Privacy Notice to California Job Applicants

This notice (“Notice”) describes how Jackson Hewitt Inc. and its subsidiaries and affiliates (the “Company”) collects, uses, and discloses personal information of its current and former employees (“Employees”) and their emergency contacts and beneficiaries for a variety of employment-related purposes before, during, and after employment with the Company. The Company collects personal information of Employees and their emergency contacts and beneficiaries in connection with its human resources activities.

The Company is committed to ensuring that your personal information will be handled in accordance with all applicable data privacy laws. Employees, emergency contacts, and beneficiaries with disabilities may access this notice in an alternative format by contacting JTAX-HumanResources@jtax.com.

This Notice covers our practices only in the context of your relationship with the Company as an Employee. If you visit our website or are a consumer of our services, the personal information we collect in that context is subject to our consumer Privacy Notice.

If you have any questions or concerns regarding this Privacy Notice, the Company’s Privacy Policy, or the collection of your personal information, please contact: JTAX-HumanResources@jtax.com.

WHAT CATEGORIES OF EMPLOYEE INFORMATION DO WE COLLECT AND HOW DO WE USE THIS INFORMATION?

We collect the following categories of personal information for the purposes described below:

• New Hire Onboarding Information, such as name and contact information; job title and duties; contact information; Social Security Number, driver’s license number, passport and other government identification numbers; birth date; immigration and work authorization status; employee photos for identification badges and system profiles; emergency contact information; withholding tax information; voluntary self-disclosure information regarding minority, veteran, and disability status; and dependent and beneficiary information. The Company collects this information to onboard new employees and to comply with applicable laws.

• Pay Information, such as pay rate, payroll deduction information, banking information for direct deposit, credit card information and other expense reimbursement information. The Company collects this information to pay its employees and comply with applicable laws.

• Benefits Enrollment and Administration Information, such as benefit selection information; Social Security Numbers or other government identification numbers; date of birth; beneficiary information; leave of absence information; and other information necessary to administer benefits programs and process benefits claims. The Company collects this information to enroll and administer Company benefits for Employees and their beneficiaries.

• Performance Management Information, such as employment status (full-time or part-time, regular or temporary); work schedule; job assignments; hours worked; business travel information; expatriate and secondment assignments; accomplishments and awards; training and development information; performance evaluation information; discipline and counselling information; and employment termination information. The Company collects this information to manage our employment relationships with Employees.

• Equality and Diversity Information, such as minority, veteran, and disability status. The Company collects this information through voluntary self-disclosure and other means to implement the Company’s diversity programs and to comply with applicable laws.

• Health and Safety Information, such as health condition, job restrictions, workplace accident and illness information, and health insurance information. The Company collects this information to maintain a safe workplace, assess your working capacity, administer health and Workers’ Compensation insurance programs, and comply with applicable laws.

• Electronic Communications Information, such as email, computer, internet, telephone, and mobile device usage; IP address; log-in information; and location information. The Company collects this information to protect Company, customer, and employee property, equipment, and confidential information; monitor employee performance; and enforce the Company’s electronic communications acceptable use policies.

• Legal and Contractual Information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to legal claims. The Company collects this information to comply with legal and contractual requirements and to establish, exercise, and defend legal and contractual rights and claims.

WHAT CATEGORIES OF EMERGENCY CONTACT INFORMATION DO WE COLLECT AND HOW DO WE USE THIS INFORMATION?

We collect the following categories of personal information for the purpose described below:

• Name and contact information; and
• Relationship to Employee.

The Company collects this information to contact the Employee’s designated emergency contact

Person(s) in the event of an emergency.

WHAT CATEGORIES OF BENEFICIARY INFORMATION DO WE COLLECT AND HOW DO WE USE THIS INFORMATION?

We collect the following categories of personal information for the purposes described below:

• Name and contact information;
• Relationship to the Employee;
• Birth date;
• Social Security Number; and
• Information necessary to process benefits claims.

The Company collects this information to enroll and administer benefits with respect to beneficiaries of Employees.

HOW DOES THE COMPANY DISCLOSE PERSONAL INFORMATION?

The Company may disclose personal information to service providers rendering services for the Company or on the Company’s behalf. Common examples of service providers include payroll processors, onboarding vendors, and travel services, as well as service providers who require certain employee information in order to provide services to the Company, such as providers of IT services (including maintenance and hosting of our websites); accounting, auditing, and tax services; and legal and other professional services. 

The Company may also disclose information to providers who offer retirement, health, and other benefit programs, services, or products to which Employees and their dependents or other beneficiaries receive access through their employment.

The Company may disclose personal information where necessary to comply with applicable law, to respond to requests from regulatory authorities (including tax authorities), government agencies, and parties (including legal or other advisors) in legal proceedings, or to enforce our terms of service and policies.

The Company may also share personal information: 

• During emergency situations or where necessary to protect the safety of persons;
• To other entities in the Company’s corporate family, for purposes consistent with this Notice; and
• In the event of a business transfer, merger, sale, or other change in ownership of all or a part of our business operations.

HOW LONG DOES THE COMPANY RETAIN THIS INFORMATION?

The Company will retain Employees’ (and their beneficiaries’ and emergency contacts’) personal information for as long as is necessary to complete the purposes for which it was collected, or as may be required by law. The Company utilizes the following criteria to determine the length of time for which it retains such information:

• The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;

• Whether the Company is required to retain the information type in order to comply with internal company policies, legal obligations, or contractual commitments or to defend against potential legal claims, or is otherwise necessary to investigate theft or other activities potentially against the law or in violation of the Company’s policies and procedures applicable to Employees, to ensure a secure online environment, or to protect health and safety;

• The privacy impact on the consumer of ongoing retention; and

• The manner in which information is maintained and flows through Company systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems infrastructure.

Individual pieces of personal information such as those listed above may exist in different systems that are used for different business or legal purposes. A different maximum retention period may apply to each use case of the information. Certain individual pieces of information may also be stored in combination with other individual pieces of information, and the maximum retention period may be determined by the purpose for which that combined information set is used.

CHANGES TO THIS NOTICE

The Company reserves the right to amend this Notice from time to time and will update the effective date at the top of this Notice when it does so.  The Company will either provide you with a copy of the amended Notice or advise you when and where an amended Notice is available for review.

CALIFORNIA CONSUMER PRIVACY ACT

If you are a California resident, you have certain rights under the California Consumer Privacy Act (“CCPA”). The below supplemental provisions apply to the extent that we collect personal information relating to you that is subject to the CCPA.

Our Practices 

We collect personal information for purposes as set forth above in the section of this Notice entitled “WHAT CATEGORIES OF EMPLOYEE INFORMATION DO WE COLLECT AND HOW DO WE USE THIS INFORMATION?” Additional information about those categories, written to align with categories enumerated in the CCPA, is set forth below. Certain personal information may fall into multiple CCPA categories. These examples of personal information are illustrative and do not represent a complete description of the data elements we process.

Category	Required Information
Identifiers	Name, email address, phone number, contact address, username, social media handle. Source: Directly from you. Purpose of collection and use: All purposes listed above. Retention Considerations: Personal details about you are maintained throughout the life of your employment in order to administer the employment relationship. Such details also appear in a variety of documents that are generated on a regular basis throughout your employment. We also maintain identifying details about you for a period of time following your employment, e.g., if required by law, to fulfill any ongoing duties owed to you such as provision of benefits, or so that we may verify your employment to your other prospective employers.
Personal Information Categories (Cal. Civ. Code § 1798.80(e))	Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 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. Source: Directly from you; generated in the course of your employment. Purpose of collection and use: All purposes listed above. Retention Considerations: Personal details and performance information about you are maintained throughout the life of your employment in order to administer the employment relationship. Such details also appear in a variety of documents that are generated on a regular basis throughout your employment. Medical and health insurance information may be maintained for the length of time required to provide you with benefits, or longer if relevant to your ongoing employment. We also maintain identifying details about you for a period of time following your employment, e.g., so that we may verify your employment to your other prospective employers.
Protected Classification Characteristics	Age (40 years or older), national origin, marital status, gender, veteran or military status Source: Directly from you. Purpose of collection and use: All purposes listed above. Categories of Parties to Whom PI is Disclosed: Benefits Providers, Service Providers, Governmental Agencies where required by law. Retention Considerations: Personal details about you are maintained throughout the life of your employment in order to administer the employment relationship.
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies We do not collect commercial information in the employment relationship.
Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, scans of the hands or face geometry, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data Source: Directly from you when you elect to use biometric information in lieu of other password systems on Company-issued devices and systems. Purpose of collection and use: All purposes listed above. Retention Considerations: Biometric information is typically deleted at regular intervals when the information is no longer necessary for the purposes for which it is collected.
Internet/Network Activity	Device ID, IP address, and information regarding your interaction with internet websites and applications when you use Company-issued devices Source: Automatically generated when you use Company-issued devices and systems. Purpose of collection and use: All purposes listed above. Retention Considerations: Internet or other network activity information is typically deleted at regular intervals when the information is no longer necessary for the purposes for which it is collected. The retention period may be extended, however, if the information is needed to investigate issues related to security, compliance with company policies, or employee conduct.
Geolocation Data	Precise location or movements. Source: May be automatically generated when you use a mobile device to clock in and out of work; may be inferred from video and still images automatically generated by our security systems. Purpose of collection and use: All purposes listed above. Retention Considerations: Geolocation information is typically deleted at regular intervals when the information is no longer necessary for the purposes for which it is collected.
Sensory Data	Sensory Data Audio, electronic, visual, thermal, olfactory, or similar information Source: Call recordings are automatically generated on lines used by our customer service center employees; video and still images are automatically generated by our security systems. Purpose of collection and use: All purposes listed above. Retention Considerations: Call recordings and visual images are typically deleted at regular intervals when the information is no longer necessary for the purposes for which it is collected.
Professional/Employment-related Information	Work history, job performance information Source: Directly from you; generated over the course of your relationship with the Company. Purpose of collection and use: All purposes listed above. Retention Considerations: Recruitment data and professional qualifications and performance information are maintained throughout the life of your employment in order to administer the employment relationship. We also maintain such information for a period of time following your employment, e.g., if required by law, to initiate or respond to legal claims, or so that we may verify your employment to your other prospective employers.
Education Information	Institutions attended, degrees obtained, and courses taken Source: Directly from you. Purpose of collection and use: All purposes listed above. Retention Considerations: Information submitted in connection with your application for employment at the Company may be maintained for the length of your employment, in order to provide us with holistic view if your qualifications for job-related tasks or advancement.
Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes Source: We do not actively create profiles of the preferences or interests of our employees; however, certain of this information may be collected incidentally about you over the course of your employment, either directly from you or from the individuals you interact with at the Company, for instance in performance evaluations. Purpose of collection and use: All purposes listed above. Retention Considerations: The retention period for this type of information will vary depending on the nature of the underlying document in which the inference is recorded.
Sensitive Personal Information	Social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email and text messages; genetic data and biometric information; information collected and analyzed concerning a consumer’s health; or information collected and analyzed concerning a consumer’s sex life or sexual orientation. Source: Directly from you; we do not collect details that would allow us to access your financial accounts, but we may collect payment card information from you if necessary to facilitate payment of work-related expenses such as travel, and financial account information to facilitate payroll or administration of company benefits. Purpose of collection and use: All purposes listed above. Retention Considerations: Personal details about you are maintained throughout the life of your employment in order to administer the employment relationship.

Sale, Sharing, and Disclosure of Personal Information for a Business Purpose

We do not sell or share personal information relating to our Employees, as the terms “sell,” and “share” are defined under the CCPA. Any such personal information may, however, be disclosed to service providers and other third parties as described in the section titled “HOW DOES THE COMPANY DISCLOSE THIS INFORMATION?” above. Certain personal information may also be disclosed, primarily for enrollment or outreach purposes, to benefit providers who offer services to our workforce members. If you elect to enroll in certain benefits, you may provide additional information directly to a provider pursuant to their privacy policy.  

Your Rights under the CCPA 

You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You also have the right to request we correct inaccurate information, and to request in certain circumstances that we delete personal information that we have collected directly from you.

You have the right to opt out of the sale or sharing of personal information related to you. However, as stated above, the Company does not sell or share personal information relating to our workforce members.

You have the right to request, in certain circumstances, that we limit the processing of your sensitive personal information.

You have the right to be free from discrimination based on your exercise of your CCPA rights.

How to Submit a Request 

You may submit a request to exercise your rights under the CCPA through one of two means:

• By emailing us at privacy@jhnet.zendesk.com

• By calling us at (800) 234-1040

Upon receipt of your request, we will contact you (via the email address provided in your request) with instructions on how to verify your identity. The information you submit during the verification process will be matched against our records.

There may be a reason under the law why we cannot or are not required to comply with your request, or why we may comply with it in a more limited way than you anticipated. If so, we will explain that to you in our response.

You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make any of the requests described above on your behalf.