Global Data Privacy Policy

The TEAM Companies, LLC., (“TTC”) takes your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

TTC collects and processes personal data only as instructed or permitted by our clients (your common law employer) or you. This policy explains our practices with regard to the personal data we receive from our clients as a service provider/processor under the California Consumer Privacy Act of 2018 (“CCPA”), the Canadian Privacy Personal Information Protection and Electronic Documents Act (PIPEDA) of 1996/2019, and the Global Data Protection Regulation of 2016 (“GDPR”) which applies across the European Union (including in the United Kingdom).

TTC processes a variety of personal data regarding current, future and former employees of our clients (the common law employer), in order to provide for compensation and benefits. TTC maintains appropriate security measures/controls to protect your information.

1:Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our	The TEAM Companies, LLC (TTC), Talent Payment Services, ULC (TPS) and any other subsidiary or company of TTC or TPS.
Our Representative	Eileen M. McNamara General Counsel/SVP, HR The TEAM Companies, LLC 901 West Alameda Ave, Burbank, CA 91506 Located in the United States +1 (833)-4 TTC PRIV [email protected]
Our data protection officers	Eileen M. McNamara and Mujeebur Rahmansaher The TEAM Companies 901 West Alameda Ave, Burbank, CA 91506 Located in the United States +1 (833)-4 TTC PRIV [email protected]
Personal information	Any information relating to an identified or identifiable individual.
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data. Data concerning health, sex life or sexual orientation.

2. Personal Information We Collect About You.We may collect and use the following personal information for business purposes only, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)	TTC collects, real name, postal address, unique personal identifier, email address, account name, phone number, social security number, or other similar identifiers for business purposes only.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	TTC collects name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information for business purposes only.
Characteristics of protected classifications under California or federal law.	TTC collects information on gender, race, ethnicity, age, and similar data for business purposes only.
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	TTC is a data processor/service provider and does not track personal information for use in commercial sale.
Biometric information	TTC does not collect biometric information.
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)	TTC collects the electronic network activity of its employees and activities related to its online TTCONLINE software. TTC does not track personnel information as it relates to a specific individual from its internet or website.
Geolocation data	TTC does not track individual geolocation data.
Audio, electronic, visual, thermal, olfactory, or similar information	TTC does not track individual audio, electronic, visual, thermal, olfactory or any other similar information without express written consent.
Professional or employment-related information	TTC collects professional and employment related information for its service provider business purposes.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)	TTC does not collect this information.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	TTC is a service provider/processor and does not collect such information.

This personal information is required to provide services to you and/or our clients, your common law employer. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you or our client.

3. How Your Personal Information is Collected. We collect most of this personal information directly from you or your common law employer—in person, by telephone, text or email, and/or via our TTC Online website and apps. However, we may also collect information:

From publicly accessible sources (e.g., public records);
Directly from a third party (e.g., common law employer or credit reporting agencies);
From a third party with your consent (e.g., your common law employer or your bank);
From cookies on our website; and
Via our IT systems, including:
Door entry systems and reception logs;
Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

4. How and Why We Use Your Personal Information. Under various data protection laws, we can only use your personal information if we have a proper business reason for doing so, e.g., process your payroll, or obtain a talent agreement or similar business purpose; and

To comply with our legal and regulatory obligations;
For the performance of our contract with our clients;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide services to you and/or our clients	For the performance of our contracts to execute at our client’s specific request.
To prevent and detect fraud against you, our clients or The TTC Companies	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us, for you and our clients.
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations.
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies, or unions	To comply with our legal and regulatory obligations.
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service.
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service at the best price.
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations.
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, service and efficiencies or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service at the best price.
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us, our clients and for you. To comply with our legal and regulatory obligations.
Updating and enhancing customer records	For the performance of our contracts. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing orders and new services.
Statutory returns	To comply with our legal and regulatory obligations.
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best services.
Marketing our services and those of selected third parties to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients.
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e. to ensure our clients are likely to be able to pay for our services.
External audits and quality checks, e.g. for SOC, union trust funds or state, federal or local audits of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations.

The above table does not apply to special category personal information, which we will only process with your explicit consent, or as required under our service provider contracts.

Promotional Communications. TTC does not share any California consumer personal data with third parties for marketing purposes without consent. The TEAM Companies does use personal information to promote its services. However, we may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside The TEAM Companies’ group for marketing purposes.

TTC does not track its customers or clients over time and across third party websites to provide targeted advertising and therefore does not respond to DO NOT TRACK (DNT) signals.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us at [email protected] for marketing opt-out;
Using the “unsubscribe” link in emails or “STOP” number in texts; or

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

5. Who We Share Your Personal Information With. We routinely share or exchange personal information with:

Our affiliates, including subsidiaries of The TEAM Companies;
Our clients, such as your common law employer and delivery companies who use us to help deliver services to you;
Other third parties we use to help us run our business, such as marketing agencies or website hosts;
Third parties including social media sites you choose to link your account to or third-party payment providers such as your bank;
Credit reporting agencies;
Our insurers and brokers;
Our banks;

We are a service provider/processor. As such, our clients depend on our ability to keep your information secure and private. Our clients only allow us to handle your personal information if they are satisfied that we take appropriate measures to protect your personal information. We also impose contractual obligations on our clients to ensure they are complying with appropriate laws and regulations to provide us information so we may service them and you. We may also share personal information with external auditors, e.g. in relation to SOC, union health/welfare and pension trust funds and the various governmental audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

6. Personal Information Disclosed for a Business Purpose. In the preceding 12 months, we may have disclosed or received for a business purpose to or by one or more third parties (i.e., common law employer) the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
Characteristics of protected classifications under California or federal law;
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement); and
Professional or employment-related information;

7. Where Your Personal Information is Held. Information may be held at our offices in Los Angeles, California and those of our group companies in the United States and Canada, third party agencies, other service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

The TEAM Companies is located outside the European Economic Area. All of these third parties are based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

8. How Long Your Personal Information Will Be Kept. We will keep your personal information as required by law, and while our client has an account with us or while we are providing services to you and/or our clients. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

9. Transferring Your Personal Information Out of the EEA. TTC is located outside the EU. All business transactions occur outside the EU; however, it may be that from time to time, TTC will perform services involving a resident of the EU that may be under the protection of the GDPR. In such case, to deliver services to our clients or to you, it is necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

The TEAM Companies has offices located in Los Angeles, CA; New York, NY; Detroit, MI; Portland, OR and Toronto, Canada. TTC does not have offices within the European Union.
With our other clients whom are all located outside the EEA;
If you are based outside the EEA; or
Where there is an international dimension to the services we are providing.

These transfers are subject to special rules under European and UK data protection law.

The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: Canada.

These other non-EEA countries, such as the United States do not have the same data protection laws as the United Kingdom and EEA. When dealing with a resident of the EU whom may be subject to the protections of the GDPR, we will ensure the transfer complies with data protection law and all personal information will be secure. To obtain a copy of our standard data protection contract clauses write to [email protected]

If you would like further information, please contact our Data Protection Officer (see “How To Contact Us” below).

10. Your Rights Under the GDPR.

Right to Access	The right to be provided with a copy of your personal information (the right of access).
Right to Rectification	The right to require us to correct any mistakes in your personal information.
Right to be Forgotten	The right to require us to delete your personal information—in certain situations.
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data.
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
Right to Object	The right to object: ¾ at any time to your personal information being processed for direct marketing (including profiling); ¾ in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

If you are located within the European Economic Area (EEA) or Switzerland and wish to file a complaint as a third-party beneficiary, please contact the Data Protection Officer listed above or with the relevant authorities or the courts.

11. Your Rights Under the CCPA, and PIPEDA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), Personal Information Protection and Electronic Documents Act (PIPEDA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: · The categories of personal information we have collected about you; · The categories of sources from which the personal information is collected; · Our business or commercial purpose for collecting or selling personal information; · The categories of third parties with whom we share personal information, if any; and · The specific pieces of personal information we have collected about you. Please note that we are not required to: · Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; · Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or · Provide the personal information to you more than twice in a 12-month period.
Personal Information Used for a Business Purpose	In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know: · The categories of personal information about you that we used for business purpose and the categories of third parties to whom the personal information was shared; and · The categories of personal information that we disclosed about you for a business purpose. The TEAM Companies DOES NOT SELL any personal information.
Right to Deletion (CCPA) Right to Accuracy (PIPEDA)	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: · Delete your personal information from our records; and · Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: · Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; · Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; · Debug to identify and repair errors that impair existing intended functionality; · Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; · Comply with the California Electronic Communications Privacy Act; · Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; · Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; · Comply with an existing legal obligation; or · Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. · Right to correct your information on file.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the these laws. This means we cannot, among other things: · Deny goods or services to you; · Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; · Provide a different level or quality of goods or services to you; or · Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

12. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those at TTC processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems and are SOC compliant, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. TTC will work with our clients on any personal data request, as necessary.

13. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

Complete a data subject request form available on our website at https://privacy.theteamcompanies.com/privacy-policy/datarequestform/
Call us, toll-free, at +1 (833)-4 TTC PRIV; or
Email/write to us at [email protected] or 901 West Alameda Ave, Suite 100, Burbank, CA 91506.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by website/email/phone/in writing, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and last four digits of social security or other identifier);
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

14. How to File a PIPEDA or GDPR Complaint. We hope that our Representative or Data Protection Officer can resolve any query or concern you raise about our use of your information. You may use the attached form to make a query or raise a concern: Click HERE

The Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) and the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the Canada and the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. The supervisory authority in the country where you reside is the entity who may be contacted depending on where you live. Please contact our Representative to find out how to reach your supervisory authority where you live.

15. Privacy of Children — Protecting children’s privacy is especially important to us. The Company recognizes that parents, guardians, or other adults may purchase our services for use by minors. It is our policy to comply with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws.

16. Third Party Sites – The TEAM Companies’ website contains links to other sites operated by other companies or organizations. The TEAM Companies does not share your personal information with those websites and is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies. Some of these third-party sites may be co-branded with or include a The TEAM Companies logo or links to any or all of the TEAM companies, even though they are not operated or maintained by The TEAM Companies. Although we choose our business partners carefully, The TEAM Companies is not responsible for the privacy practices of websites operated by third parties that are linked to our website. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you. The TEAM Companies does not endorse or control third party websites (other than The TEAM Companies websites), and users assume all risks of using third party websites including, without limitation, all responsibility for the policies and procedures of such other websites.

17. Cookies and Tracking – A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the site uses to track the pages you’ve visited, but the only personal information a cookie can contain is information you supply yourself. A cookie can’t read data off your hard disk or read cookie files created by other sites. Some parts of The TEAM Companies’ website use cookies to track user traffic patterns. We do this in order to determine the usefulness of our website information to our users and to see how effective our navigational structure is in helping users reach that information. If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of TTC’s website if you do so. In particular, you may be required to accept cookies in order to complete certain actions on our website. You do not need to have cookies turned on, however, to use or navigate through many parts of our website, except access to certain of The TEAM Companies’ web pages that require a login and password.

18. Changes to This Privacy Notice. This privacy notice was published on January 1, 2020 and last updated on December 31, 2019.

We may change this privacy notice from time to time–when we do, we will post it online via our website.

19. How to Contact Us. Please contact us and/or our Representative/Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details	Eileen M. McNamara
contact address	The TEAM Companies 901 West Alameda Avenue, Suite 100, Burbank, CA 91506
contact email address	[email protected]
contact telephone number	+1 (833)-4 TTC PRIV

20. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).1

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