have the right to request deletion of their Personal Information that we have collected about them and to have such Personal Information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.
• Do Not Sell or Share My Personal Information. TRANZACT may “sell” or “share” certain Personal Information that we collect when you access our website or career portal. As such, California residents have the right to opt-out of the sale or sharing of this Personal Information.

Requests to Know, Requests to Delete, and Requests to Correct may be submitted:

• By contacting us at 877-680-4487 (toll free)
• By submitting a Consumer Request through this link

Please click on the Your Privacy Choices link located in the footer of the home page at www.tranzact.net to opt out of the sale or sharing of your Personal Information.

If you enable a browser-based opt-out preference signal, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of Personal Information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you may need to enable the signal on each browser or profile.

For Requests to Know, Requests to Delete, and Requests to Correct, we may request certain information to verify your identity before we can respond to your privacy rights request. We will acknowledge receipt of your Consumer Request, verify it using processes required by law, then process and respond to your request as required by law. To verify such requests, we may ask you to provide the following information:

• For a Request to Know categories of personal information which we collect, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you against information in our systems which are considered reasonably reliable for the purposes of verifying a consumer’s identity.
• For a Request to Know specific pieces of personal information or for Requests to Delete, we will verify your identity to a high degree of certainty by matching at least three pieces of personal information provided by you to personal information maintained in our systems and also by obtaining a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request.

We will never require you to verify your identity to process your request to opt-out of the sale or sharing of your Personal Information.

You may authorize someone to make a privacy rights request on your behalf (an “authorized agent”). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.

The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

To request information we may collect about you as a consumer, please follow the instructions provided in our Privacy Notice.

7. Security

TRANZACT will use reasonable organizational, technical and administrative measures to protect Personal Information consistent with applicable privacy and data security laws and regulations, including requiring service providers to use appropriate measures to protect the confidentiality and security of Personal Information.

8. Employee Obligations

Please keep Personal Information up to date and inform us of any significant changes to Personal Information. You agree to inform your dependents whose Personal Information you provide to us about the content of this Notice and to explain the use (including transfer and disclosure) of that Personal Information by us as set out in this Notice.

9. Changes to the Policy

We may modify or update this Notice from time to time.

If we change this Notice, we will notify you of the changes. Where changes to this Notice will have a material impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing) and obtain your consent where required under applicable law.

10. Human Resources and Privacy Officer Contact

For questions or comments about this Notice, please contact Human Resources at hr_communications@tranzact.net or email privacy@tranzact.net.

11. Consumer Requests Received in 2024.

In calendar year 2024, we received and responded to consumer requests under the CCPA as set forth in the table below:

*This includes requests that were denied because we were unable to verify the identity of the request.