California Consumer Privacy Act HR Applicant Supplement for California Residents

Billhighway (dba “Billhighway,” “greekbill,” and “Impexium”) respects your privacy.

This Privacy Policy (“Policy”) applies to the Processing of Personal Information by Billhighway collected in connection with your employment application at Billhighway and our recruitment process. This Policy applies to all individuals who apply to work for or provide services to us (“You” or “Individuals“). Please note that if you apply for a job outside of the country in which you reside, your Personal Information will be collected and processed in accordance with applicable laws.

This Policy does not cover the collection and use of your Personal Information by Billhighway in the context of other Billhighway programs, by third parties on Billhighway-branded websites or any other information or communications that may reference Billhighway outside of your recruitment process.

The Policy describes the types of Personal Information we collect in connection with the recruitment process and, if successful, the pre-employment/onboarding process, the purposes for which we collect that Personal Information, the other parties with whom we may share it and the measures we take to protect the security of such data. It also tells You about your rights and choices with respect to your Personal Information, and how You can reach us to update your contact information or ask questions You may have about our privacy practices.

Personal Information We May Collect

We collect the following Personal Information about you in connection with your employment application and as part of our recruitment process, as permitted under applicable law:

• Personal Identifiers (e.g., first name, last name, Social Security number, date of birth, driver’s license)
• Contact information (e.g., email address, phone number, address, city, state, zip code, country)
• Gender
• Business or government relationships that may lead to conflicts of interest
• Resume
• Employment history
• Education history
• Skills inventory (including by way of skills assessments You may take part in, as permitted by applicable law, as part of any application process)
• LinkedIn Profile URL, the publicly available sections of your LinkedIn profile URL, if you provide it to us, and other professional websites you provide to us
• Immigration status and work permits
• Demographic information and/or protected classifications (as required by applicable law)
• Desired salary (if applicable)
• Salary history (to the extent permitted by applicable local laws)
• Results of any pre-employment testing (such as psychometric testing, credit history checks and other screening, subject to strict conditions, as permitted under applicable law
• Video/photo images or audio recordings (e.g., via virtual interviews (where applicable))
• Calendar availability
• Results of the selection process
• Online identifiers and website, device and mobile app usage, and similar information collected via automated means, such as cookies and similar technologies
• Any other information you choose to share, such as information included in your CV/resume and/or shared with us during the interview process
• In certain circumstances and depending on the country in which You are located, Billhighway may collect additional types of Personal Information as required or permitted by law (e.g., tax identification number)

In certain jurisdictions, and only to the extent we may lawfully do so under applicable law, Billhighway may process Sensitive Personal Information, such as racial or ethnic origin, health-related data, religious beliefs, and trade union membership, for the limited purposes as set out below.

To the extent permitted by law, Billhighway may receive Personal Information directly from You (e.g., provided in our payroll system and/or through our Talent Community) and indirectly from third parties (e.g., former employers, educational institutions, publicly available sources and professional social networking sites, online recruitment platforms, professional recruitment agencies, and government agencies).

How We May Use Your Personal Information

We may use your Personal Information to:

• Identify and contact you
• Evaluate your application for employment
• Manage applicant and employment data in our Applicant Tracking System
• Schedule and facilitate interviews
• Determine your suitability for current and future job roles with us
• Contact references or other individuals who may provide information to us about your employment history
• Perform pre-employment screening and testing
• Potentially prepare employment terms or an employment agreement
• Financial planning and budgeting
• Engage in diversity and equal opportunity initiatives (where permitted and/or required under applicable law)
• Provide reasonable workplace accommodations and a safe workplace
• Make staffing decisions
• Enforce our Terms of Use and other legal rights
• Improve and develop our recruitment processes (including by way of candidate experience surveys)
• Ensure the safety and security of our systems
• Audit, research, and perform analyses to improve the recruiting experience on our sites
• Respond to inquiries, complaints, and disputes
• Perform certain data analysis regarding use of our recruiting sites and our recruitment programs
• Comply with legal and other requirements

Where we seek to review and implement measures to improve our recruitment activities and ensure compliance with our policies such as equal opportunity initiatives, we use anonymized and aggregated data.

If you accept a position and are employed by us, the information obtained through the application and recruitment process will become part of your employment record and used for employment-related purposes subject to applicable law.

Billhighway only processes Personal Information for the above purposes to the extent permitted by applicable law and, where required, only when it can rely on a legal basis. In certain cases, such as when looking to fill a job opportunity, we may process Your Personal Information with assistance from automated employment tools. However, all decisions with regards to the use of automated employment tools also include the use of human review and/or intervention.

How We may Share Your Personal Information

We will not sell your Personal Information. We may share your Personal Information as set out in our general Privacy Policy and as follows:

Sharing for Legal Purposes: We may share personal information with third parties in order to: (a) comply with a legal process or a regulatory investigation (e.g., a subpoena or court order); (b) enforce our Terms of Service, our Privacy Policies, or other contracts with our business partners, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our business partners, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, spam/malware prevention, and similar purposes.

Sharing In the Event of a Corporate Transaction:  We may also share personal information in the event of a corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, for purposes of due diligence connected with any such transaction or transition of service to another provider. In such cases, your personal information may be sold or transferred as part of such a transaction, as permitted by law and/or agreement.

Sharing With Service Providers:  We share any personal information we collect with our service providers, which may include (for instance) providers involved in technical or customer support, operations including payroll, benefits, insurance, travel, background screening, search firms who submit candidate information to us, recruiting, web or data hosting, billing, accounting, auditing, legal consultancy, security, marketing, or otherwise assisting us to provide, develop, maintain, and improve our company and our services.

Sharing of Aggregate Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to a single person. We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers and partners, at our discretion.

Retention of Personal Information

Personal information will not be kept for longer than is necessary for the Business Purpose for which it is collected and processed and will be retained in accordance with our internal document retention policies. In certain cases, laws or regulations require us to keep records for specific periods of time, including following termination of the employment relationship. In other cases, records are retained in order to administer the employment relationship or to resolve queries or disputes which arise from time to time.

Your Rights and Choices

We honor the rights of individuals under the privacy and data protection laws to which their data is subject. Depending on the country in which you are located, You may have certain rights, including but not limited to the right to:

• Access your Personal Information, rectify it, restrict, or object to its processing, or request its deletion.
• Receive the Personal Information You provided to us in a structured, commonly used, and machine-readable format to transmit it to another company.
• Withdraw any consent provided.
• Where applicable, lodge a complaint with your Leader or TMS.

Please be aware, that if You exercise your right to object or your rights of restriction or deletion, or if You decline to share certain information with us, we may not be able to assess your suitability for (continued) employment.

Updates to this Policy

Billhighway regularly reviews and updates its policies in response to business changes or to comply with applicable laws and regulations. We reserve the right to modify this policy at any time, so please review it frequently, noting the “Last Updated” date at the top of this Policy.

How to Contact Us

You can contact us at our corporate headquarters at:

Billhighway
5435 Corporate Drive
Suite 300
Troy, MI 48098

Email: privacysupport@billhighway.com
Phone: 1.866.245.5499