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Workforce and Applicant Privacy Notice

California Workforce and Applicant Privacy Notice

Effective Date: 1/29/26

This Privacy Notice for California Employees (the “Notice”) applies solely to all job applicants, employees, owners, directors, officers, and contractors (collectively referred to in this Notice as “workforce”) who reside in the State of California (“you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

We are committed to protecting the privacy and security of the information we collect and to being transparent about the purposes for which we use your information. This Notice sets forth our policies and practices for handling the information we collect and use in the workforce context.

I. Categories of Personal Information We Collect

When a person applies to join our team or over the course of a person’s employment or engagement, we may collect the following categories of personal information. We collect and use this information only as permitted or required by, and in compliance with, law.

  • Contact Information, including name, alias and other names, email address, telephone or mobile phone number, address, Social Security Number, driver’s license number or state ID card number, passport number, and other unique personal identifiers associated with you or other beneficiaries such as your spouse or child;
  • Sign-In and Device Information, including username and password, account name or number, and other online or device identifiers, Internet or other electronic network activity information such as browsing and search history and information regarding interactions with websites and applications, our systems, and networks;
  • Educational, Professional, and Employment-Related Information, including employment, engagement, work and education history, professional licenses, marital or domestic partner status, date of birth, age, gender, classifications protected under state or federal Equal Employment Opportunity laws (such as race or national origin), medical condition or information, and health insurance information and policy number;
  • Geolocation data, including badge access and telematics data
  • Biometric information, including imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, or voice recordings and keystroke patterns or rhythms, gait patterns or rhythms, and other characteristics that can be used to establish identity; and
  • Financial Information, including bank account, benefit accounts, billing address, and information about your income and account balances.

II. Purposes for Which Personal Information Is Used 

We process your personal information for the following business purposes:

  • Determining your eligibility for a position with the company, including processing your application, assessing your fit with us or for a specific role, conducting interviews, carrying out background and reference checks in accordance with law, and keeping records related to our hiring and engagement processes;
  • Managing compensation, benefits, and business-related expenses, including payroll processing, invoice payment, managing salaries and expenses, managing corporate credit cards and expense reimbursements, as well as administering equity, compensation, bonus, and insurance programs;
  • Managing professional development, performance, and conduct, including responding to complaints of misconduct, managing conflicts of interest, conducting performance appraisals, supporting career development, and managing whistleblower programs;
  • Protecting the company against illegal activity and other misconduct, including by detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Undertaking activities to verify and maintain the quality, safety, and performance of our products and services, including product and service testing, research, and development;
  • Complying with our legal obligations, including those related to tax and anti-discrimination laws; and
  • Other routine business purposes.

III. Contact Information & Updates 

We may update this Notice from time to time, in which case the revised Notice will be posted to our intranet or provided to you in writing, by email, or mail. If you have any questions or comments about this Notice and the ways in which Azul collects and uses your information as described above, please do not hesitate to contact us at: [email protected]

UK/EU Privacy Notice for UK/EU Employees, Workers, and Contractors 

Effective Date: 1/29/26
Data Controller: Azul Systems, Inc., 385 Moffett Park Dr., Suite 115, Sunnyvale, CA 94089

1. Purpose of this Notice

Azul Systems, Inc. is committed to protecting the privacy and security of your personal information. This notice describes how we collect and use personal information during and after your working relationship with us, in accordance with UK data protection legislation (including the General Data Protection Regulation (UK GDPR) and Data Protection Act 2018) and Portuguese data protection legislation (which includes EU GDPR and Law No. 58/2019 (Lei de Execução do RGPD)).

2. Data We Collect

We may collect, store, and use the following categories of personal information:

  • Identification information, such as first name, middle name(s), last name, contact details (address, phone, email), date of birth, nationality
  • Employment information, such as your job title, employment history, qualifications, office location, and appraisal and performance reviews
  • Financial information, such as your bank details for payroll purposes, tax information, National Insurance number
  • Health information, such as any medical records, sick notes, emergency contact details or other health related information you provide including, where appropriate, details of your GP and allergies
  • Recruitment information, as provided or recorded during our recruitment process including CVs, references, etc.
  • Right to work check information, such as passport information, driving licence
  • Shirt size
  • Hobbies
  • Social links

3. How We Use Your Data (Legal Basis)

We will only use your personal information when the law allows us to, primarily:

  • Performance of Contract: To fulfill our obligations in your employment/service contract.
  • Legal Obligation: To comply with tax, health & safety, and employment laws.
  • Legitimate Interests: For business management, planning, and security, provided your interests do not override ours.

4. Data Sharing

We may share your data with third-party service providers (e.g., payroll, IT services, benefits providers) that assist in managing our business, provided they have agreed to process your data securely and lawfully.

5. International Data Transfers (U.S. Access)

As a U.S. company, we may transfer your personal data to the United States. We ensure this data is protected by implementing appropriate safeguards, such as Approved Standard Contractual Clauses (SCCs) or the UK Addendum in instances needed to comply with UK GDPR for transfers.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements. Employee records are typically retained for the duration of employment and for a set period afterward (e.g., 6–10 years for tax purposes).

7. Your Rights

Under UK/EU GDPR, you have the following rights regarding your personal data:

  • Access: Request a copy of the data we hold about you.
  • Rectification: Request correction of inaccurate or incomplete data.
  • Erasure (Right to be Forgotten): Request deletion of data when no longer necessary.
  • Restriction: Restrict processing in certain circumstances.
  • Data Portability: Request transfer of your data to another party.
  • Object: Object to processing based on legitimate interests.
  • Complaints: Lodge a complaint with the Information Commissioner’s Office (ICO) in the UK or your local supervisory authority in the EU.

For more information about your data rights and privacy or data protection in general, UK employees can visit the Information Commissioner’s Office website: https://ico.org.uk; Portuguese employees can visit Comissão Nacional de Proteção de Dados’s website: https://www.cnpd.pt/

8. Contact Us

For questions or to exercise your rights, please contact our the Azul HR Department at: [email protected] or 385 Moffett Park Dr., Suite 115, Sunnyvale, CA 94089