Declaración de Privacidad

Last Updated: May 22, 2026

Your privacy is a priority for Veltek Associates, Inc. (sometimes referred to as “VAI,” “us,” “our,” or “we”). We want you to be familiar with what information we collect that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“Personal Information”) and why and how we use and disclose the information. This Privacy Statement describes our practices with Personal Information that we, or our service providers, collect from a user (sometimes referred to as “you” or “your”), including through the website or applications operated and controlled by us from which you are accessing this Privacy Statement (collectively, the “Site”).

Please review this Privacy Statement carefully. By accessing or using the Site or by providing us with Personal Information, you agree and consent to the terms and conditions of this Privacy Statement.

VAI can be contacted at Privacy@sterile.com.

1. Collection of Personal Information From Users

When you interact with us through the Site, we may collect information from you as described below.

a. Information you provide

We collect Personal Information that you knowingly choose to provide to us in order to benefit from specified features or to participate in certain activities, such as information that you knowingly provide to us through the Site, including when you contact us through the “Contact Us” portion of the Site, when you request product information, or when you create a profile on the Site to view product information, technical data, or receive change notification communications. For example, if you request product information through the Site, you may provide us with information such as your name, company name, address, phone number, and email address. If you apply for a job with VAI, you may email your resume and information to an email address provided on the Site.

We may combine information you submit through the Site with other information we have collected from you, whether on-line or off-line. We treat the combined information in accordance with this Privacy Statement.

b. Location Information

Any system on the Site may utilize an opt-in geolocation service in accordance with a prevailing community standard. Such geolocation opt-in ability is managed by the user’s browser settings. If a user chooses to opt-in to the geolocation service, the user’s input of its information may be associated with the user’s location, both internally within VAI and publicly on the Sites. For example, when a user inputs its name, company name, address, and email information through the Site’s request production information page, the information input by the user may be associated with the user’s location.

c. Passive Information Collection, Use, and Choices

Also, as you navigate the Site, certain Personal Information may be passively collected, meaning it is gathered without your actively providing it. This is done using the following techniques in the following ways:

- IP Addresses: An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our Site, we may view the IP address of the device you use to connect to the Internet. We may use this information to determine the general physical location of the device and understand from what geographic regions our website visitors come. We also may use this information to enhance our Site.
- Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.
- Cookies: Like many companies, our Site may use “cookies” to help make sure the Site is meeting the needs of its users and to help us make improvements. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies set by us on the Site to tell us, for example, whether you have visited us before or if you are a new visitor. We use third-party cookies set by our service providers, like Google Analytics and Hotjar, to collect information about how visitors use the Site, including how long you spend on each page, and how you got to the Site. These third-party cookies help us better understand our Site visitors’ needs and to optimize the Site and experience. Many analytics services allow you to opt out of data collection. For example, to learn more about Google Analytics practices and to opt-out, visit https://www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout. To learn more about Hotjar, please see the ‘about Hotjar’ section of Hotjar’s support site located at https://help.hotjar.com/hc/en-us/sections/115003204947. Specifically the following cookies are used on the Site:
  - Necessary cookies are required to enable the basic features of our Site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any Personal Information.
  - Functional cookies help perform certain functionalities like sharing the content of the Site on social media platforms, collecting feedback, and other third-party features.
  - Analytical cookies are used to understand how visitors interact with the Site. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.
  - Advertisement cookies are used to provide visitors with customized advertisements based on the pages you visited previously and to analyze the effectiveness of the ad campaigns.
- Pixels or Web Beacons: A pixel or web beacons is an HTML code snippet embedded in a website or email that collects information about user behaviors and interactions with the website or email. We may utilize pixels/web beacons both on certain aspects of the Site and in HTML-formatted email messages to you. Pixels/web beacons may be used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Site usage and tracking the activities of users of the Site and email recipients. For instance, we may use pixels from Google on the Site to enable us to create targeted advertisements and measure the effectiveness of our advertisements. For additional information on interest-based advertising, please see Section 2 (Interest-Based Advertising). Please note that information collected via pixels/web beacons may be shared with our website analytics and digital advertising vendors.

You can refuse our use of all cookies and pixels/web beacons except Necessary Cookies by clicking on the cookie icon at the bottom left corner of the Site and selecting “Reject All”.

You may also manage your cookie preferences by turning off the use of cookies in your web browser. If you use your browser settings to block all types of cookies you may not be able to access all or parts of our Site or functionality may be limited.

You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. Upon notification, you can choose to not accept the cookies and keep the cookies turned off.

Changing your internet browser settings can prevent the use of cookies. Each browser has a different procedure for disabling the use of cookies. The Help function within your browser should tell you how. Alternatively, you may visit http://www.aboutcookies.org where you can review information on how to control cookies on a variety of browsers. You will also find details of how to delete cookies from your computer and other general information about cookies.

For more information about our use of cookies and pixels/web beacons, please visit [LINK TBD].

We do not track your behavior across third party websites. Our Site currently does not respond to “Do Not Track” (DNT) signals and we operate as described in this Privacy Statement whether or not a DNT signal is received, as there is no consistent industry standard for compliance.

d. Sensitive Information

We ask that you not send or otherwise disclose to us through the Site your sensitive Personal Information, such as racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership. Where you provide us with such information, we reserve the right to erase any such information at our discretion.

e. Information About Minors

The Site is not intended for persons under the age of 18. We do not knowingly collect or maintain Personal Information from persons in this age group. We reserve the right to delete any information identified as having been provided by such persons at our discretion.

2. Interest Based Advertising

We may collect information about your online activities on our Site to provide you with advertising about products tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our advertisements are served.

You may see certain advertisements on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites, including our Site, by collecting information through automated means, including through the use of third-party cookies and pixels/web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our advertising partners’ targeted advertising services to show you our advertisements on other websites based on your prior visits to our Site and other online activity.

Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you may opt out of interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising). To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices.

You may also opt out of the use of cookies and pixels/web beacons, including Advertisement Cookies, by clicking on the cookie icon at the bottom left corner of the Site and selecting “Reject All”.

Opting-out does not mean that you will stop receiving advertisements from us. It means that you still stop receiving advertisements from us that have been targeted to you based on your visits and browsing activity across websites over time.

3. How We Use the Information We Collect

We use Personal Information submitted by you or otherwise collected through the Site and through other sources for the purposes described in this Privacy Statement and as otherwise described to you at the point of collection. Generally, we use the information you provide to us for the reason for which it was provided. For example, if you sign up to receive email notifications, we will contact you by email. If you provide us with information to request product information, we will use the information to process your request. Specifically, we may use Personal Information from or about you:

- to provide the Site to you;
- to create and manage your account with us;
- to respond to your inquiries and fulfill your requests, such as to send you product or technical information for which you have subscribed;
- to send you important information regarding our relationship with you or regarding the Site, changes to our terms, conditions, and policies, and other administrative information;
- to notify you about upcoming events that may be of interest to you;
- to promote our services, and the services of our affiliates that we think may be of interest to you;
- to operate and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
- to personalize our advertising and marketing communications;
- for customer service, security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
- for our business purposes, such as data analysis, audits, recordkeeping, developing new products or services, enhancing the Site, improving our services, identifying Site usage trends and personalizing your experience on the Site;
- as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Statement; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

We do not use Personal Information submitted by you or otherwise collected through the Site and through other sources to make automated decisions, including profiling, that may have legal or similarly significant effect on you.

We may use any de-identified information for any purpose.

4. Our Disclosure of Your Information

VAI may share your Personal Information with third parties only as described in this Privacy Statement or as otherwise described at the point where we collect the information from you, including:

- to our affiliates for the purposes described in this Privacy Statement.
- to the companies or individuals that we hire to provide services to us, such as website hosting services.
- to tracking technology providers. We may disclose information collected through tracking technologies set on the Site, such as third-party cookies and pixels/web beacons, to our website analytics and digital advertising service providers.
- to a third party in the event of any corporate transaction, including but not limited to a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
- for legal purposes. We also may disclose information we collect as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also disclose Personal Information as required to pursue available remedies or limit damages we may sustain.

5. Links to Third Party Site and Online Services

The Site may contain links to third-party websites and online services for the convenience of users in locating information, products, or services that may be of interest. If you access a third-party website or online service from a link on the Site, any information you disclose on that website or online service is not subject to this Privacy Statement. It is possible that these links may be used by third parties or others to collect personal or other information about you. VAI is not responsible for the privacy practices of such websites, online services, advertisers, or third parties or the content of such websites or online services and it is your sole obligation to review and understand the privacy practices and policies of these other websites or online services.

6. Where Your Information is Processed

VAI is based in the United States. No matter where you are located, you consent to the processing and transfer of your Personal Information in and to the United States and other countries. The laws of the United States and other countries governing data protection may not be as comprehensive or as protective as the laws in the country where you live. We will transfer your Personal Information to the United States through the use of appropriate safeguards as required by applicable laws.

7. Security

VAI will take reasonable steps to protect the information collected and provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, you should understand that no transmission over the Internet is ever fully secure. Also, VAI uses reasonable efforts to ensure that the Site is generally available. However, there will be occasions when access to the Site will be interrupted or unavailable. VAI will use reasonable efforts to minimize such disruption where it is within its reasonable control. You agree that VAI shall not be liable to you for any modification, suspension or discontinuance of the Site.

8. Data Retention

We generally retain Personal Information for so long as it may be relevant for the purposes identified in this Privacy Statement or at the time the information is collected, unless a longer period of time is required by law.

9. Your Data Rights and Choices

You can unsubscribe from certain emails from VAI by clicking on the “unsubscribe” link they contain. You can opt-out of the use of certain cookie and pixel/web beacon-related processing by following the instructions in Section 1(c) above (Passive Information Collection, Use, and Choices).

The laws in some countries and some states may give you particular rights with respect to your Personal Information, including the right to access the Personal Information that we maintain, and the right to object to certain processing of Personal Information by VAI. For more information on such rights and how to exercise them, please see Sections 10 (EU/UK/Switzerland Residents), 11 (Nevada Residents), 12 (California Residents) and 13 (Notice for California Job Applicants, Employees, and Independent Contractors). These rights and options that you have with respect to Personal Information are subject to limitations and exceptions under applicable law. In addition to those rights, if you live in certain jurisdictions, you have the right to submit a complaint to your relevant supervisory authority. However, we encourage you to contact us first by emailing Privacy@sterile.com and we will try to resolve your concerns.

10. EU/UK/Switzerland Residents

With respect to “personal data” as defined by Regulation (EU) 2016/679 (“GDPR”), any national law of an EU member state adopted pursuant to the GDPR, the United Kingdom Data Protection Act of 2018, and the Switzerland Federal Act on Data Protection (collectively, “European Data Protection Laws”), we serve as the “controller”.

We process each of the personal data set forth in Section 1 (Collection of Personal Information From Users) above for the purposes set forth in Section 3 (How We Use the Information We Collect) above. We disclose each of the personal data we process with the third parties set forth in Section 4 (Our Disclosure of Your Information) above.

Our lawful bases for processing personal data include:

- To enter into and perform a contract with you: We may process Personal Information to meet our contractual obligations to you, or to take steps in anticipation of entering into a contract. For example, we process Personal Information on this basis to create an account or to prepare a letter with VAI’s product or service information.
- To comply with a legal obligation: We need to use and disclose Personal Information in certain ways to comply with our legal obligations.
- For our legitimate interests, where those interests are not overridden by your fundamental rights and freedoms: In many cases, we handle Personal Information because it furthers our legitimate business interests. This includes:
  - Providing a safe user experience on our Site;
  - Customer service;
  - Sending communications to you to let you know about information you have told us is important to you;
  - Protecting users, our workers, and our property;
  - Analyzing and improving our operations (e.g., optimizing the design and operation of our Site);
  - Processing job applications; and
  - Managing legal issues.
- With your consent: Where permitted by law, we handle Personal Information on the basis of your implied or express consent.

As stated above in Section 6 (Where Your Information is Processed), VAI is located in the United States. We will transfer your Personal Information to the United States through the use appropriate safeguards as required by European Data Protection Laws.

As stated above in Section 8 (Data Retention), we generally retain Personal Information for so long as it may be relevant for the purposes identified in this Privacy Statement or at the time the information is collected, unless a longer period of time is required by law.

Under European Data Protection Laws, you have the following privacy rights, which you may exercise by contacting us at 1-888-478-3745 or by contacting us at Privacy@sterile.com:

- Right of Access. You have the right to obtain confirmation as to whether your personal data is being processed, as well as access to the personal data along with certain information, including the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipients to whom the personal data have been or will be disclosed.
- Right to Rectification. You have the right to rectify your inaccurate personal data and to complete any incomplete personal data, including by means of providing a supplementary statement.
- Right to Erasure or Right to be Forgotten. You have the right to erase your personal data under certain circumstances.
- Right to Restrict Processing. You have the right to restrict our processing of your personal data under certain circumstances.
- Right to Object. You have right to object, on grounds relating to your particular situation, at any time to our processing of your personal data, which is based on public interest or our legitimate interests, including the profiling of data. In this case, we will stop processing your data, except for where we have compelling legal grounds for the processing which override your interests, rights and freedoms, or for the exercise or defense of possible legal claims. You also have a right to object to the processing of your personal data for direct marketing purposes.
- Right to Data Portability. Under certain circumstances, you have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format, and have the right to transmit such data to another controller without hindrance from us.
- Right to Withdraw Consent. If you have provided us with your consent for the processing of your personal data, you may withdraw your consent at any time to stop any further processing.
- Right to Lodge a Complaint. You have a right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data violates the European Data Protection Laws.

11. Nevada Residents

Under Nevada law, VAI does not sell your Personal Information. However, if you are a Nevada resident, you may submit a request that we not sell any Personal Information we have collected about you by contacting us at Privacy@sterile.com.

12. California Residents

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CPRA”) provides California residents with specific rights regarding their Personal Information. The below describes such rights and how you may exercise such rights, and our information practices, including the categories of Personal Information we collect, use, retain, disclose, sell or share, and how and why we collect, disclose, sell or share such information.

Consumer Rights

Right to Know

You have the right to request that we disclose what Personal Information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

1. 1. The categories of Personal Information we have collected about you.
  2. The categories of sources from which the Personal Information is collected.
  3. The business or commercial purpose for collecting, selling or sharing Personal Information.
  4. The categories of third parties with whom we disclose Personal Information.
  5. The specific pieces of Personal Information we have collected about you.

You may also request that we disclose to you:

1. 1. The categories of Personal Information that we have sold or shared about you and the categories of third parties to whom the Personal Information was sold or shared, by category or categories of Personal Information for each third party to whom the Personal Information was sold or shared.
  2. The categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Right to Delete

You have the right to request that we delete any Personal Information about you which we have collected from you. If it is necessary for us to maintain your Personal Information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your Personal Information when you request us to do so, we will inform you and tell you why we are not deleting it.

Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to direct a business that sells or shares Personal Information about you to third parties not to sell or share your Personal Information. We do not sell your Personal Information for monetary consideration. However, we do use tracking technologies, such as cookies and pixels/web beacons, for targeted advertising purposes. The collection of data through certain tracking technologies for our targeting advertising purposes may be considered a “sale” and is considered “sharing” under the CPRA. To opt-out of having your information sold and shared with third-party website analytics and digital advertising service providers for this purpose, you may submit a request by contacting us at Privacy@sterile.com .

Right to Correct Inaccurate Personal Information

You have the right to request a business that maintains inaccurate Personal Information about you to correct that inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to direct a business that collects sensitive Personal Information about you to limit its use of your sensitive Personal Information (1) to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; (2) for certain business purposes; and (3) as authorized by the implementing regulations of the CPRA. VAI does not collect any sensitive Personal Information.

No Discrimination

You have the right not to be discriminated against because you exercised any of your aforementioned rights.

How to Submit a Request

To exercise the rights described above, you must submit a verifiable request to us. You can do so by calling us at 1-888-478-3745 or by contacting us at Privacy@sterile.com.

To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the Personal Information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use Personal Information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

How We Collect, Use, Disclose, Sell and Share Personal Information

VAI has collected the following categories of Personal Information and used, disclosed, sold or shared such information in the twelve (12) months prior to the effective date of this Privacy Statement:

- Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
- Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
- Commercial information, such as records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
- Geolocation data.

Each of the above categories are disclosed for a business or commercial purpose as described above in Section 3 (How We Use the Information We Collect) to the third parties listed in Section 4 (Our Disclosure of Your Information).

The following categories of Personal Information were sold or shared in the twelve (12) months prior to the effective date of this Privacy Statement:

- Identifiers, such as unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
- Geolocation data.

Such information is sold to or shared with our third-party website analytics and digital advertising service providers.

We share or sell such information:

- to provide the Site to you;
- to promote our services, and the services of our affiliates that we think may be of interest to you;
- to operate and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;

- to personalize our advertising and marketing communications;
- for security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
- for our business purposes, such as data analysis, audits, recordkeeping, developing new products or services, enhancing the Site, improving our services, identifying Site usage trends and personalizing your experience on the Site;
- as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Statement; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

VAI does not collect sensitive Personal Information.

VAI collects the Personal Information described above from or through the following categories of sources:

- You, directly and indirectly, including when you access the Site or when you purchase our products or services, register an account with us, or otherwise contact us; and
- Service providers, including those that provide website analytics services to help us understand the activities taken on the Site.

As stated in Section 8 (Data Retention), we generally retain Personal Information for so long as it may be relevant for the purposes identified in this Privacy Statement or at the time the information is collected, unless a longer period of time is required by law.

Personal Information of Minors

VAI does not have actual knowledge that it sells or shares Personal Information about minors under the age of 18.

Shine the Light

Under California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, if you are a California resident, you have a right to prevent your Personal Information from being disclosed to third parties for those third parties’ direct marketing purposes. If you would like to exercise this right, you may submit a request by contacting us at Privacy@sterile.com.

13. Notice for California Job Applicants, Employees, and Independent Contractors

For privacy rights and choices specific to California residents who are job applicants, independent contractors, or employees of VAI, please see our Employee Privacy Notice for California Residents here.

14. Right to Change Privacy Statement.

VAI reserves the right at any time to modify, alter, or update this Privacy Statement. Your continued use of the Site following any changes means that you agree to follow and be bound by the Privacy Statement as changed, subject to limitations under applicable law. Please review this policy periodically, and especially before you provide any Personal Information to us. The Privacy Statement was last updated on the date indicated above.

15. Contacting Us.

Please feel free to contact us if you have any questions or concerns about this Privacy Statement or our information practices. You may contact us as follows:

Veltek Associates, Inc.
15 Lee Boulevard
Malvern, PA 19355
Attention: Legal Department
Email: Privacy@sterile.com

Employee Privacy Notice for California Residents

Last Updated: May 22, 2026

The purpose of this Employee Privacy Notice for California Residents is to inform our personnel (including employees, temporary workers, job applicants, and contractors) who reside in the State of California (referred to herein as “you” or “individual”) about the categories of personal information collected, used, disclosed, sold, shared and retained by Veltek Associates, Inc. (referred to herein as “VAI”, “we”, “us” or “our”) and the purposes for which the categories of personal information will be used and with whom such categories of personal information will be disclosed, sold and shared. This Employee Privacy Notice for California Residents also describes the rights provided to you under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 202 (“CCPA”) and how you may exercise such rights. We adopt this Employee Privacy Notice for California Residents to comply with the CCPA and any terms not defined herein shall have the same meaning set forth in the CCPA.

Information We Collect

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (“personal information”). In particular, VAI collects, uses and discloses the following categories of personal information regarding our personnel:

Category	Examples	Disclosed for a business purpose?	Categories of third parties to whom the personal information is disclosed
Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes	· Third-party service providers including, but not limited to, payroll processors, benefits administration providers and data storage or hosting providers as well as credit card vendors, travel agents and similar service providers who support the performance of employment responsibilities · Our affiliates · Government agencies or law enforcement to comply with legal obligations or valid legal processes such as search warrants, subpoenas or court orders and to protect our rights and property or protect the rights, property or safety of others · Buyers/acquirors in the event of a corporate transaction, including but not limited to a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.	Yes
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
Geolocation	Geolocation	Yes
Professional or employment-related information.	Current or past job history or performance evaluations.	Yes
Audio, electronic, visual or similar information	Photographs for badging, video recordings from CCTVs in VAI buildings/offices	Yes
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	Yes

Category	Examples	Disclosed for a business purpose?	Categories of third parties to whom the personal information is disclosed
Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes	Active
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Designer	Pending
Michael Brown	Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.	Project Manager	Active
Emma Wilson	emma@example.com	QA Tester	Inactive