Applicant and Employee Privacy Notice

**Effective Date: **April 19, 2023

We are excited that you are joining or considering joining the Seam family! Seam takes the privacy and protection of its Applicants’ and Workforce Members’ personal information very seriously. This** Applicant and Employee Privacy Notice** (“Notice”) describes the types of information we collect, how we use and share information, and how you can manage certain information. We want anyone we recruit, anyone that is considering, and anyone who has a position with us to understand how we collect, use and share their information so please read this full Notice carefully.

If you have a question or concern related to Seam’s data practices, please refer to the “How to Contact Us” section below.

Who is Covered by this Notice

This Notice covers the following:

• All applicants and candidates for positions with Seam as well as all individuals recruited by Seam (“Applicants”); and
• All current and former Seam employees, whether on-site or remote, are covered under this Notice. This includes full-time employees, seasonal employees, interns, and flextime employees. It also covers current or former members of the Board of Directors. We refer to all of these covered individuals as “Workforce Members.”

The Seam entity you applied with, that recruited you, or that you work for (“Seam,” “we,” “us,” “our”) is the controller of your personal information for purposes of this Notice. By “controller,” we mean the Seam entity that is primarily responsible for managing your information. The Seam entity you work for may depend on the geographical location where you are based. If you are a member of the Board of Directors, your data controller is Seam Inc. Contact us if you have questions about which Seam entity is the controller of your personal information.

Applicants and Workforce Members for an Seam entity based in California or any other location with applicable data protection laws should refer to the “Applicant and Workforce Member Data Rights” section below for information about your data rights.

What Personal Information We Collect and How We Use It

We collect information about you throughout your recruitment process and working relationship with Seam. This includes personal information, information that identifies you or has the potential to identify you as a natural person. In some cases, the personal information we collect may include sensitive personal information, such as health information or racial or ethnic information, as permitted under applicable law.

Ways We Collect Personal Information:

We may collect personal information when you provide it to us directly; for example:

• If you are an Applicant, we may ask you to provide information to complete an employment application or supplement your candidacy for a position. This might include asking you to submit a resume or CV and/or fill out application forms. You might also provide us with your information at a job fair or recruitment event.
• If you are an Employee, we may ask you to provide information for hiring, onboarding, and benefits, as applicable.

We may also collect personal information about you from a Seam worker or a third party recruiting agency, if they refer you for a position. For example, the Seam worker who refers you may provide us with your resume or CV or information about how they know you.

We may generate personal information about you as follows:

• As part of our recruitment process, including through the application and interview process. For example, we may prepare notes to evaluate your application or interview; or
• As part of our relationship with you as a Workforce Member. For example, we may generate information about your work performance as part of our workforce performance evaluations.

We also may collect personal information from third parties or public sources, as allowed by applicable law. For example, as part of the hiring process, we may conduct background screenings through a third-party vendor that will collect information about your past education, employment, credit and/or criminal history, and/or professional licenses or certifications. As part of our ongoing talent and workforce development activities, we also may screen social media profiles to obtain information about your work-related experience and/or interests. During our working relationship, if you are involved in an investigation, we may obtain information about the incident from witnesses who may include private parties, law enforcement or public sources like news sources.

If we are not able to collect and use certain personal information, we may not be able to process your application, perform the necessary steps to consider you for a position with us, or to perform our workforce operations or provide you with the full benefits of your working relationship with us. In some cases, if we are not able to collect and use certain personal information, we may not be able to engage with you as an applicant/candidate or worker.

What Personal Information We Collect and How We Use It:

We may use personal information about our Applicants and Workforce Members to carry out our business functions and in connection with the purposes below, as permitted under applicable law. For each of these purposes, we may collect and use your name, home address, phone number(s), email addresses, and Seam ID number (if you are a Workforce Member). If you are a Workforce Member, and for certain purposes, we may receive limited personal information about an employee’s family members or other dependents or beneficiaries. We may also collect additional information for each of these purposes, such as the information described below.

Personal Information Collected from Applicants and How We Use It:

• Identify potential candidates, process and evaluate applications, make hiring decisions, and onboard new hires: We may collect and use your personal information to process your application, evaluate your capabilities and qualifications for a certain position, and make hiring decisions. This may include using your information to consider you for opportunities at Seam that you did not specifically apply for but for which we think you might be a good fit. If we hire you, we will transfer your information to our human resources systems, use it to manage the new-hire process, and incorporate it into your employee file. This information may include your education information such as graduation date, degree and institution, qualifications, previous work experience, citizenship and work authorization status, skills, cover letter information, professional and other work-related licenses, memberships, permits and certifications, demographic information as required or permitted under applicable law, social media profile information and any other information that you elect to provide to us.
• Conduct reference and background checks: We may collect and use personal information to verify your information, conduct reference checks and, if we offer you a position, conduct background checks, as permitted under applicable law. This information may include name and contact information for your references, government issued IDs, and criminal records and/or credit reports as allowed by applicable law. Some of the background check information may include sensitive personal information such as alleged or actual criminal offenses, which we collect and use as permitted under applicable law.
• Communicate with you: We may collect and use your personal information to respond to your inquiries, communicate with you about positions that may interest you, tell you about recruiting or other Seam events, talk to you about your application, send you updates regarding our careers website(s) and applicant tracking system, or inform you about changes to our terms and policies. This information may include email address, social media, or other contact information.
• Foster a Diverse and Inclusive Environment: In some cases, we may collect limited sensitive personal information from you as part of our efforts to foster a diverse and inclusive working environment, as permitted under applicable law. This sensitive personal information may include racial and ethnic information and any health condition or work restrictions you may have. As an Applicant, you may choose not to provide this sensitive personal information if you prefer not to do so. If you provide this information, we will use it to maintain and strengthen our diversity and inclusion initiatives, as well as to comply with anti-discrimination laws and applicable government reporting obligations, help ensure equal employment opportunities, and provide reasonable accommodations, as required under applicable law.
• Improve Our Recruiting and Hiring Process: We want to provide the best experience to our Applicants. To help us do this, we may collect and use your personal information to manage and improve our recruiting and hiring processes and programs.
• Legal Requirements: We may collect and use your personal information to comply with our legal obligations and otherwise as required or permitted by law.

Personal Information Collected from Workforce Members and How We Use It:

• Hiring and Your Workforce Member Account: We collect and use your personal information during hiring and onboarding, including as a result of an acquisition, as applicable. For example, we may use this information to establish your account as a Workforce Member in our HR data systems. This information may include your Social Security or government ID number, driver's license number or government-issued identification card, visa, date of birth, gender, demographic information, work history, social media profile information, company ID number, Seam profile photograph, and background check information. Some of the background check information may include sensitive personal information such as alleged or actual criminal offenses, which we only process or consider in accordance with applicable law. 2.Workforce Administration: We collect and use your personal information to administer our workforce. These types of activities may include creating and maintaining Workforce Member records and directories, conducting payroll activities, facilitating employee transfers, conducting performance reviews, administering employment terminations, communicating with you, resource planning, reporting, ensuring the safety of our physical locations, our network, and of Workforce Members at our facilities and while on official Seam travel, and expense management. This personal information may include your Social Security or government ID number, demographic information, financial account information, self-assessment information, your work development goals, performance feedback about you provided by you or others, expense information such as receipts, and performance information. 3.Benefits: We collect and use your personal information to establish and administer benefits, such as health and wellness benefits, financial benefits, fee or stock option planning, and perks. This personal information may include your Social Security or government ID number, and information regarding your family members or other dependents or beneficiaries. When you sign up for or change your health and wellness benefits, we may, in accordance with applicable law, also collect sensitive personal information about you and/or your family members or other dependents, such as health information. 4.Life and Work Events and Time Away: We collect and use your personal information in the event of certain life and work events, such as when a Workforce Member takes a leave of absence. This personal information may include, e.g., your Social Security or government ID number, driver’s license number, the type of leave you are requesting, reason for leave, dates of leave, and other details you may provide regarding a particular event. Depending on the event, and in accordance with applicable law, some of this personal information may include sensitive personal information, such as health information.
• Your Seam Life: We collect and use your personal information during the course of your relationship with us to provide you with services and offerings as a Workforce Member. For example, we may provide travel services, issue and manage company credit cards, hold company events, administer training, conduct surveys, to facilitate delivery of gifts and/or professional or personal acknowledgements, and respond to questions or complaints. This personal information may include your travel preferences, meal preferences, t-shirt size, social media profile information, information about training programs you have completed, your photo, date of birth, and any feedback about Seam you may provide. 6.Foster a Diverse and Inclusive Environment: In some cases, we may collect limited sensitive personal information from you as part of our efforts to foster a diverse and inclusive working environment, as permitted under applicable law. This sensitive personal information may include racial, religious, and ethnic information and any medical conditions or work restrictions you may have. You may choose not to provide this sensitive personal information if you prefer not to do so. If you provide this information, we will use it to maintain and strengthen our diversity and inclusion initiatives, as well as to comply with anti-discrimination laws and applicable government reporting obligations, help ensure equal employment opportunities, and provide reasonable accommodations, as required under applicable law.
• Conduct and Investigations: We collect and use your personal information to assess and evaluate Workforce Member conduct and to conduct investigations. For example, we may investigate claims, such as harassment or discrimination allegations, respond to complaints or disputes, make and administer disciplinary decisions, and respond to an emergency, which we believe poses a risk of harm to person, property, or the business interest of the company. This personal information may include any complaints made by or about you, disciplinary reports and findings, emergency contact information, and information about your conduct. Depending on the event, and in accordance with applicable law, some of this information may include sensitive personal information, such as medical condition.
• Monitoring: We collect and use your personal information to monitor and provide for the security of Seam systems, data and other confidential information, maintain the security and safety of Seam’s facilities and staff, and to protect Seam’s business interests, as permitted by applicable law. This personal information may include your email or web browsing activity and data access activity when on Seam devices and/or using Seam networks and systems and badging activity at Seam facilities. For more information about how we monitor Seam systems and devices, please see our policies available on the Seam intranet.
• Legal Requirements: We collect and use your personal information to comply with our legal obligations (such as obligations under statutes or regulations) and otherwise as required or permitted by law. This information may include files you may have stored on your Seam computer or device or on Seam systems or apps, such as email files and Human Resources files.

Workforce Members may have limited choices in how we use their personal information. We will offer choices to affected Workforce Members when we intend to use personal information for a purpose not previously disclosed in this Notice or any other notice.

How We Share Your Personal Information Within Seam: We may share your personal information internally within Seam and among Seam’s affiliates and subsidiaries for purposes of recruiting and/or evaluating Applicants, resource planning, talent and recruiting, for our human resources and business functions, as described in this Notice, and as required under applicable law. All Seam and Seam affiliate and subsidiary Workforce Members who handle personal information must comply with Seam’s privacy and security policies. These policies are available on Seam’s intranet site. As used in this Notice, “affiliates and subsidiaries” means companies related by common ownership or control.

With Third Party Service Providers and Agents: We may share personal information with third parties that help us provide and administer our talent and recruiting, our Human Resources and other business functions. We require these third parties to agree to safeguard the personal information they receive.

With Third Parties Who Provide You Benefits or Services: In some cases, Seam may offer benefits provided by third parties that establish an independent relationship with you directly. In those instances, the third party’s use and sharing of your personal information will be covered by that third party’s privacy Notice. Be sure to review the privacy Notice of the third party when you decide to establish a relationship with them.

Merger or Sale of Our Business: If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your personal information with that company and its advisors before and after the transaction date.

Response to Legal Requests: We or our affiliates or subsidiaries may share your personal information with third parties when we reasonably believe disclosure is required or permitted in order to comply with a subpoena, court order or other applicable law, regulation or legal process.

Protection of Seam and Others: We may share your personal information when we believe it is appropriate to protect the rights, property, or safety of Seam, our products or services, our customers, our Applicants, Workforce Members or others.

**Aggregate Information: **We may share your personal information in a form that does not identify you individually, such as in aggregate and/or de-identified form, internally within Seam or with certain third parties for purposes such as research, reporting and benchmarking.

How You Can Manage Your Personal Information

For Applicants, you have the ability to access, review, update and correct certain personal information you provided to us through our online applicant tracking system portal if you have created an account.

For Workforce Members, you may access, review, update and correct certain personal information you provide to us through the online tools available to you. You can access these tools through Seam’s intranet site. We will require proper credentials for you to be able to access your personal information.

If you have questions about these online tools or managing your personal information, contact us using the information in the “How to Contact Us” section below.

Applicant and Workforce Member Data Rights

Legal Basis for Processing Personal Information:

Our legal basis for collecting and using the personal information described in this Notice will depend on the personal information concerned and the specific context in which we collect it.

We collect and use your personal information where we need the personal information to perform a contract with you (such as to administer an employment or work relationship with us), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we may have a legal obligation or may otherwise need the personal information to protect your vital interests or those of another person. In some limited cases and when applicable, we may collect and use your personal information where we have your consent.

If you have questions about the legal basis we use to collect and use your personal information, please contact us using the contact methods in the “How to Contact Us” section of this Notice.

How You Can Exercise Rights Regarding Your Personal Information:

This section applies to Applicants and Workforce Members based in the EEA, California or other regions where there are applicable data protection laws.

If you live in the EEA, your rights may include:

• Right to Access – The right to be informed of and access the personal information we process about you, including, in certain circumstances, a right to know what personal information we collected, or disclosed about you, including the specific pieces of personal information held.
• Right to Erasure – The right to request deletion of your personal information, subject to certain exceptions.
• **Right to Rectification **– The right to request that we amend or update inaccurate or incomplete personal information.
• Right to Restrict Processing – The right to request that we temporarily or permanently stop processing all or some of your personal information.
• Right to Object – The right to object to Seam processing personal information, such as when automated decision making is used.
• Right to Data Portability – The right to request a copy of your personal information in electronic format and the right to further request that we send such personal information to another party.
• **Right to Lodge a Complaint **– The right to lodge a complaint with the applicable supervisory authority. Although you are not legally required to do so, we ask that you first contact us so we can make reasonable efforts to address your complaint.

If you live in California, your rights may include:

• **Right to Know **– The right to know what categories and specific pieces of personal information we collect, the purposes for which we collect personal information, the sources from which we collect personal information, and whether personal information is disclosed, sold, or shared with third parties.
• **Right to Erasure **– The right to request deletion of your personal information, subject to certain exceptions.
• Right to Correction – The right to request that we correct inaccurate or incomplete personal information.
• Right to Opt Out – The right to opt out of the sale or sharing of your personal information, and the right to opt out of automated-decision making technology.
• Right to Non-Discrimination – The right not to receive discriminatory treatment for exercising your rights.
• **Right to Limit Use of Sensitive personal information **– The right to limit the use and disclosure of your sensitive personal information.

If you are an Applicant or Workforce Member in France, you also have the right to give directives about the processing of your personal information after your death.

To make a request, please contact us using the methods described in the “How to Contact Us” section below. We will consider and act upon any such requests in accordance with applicable data protection laws. If you are a California resident, you may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must (a) provide signed permission to that authorized agent to submit requests on your behalf, (b) verify your identity directly with us, and (c) directly confirm with us that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent.

In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information. You must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

When we receive your request to exercise your rights: (a) we will acknowledge receipt of your request; (b) we will try to match the personal information you provide in making the request with personal information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including personal information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

We will only use personal information we collect during the verification process for the purpose of verifying your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.

We will respond to your requests within the time periods prescribed by applicable law. If we require additional time, we will inform you of the reason and extension period.

When applicable, if we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

Please be aware that you may have limited choices in your ability to request deletion of personal information due to Seam’s legal obligations to retain certain information.

California Residents

This Section provides additional provisions that apply to residents of California. In the event of a conflict between this section and the remainder of this Notice, this section shall take precedence for California residents. In this section only, capitalized terms not defined in this Notice shall have the meanings set forth in the California Consumer Privacy Act (“CCPA”). Some of this information may constitute sensitive personal information defined by the CCPA. Where our processing of this sensitive personal information is not for a permissible business purpose, we will provide you an opportunity to limit the processing of that information. For example, collection of that information may be opt-in only.

For details on the information we process, please refer to the CCPA Right to Know chart at the bottom of this Notice.

How We Retain Your Personal Information

We will retain your personal information in compliance with Seam's records and information management policies. For example, we may retain personal information to comply with obligations under applicable laws and regulations, resolve disputes, and enforce our agreements. We will retain your personal information no longer than is necessary to carry out the purposes provided in this Notice and/or as required or permitted by applicable law.

How We Secure Your Personal Information

Seam uses appropriate technical and organizational measures to protect the personal information of its Applicants and Workforce Members. For example, we limit access to your personal information to members of Seam’s and Seam’s affiliates' and subsidiaries’ personnel with a need to know in connection with their job duties, such as select personnel within the recruiting, human resources, finance, legal, insurance, information security and IT departments, as well as individuals evaluating you as a candidate, and for talent acquisition, human resources, and business uses.

International Data Transfers

We may transfer, process and store personal information, including sensitive personal information, about our Applicants and Workforce Members outside their country of residence, including countries where we and our third-party service providers operate, in accordance with and as permitted by applicable law and regulations. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective). This means that personal information about Applicants and Workforce Members based outside of the United States may be transferred to Seam Inc. in the United States and to third-party service providers located in the United States and other countries, for the purposes identified above. For information about where our third-party service providers store your personal information, please contact us as described in the “How to Contact Us” section. We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Notice.

How to Contact Us

Questions or Comments: If you have questions or comments about this Notice or our privacy practices, please contact us by email at hr@getseam.com.

Exercising Your Data Rights: If you are based in the EEA, California or another region with data rights under applicable data protection laws, please contact us at the number posted on Seam’s intranet or listed below. If you are a Workforce Member, you can also use the online chat or case submission features accessible through the HR Connect page on Seam’s intranet, where available.

Complaints or Disputes: If you are an Employee and have complaints or disputes about this Notice or our privacy practices, please contact hr@getseam.com.

Please also see our Employee Privacy Complaint Policy on Seam’s intranet.

If you are an Applicant and have complaints or disputes about this Notice or our privacy practices, please contact us at hr@getseam.com.

Changes to this Notice

We may update this Notice from time to time in response to changing legal, technical or business developments. If you are an Applicant, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If you are a Workforce Member, and as required under applicable law, we will provide you notice of changes to the way we process your personal information via Seam’s intranet pages and/or email and will obtain your consent as required by applicable law. All changes are effective immediately upon posting a notice. You can see when this Notice was last updated by checking the "Effective Date" date displayed at the top of this Notice.

CCPA Right to Know Disclosures

Category of Personal Information (and examples)	Category of Source from which Personal Information is Collected	Purpose of Collection	Category of Third Parties to whom Personal Information is Disclosed for a Business Purpose	Category of Third Parties to whom Personal Information is Sold	Category of Third Parties to whom Personal Information is Shared
Identifiers ● Full name, nicknames or previous names (such as maiden names) ● Mailing address ● Email address ● Telephone Number ● Mobile number	Directly from you Third parties (e.g., recruiters, government agencies) Public Communities (e.g., social media)	See section above titled “What Information We Collect and How We Use It”	Service Providers Benefits Administrators Security Providers Hotels and Lodging Providers Goods and Service Vendors	N/A. We do not sell Personal Information.	Advertising Partners.
Protected Classifications ● Race and ethnicity ● Disability status ● Veteran status	Directly from you Third parties (e.g., government agencies) Public Communities (e.g., social media)	See section above titled “What Information We Collect and How We Use It”	Service Providers Benefits Administrators Government Agencies	N/A. We do not sell Personal Information.	N/A. We do not share this Personal Information.
Biometric Information ● Fingerprints for secure access to buildings	Directly from you