Privacy Policy

Website Privacy Policy

Effective Date: August 28, 2026

This Privacy Policy (“Policy”) describes how iSpace, Inc. and iSpace Global, Inc. (“iSpace”, “we”, “us”, or “our”) handle the information we collect from and about you through:

• Our digital platforms that link to this Policy, including our websites (collectively, the “Site”).
• Your communications and interactions with us, including about our services, questions and comments you may have, and troubleshooting issues.
• Your business-to-business engagements with us through a vendor, supplier, or other commercial relationship with us.
• Your engagement of our services.
• Offline activities described in this Policy, including engaging us to provide you with our service offerings.

U.S. State Supplements: See the State-Specific Supplements section below for important information about your personal information and rights under applicable state privacy laws.

Not In Scope

This Policy does not apply to the personal information that we collect about employees and other personnel related to their working relationship with us. Current and former employees, see our Employee Privacy Policy. Job applicants, see our Applicant Privacy Policy. We may also collect, generate, use and disclose aggregate, anonymous, and other non-identifiable data, which is not personal information subject to this Policy.

Contact Us With Questions

If you have any questions, please contact us as provided below. You may download a copy of this Policy from our website at https://ispace.com/privacy-policy. If you need to receive this Policy in a different format, please contact us at 1-800-758-7816 or privacyofficer@ispace.com.

Read This Policy

Please read this Policy carefully to understand our privacy policies and practices. By using our Site, services, and/or communicating or interacting with us, you consent to the collection, use, and sharing or disclosure of your information by iSpace consistent with this Policy. If you do not agree with any term in this Policy, you should not access and use the Site and please do not otherwise provide us with any personal information.

Categories of Personal Information We Collect

The type of information that we collect depends on your interaction and relationship with us. For example, personal information may be collected when you visit our Site, fill out an inquiry form on the ‘Contact Us’ page on our Site, when you do business with us, when you call or email us, or when you otherwise provide us personal information. We collect the below categories and types of personal information with your consent or as otherwise required or permitted by law.

• Identifiers, such as name, alias, telephone number, postal address, Internet Protocol (“IP”) address, email address, signature, or other similar identifiers.
• Audio, electronic, visual, or similar information, such as voicemail messages that you leave for us, electronic messages you send to us, and recorded telephone calls.
• Commercial information, including records relating to billing records, and records reflecting your past business relationship(s) with us.
• Professional or employment-related information. For representatives of entities that have a business relationship with us or otherwise seek to have a business relationship with us, we also collect the identity of your employer or the entity you represent.
• Internet or Other Electronic Network Activity Information, such as IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site.

Sources Of Personal Information

We collect personal information in the following ways:

• Directly from you. When you contact us for any reason, we collect identifiers from you to identify you and communicate with you; depending on the method in which you contact us, we may also collect audio/visual/electronic information from you. For example, we collect from primary contacts of prospective customers their identifiers; audio, electronic, visual, or similar information; and professional or employment-related information.
• Automatically. When you access our Site, we may log, monitor and record information about you, your computer or mobile device, and your activity on our I.T. assets, including our Site. Further details regarding our automatic collection of data can be found in the below Section entitled “Information We Collect Through Automatic Data Collection Technologies.”
• From third parties. We may collect identifiers from third-parties including our business contacts and vendors.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we use automatic data collection technologies to collect certain information about your equipment and browsing actions. Specifically, we use “cookies” (also known as “browser cookies”). Cookies are small files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of tracking user activity, helping the visitor navigate between pages efficiently, remembering preferences, improving the visitor's browsing experience, and enabling functionality. You can learn more about cookies and how to control them at www.allaboutcookies.org. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site.

Purposes for Collecting Personal Information

We use personal information for the following purposes:

• Providing our Services. We use identifiers, audio/electronic/visual data, commercial information, professional or employment-related information, to facilitate the generation of new and expansion of existing business opportunities, to allow our customers to engage us to assist them, and to provide our services.
• Transactional Purposes. We use identifiers, commercial information, audio/electronic/visual data, and professional or employment-related information to: (i) communicate with our customers; (ii) provide them with assistance; and (iii) provide supporting business activities such as billing and collections, and related activities.
• Business Operations. We use identifiers, internet or other electronic activity information, audio/electronic/visual data, commercial information, and professional or employment-related information for our day-to-day business operations, including maintaining records, managing and securing our assets and facilities, maintaining customer service quality control, planning, budgeting, calibration, database administration, reports, compliance, regulatory, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.
• Maintenance and Improvement of our I.T. Assets and Systems. We use identifiers, audio/visual/electronic data, and internet or other electronic network activity information to improve our information technology assets and systems, provide and maintain functionality on our Site and systems, and help us diagnose technical and service problems. Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing information technology support services.
• Security and Fraud Prevention. We use identifiers, professional or employment-related information, and internet or other electronic network activity information to: (i) protect us, our employees, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; (iii) conduct vendor/service provider and customer due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
• Complying with Legal and Ethical Obligations and Legal Process. We use identifiers, internet or other electronic activity information, audio/electronic/visual data, commercial information, and professional or employment-related information, to comply with our legal obligations, and inference information, including responding to data subject requests, reporting requirements and responding to court orders, warrants, or subpoenas, defend ourselves in legal proceedings, and protect our company and our property, associates, and others through legal proceedings.

We combine personal information we collect from you on the Site with personal information we receive from you offline or through your communications or interactions with us. We combine information across devices, such as computers and mobile devices. We also combine information you provide with information we obtain from our service providers and other third parties when you interact or provide information to them, visit our Site, use our service offerings, or otherwise get in contact with us.

How We Disclose Personal Information

We disclose personal information in the following circumstances:

• Service Providers. We may share personal information with vendors that are our service providers who support the operation of our services and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, payment processing, insurance, and operating systems and platforms). In some cases, the service provider may directly collect the information from you on our behalf. In the past 12 months, we have disclosed identifiers, internet or other electronic network activity information, audio, electronic, visual, or similar data, and professional or employment-related information, to our service providers.
• Professional Advisors. We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us. In the past 12 months, we have disclosed identifiers and professional or employment-related information to our professional advisors.
• Government Entities. We may share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.
• Corporate Transaction Recipients. We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.
• Affiliates. We may share some or all of your personal information with our parent company, subsidiaries, and other companies under common ownership or control with us for purposes consistent with this Policy.
• Other Reasons. We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.

Sensitive Personal Information

Unless specifically requested, we ask that you not send us, and you not disclose to us, through the Services or otherwise, any Sensitive Personal Information (e.g., social security number, taxpayer identification number, passport number, driver's license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, citizenship or immigration status, medical or health information, genetic or biometric information, biometric templates, precise geolocation, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).

Accessing Your Information & Your Choices

Your data rights are largely dependent upon the State of which you are a resident. Various States have enacted data privacy laws, which generally provide the following data rights:

• Access and Portability. You may request that we tell you (i) what personal information we have collected about you, (ii) the sources of that information, (iii) the purposes for collecting, selling or sharing the personal information; and (iv) the categories of third-parties to whom we have disclosed personal information. You may request that we provide you with a copy of your personal information. The response to your access request will be dependent on the requirements of applicable law.
• Deletion. You may request that we delete personal information that we have collected from you. We may not delete all of your personal information if applicable laws require us to retain certain information, or if an exception to any applicable law applies.
• Correction. You may request that we correct inaccurate personal information that we collect about you.
• Opt-Out of Using Personal Data for Targeted Advertising and Sales. iSpace does not use your personal information for targeted advertising or sales.

Non-Discrimination Rights. You have the right to not be discriminated against for exercising any of your data privacy rights under applicable law. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of the above data rights.

Requests Regarding Your Personal Information. To make any requests relating to your personal information, please email us at privacyofficer@ispace.com, call us toll free at 1-800-758-7816, or use the webform on our Site to submit a request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You can ask to appeal any denial of your request in the same manner through which you may submit a request.

For all requests, you should provide us with sufficient information to verify your identity and process your request. This includes your name, and email address or phone number. If we are unable to identify you, we may ask you to provide additional information to process your request. Failure to provide identifying information may prevent us from processing your request. If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.

Authorized Agents. Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

How Long We Keep Personal Information

We will retain and use your information for as long as we need it to provide you our services, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We use the following criteria to determine retention periods:

• how long the information is needed to provide our services and operate our business;
• whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
• whether any law, statute, or regulation allows for a specific retention period;
• whether an individual has agreed to a longer retention period;
• whether the data is considered to be sensitive data; and
• what the expectation for retention was at the time the data was provided to us.

Links to Other Websites

Our Site may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use.

Security

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

This Website is Not Intended for Minors

Our Site is not intended for use by individuals under the age of 18. We do not knowingly collect or store any personal information from anyone under the age of 18. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us by sending an email to privacyofficer@ispace.com.

Information Storage

Information we collect may be stored in the United States or other countries. If you live outside of the United States and choose to use our services or interact or otherwise develop a relationship with us, you understand that it is at your own risk. You also understand that your information may be sent to the United States. The United States may not afford the same level of protection as laws in your own country. We may store your data in other countries. As permitted by law we may transfer your information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Contact Us

If you have any questions about this Policy or our privacy practices, you can contact us in one of the following ways:

Email us:
privacyofficer@ispace.com

Write to us:
iSpace
Attn: Data Privacy Officer
840 Apollo Street, Suite 100
El Segundo, CA 90245

Call us:
1-800-758-7816

Updates to Our Privacy Policy

We may change our Policy and privacy practices over time. This Policy includes an “effective date,” which is the date the current version was last changed. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another acceptable manner. Any modifications to this Policy will be effective upon our posting the modified version as described above (or as otherwise indicated at the time of posting). In all cases, your continued use of the Site and our services after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

State-Specific Supplements

California Privacy Notice
If you are a California resident, this section applies to you. This California Privacy Notice supplements the information in iSpace’s Privacy Policy.

Shine The Light. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at privacyofficer@ispace.com and include “CA Shine the Light” in the subject line of your email. We do not currently disclose your personal information to third parties for their own direct marketing purposes.

California Consumer Privacy Act (“CCPA”), as Amended by the California Privacy Rights Act (“CPRA”).

Sale or Sharing of Personal Information. The CCPA puts certain obligations on businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes. The CCPA defines a “sale” as disclosing or making available to a third-party Personal Information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. Based upon our understanding of the CCPA, we do not disclose personal information in such a way that constitutes “sale” or “sharing” under the CCPA. We also do not knowingly sell or share the personal information of minors under the age of 18.

Use or Disclosure of Sensitive Personal Information. Based upon our understanding of the CCPA, we do not collect “Sensitive Personal Information” as part of our data collection practices as described in this Policy.

Employee Privacy Policy

The Privacy Policy describes how iSpace, Inc. (“iSpace,” “us,” “we,” and “our”) collects, stores, uses, and discloses Personal Information about you as a former or current employee in connection with your employment. This notice describes how we use that Personal Information, to whom we disclose it, how you can exercise your data choices, and how you can contact us. Your “Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

California Residents: See the California Privacy Rights section below for important information about your Personal Information and rights under applicable state privacy laws.

Not in scope. This Privacy Policy does not apply to interactions with iSpace outside of the employment context, such as browsing our website or using our services. Please click here: https://www.ispace.com/privacy-policy to review our Privacy Policy and learn more about our privacy practices related to those interactions. We may also collect, generate, use, and disclose aggregate, anonymous, and other non-identifiable data that is not Personal Information subject to this Privacy Policy.

If you have any questions, contact us using the information provided below. You may download a copy of this Privacy Policy from our website at https://ispace.com/privacy-policy#employee-privacy-policy. If you need to receive this Privacy Policy in a different format, contact us at 800-758-7816 or privacyofficer@ispace.com.

Categories of Personal Information We Collect
We have collected the below categories of employee Personal Information with your consent or as otherwise required or permitted by law in the preceding 12 months.

• Personal Identifiers, such as your name, address, telephone number, email address, Social Security number, Driver's license number, Passport number, Alien Registration Number/Alien Admission Number, signature, and emergency contact information.
• Characteristics of Protected Classifications, such as your race, national origin, country of birth, citizenship and immigration status, sex, age, disability information, and marital status and family information, if you provide this information.
• Audio/Visual Data or Similar Information, such as your employee photograph. We also collect messages (whether in electronic, text, or audio/voice form) that you send to us.
• Professional or Employment Information, such as information related to your employment history that was collected as part of the recruiting and application process. Additionally, we collect information relating to your dates of employment, your work attendance, and your work performance.
• Education Information, such as your education history.
• Financial Information, such as your bank account information to process payroll, and payment information relating to employee benefits received by you or your spouse and dependents.
• Health Insurance Information, such as enrollment details and premium payments concerning you, your dependent or spouse, in furtherance of processing your health insurance enrollment and manage your benefits.
• Medical Information, such as work restrictions and accommodation requests, as well as your ability to work to the extent provided to us and the extent permitted and required by applicable laws.

Sources Of Personal Information
We collect, and in the preceding 12 months have collected, Personal Information in the following ways. We may combine information that we collect from different sources.

• Directly from you. We may collect Personal Information directly from you, such as during the job application or onboarding process, during your employment, and/or when you experience a change in your employment status with us.
• From third parties. We may collect certain Personal Information about you from third parties. For example, this includes vendors that run background checks, vendors that administer iSpace's leave of absence and employee benefits, healthcare providers whom you direct to communicate with us, your spouse and/or dependents, references and referrals you provide to us, and clients when they provide feedback or reviews of their interactions with you.
• From our employees. Other iSpace employees may provide us with information about you, such as performance or evaluation information from a manager or supervisor.

Purposes for Collecting Personal Information
We use Personal Information for the following purposes:

• Onboarding. We use identifiers, characteristics of protected classifications, professional or employment information, and education information to conduct background checks as necessary, facilitate work authorizations, complete new hire paperwork, enroll you in our human resources system, and set up your personnel file.
• Benefits. We use identifiers, financial information, professional or employment information, health insurance information, and medical information we collect to create and facilitate benefits packages and, if eligible, provide your employee benefits through us and/or through third-party benefits administrators.
• Payroll. We use identifiers, professional or employment information, and financial information to manage reimbursements and pay you for services provided.
• Leave and Accommodation Requests. We use identifiers, professional or employment information, medical information, and characteristics of protected classifications we collect to evaluate and process time off, sick leave, leaves of absence, or accommodation requests if you make such requests.
• Training, Performance Reviews, and Goals Monitoring. We use identifiers and professional or employment information we collect to provide you with relevant training and feedback and to support your career development.
• Business Operations. We use identifiers, characteristics of protected classifications, audio/visual data, professional or employment information, education information, and financial information we collect to guide our recruiting and hiring process, maintain files, and/or support our business operations and the operations of our affiliates.
• Security and Crime Prevention. We use identifiers, audio/visual data, and professional or employment information to secure our facilities and networks, such as by monitoring access to our network, conducting periodic security checks, investigating workplace incidents, and limiting access to our facilities and assets.
• Legal Compliance and Protection. We use the identifiers, characteristics of protected classifications, audio/visual data, professional or employment information, education information, financial information, health insurance information, and medical information we collect to comply with applicable laws, our legal obligations and in defense of our company, property, and others through legal proceedings.

How We Disclose Personal Information
We disclose Personal Information in the following circumstances:

• Service Providers. We disclose Personal Information with vendors who support the operation of our business, including our payroll provider(s), benefits administrator(s), insurance administrator(s), background check vendor(s), and retirement plan administrator(s). In some cases, the service provider may directly collect the information from you. In the past 12 months, we have disclosed identifiers, characteristics of protected classifications, financial information, professional or employment information, health insurance information, education information, and medical information to our service providers.
• Professional Advisors. We disclose Personal Information to professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of their services. In the past 12 months, we have disclosed identifiers, characteristics of protected classifications, medical information, health insurance information, professional or employment information, and education information to our professional advisors.
• Government Entities. We may disclose Personal Information with regulatory and government entities, including government, administrative, law enforcement, and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process, or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and enforcing or protecting our contracts, legal rights, or the rights of others, including by responding to claims against us. In the past 12 months, we have disclosed personal identifiers and financial information to government entities.
• Other Reasons. We may disclose Personal Information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.

How Long We Keep Personal Information
To the extent permitted by applicable law, we will retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or other reporting requirements or obligations. We use the following criteria to determine retention periods:

• how long the information is needed to provide our services and operate our business;
• whether there are contractual or legal obligations that exist that require us to retain the information for a period of time;
• whether any law, statute, or regulation allows for a specific retention period;
• whether an individual has agreed to a longer retention period;
• whether the data is considered to be sensitive data; and
• what was the expectation for retention at the time the data was provided to us?

Security
We follow generally accepted industry standards to protect the Personal Information submitted to us and have implemented reasonable technical, organizational, administrative, and physical measures to protect it. However, no method of transmission or method of electronic storage is 100% secure.

Data Processing
By having an employment relationship with us and/or by providing us with your Personal Information, you acknowledge your Personal Information may be transferred to and processed in jurisdictions outside your own as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your Personal Information transferred to other jurisdictions may differ from those in your place of residence.

California Privacy Rights
If you are a California resident, this section applies to you.

California Consumer Privacy Act (“CCPA”), as Amended by the California Privacy Rights Act (“CPRA”).

Sale or Sharing of Personal Information. In the preceding 12 months, we have not “sold” or “shared” (as we understand those terms are defined in the CPRA) any Personal Information (including Sensitive Personal Information) to “third parties” as we understand that term.

Use or Disclosure of Sensitive Personal Information. The following forms of data listed above constitute “Sensitive Personal Information”: Social Security number, Driver's license number, Passport number, race, national origin, citizenship or immigration status, and your health information, if provided to us. We do not use or disclose Sensitive Personal Information, as defined by California law, for inferring characteristics or for purposes other than those permitted by law.

Your Rights Under the CPRA. Subject to certain exceptions and limitations, the CPRA affords iSpace's employees the following rights:

• You have the right to request that we tell you (i) what Personal Information we have collected about you, (ii) the sources of that information, (iii) the purposes for collecting, selling, or sharing the Personal Information; and (iv) the categories of third parties to whom we have disclosed Personal Information.
• You have the right to request that we provide you with a copy of your Personal Information.
• You have the right to request that we delete the Personal Information we collected from you. We may not delete all of your Personal Information if one of the exceptions to the CPRA applies.
• You have the right to correct inaccurate Personal Information that we hold about you.
• You have the right not to be discriminated against for exercising your CCPA rights. We will not discriminate against you if you exercise any of your CCPA rights.

Exercising Your Rights. To exercise any of your rights, contact us at privacyofficer@ispace.com or 800-785-7816 to submit a request, or use our webform. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You can ask to appeal any denial of your request in the same manner through which you may submit a request.

For all requests, you should provide us with your name, employee ID number (if known), email address, and phone number. We will verify your identity by matching the information we have regarding our current and former employees against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request. If you have requested that we correct your Personal Information, we may contact you to request additional information about the Personal Information that you believe is inaccurate, including supporting documentation.

Authorized Agents. Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent under applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Contact Us
If you have any questions about this Policy or our privacy practices, contact us at privacyofficer@ispace.com or 800-785-7816.

At-Will Employment
This Employee Privacy Policy does not form any part of any contract of employment. Your status as a current/former at-will employee with us does not change by virtue of this Employee Privacy Policy.

Updates to Our Privacy Policy
This Employee Privacy Policy may be updated from time to time for any reason. If we make material changes to this Privacy Policy, we will notify you by posting the new Privacy Policy at https://ispace.com/privacy-policy#employee-privacy-policy and changing the effective date listed at the top of this Privacy Policy. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner in which we communicate with you as an employee. Any modifications to this Employee Privacy Policy will be effective upon our posting the modified version as described above (or as otherwise indicated at the time of posting).

Applicant Privacy Policy

The Privacy Policy describes how iSpace, Inc. (“iSpace,” “we,” “us,” or “our”) collects, stores, uses, and discloses Personal Information about you as a job applicant. This notice describes how we use that Personal Information, to whom we disclose it, how you can exercise your data choices, and how you can contact us. Your “Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

California Residents: See the California Privacy Rights section below for important information about your Personal Information and rights under applicable state privacy laws.

Not in scope. This Privacy Policy does not apply to interactions with iSpace outside of the job application context, such as browsing our website or using our services. Please click here: https://www.ispace.com/privacy-policy to review our Privacy Policy and learn more about our privacy practices related to those types of interactions. We may also collect, generate, use, and disclose aggregate, anonymous, and other non-identifiable data which is not Personal Information subject to this Privacy Policy.

If you have any questions, please contact us as provided below. You may download a copy of this Privacy Policy at https://ispace.com/privacy-policy. If you need to receive this Privacy Policy in a different format, please contact us at 1-800-758-7816 or privacyofficer@ispace.com.

Categories of Personal Information We Collect
We collect, and in the preceding 12 months have collected, the below categories of applicant Personal Information with your consent or as otherwise required or permitted by law.

• Personal Identifiers, such as your name, telephone number, home address, and email address from you during our recruitment processes. If you receive a conditional offer of employment from us, we may also collect your Social Security number, passport number, and Alien Registration Number/Alien Admission Number.
• Characteristics of Protected Classifications Under California or Federal Law, such as your race, national origin, marital status and family information, sex, age, date of birth, country of birth, citizenship or immigration status to establish your authorization to work in the United States.
• Professional or Employment-Related Information, such as your employment history (i.e., your prior dates of employment, where you worked, and the details of jobs you previously held), including your resume.
• Education Information, such as your education history (including information about your degree(s), certification(s), and educational credentials).
• Audio, electronic, or similar information, such as electronic messages, including emails, that you use to communicate with us regarding your interest to work at iSpace. We also collect any voicemails you may leave for us, as well as screenshots that may be taken during a video interview.

Sources Of Personal Information
We collect, and in the preceding 12 months have collected, Personal Information in the following ways:

• Directly from you. We may collect Personal Information directly from you as part of the application and recruiting process, such as when you submit a job application and resume (whether directly to iSpace or through a third-party platform), are interviewed by us, or when you inquire about opportunities with us.
• From third parties. We may collect certain Personal Information about you from third parties. For example, this includes from vendors that run background checks and references you provide to us. If you apply to work with us through a third-party platform, we receive your submission through that platform. Our employees may provide us with information about you in connection with any job interviews you have with us. We may combine information that we collect from different sources.

Purposes for Collecting Personal Information
We use Personal Information for the following purposes:

• Recruiting and hiring. We use identifiers, professional or employment information, audio, electronic, or similar information, and educational information we collect from your application and through the application and interview process to evaluate your qualifications and eligibility for employment. We do not consider any Characteristics of Protected Classifications under California or Federal Law as part of determining whether you are qualified for employment with us.
• Post-Offer Diligence. If you are given a conditional offer of employment, we may thereafter conduct a background check and, as a result, may use identifiers, professional or employment information, education information, and Characteristics of Protected Classifications under California or Federal Law as part of the background check process. In addition, we may use identifiers, professional or employment information, education information, and Characteristics of Protected Classifications under California or Federal Law to facilitate your authorization to work in the United States.
• Legal Compliance and Protection. We use identifiers, professional or employment information, Characteristics of Protected Classifications under California or Federal Law, and education information we collect to comply with mandatory government reporting requirements and applicable laws, our legal obligations, and in the defense of our company, property, and others through legal proceedings.

How We Disclose Personal Information
We disclose Personal Information in the following circumstances:

• Service Providers. We disclose Personal Information with service providers who support the operation of our business, including our background check vendors. In some cases, the service provider may directly collect the information from you. In the past 12 months, we have disclosed identifiers, Characteristics of Protected Classifications under California or Federal Law, education information, and professional or employment information to our service providers.
• Job References and Prior Employers. If you identify a reference or any other employer(s) as part of your application, we may disclose your Personal Information to them. In the past 12 months, we have disclosed identifiers and professional or employment information to other employers and/or references.
• Professional Advisors. We may disclose Personal Information to professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us.
• Government Entities. We may disclose Personal Information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we believe it is appropriate, obtaining legal remedies or limiting our damages, and enforcing or protecting our contracts, legal rights, or the rights of others, including by responding to claims against us.
• Other Reasons. We may disclose Personal Information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.

How Long We Keep Personal Information
To the extent permitted by applicable law, we will retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or other reporting requirements or obligations. We use the following criteria to determine retention periods:

• how long the information is needed to provide our services and operate our business;
• whether there are contractual or legal obligations that exist that require us to retain the information for a period of time;
• whether any law, statute, or regulation allows for a specific retention period;
• whether an individual has agreed to a longer retention period;
• whether the data is considered to be sensitive data; and
• What was the expectation for retention at the time the data was provided to us?

Security
We follow generally accepted industry standards to protect the Personal Information submitted to us and have implemented reasonable technical, organization, administrative, and physical measures to protect Personal Information. No method of transmission or method of electronic storage is 100% secure, however.

California Privacy Rights
If you are a California resident, this section applies to you.

California Consumer Privacy Act (“CCPA”), as Amended by the California Privacy Rights Act (“CPRA”).

Sale or Sharing of Personal Information. In the preceding 12 months, we have not “sold” or “shared” (as we understand those terms are defined in the CPRA) any Personal Information (including sensitive Personal Information) to “third parties” as we understand that term is defined in the CPRA.

Use or Disclosure of Sensitive Personal Information. The following forms of data listed above constitute “Sensitive Personal Information”: your Social Security number, passport number, race, and citizenship or immigration status, if provided to us. We do not use or disclose Sensitive Personal Information, as defined by California law, for inferring characteristics or for purposes other than those permitted by law.

Your Rights Under the CPRA. Subject to certain exceptions and limitations, the CPRA provides the following rights:

• You have the right to request that we tell you (i) what Personal Information we have collected about you, (ii) the sources of that information, (iii) the purposes for collecting, selling, or sharing the Personal Information; and (iv) the categories of third parties to whom we disclose Personal Information.
• You have the right to request that we provide you with a copy of your Personal Information.
• You have the right to request that we delete the Personal Information we collected from you. We may not delete all your Personal Information if one of the exceptions to the CPRA applies.
• You have the right to correct inaccurate Personal Information that we hold about you.
• You have the right not to be discriminated against for exercising your CPRA rights. We will not discriminate against you if you exercise your CPRA rights.

Exercising Your Rights. To exercise any of your rights, you may email us at privacyofficer@ispace.com, call us toll-free at 800-758-7816, to submit a request, or use our webform: https://ispace.com/privacy-policy. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You can ask to appeal any denial of your request in the same manner through which you may submit a request.

You should provide us with your name, email address, and phone number for all requests. We will verify your identity by matching our information regarding our job applicants against the information you provided. Failure to provide the foregoing information may prevent us from processing your request. If you have requested that we correct your Personal Information, we may contact you to request additional information about the Personal Information that you believe is inaccurate, including supporting documentation.

Authorized Agents. Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent authorization to submit the request.

Contact Us
If you have any questions about this Policy or our privacy practices, please email us at privacyofficer@ispace.com or call us toll-free at 800-758-7816.

Updates to Our Privacy Policy
This Applicant Privacy Policy may be updated occasionally for any reason. If we make material changes to this Privacy Policy, we will notify you by posting the new Privacy Policy at https://ispace.com/privacy-policy and changing the effective date listed at the top of this Privacy Policy. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner in which we communicate with you as a job applicant. Any modifications to this Applicant Privacy Policy will be effective upon our posting the modified version described above (or as otherwise indicated at the time of posting).