ZestFinance, Inc. (d/b/a “Zest AI,” including its parent, subsidiary and affiliated corporations and entities, and their successors and assigns; collectively, "Zest," “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 Employment Privacy Policy (“Policy”) explains the personal information we collect and the purpose(s) for which we use it in connection with your employment at Zest. 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 specified below. If you have any questions or concerns about this Policy, please contact us where indicated below.

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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.” Note that when you apply to a position at Zest, 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.

Information We Collect

In the course of the hiring process and, if hired, during your tenure at Zest, 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;
• 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

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.

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Use of Information

We use the above-mentioned personal information in connection with various employment-related
business purposes, including:

• Recruitment (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 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 who require such access based on their role, according to a need-to-know basis.

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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’s third-party service providers – such as 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 and our affiliates, users, or
  the general public; and
• With your consent – we may share personal information for any other purposes

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.

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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, 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 conforms with the requisite security protocols in the retention of your personal information.

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Security of Information

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

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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.
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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.

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Changes to this Policy

Zest 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. Changes to this Policy will be posted on our intranet site, transparenZ.

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Questions

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