California Employee Privacy Rights

Applicant/Employee CCPA/CPRA Notice

Date: November 1st, 2022

This notice describes the categories of personal information (“PI”) collected by MGA Entertainment, Inc. (“MGA”) and the purposes for which Consumer PI may be used. We are providing this notice to you in accordance with California Civil Code Sec. 1798.100(b). This Privacy Notice applies solely to natural persons residing in California (“Consumers”), and does not apply to individuals living elsewhere, businesses or other corporate entities.

Categories of Personal Information Collected	Purposes Personal Information is Used.
Identifiers and Contact information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, dates of birth, Social Security numbers, driver’s license or state identification numbers, bank account information, dependent and beneficiary information (names, dates of birth, Social Security numbers) and other similar contact information and identifiers.	Collect and process employment applications, including confirming eligibility for employment, background and related checks, and onboarding Processing payroll and employee benefit plan and program administration including enrollment and claims handling Maintaining personnel records and record retention requirements Communicating with employees and/or employees’ emergency contacts and plan beneficiaries Complying with applicable state and federal labor, employment, tax, benefits, workers’ compensation, disability, equal employment opportunity, workplace safety, and related laws Preventing unauthorized access to or use of the MGA’s property, including the MGA’s information systems, electronic devices, network, and data Ensuring employee productivity and adherence to the MGA’s policies Investigating complaints, grievances, and suspected violations of MGA policy
Protected classification information. This category includes characteristics of protected classifications under California or federal law.	Complying with applicable state and federal Equal Employment Opportunity laws Design, implement, and promote the MGA’s diversity and inclusion programs Investigate complaints, grievances, and suspected violations of MGA policy
Internet or other electronic network activity information. This category includes without limitation: all activity on the MGA’s information systems, such as internet browsing history activity, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames and passwords all activity on communications systems including phone calls, call logs, voice mails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an Employee’s use of MGA-issued devices	Investigate complaints, grievances, and suspected violations of MGA policy
Geolocation data. This category includes GPS location data from MGA-issued mobile devices and MGA-owned vehicles.	Improve safety of employees, customers and the public with regard to use of MGA property and equipment Preventing unauthorized access, use, or loss of MGA property Improve efficiency, logistics, and supply chain management/li> Ensuring employee productivity and adherence to the MGA’s policies Investigate complaints, grievances, and suspected violations of MGA policy
Professional and employment-related information. This category includes without limitation: data submitted with employment applications including, employment history, employment recommendations, etc. background check and criminal history; work authorization professional licenses educational degrees fitness for duty data and reports (upon return from a medical leave of absence) performance and disciplinary records salary and bonus data benefit plan enrollment, participation, and claims information leave of absence information including religious and family obligations, physical and mental health data concerning employee and his or her family members	Collect and process employment applications, including confirming eligibility for employment, background and related checks, and onboarding Employee benefit plan and program design and administration, including leave of absence administration Maintaining personnel records and complying with record retention requirements Communicating with employees and/or employees’ emergency contacts and plan beneficiaries Complying with applicable state and federal labor, employment, tax, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws Business management Preventing unauthorized access to or use of the MGA’s property, including the MGA’s information systems, electronic devices, network, and data Ensuring employee productivity and adherence to the MGA’s policies Recruiting Investigating complaints, grievances, and suspected violations of MGA policy
Education information. This category includes education history	Evaluate an individual’s appropriateness for hire, a participation position at the MGA, or promotion to a new position.
Inferences drawn from the PI in the categories above.	Engaging in human capital analytics, including but not limited to, identifying certain correlations about individuals and success on their jobs, analyzing data to improve retention, and analyzing employee preferences to inform HR Policies, Programs and Procedures.

To carry out the purposes outlined above, MGA may share information with third parties, such as background check vendors, third-party human resources and information technology vendors, outside legal counsel, and state or federal governmental agencies. MGA may add to the categories of PI it collects and the purposes it uses PI. In that case, MGA will inform you.

RIGHT TO ACCESS

You have the right to access PI which we may collect or retain about you. If requested, we shall provide you with a copy of your PI which we collect as permitted by the CCPA/CPRA. You also have the right to receive your PI in a structured and commonly used format so that it can be transferred to another entity (“data portability”).

RIGHT TO KNOW

You have the right to request that we disclose the following about your PI, as defined by the CCPA/CPRA:

The specific PI we may collect;
The categories of PI we may collect;
The categories of sources from which we may collect your PI;
The business purpose(s) for collecting or sharing your PI;
The categories of PI we may disclose for business purposes; and
The categories of third parties to whom we may share your PI.
The specific pieces of personal information we collected about you.

RIGHT TO OPT-OUT / DO NOT SELL MY PERSONAL INFORMATION

MGA does not sell PI within the meaning of the CCPA/CPRA.

RIGHT TO DELETION

In certain circumstances, you have the right to request the erasure of your PI. Upon verifying the validity of a deletion request, we will delete your PI from our records, and instruct any service providers or third parties to delete your information, when applicable.

RIGHT TO CORRECT/RIGHT TO RECTIFICATION

In certain circumstances, you have the right to request correction of any inaccurate PI. Upon verifying the validity of a verifiable consumer correction request, we will use commercially reasonable efforts to correct your PI as directed, taking into account the nature of the PI and the purposes of maintaining your PI.

EXERCISING YOUR RIGHTS

However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may:

Charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or
Refuse to act on the request and notify you of the reason for refusing the request.

VERIFYING CONSUMER REQUESTS

When you make a request to us, we will require your name, e-mail, phone number, and address. We will attempt to match our records based on that information. Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm their identity. If we are unable to verify the identity of the person making the request after requesting additional information, and that information is not provided, we will be unable to comply with the request.

DISCLOSURE OF PERSONAL INFORMATION

MGA shall use a reasonable standard of care to store and protect from disclosure any PI collected using the principles of least-privileged access and by limiting access to PI to individuals with a ‘need to know’.

PI will be retained by us as set out in the MGA’s policies. The Firm may share your PI under the following circumstances:

In the event that we sell or purchase any business or assets, or if all or substantially all of the MGA’s assets are acquired by a third party, in which we may disclose your PI to the prospective seller or buyer of such business or assets, solely for the purpose of permitting the due diligence required to decide whether to proceed with a transaction;
If reasonably necessary to protect the vital interests of a person or MGA;
If we are subject to disclose or share your information in order to comply with any legal or regulatory obligation; or
To enforce or apply our terms and conditions or to establish, exercise or defend the rights of MGA, MGA Personnel, clients, customers or others.

Our third party service providers are subject to security and confidentiality obligations and are only permitted to process information for a specified, legitimate business purpose and in accordance with our instructions.

We only share your information with the following third parties:

Affiliated firms and advisors as necessary to carry out the purposes for which the information was supplied or collected; and/or
Service providers that assist with providing services to you, including data hosting providers, recruitment agencies, IT and software providers, marketing database providers, accountants and HR system providers, including benefits and payroll providers.

DATA STORAGE AND SECURITY

MGA shall use a reasonable standard of care to store and protect your PI. We use appropriate physical, technical and organizational security measures and procedures to protect PI from unauthorized use, loss, alteration, destruction or modification. MGA shall retain your PI until the initial purpose for collecting and retaining such data has been satisfied. If you subsequently agree to a new or additional purpose, your PI may be retained for that.

CONTACT

If you have questions about the MGA’s privacy policies and procedures, rights you may have concerning your personal information, you may call the Human Resources at 818-894-2525 or email privacy@mgae.com

Data rights requests by employees, job applicants, employee benefits plan beneficiaries and B2B partners of MGA may be submitted via this link.