Employee and Applicant Privacy Policy

Last updated 06/30/2025

ZestFinance, Inc. (d/b/a “Zest AI,” including its parent, subsidiary and affiliated corporations and entities,  and their successors and assigns; collectively, “Zest AI,” “we,” “us,” “our”) is committed to protecting the  privacy and security of the information we collect, and to being transparent about the way we collect and  process your information. This Employee and Applicant Privacy Policy (“Policy”) explains the personal  information we collect and the purpose(s) for which we may use it in connection with your employment at  Zest AI.  

2 Scope 

This Policy applies to applicants, existing and former employees, independent contractors, and  interns. Please read this Policy carefully, which was last updated on the effective date specified herein.  

A copy of this policy must be provided or made available to all applicants, employees, or  subcontractors prior to interviewing with Zest AI and upon hire. 

3 Policy Requirements 

3.1 Information We Collect 

In the course of the hiring process and, if hired, during your tenure at Zest AI, we collect personal  information directly from you that may include (as applicable): 

• Basic information and contact details – such as your name, date of birth, age, gender, email  address, phone number, physical address, postal address, emergency contact, and similar  information;  
• Career and background information – such as your education and employment history, places  you have lived and worked, roles previously held, skills, certifications, professional references,  and any other information you disclose in your application, résumé/CV, cover letter, or related  materials; 
• Identity-related information – such as your nationality/citizenship, Social Security number, driver’s  license number, or other government-issued ID card; 

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• Financial, tax, and benefits information – such as your bank account number, taxpayer ID, marital  status, number of dependents, insurance, work benefits, beneficiaries, etc.; and  
• Job- and role-specific information – such as your employee ID number, job title, job grade and  function, date of hire, date(s) of promotions(s), work history, hours worked, work location, direct  manager/ supervisor information, language capabilities, trainings attended, vacation and sick  days, salary information, performance evaluations, disability information for purposes of work  accommodations, and other related information. 

We may also collect certain information automatically from you when you use our systems or company – issued IT devices, such as IP address, internet or other electronic network information, login credentials  and activity information, certain metadata, and related technical information. In certain cases, we may  also receive certain information described above from third parties, such as third -party recruitment  agencies who you may have directed to share your information with us when you applied for a role at  Zest AI.  

Some of the personal information we collect from you may be considered “sensitive” under California or  federal law, such as government-issued ID cards or numbers, race/ethnicity, religion, information  revealing your health (for example, disability information to make workplace accommodations), or other  types of information that may be defined as “sensitive.” Additionally, note that when you apply to a  position at Zest AI, you are given the opportunity to submit a “Voluntary Self -Identification of Disability”  form (Form CC-305), which we make available to comply with equal opportunity laws. To the extent that  we collect and process sensitive personal information, we do so in accordance with applicable law.  

3.2 Use of Information  

We use the above-mentioned personal information in connection with various employment-related  business purposes, including, without limitation: 

• Recruitment and interviewing (including, but not limited to, assessing your qualifications for a  position or conducting background checks); 
• Onboarding when hired; 
• Managing the employer/employee relationship (including, but not limited to, day -to-day work related activities, payment of wages/earnings, pay parity analysis, maintaining time records, direct  deposit authorization, and reimbursements);  
• Preparing legally required records (including I-9 and EEO-1 forms);  
• Our own internal business purposes (such as for general People Ops resourcing, accounting  purposes, financial planning, protecting personal information and technology systems, preventing  or detecting fraud or other illegal activities, protecting the safety of Zest AI employees and  visitors, or internal investigations); and 
• Compliance and legal purposes (such as to comply with law enforcement or government agency  requests, for litigation related purposes, or to exercise a right or fulfill an obligation conferred or  imposed by law). 

Access to personal information is restricted to only those individuals at Zest AI who require such access  based on their role, according to a need-to-know basis. 

3.3 Use of Artificial Intelligence in the Interview Process 

Zest AI currently uses artificial intelligence (“AI”) technology in limited aspects of our interview process, currently specifically for:

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• Scheduling candidate interviews; and 
• Recording candidate interviews. 

Your personal information, including personally identifiable information (“PII”), may be processed by AI systems provided by third parties as part of these functions. Such third parties are subject to Zest AI’s  Vendor Risk Management Program which includes a thorough review of the contracted AI-based  services. Zest AI prohibits its vendor-provided AI systems from training on your PII. We implement appropriate safeguards to ensure that your personal information processed through AI systems maintain the same level of protection as outlined elsewhere in this Policy.  

Zest AI reserves the right to expand its use of AI in the interview process beyond the current limited applications described above. In the event that we implement additional AI uses in our interview process, such additional uses will be documented and disclosed in updates to this Policy. We will provide notice of any material changes to our AI usage practices in accordance with the “Changes to this Policy” section below. 

3.4 Disclosure of Information 

We may share your personal information with the following parties for the above-mentioned business  purposes: 

• With our corporate affiliates – for conducting our day-to-day business as a company, including  (but not limited to) recruitment and People Ops-related purposes; 
• With Zest AI’s third-party service providers – such as software providers, payroll agencies, health  insurance and other benefits providers, equity management companies, retirement plan providers  and advisors, and other such providers;  
• For transaction-related business transfers – we may share personal information with third-party  businesses or investors in connection with a substantial corporate transaction, such as a sale,  merger, consolidation, initial public offering, or in the unlikely event of bankruptcy;  
• For legal purposes – we may disclose personal information to respond to subpoenas, court  orders, legal process, law enforcement requests, legal claims or government inquiries, and to  protect and defend the rights, interests, safety, and security of Zest AI and our affiliates, users, or  the general public; and  
• With your consent – we may share personal information for any other purposes disclosed to you  at the time we collect the information or pursuant to your consent.  

For current employees, depending on the platforms and software used for work purposes, such as Slack,  Google Suite, Atlassian, etc., your personal information may also be collected by such third -party  providers. Please check your information-sharing settings when using such platforms.  

We do not and will not sell (as defined under California law) your personal information, nor do we share it  for purposes of cross-context behavioral advertising. 

3.5 Retention of Information 

If you do not join our team, we will retain your personal information for as long as necessary to fulfill the  purpose(s) for which it was collected, and thereafter as required by law. If you are hired at Zest AI, we  will retain your personal information for the duration of your employment, and for a limited period  thereafter as necessary and pursuant to our internal Data Retention Policy found in our Information  Governance Policy. Zest AI conforms with the requisite security protocols in the retention of your  personal information.

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3.6 Security of Information 

We maintain reasonable security measures to safeguard personal information from loss, theft,  interference, misuse, unauthorized access, disclosure, alteration, or destruction.  

3.7 Rights  

Where provided by applicable law (and subject to applicable exceptions), you have the right to access,  correct, or erase your personal information, as well as to object to or restrict the processing of your  personal information (including sensitive personal information, as applicable). If you become aware of  changes or inaccuracies in your information, you should inform us of such changes so that the  information may be updated or corrected.  

To submit a request to exercise one of the rights listed above, or to have an authorized agent submit a  request on your behalf (where so provided by applicable law), please contact us at legal@zest.ai or  peopleops@zest.ai. Once we receive your request, we may verify it by requesting information sufficient  to confirm your identity (and/or the identity of your authorized agent and their mandate to act on your  behalf). We will not discriminate against you when you exercise your rights. 

3.8 Changes to this Policy 

Zest AI may periodically update this Policy, which was last updated on the effective date specified above.  We may make changes to it from time to time to better clarify our practices and comply with applicable  laws. A copy of the current policy in force must be provided to applicants prior to interview and is made  available to employees on our intranet site, transparenZ and on our website.  

3.9 Questions 

We welcome any questions, concerns, or feedback about this Policy at legal@zest.ai.