THE VOLEON GROUP

APPLICANT PRIVACY NOTICE - PRIVACY RIGHTS AND DISCLOSURES

Last Updated: May 9, 2025

This Job Applicant Privacy Notice (“Privacy Notice” or “Notice”) explains how Voleon Capital Management LP, d/b/a The Voleon Group, and its affiliates, Locally Compact, Inc. and Typical Set, LLC (collectively “Voleon,” or “we,” or “us,” or “our”) collects personal information from job applicants (“personal information”), including job applicants who are California residents, to the extent such personal information is collected and used by us solely within the context of their status as a job applicant. This Notice supplements other privacy notices you may receive in connection with your relationship with us.

Notice at Collection: Personal Information We Collect

We collect the following categories of personal information about job applicants:

  • Personal identifiers: name, address, email address, government-issued identification documents
  • Protected class information: race, ethnicity, gender, gender identification, veteran status
  • Internet or other electronic activity information: your device and browser type, your browsing and search history on our website, and information regarding your interaction with our website and our advertisements
  • Professional information: information included in your resume, including records of your work and education history (including internal and external work history and references)
  • Educational information: education history; trade school records; certificates obtained
  • Sensitive personal information: Social Security number, driver's license information or passport information; race, ethnicity and other diversity data

We have collected the above categories of personal information of applicants during the 12 month period prior to the date of this Notice.

Notice at Collection: Purposes for Collection of Personal Information

We use personal information of applicants to evaluate your application for employment, to compare your qualifications with other applicants, to conduct job interviews, and to comply with applicable law.

Notice at Collection: Categories of Personal Information We Sell or Share

We do not sell or share for cross-context behavioral advertising personal information of applicants.

Notice at Collection: Retention Periods

We retain the categories of personal information of applicants for the length of time necessary to evaluate applicants, comply with legal obligations and to protect our legal rights.

Sources From Which We Collect Personal Information

We collect personal information of applicants from the following sources: applicants, recruiters, background check providers, recruiting agencies, any references or professional contacts that may provide references or other information about applicants, our employees or contractors that may interview or otherwise evaluate applicants, and from publicly-available sources.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose sensitive personal information of applicants to infer characteristics about applicants or for any purposes other than to identify and evaluate applicants, comply with applicable laws, or operate our business.

Disclosure of Personal Information For Business Purposes in the Past 12 Months

The following chart describes the categories of personal information of applicants that we disclosed to third parties for a necessary business purpose in the 12-month period prior to the date of this Notice:

Categories of Personal Information of Applicants Categories of Third Parties to Which We Disclosed Personal Information of Applicants for a Business Purpose
Personal identifiers: name, address, email address Service providers that assist in providing human resource functions; that facilitate scheduling and email communications; that assist with recruitment activities; that assess and evaluate candidates; that assist the Company with services necessary to operate the business
Protected class information: race, ethnicity, gender, gender identification, veteran status Service providers that assist in providing human resource functions; that assist with recruitment activities; that assist the Company with services necessary to operate the business
Internet or other electronic network activity information: your device and browser type, your browsing and search history on our website, information regarding your interaction with our website and our advertisements, your interactions with our emails. Service providers that provide security services and cloud-based data storage, host our websites and assist with other IT-related functions; that assist with recruitment activities; that assist the Company with services necessary to operate the business
Professional information: records of your work and education history (including internal and external work history and references) Service providers that assist with recruitment activities; that assist in providing human resource functions; that assess and evaluate candidates; that assist the Company with services necessary to operate the business
Educational information: Education history; trade school records; certificates obtained Service providers that assist with recruitment activities; that assist in providing human resource functions; that assess and evaluate candidates; that assist the Company with services necessary to operate the business

Business Purposes for Such Disclosures

We disclosed the aforementioned categories of personal information of applicants to the categories of third parties identified above for the following purposes: to provide human resource functions; facilitate scheduling and email communications; assess and evaluate applicants; provide security services and cloud-based data storage; assist with other IT-related functions; provide analytics; host or facilitate teleconferencing or video conferencing; prevent fraud and other illegal activities; to obtain professional advice about legal matters; and to provide other services necessary to operate our business.

Additional Information About How We May Disclose Personal Information

We may also share personal information of applicants as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share personal information of applicants with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer personal information of applicants to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

Rights Related to Personal Information Held by Us

Your Right To Know About Personal Information We Collect

You can ask us for the following information with respect to the personal information of applicants that we have collected about you since January 1, 2022:

  • Specific pieces of personal information we have collected about you;
  • Categories of personal information we have collected about you;• Categories of sources from which such personal information was collected;
  • Categories of personal information that the business sold or disclosed for a business purpose about you;
  • Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • The business or commercial purpose for collecting your personal information.

Your Right To Request Deletion of Personal Information We Have Collected From You

Upon your request and subject to any applicable legal exceptions, we will delete personal information we have collected about you unless doing so would cause us to violate any applicable legal obligations.

Your Right to Request to Correct Personal Information We Hold About You

You have the right to request that we correct personal information regarding you as an applicant that we hold that you believe is not accurate. We will take steps to determine the accuracy of the personal information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal information regarding you as an applicant that you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct in order to assist us in evaluating the request.

Opt-out Preference Signals

An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer's choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.

We recognize the Global Privacy Control signal and do so at the browser level and it does not apply to personal information we may collect offline or that we may associate only with your name or email address. This means that if the signal is sent through a specific browser, we will recognize it for that browser only, and only with respect to the identifiers for that browser. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).

Our Commitment to Honoring Your Rights

No applicant will be subject to retaliation for exercising any of their rights set forth in this Privacy Notice.

Exercising Your Rights and How We Will Respond

To exercise your rights to know, delete, or correct personal information of an applicant, or to ask a question about your data subject rights, contact us at 510-704-9870 or click here privacy@voleon.com. For such requests, will first acknowledge receipt of your request within ten (10) business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.

In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.

Verification of Identity

If you submit a request, we will ask you for two (2) pieces of personal information and attempt to match those to information that we maintain about you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.

Authorized Agents

You may designate an agent to submit requests on your behalf. The agent can be a natural person or an entity.

If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process. Specifically, if the agent submits requests to access, know or delete your personal information as an applicant, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with applicable law pertaining to powers of attorney.

Personal Information of Minors

We do not advertise our positions to minors under 16 and do not knowingly collect or sell the personal information of minors, including minors under 16 years of age.

Third Party Websites

Our Services may contain links to third-party websites. This Privacy Notice does not govern how those third parties collect or use personal information and we do not endorse or have control over their practices. The privacy policies and terms of use for those third parties' websites/apps govern those companies' privacy practices. We are not responsible for the content or privacy practices of any third-party websites or platforms.

How We Keep Your Personal Information Secure

We maintain reasonable security measures appropriate to the nature of the personal information of applicants that we collect, use, retain, transfer or otherwise process. Those measures include administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

Changes to This Notice

We may update this notice from time to time. When we make substantive changes, we will update date of this Notice. In certain cases and if the changes are material, you will be notified via email or a notice on our website.

Accessibility

We work to make our communications accessible to people with disabilities. To submit accessibility-related requests or report barriers, please contact us at hr@voleon.com.

Contact Us

If there are any questions regarding this Privacy Notice or to request a copy of this Privacy Notice in another format you may contact us at privacy@voleon.com or 510-704-9870.

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